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HomeMy WebLinkAbout12-1181 PLED-OF r ICS: OF THE PR'DT, OYOTAF,%'I 2012 FEB 2 4 AV, 10: 1 S CUMBERLAND COUNTY PENNSYLVANIA PHELAN HALLINAN & SCHMIEG, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff v. 234682 GRETCHEN G. SORTZI 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE ENOLA, PA 17025-3423 Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM A) NO. Aa- // OQ (,' IIII CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 234682 C> r ?lL F# /1'5% sS J2-9 c2 7/ q& 2 1 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 #: 234682 Plaintiff is WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 2971.5 2. The name(s) and last known address(es) of the Defendant(s) are: GRETCHEN G. SORTZI 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025-3423 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 11/30/2004 GRETCHEN G. SORTZI made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR NBANK, N.A. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book 1889, Page 3922. By Assignment of Mortgage recorded 04/16/2010 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201009614.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 12/01/2009 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 #: 234682 6. 1'he following amounts are due on the mortgage as of 11,'25/2011: Principal Balance $214,362.88 Interest $25,462.31 through 11/25/2011 Late Charges $201.99 Property Inspections $415.00 Escrow Deficit $11,193.76 Corporate Advance Credit $( 58.51)) TOTAL $251,577.44 7 9. Plaintiff is not seeking a judgment of personal liability (or an in ep rsonam 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. 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. "fhe action does not come under Act 6 of 1974 because the original mortgage amount exceeds the dollar amount provided in the statute. File #: 234682 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $251,577.44, 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. AN & SCHMIEG, LLP By: Robert A)?. Cusick, Esquire Attorney for Plaintiff File #: 234682 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern dedicated right-of-way line of Wexford Drive (fifty (50) feet wide) at the dividing line of Lot #I 11 and Lot #112; thence by line of Lot #I 11. South four degrees fifty-three minutes twenty-nine seconds East (S 04 degrees 53 minutes 29 seconds E), one hundred and zero hundredths (100.00) feet to a point; thence by line of land now or formerly of East Pennsboro Athletic Commission, Inc., South eighty-five degrees six minutes thirty-one seconds West (S 85 degrees 06 minutes 31 seconds W), eighty-eight and sixty-nine hundredths (88.69) feet to a point at the dividing line of Lot # 113 and Lot # 112; thence by line of Lot #113, North two degrees four minutes fifty-nine seconds West (N 02 degrees 04 minutes 59 seconds W), one hundred and thirty-three hundredths (100.33) feet to a point on the southern right-of-way line of Wexford Drive; thence by said right-of-way line by a curve to the left having a radius of one hundred seventy-five and zero hundredths (175.00) feet and an arc length of eight and fifty- eight hundredths (8.58) feet to a point; thence by same, North eighty-five degrees six minutes thirty-one seconds East (N 85 degrees 06 minutes 31 seconds E), seventy-five and twenty hundredths (75.20) feet to a point at the dividing line of Lot #I I.1 and Lot #112, the place of BEGINNING. BEING Lot #112 on the Final Subdivision Plan for Logans Run, Phase IV, recorded in Plan Book 83, Page 27. File #: 234682 UNDER AND SUBJECT to restrictions as set forth in Miscellaneous Book 451, Page 687; and amended in Miscellaneous Book 475, Page 657; and Miscellaneous Book 651, Page 825. UNDER AND SUBJECT nevertheless to easements, restrictions, reservations, conditions and rights of way of record or visible upon inspection of premises PROPERTY ADDRESS: 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025-3423 PARCEL # 09-14-0836-287 File #: 234682 VERIFICATION Monica Vargas, hereby states tha3Xe/she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter, thatXie/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 /S/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. V If ?':? Nam :Monica Varga DATE: ??? ?j ?? ? Title: Vice President Loan Documentation 032-PA-V3 File #: 234682 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ' °w : Sheriff t=?"'' n ! 1( 4114 Jody S Smith Chief Deputy ??j 'q , Richard W Stewart CIMBBLA-,'J Solicitor . S l'? , A Wells Fargo Bank, NA Case Number vs. Gretchen G. Sortzi 2012-1181 SHERIFF'S RETURN OF SERVICE 02/27/2012 01:41 PM - William Cline, Corporal, who being duly sworn according to law, states that on February 27, 2012 at 1341 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Gretchen G. Sortzi, by making known unto herself personally, at 3 Wexford Drive, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. WIL I M CLINE, DEPUTY SHERIFF COST: $43.00 February 28, 2012 SO ANSWERS, RON y R ANDERSON, SHERIFF I t_t?-Or 171CE C11. THE PROTHIONO 1AR PHELAN HALLINAN & SCHM29(?, 'w? 0 AM 10:0 3 Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 CUMBERLAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. VS. GRETCHEN G. SORTZI Attorney for Plaintiff . CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION : No. 12-1181 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 GRETCHEN G. SORTZI, Defendant(s) 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 $251,577.44 TOTAL $251,577.44 I hereby certify that (1) the Defendant's last known address is 3 WEXFORD ROAD that note has been given in A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025-3423, an accordance with Rule Pa.R.C.P 237.1. Date I l?/ Robert W. Cusick, Esquire Q SOqPd0 Attorney for Plaintiff ?'tik?? .? P qy ?a1y0?7. DAMAGES ARE HEREBY ASSESSED AS INDICATED. 'e- w1d"I" DATE: PHS # 234682/ Cc: Karl E. Rominger, PROTHONOTARY 234682 PHELAN HALLINAN & SCHMIEG, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Attorney for Plaintiff Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. VS. GRETCHEN G. SORTZI : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 12-1181 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 defendant(s) is/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 GRETCHEN G. SORTZI is over 18 years of age and resides at 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025-3423. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date v Robert W. Cusick, Esquire Attorney for Plaintiff 234682 (Rule of Civil Procedure No. 236) - Revised WELLS FARGO BANK, N.A. VS. GRETCHEN G. SORTZI CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 12-1181 Notice is given that a Judgment in the above captioned matter has been entered against you on ?a By: If you have any questions concerning this matter please contact: Phelan Hallinan & Schmieg, LLP Robert W. Cusick, 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 BEANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY** 234682 WELLS FARGO BANK, N.A. v. GRETCHEN G. SORTZI Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-4133 Defendant(s) CUMBERLAND COUNTY TO: GRETCHEN G. SORTZI 3 WEXFORD ROAD A/K/A 3 WEXFORD DRIVE ENOLA, PA 17025-34423 DATE, OF NOTICE: Z- 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 WELL 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 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 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 By: Dan: n sky, Esquire A:ttcacIle, Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 234682 WELLS FARGO BANK, N.A. V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 12-1181 GRETCHEN G. SORTZI CUMBERLAND COUNTY Defendant(s) TO: GRETCHEN G. SOR`1"7I CIO KART, F,. ROMTNGF,R, F,SQ 155 SOUTH IIANOVER STREET CARLISLE, PA 17013 DATE OF NOTICE: - 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 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 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 TOF.,LTGIBLE 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 By' -` Dana sti ovsky, Esquire Attar. ey orPlaintiff Phelan allt?an & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 234682 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 12-1181 GRETCHEN G. SORTZI Defendant(s) CUMBERLAND COUNTY To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 04/21/2012 to Date of Sale ($41.36 per diem) TOTAL Note: Please attach description of property. PHS # 234682 s $d8.5o Pp A`tey q3. 00 09F 103?5 ? ?r • SO a .so PO A-TTY 4a..aS ckkk C SO Lk, 19 a!;, AV c? $251,577.44 - - C= $5,707.68 pi- "- r? Xim $257,285.12 -= - _ -- - a , cM.a 7 'an-Rallinan & Schmieg, LLP ohn Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff w Q Q O w a? w ? ? O N W ¢ O a, 3 ?XQ b ?3°z ¢ c?Mw w z w ?' 00 az w 00 z o ?^ o a ;z z ? o o ab H o z x H U? z ?' 1. ?w d a o .? C) U c? ?Cd o = o O r w ? PLO w ° U Q a x?? ? o 1 U 3 > a w w .Y PHELAN HALLINAN & SCHMIEG, LLP John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff V. GRETCHEN G. SORTZI Defendant(s) Attorneys for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO.: 12-1181 CUMBERLAND COUNTY CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( } the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: JMelan Hallinan & Schmieg, Ll,?; , John Michael Kolesnik, Esq., Id. 1.30f/7 Attorney for Plaintiff v ' =_= = -) , / tel.` ? `? WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 12-1181 GRETCHEN G. SORTZI Defendant(s) CUMBERLAND COUNTY PHS # 234682 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FAIRGO BANK, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025-3423. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) GRETCHEN G. SORTZI 3 WEXFORD ROAD A/K/A, 3 WEXFORD VIA.;, ENOLA, PA 17025-3423 =M C= 7-- Name and address of Defendant(s) in the judgment: r._ Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE ?`•°` - Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) DISCOVER BANK 6500 NEW ALBANY ROAD NEW ALBANY, OH 43054 DISCOVER BANK C/O JAMES C. 436 SEVENTH AVE WARMBRODT, ESQUIRE STE 1400 PITTSBURGH, PA 15219 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT GRETCHEN G. SORTZI C/O KARL E ROMINGER, ESQUIRE DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE 3 WEXFORD ROAD A/K/A 3 WEXFORD DRIVE ENOLA, PA 17025-3423 155 SOUTH HANOVER STREET CARLISLE, PA 17013 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE U.S. ATTORNEY FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING 228 WALNUT STREET, SUITE 220 PO BOX 11754 HARRISBURG, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: -3 f By: rfi Hallinan & Schmieg, LLP Michael Kolesnik, Esq., Id. No.308877 nev for Plaintiff WELLS FARGO BANK, N.A. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION VS. : NO.: 12-1181 GRETCHEN G. SORTZI Defendant(s) : CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GRETCHEN G. SORTZI 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE ENOLA, PA 17025-3423 "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 AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025- 3423 is scheduled to be sold at the Sheriff's Sale on 09/05/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $2&,5! 44 obtained by WELLS FARGO BANK, N.A. (the mortgagee) against you. In the event the sale is c9-4 announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. M C= NOTICE OF OWNERS RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE :- a- C) To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) U MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RI EVEN IF PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern dedicated right-of-way line of Wexford Drive (fifty (50) feet wide) at the dividing dine of Lot #111 and Lot #112; thence by line of Lot #111, South four degrees fifty-three minutes twenty-nine seconds East (S 04 degrees 53 minutes 29 seconds E), one hundred and zero hundredths (100.00) feet to a point; thence by line of land now or formerly of East Pennsboro Athletic Commission, Inc., South eighty-five degrees six minutes thirty-one seconds West (S 85 degrees 06 minutes 31 seconds W), eighty- eight and sixty-nine hundredths (88.69) feet to a point at the dividing line of Lot # 113 and Lot # 112; thence by line of Lot # 113, North two degrees four minutes fifty-nine seconds West (N 02 degrees 04 minutes 59 seconds W), one hundred and thirty-three hundredths (100.33) feet to a point on the southern right-of-way line of Wexfbrd Drive; thence by said right-of-way line by a curve to the left having a radius of one hundred seventy-five and zero hundredths (175.00) feet and an arc length of eight and fifty-eight hundredths (8.58) feet to a point; thence by same, North eighty-five degrees six minutes thirty-one seconds East (N 85 degrees 06 minutes 31 seconds E), seventy-five and twenty hundredths (75.20) feet to a point at the dividing line of Lot #I I 1 and Lot # 112, the place of BEGINNING. BEING Lot # 112 on the Final Subdivision Plan for Logans Run, Phase IV, recorded in Plan Book 83, Page 27. UNDER AND SUBJECT to restrictions as set forth in Miscellaneous Book 451, Page 687; and amended in Miscellaneous Book 475, Page 657; and Miscellaneous Book 651, Page 825. UNDER AND SUBJECT nevertheless to easements, restrictions, reservations, conditions and rights of way of record or visible upon inspection of premises TITLE TO 'SAID PREMISES VESTED IN Gretchen G. Sortzi, single woman, by Deed from Frederick D Weis and Hydee L. Weis, h/w, dated 11/20/2004, recorded 12/01/2004 in Book 266, Page 2546. PREMISES BEING: 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025-3423 PARCEL NO. 09-14-0836-287 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 12-1181 WELLS F'ARGO BANK, N.A. vs. GRETCHEN G. SORTZI owner(s) of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumberland County, Pennsylvania, being (Municipality) No.' 09-1 A/K/A. 3 PA 1702 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $251,577.44 Phelan Halligan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-1181 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., Plaintiff (s) From GRETCHEN G. SORTZI (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $251,577.44 L.L.: $.50 Interest from 4/21/12 to Date of Sale ($41.36 per diem) -- $5,707.68 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $194.25 Other Costs: Plaintiff Paid: Date: 6/1/2012 ? l - . Z David D. B ell, Prothonotary (Seal) Deputy REQUESTING PARTY: Name: JOHN MICHAEL KOLESNIK, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BLVD, SUITE 1400 PHILADELPHIA. PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 308877 .y-- S T,E F) k " HO)O j?1 2'12 JUt 12 CUMBERLAIgD COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK, N.A. Plaintiff Court of Common Pleas Civil Division V. GRETCHEN G. SORTZI CUMBERLAND County No.: 12-1181 Defendant RULE AND NOW, this / ,&i/L day of 2012, a Rule is entered upon the Defendant 1z ej, to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant 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 THE COURT -2? A41,- J. 234682 Allison F. Wells, Esq., Id. No.309519 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 TEL: (215) 563-7000 FAX: (215) 563-3459 KARL E. ROMINGER, ESQUIRE 155 SOUTH HANOVER STREET CARLISLE, PA 17013 OPO 234682 234682 ",6- THE PR0TH0' N'-0T11 , 2012 JUL 20 AM 11: 04 CUMKRLAN0 COUNTY PENNSYLVANIA Phelan Hallinan & Schmieg, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division vs. GRETCHEN G. SORTZI Defendant CUMBERLAND County No.: 12-1181 CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's July 12, 2012 Rule directing the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individual on the date indicated below. KARL E. ROMINGER, ESQUIRE 155 SOUTH HANOVER STREET CARLISLE, PA 17013 DATE: Phelan Hallinan leg, LLP Allison F. We , squire Attorney for Plaintiff 23 ? t1.?8.pg?,Ofi?p pF Z1VE P - g: 5 ?01? ?U? "6 ?? t 1`l c?t1M??R SY?? p,Nl A Phelan Hallinan & Schmieg, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division vs. GRETCHEN G. SORTZI Defendant CUMBERLAND County No.: 12-1181 MOTION TO MAKE RULE ABSOLUTE WELLS FARGO BANK, N.A., 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 July 10, 2012. 2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a its proposed Motion to Reassess Damages and Order to the Defendant on June 27, 2012 and requested the Defendant's Concurrence. On July 2, 2012, Plaintiff received a letter via facsimile from Defendant's counsel, which states "our office opposed the request to increase the amount of the judgment and the Motion to Reassess Damages and Order that your office intends to file with the court" . True and correct copies of Plaintiff s letter pursuant to Local Rule 208.3(9), of 2 certification of mailing, and counsel's letter are attached hereto, made part hereof, and marked Exhibit "A". 3. A Rule was issued by the Honorable Christylee L. Peck on or about July 12, 2012 directing the Defendant to show cause by July 31, 2012 why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part and marked Exhibit "B." 4. The Rule to Show Cause was timely served upon all parties on July 19, 2012 i 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. 5. Defendant failed to respond or otherwise plead by the Rule Returnable date of July 31, 2012. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff s Motion to Reassess Damages. DATE: _ Phelan Schmieg, LLP Y: Allison F. W uire Attorney for Plaintiff 2 Exhibit "A" PHELAN HALLINAN & SCHMIEG, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallinan & Schmieg, LLP Representing Lenders in Pennsylvania and New Jersey June 27, 2012 KARL E. ROMINGER, ESQUIRE, 155 SOUTH HANOVER STREET CARLISLE, PA 17013 RE: WELLS FARGO BANK, N.A. v. GRETCHEN G. SORTZI Premises Address: 3 WEXFORD ROAD A/K/A3 WEXFORD DRIVE ENOLA, PA 17025 CUMBERLAND County CCP, No. 12-1181 Dear Counsel, 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 July 2, 2012. Should you have further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided aci:ordingt . Very truly yours, Allison F. ills. Esquire Attorney yr Plaintiff Enclosure 23468: x' ? a x c Y U v7 E c 0 -7 ?-y et M A c ? p .„a m'.° U C G O y V F T O J 'G O U L UO F t c ? vu 3 o .? c F H U v ` 6 a E ti L2 E u v F w ? v u v ` ?' o i1 ? o u o Cd .? v ° w u 't L 0.19 O N O .N G ?y0 O N O O CD d A C O T - ?owa.E - m c C r ° E E - C r c ti E ?' o v N E c ° ? 00 `o v E M :A Krn - y M N ? L Nw°'aHCC ?i a 0 h ? A ¢ 4 u a (x ° °c w O w '? ? r O a 0 ? ? ? V CO F L4? 'O aw `vi E.? ?o Y L (yy ? U a G o? m 3 x tzi a U o anU a Ha H o0 xw? o Wa ? ?? ? N Q E ? u a ?a s z ? v vi ? E ?'bw C ti }y8 z¢o a ?a N 00 M N From:Rom'nger & Associates 7172416878 07/02/2012 13:01 ROMINGER & ASSOCIATES Attorneys at Law Offices rr, "155 South Hanover Street Qunp HUI P Carlisle, Pennsylvania 17013 Chambersburg Tel: (717) 241-6070 Ephrata Fax: (717) 241-6878 Hanover Harrisburg Hershey Lancaster Lebanon July 2, 2012 Allison F. Wells, Esquire 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 #754 8.001/001 Karl E. Rominger Vincent M. Monfri Steven R. Snyder Lee Mandarnlo** * Licensed io Pracirce m PA an NJ " Licensed to I- rce in PA ar d NY RE: Wells Fargo Bank, N.A. v. Gretchen G. Sortzi Premise Address: 3 Wexford Road AfK/A 3 Wexford Drive, Enola, PA 17025, Cumberland County CCP, No. 12-1181 Dear Counsel; This correspondence is in response to your letter dated June 27, 2012 in which you requested our concurrence with the request to increase the amount of the judgment. Our office opposed the request to increase the amount of the judgment and the Motion to Reassess Damages and Order that your office intends to file with the court. Please feel free to contact my office if you have any further questions or concerns. Sincerely, Karl E. Rominger, Esquire KER;mlw www.romingerlaw.coni ADVOCACY • ADVICE • ANSWERS Exhibit "B" riv iNC"1;,; . n ., 201? JUL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK, N.A. Plaintiff V, GR_1 ±TCHEN G. SO R77-1 Defendant Court of Corainon Pleas Civil Division CUMBERLAND County No.: 12-1181 RULE L AND NOW, this,_ ??? .. ....._. day of to _ 2012, a Rule is entered upon tine Defendant to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant shall have twenty (20) days from the date of this Order to file a response o Plaintif±°s .Motion to Reassess Damages. .If no response is filed with the Court, Plaintiff nay lil a Motion to T\4.ake Rule Absolute and no 1"ie:tr•ing will be scheduled or7 this matter. BY 111.1::; COURT, ?1? _ ? ?;P r Ff Itt, fi +. t 1 ?, 3,1 (. Exhibit "C" Phelan Hallinan & Schmieg, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff vs. GRETCHEN G. SORTZI Defendant rf , d sq ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division CUMBERLAND County No.: 12-1181 CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's July 12, 2012 Rule directing the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individual on the date indicated below. KARL E. ROMINGER, ESQUIRE 155 SOUTH HANOVER STREET CARLISLE, PA 17013 DATE: _ Phelan Halliiian,& S ieg, LLP Allison F. Wel , ?squire Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division vs. GRETCHEN G. SORTZI Defendant CUMBERLAND County No.: 12-1181 CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Make Rule Absolute were served upon the following individual on the date indicated below. KARL E. ROMINGER, ESQUIRE 155 SOUTH HANOVER STREET CARLISLE, PA 17013 DATE: Phelan Halli c Zieg, LLP B• Allison F. We Esquire Attorney for Plaintiff 23 r AFFIDAVIT OF SERVICE (FHLMC) PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK, N.A. pHS # 234682 DEFENDANT SERVICE GRETCHE G. SORTZI COURT NO.: TEAM/ 181 SERVE GRETCHEN G. SORTZI AT: TYPE OF ACTION t?ER4. ? C NT Y 3 WEXFORD ROAD A/K/A XX Notice of Sheriffs Sale P.EsNSYLyAN A 3 WEXFORD DRIVE SALE DATE: September 5, 2012 ENOLA, PA 17025-3423 SERVED Served and made known to GRE CHEN G. SOR Defendant on the L° day of 20 ? at _, o'clock M., at XT :P , 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: l Deess{c?ripttign:: Age Height Weight Cso Race w Sex T Other I,C tIi ` 0be , a competent adult, hereby verify that I personally handed a true and correct 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. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsifi ationpo authorities. DATE: 6 D61 `? NAME: PRINTED NAME-J 1 TITLE: OO SS SQm r- NOT SERVED On the day of , 20_, at - o'clock _. M., Defendant NOT FOUND because: Vacant - Does Not Exist - Moved _ Does Not Reside (Not Vacant) _ No Answer on at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. 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 Melissa J. Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, 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 _ IN THE COURT OF COMMON PLEAS Cj w. CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO•BANK, N.A. Plaintiff Civil Division vs. GRETCHEN G. SORTZI Defendant ORDER Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendant 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 nunc pro tunc as follows: AND NOW, this %?Vk day of 1 2012, upon consideration of Plaintiff's Principal Balance Interest Through September 5, 2012 Per Diem $33.77 Late Charges Legal fees Cost of Suit and Title Property Inspections Mortgage Insurance Premium/ Private Mortgage Insurance Mortgage Insurance Premium to be paid prior to September 5, 2012 Escrow Deficit TOTAL Court of Common Pleas CUMBERLAND County No.: 12-1181 $214,362.88 $35,097.94 $201.99 $1,750.00 $795.75 cw $510.9co $3,758.4'-' ch _... $449.9 a r $8,278.8. $265,205.61--? ca Plus interest from September 5, 2012 through the date of sale at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. L-' 51e,,-C-r AX-5on BY THE COURT: J. 234682 ~= eL~O-0~~ ~= iC~: y ~~ Pf3TN0N0i'An.~. PHELAN HALLINAN & SCHMIEG, AIJG l 3 A1~9 l0~ 4 Attorney for Plaintiff John Michael Kolesnik, Esq., Id. No.30 1617 JFK Boulevard, Suite 1400 CI~;-~~E~LgND COUNT" One Penn Center Plaza ~'ENNSYLVANIA Philadelphia, PA 19103 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. Plaintiff, v. CUMBERLAND COUNTY COURT OF COMMON PLEAS GRETCHEN G. SORTZI Defendant(s) CIVIL DIVISION No.: 12-1181 AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(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 the persons or parties named, at that address, set forth on the Affidavit and as amended applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Retu~ Receipt stamped by the U.S. Postal Service is attached hereto Exhibit "A". Date: ~g~f 2 E-iael Kolesnik, Esquire for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may n 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 press at the sale. PHS # 234682 r _ __ v ~ -; - 3 ...._. _ ._ ~ ...____~..._n ~ .~,_~. ~ _...~ _ ._..... .. __._..~_~.._...__ _ ~ _.._....._ ___. _.__..____ _ - - _- -r ~ 0 ~ i- z ~ 00 ~.1 T U1 A W N r ~ =. ~, ~~ - a - ---- - , ~~ a rt^ j ~ x• x• ~ x x• ~ -~, p a ~ ,w O N ~ C C ro p ~Cw. m '~ ~ O R'+ W C O ~ tl~ 1'~y ~"~ ._] W d ~ th ~ C17 cW cW "j Z °° ' " C7 ~'o ~'~ at7 ' °' o ~ ~"' o x y o wee ee r.~'+ ~vitsl ~, n ~-3 ~n(~ CC °o ~, '~~~y~ ~ k>f 8 o ~ a ~.~ o n 3 e ° ~ ~ Z ~~ ~ ~ ~.~_.~ ~. ~ ~ < ~~~ am ~ ~ r~~~ z z~ < y~ ~oo, a ~R ~ ~ f ~ •o,A ~ a~ 3 'O ~o aa~ "C ~ o ~' , .. o ~ Z ros G7 H b° a - ~ 3a ~ ~ O r~d na. ~ ~ O ~ y .,~ ~o ~ x x od ~ ,~ ~ ~ ~ ~ M ~ ~ N C ~ ra-. ~ b W ~ ~ y ~ Z ~ '~ C X W ~ ~ ~ ~ O ~ ~ Cn Op0 C _. ~ C N ~ ~ N ~ tD D ~ ~~w ~ '" ~ r ~ n O C r C ' W ~ ~ ~ ` A ~ ~ ~~ ~ r: ~ w . ~ !~ ~ ~p W ~ y U1 o N ~:. d i N ~ ..3 . + ~ .- ~ ~ N d' A C ~ ~ K ZJ ~ .. F f 9 ~} A N d fD ~ ~ V1 ~ ~ ~ M ~ N 3 N "" c ~ v ~ a o <. m o „~ C7 ~ O w ~ a m N ^ 1 J ~. ~. H ~ _~,' e ~o n, 3 ~ ~C f ~< ti V -~ ~ ~ .~ R ~z ~ o `"' ~ m O .~ 3 ~ ro a 9 r a x O o `° z ~ ° a °' ~ I y~y l-/ ^^~ N ~ y ~ y.~ y ~ ~ j 3 -IV.o_.~ r N ~ ~ 7 3^~y ,Wp C ~ ~ I- o o °, -' N y y l'~ ~ ` i ~ ~ o' t ~ i y ~ - a ~ F 3 = ~ o C :' M ~ N t to 'o o~ ~ C o rt " °o ~ ~ o c A r m a ~ q ° C ~ i - . rt d . o G o r ~ n n ~ -_ v i y ~ j p ~ H 3 H < ~ ~ ~ `t ~ X o. ~ w v ~ 3 ~ fD w 3 ~ o', ~ R m_ p n n m 9 0 - ~ ° ' o ~ 3 `n- ~ ~ `` '° ~ -- ~ a 0 3 ' ^p o ~ O x ~' -i ~ ~ o = m d G ~ u =. m 1 Y x m Y ~ _ ~ ~ 3 " , ,r ` ~ ~ , n ~^ ~ n i'~ ~ ~ _~_ .,-....._... n _ o~ ~ o ~ w n w Q o o ~ i 'S.~~ ~a ~_ o~ i/I p v: .v c r. 0 4 O 0 3 w oaz ^+,aw to A- ~ ~ ~ ~ ~ N ~ -. a. 1 O ~ ~ fD ~ ~ ~ ~ nOd~= ~ °c ~ ~~~ 'v ~ R° w a ~ W Uj S C _• ~. ~ QQ Ar o ~.- O ~..~ ~ _li _ T,~: Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY -~ ; _ °~ ~!:°ii~,~~li ~ ~1yg, ~i 4a~tir;~trp f Wells Fargo Bank, NA vs. Gretchen G. Sortzi Case Number 2012-1181 SHERIFF'S RETURN OF SERVICE 06/18/2012 10:14 AM -Deputy Amanda Cobaugh, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 3 Wexford Road, East Pennsboro Township, Enola, PA 17025, Cumberland County. 06/18/2012 10:14 AM -Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Gretchen G. Sortzi at 3 Wexford Road, East Pennsboro Township, Enola, PA 17025, Cumberland County. 09/06/2012 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, Carlisle, PA on September 5, 2012 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Daniel Schmieg, on behalf of Federal Home Loan Mortgage Corporation, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $754.0'7 November 20, 2012 SO ANSWERS, ~`~ RON1~t R ANDERSON, SHERIFF ~~~oa Pd. ~ a .as Pd , ~ s'D LLP~• ~L7f' ~~/tea ~ a-~ 33 ~G WELLS FARGO BANK, N.A. Plaintiff v. GRETCHEN G. SORTZI Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 12-1181 CUMBERLAND COUNTY PHS # 234682 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025-3423. I . Name and address of Owner(s) or reputed Owner(s): Name GRETCHEN G. SORTZI Address (if address cannot be reasonably ascertained, please so indicate) 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE ENOLA, PA 17025-3423 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) DISCOVER BANK 6500 NEW ALBANY ROAD NEW ALBANY, OH 43054 DISCOVER BANK C/O JAMES C. 436 SEVENTH AVE WARMBRODT, ESQUIRE STE 1400 PITTSBURGH, PA 15219 4. Name and address of last recorded holder of every mortgage of record: Name. Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Narrie and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT GRETCHEN G. SORTZI C/O KARL E. ROMINGER, ESQUIRE DOMESTIC RELATIONS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA DEPARTME,N'C OF WELFARE 3 WEXFORD ROAD A/K/A 3 WEXFORD DRIVE ENOLA, PA 17025-3423 155 SOUTH HANOVER STREET CARLISLE, PA 17013 13 NORTH HANOVER STREET CARLISLE, PA 17013 P.O. BOX 2675 HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE U.S. ATTORN>`:Y FOR THE MIDDLE DISTRICT OF PA FEDERAL BUILDING 228 WALNUT STREET, SUITE 22(1 PO BOX 11754 HARRISBURG, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: .3 f By: rfi Hallinan & Schmieg, LLP Michael Kolesnik, Esq., Id. No308877 ney for Plaintiff WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION vs. N0.:12-1181 GRETCHEN G. SORTZI Defendant(s) CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: GRETCHEN G. SORTZI 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE ENOLA, PA 17025-3423 **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 AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.~* Your house (real estate) at 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025- 3423 is scheduled to be sold at the Sheriff's Sale on 09/05/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $251,577.44 obtained by WELLS FARGO BANK, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will. be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. ~~ ~ NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this She;riff s Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You ma;~ be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 2:15-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you. may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern dedicated right-of--way line of Wexford Drive (fifty (50) feet wide) at the dividing line of Lot #l l l and Lot #112; thence by line of Lot #111, South four degrees fifty-three minutes twenty-nine seconds East (S 04 degrees 53 minutes 29 seconds E), one hundred and zero hundredths (100.00) feet to a point; thence by line of land now or formerly of East Pennsboro Athletic Commission, Inc., South eighty-five degrees six minutes thirty-one seconds West (S 85 degrees 06 minutes 31 seconds W), eighty- eight and sixty-nine hundredths (88.69) feet to a point at the dividing line of Lot # 113 and Lot # 1 ] 2; thence by line of Lot # 113, North two degrees four minutes fifty-nine seconds West (N 02 degrees 04 minutes 59 seconds W), one hundred and thirty-three hundredths (100.33) feet to a point on the southern right-of--way line of Wexford Drive; thence by said right-of--way line by a curve to the left having a radius of one hundred seventy-five and zero hundredths (175.00) feet and an arc length of eight and fifty-eight hundredths (8.58) feet to a point; thence by same, North eighty-five degrees six minutes thirty-one seconds East (N 85 degees 06 minutes 31 seconds E), seventy-five and twenty hundredths (75.20) feet to a point at the dividing line of Lot # 1 I 1 and Lot #112, the place of BEGINNING. BEING Lot #112 on the Final Subdivision Plan for Logans Run, Phase IV, recorded in Plan Book 83, Page 27. (1NDER AND SUBJECT to restrictions as set forth in Miscellaneous Book 451, Page 687; and amended in 1~liscellaneous Book 475, Page 657; and Miscellaneous Book 651, Page 825. UNDER AND SUBJECT nevertheless to easements, restrictions, reservations, conditions and rights of way of record or visible upon inspection of premises TITI:E TO SAID PREMISES VESTED IN Gretchen G. Sortzi, single woman, by Deed from Frederick D. Weis and Hydee L. Weis, h/w, dated. 11/20/2004, recorded 12/01/2004 in Book 266, Page 2546. PRF,MISF,S BEING: 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025-3423 PARCEL NU. 09-14-0836-287 SHORT DESCRIPTION By virtue of~ a Writ of Execution NO. 12-1181 WELLS FARGO BANK, N.A. vs. GRETCHI?;N G. SORTZI owner(s) of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumberland County, Pennsylvania, being (Municipality) 3 WEXFORD ROAD A/K/A, 3 WEXFORD DRIVE, ENOLA, PA 17025-3423 Parcel No. 09-14-0836-287 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $251,577.44 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF E:XECUTION and/or ATTACHMENT COMMONVI~'EALTH OF PENNSYLVANIA) COUNT` OF CUMBERLAND) NO. 12-1181 Civil CIVIL ACTION --LAW T~ ~ THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., Plaintiff (s) From GRETCHEN G. SORTZI (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION . (2~ You are also directed to attach the property of the defendant(s) not levied upon in the possession o GARNISI-IEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (~ } If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $251,577.44 L.L.: $.50 Interest from 4121/12 to Date of Sale ($41.36 per diem) -- $5,707.68 Atty's Comm: % Due Prothy: $2.25 Att} Paid: $ 94.25 Other Costs: Plaintiff Paid: Date: 6/1 i 2012 David D. Buell, Prothonotar (Seal) Deputy RFQLIESTING PARTY: Name: JOHN MICHAEL KOLESNIK, ESQUIRE Address F'HELAN HALLINAN & SCHMIEG, LLP 1617 JFK BLVD, SUITE 1400 PHILADELPHIA. PA 19103 Attorney tor: PLAINTIFF Te I ephon e: 215-563-7000 Supreme Court ID No. 308877 TIZi~E CC~Y Fj°cOiVt REGORO In Testimony wherecf, !here unto set ,-ny f~an~' and the~ _s(e~Ja~l of acid C ~ ~t Carlisle, Pa.~ This 1_ day of a,;~~_., 20 ~J E'roth-onatary C ~ CUMBERLAND LAW JOURNAL writ No. 2012-1181 Civil Term Wells Fazgo Bank, NA vs. Gretchen G. Sortzi Atty.: Francis S. Hallman By virtue of a Writ of Execution NO. 12-1181. WELLS FARGO BANK, N.A. vs. GRETCHEN G. SORTZI owner(s) of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumberland County, Pennsylvania, being 3 WEXFORD ROAD a/k/a 3 WEXFORD DRIVE, ENOLA, PA 17025-3423 Parcel No. 09-14-0836- 287. Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $251,577- .44. 94 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 27, August 3, and August 10, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, E rtor SWORN TO AND SUBSCRIBED before me this 10 day of August, 2012 Notary NOTAR! DE80RAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND Cf.~UNTY My Commission Expires Apr 28, 20'4 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert: P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Federal Home Loan Mortg_a e Corporation is the grantee the same having been sold to said grantee on the 5th day of Se tp ember A.D., 2012, under and by virtue of a writ Execution issued on the 1st day of June, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 1181, at the suit of Wells Fargo Bank, N.A. against Gretchen G. Sortzi is duly recorded as Instrument Number 201236014. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this °~ ~-~ day of c'' Rec der of Deeds a ~ The Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c~he~latriot•News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949... respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 07/27112 2012.1181 Clvll Term 08/03/12 Wells FarSo Bank, NA ~ ~~ 08/10112 , Ve GretcMn G. SortrJ ~ Ally: Frands S. Nalllnan ~ ~..:~~~~ ~ I3y virtue of a Writ of Execution N0.12- ' ' ' ~~ ~~ 1181 wELISFARGOIIANx.N.A. t'~~ ~ Sworn tt arts subscribed befor~ me s ~ :~'° da f August 2012 A D ~s. GRETCHEN G. SOIrIZI , , , . . ~ owner(s) of property situate in the - • ' ,' ' , , TOWNSIIIP OF PAST PENNSBORO, ` ' ~ ~ ~ Cumberland County, pennsytvama, being Notary P u b l i c (Municipality) 3 WEXFORD ROAD AIK/A, 3 WEXFORD DRIVE, ENOLA, PA 17025- 3423 - _. ParcelNo.09-14-0836-287 ,._ ;~"~`!'`"~1V41~t~ , ~ ~ - Y ~ - - --. !At~i ~ ° ~=a~ (Acreage or street address) . - t~ Improvements thereon: RESIDENTIAL "' DWELLING JUDGMENT AMOUNT`. $251,577.44 s ;.. - i ar S - Q~ j ~ ~ .....,_, i:R( 5.