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Home My WebLink About12-1182THE l'0T"0N4TA1't.,' 2112 FEB 24 A,4 !Q: c 4 CUMBERL;ANo couNp, PENNS YLMNIA PHELAN HALLINAN & SCHMIEG, LLP Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 288642 WELLS FARGO BANK, N.A., SB/M TO WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN 329 WEST PENN STREET CARLISLE, PA 17013-2249 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 901d11-11A,?Q U? CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 288642 D 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 #: 289642 Plaintiff is WELLS FARGO BANK, N.A., S/B/M TO WELLS FARGO HOME MORTGAGE, INC. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN 329 WEST PENN STREET CARLISLE, PA 17013-2249 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. On 01/30/2002 JEFFREY D. KAUFFMAN and CHARISE M. KAUFFMAN made, executed and delivered a mortgage upon the premises hereinafter described to EQUITY ONE, INCORPORATED which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book 1748, Page 1766. By Assignment of Mortgage recorded 08/15/2002 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book 689, Page 2043.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. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 10/01 /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 #: 288642 6. The following amounts are due on the mortgage as of 01/11/2012: Principal Balance $ 76,825.75 Interest through 01/11/2012 $ 1,628.18 Late Charges $ 266.75 Property Inspections $ 80.00 Escrow Deficit $ 953.1.7 TOTAL $ 79,753.85 7. 8. 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. 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 $79,753.85, 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. PHELA HALLINAN & SCH {{ G, LLP 1. By sa J. Cantwell, Esquire Attorney for Plaintiff File k: 288642 .+ LEGAL DESCRIPTION ALL THAT certain lot of ground with the improvements thereon erected, situate in the Fourth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern line of West Penn Street, the said point being in the center line of a certain 3 foot wide alley or area-way and about 78 feet 2 inces West of the western line of a certain public alley extending North and South between Penn and Lincoln Streets; thence by the center line of the said 3 foot alley in a northerly direction along property late of Robert Thompson, a distance of 169.35 feet to the line of a 16 foot wide alley; thence along the southern line of the said alley in a western direction, a distance of 18 feet to the line of other property late of Robert Thompson; thence by the latter property in a southerly direction, a distance of 169.35 feet to the line of West Penn Street; thence by the said street in an easterly direction, a distance of 18 feet to the point and place of beginning. The said lot being improved with a 2-1/2 story frame dwelling known as 329 West Penn Street, Carlisle, Pennsylvania 17013. Including right to Grantees, their heirs, or assigns, to use the 3 foot area-way or alley between the property herein conveyed and the property immediately joining it on the East, jointly with the owner and occupants of the property immediately adjoining on the East, as set forth in Deed Book 8M 589 in the Recorder of Deeds Office for Cumberland County. PROPERTY ADDRESS: 329 WEST PENN STREET, CARLISLE, PA 17013-2249 File #: 288642 r VERIFICATION Geeta Sheth, hereby states that?e/she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter, that 1{e/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. Cq "' A s Name: Geeta Sheth DATE: Ft6r,Ag pv 012 Title: Vice President Loan Documentation 032-PA-V3 PHS: 288642 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson % Sheriff Jody S Smith( 2 PAR - AN 3: 4 2 Chief Deputy Richard W Stewart MrMBER;_ ; D E.:G1JN'i Y Solicitor PENNSYL'VANFA Wells Fargo Bank, N.A. vs. Jeffrey D Kauffman (et al.) Case Number 2012-1182 SHERIFF'S RETURN OF SERVICE 02/2712012 Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 27, 2012 at 1944 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jeffrey D. Kauffman, by making known unto Charise M. Kauffman, Wife of Defendant at 329 W. Penn Street, Carlisle, Cumberland County, Pennsylvania 170113 its contents and at the same time handing to her personally the said true and correct copy of the same. -__:::> ROB RT BITNER, DEPUTY 02/27/2012 07:44 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 27, 2012 at 1944 hours, he served a true copy of the within Complaint in Mortgage f=oreclosure, upon the within named defendant, to wit: Charise M. Kauffman, by making known unto herself personally, at 329 W. Penn Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $50.00 February 28, 2012 RO RT BITNER, DEPUTY SO ANSWERS, RON14Y R ANDERSON, SHERIFF PHELAN HALLINAN & SCHMIF,6,? I,l:>J P%t? t : ? Attorney for Plaintiff Allison F. Wells, Esq., Id. No.3095`„ 1617 JFK Boulevard, Suite 1400 ;2.D lF : rJ ` One Penn Center Plaza ''1EE,?i1 COUd? Philadelphia, PA 19103 E`'E$Y.?4??( 215-563-7000 WELLS FARGO BANK, N.A., S/B/M CUMBERLAND COUNTY WELLS FARGO HOME MORTGAGE, INC. COURT OF COMMON PLEAS VS. CIVIL DIVISION JEFFREY D. KAUFFMAN No. 2012-1182 CHARISE M. KAUFFMAN . 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 JEFFREY D. KAUFFMAN, and CHARISE M. KAUFFMAN, 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 Plaintiffs damages as follows: As set forth in Complaint TOTAL $79,753.85 $79,753.85 I hereby certify that (1) the Defendants' last known address is 329 WEST PENN STREET, CARLISLE, PA 17013-2249, and (2) that notice has been given in accord Rule Pa.R.C.P 237.1. Date 0 ag Esquir awe. ?V • S ?? Attorney for Plai k'k /l '79/1? DAMAGES ARE HEREBY ASSESSED AS INDICATED. l/ a7ya °o DATE: a 5 a PHS # 289642 PROTHONOTARY 288642 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., SB/M WELLS FARGO HOME MORTGAGE, INC. VS. JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 2012-1182 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 JEFFREY D. KAUFFMAN is over 18 years of age and resides at 329 WEST PENN STREET, CARLISLE, PA 17013-2249. (c) that defendant CHARISE M. KAUFFMAN is over 18 years of age and resides at 329 WEST PENN STREET, CARLISLE, PA 17013-2249. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date 288642 (Rule of Civil Procedure No. 236) - Revised WELLS FARGO BANK, N.A., SBIM CUMBERLAND COUNTY WELLS FARGO HOME MORTGAGE, INC. COURT OF COMMON PLEAS VS. CIVIL DIVISION JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN No. 2012-1182 Notice is given that a Judgment in the above captioned matter has been entered against you on yl.? S 1 By: If you have any questions concerning this matter please contact: Phelan Hallinan & Schmieg, LLP Allison F. Wells, 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 A TTEMPTING TO COLLECT A DEBT AND ANYINFORMATION 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 ONL Y ENFOR CEMENT OFA LIEN A GA INS T PR OPER TY* * 288642 WELLS FARGO BANK, N.A„ S/BIM WELLS FARGO HOME MORTGAGE, INC. Plaintiff JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN Defendant(s) TO: CHARISE M. KAUFFMAN 329 WEST PENN STREET CARLISLE, PA 17013-2249 DATE OF NOTICE: COURT OF COMMON PLEAS CIVIL DTVISON NO. 2012-1182 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 CONS'T'RUED 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 OTTER 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) '49-3 166 Bv: trIrevr u l );squire Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 288642 WELLS FARGO BANK, N.A., S/B/M WELLS FARGO HOME MORTGAGE, INC. Plaintiff V. JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN Defendant(s) TO. JEFFREY D. KAUFFMAN COURT OF COMMON PLEAS CIVIL DIVISON NO. 20]2-1182 CUMBERLAND COUNTY 329 WEST PENN STREET CARLISLE, PA 17013-2244) 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 CONS'T'RUED 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 "CHAT 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 ze, Jkildrew J. Marry, l.?ytui? / Attorney for Plaintiff A -° Phelan Hallinan & Schinieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 288642 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO BANK, N.A., S/B/M WELLS FARGO HOME COURT OF COMMON PLEAS MORTGAGE, INC. Plaintiff CIVIL DIVISION V. NO.: 2012-1182 JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN CUMBERLAND COUNTY Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due $79,75185 Interest from 04/26/2012 to Date of Sale .-Oz «} $1,743.63 -: ($13.11 per diem) TOTAL $81,497.48 Phelan Hallinan & Schmieg, LLP Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff Note: Please attach description of property. PHS # 288642 Gs. *,98. SO PO ATT`/ 60. oo C BF- 103•?5 " I(o•50 a.so •' 4a0l.a5 - pt Am/ 41-as bue co So LL ell IlqalgI 0 2 7waJ wQ o? ?a w? a? a oa ?H oz o° ?z o? Uw PA H? ?a U U H W H O W O x O U' W a a w 3 z z O a ? w? ?a a a w 3 > ww w 0 H U w4u o? ° w O ee ot a? a of ¢ W N ¢ W N Qa ?a ? ? ¢ o WN¢ xN¢ ¢ -AMU UMU N C?l a? a? P .= cr ? W w C_ co a xti ?Q PHELAN HALLINAN & SCHMIEG, LLP Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A., S/B/M WELLS FARGO HOME MORTGAGE, INC. Plaintiff V. JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN Defendant(s) CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 2012-1182 : CUMBERLAND COUNTY 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 ( ) Act 91 procedures have been fulfilled (X) 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 unswom falsification to authorities. B: an Hallman & Schm LP Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff ,...,? Fem.. ?. .. 7 ", 1 e WELLS FARGO BANK, N.A., S/B/M WELLS FARGO COURT OF COMMON PLEAS HOME MORTGAGE, INC. Plaintiff CIVIL DIVISION V. NO.: 2012-1182 JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN CUMBERLAND COUNTY Defendant(s) PHS # 288642 AFFIDAVIT PURSUANT TO RULE 3129.1 WELLS FARGO BANK, N.A., SB/M WELLS FARGO HOME MORTGAGE, INC., 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 i nformation concerning the real property located at 329 WEST PENN STREET, CARLI SLE, PA 17013-2249. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) JEFFREY D. KAUFFMAN 329 WEST PENN STREET = CARLISLE, PA 17013-2249 CHARISE M. KAUFFMAN 329 WEST PENN STREET r--.. -- =' ? CARLISLE, PA 17013-2249 r CD -L 2. Name and address of Defendant(s) in the judgment: ;r. Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment cre ditor 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 DISCOVER BANK C/O MATTHEW DAVID 436 7TH AVE # 1400 KOPPERS BLD URBAN, ESQUIRE PITTSBURGH, PA 15219 CAPITAL ONE PO BOX 30285 SALT LAKE CITY, UT 84130-0285 CAPITAL ONE, N.A. 140 EAST SHORE DRIVE GLEN ALLEN, VA 23059 CAPITAL ONE, N.A. C/O JAMES C. 436 SEVENTH AVE WARMBRODT, ESQUIRE STE 1400 PITTSBURGH, PA 15219 CAPITAL ONE BANK USA, N.A. 15000 CAPITAL ONE DRIVE RICHMOND, VA 23238 CAPITAL ONE BANK USA, N.A. C/O JAMES C. WARMBRODT, ESQUIRE CAPITAL ONE BANK, N.A. CAPITAL ONE, N.A. C/O MATTHEW DAVID URBAN, ESQUIRE LVNV FUNDING, LLC. LVNV FUNDING, LLC. C/O DAVID J. APOTHAKER, ESQUIRE CAPITAL ONE BANK USA, N.A. C/O M&T BANK, AS GARNISHEE CAPITAL ONE BANK USA, N.A. C/O MEMBERS 1ST FCU, AS GARNISHEE 436 SEVENTH AVE STE 1400 PITTSBURGH, PA 15219 1680 CAPITAL ONE DRIVE MCLEAN, VA 22102 436 7TH AVE # 1400 KOPPERS BLD PITTSBURGH, PA 15219 15 SOUTH MAIN STREET SUITE 500 GREENVILLE, SC 29601 520 FELLOWSHIP RD # C306 MT LAUREL, NJ 08054 PO BOX 844 BUFFALO, NY 14240 5000 LOUISE DRIVE MECHANICSBURG, PA 17055 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) JPMORGAN CHASE BANK, AS TRUSTEE, 2255 NORTH ONTARIO C/O RESIDENTIAL FUNDING SUITE 400 CORPORATION BURBANK, CA 91504 JPMORGAN CHASE BANK, AS TRUSTEE, PO BOX 30014 C/O RESIDENTIAL FUNDING RENO, NV 89520 CORPORATION C/O PEELLE MANAGEMENT CORPORATION JPMORGAN CHASE BANK, AS TRUSTEE, 3883 AIRWAY DRIVE C/O RESIDENTIAL FUNDING SANTA ROSA, CA 95403 CORPORATION C/O WASHINGTON MUTUAL BANK, FA 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. 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 329 WEST PENN STREET CARLISLE, PA 17013-2249 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675 DEPARTMENT OF WELFARE 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 autho ities. Date: B . Phelan Hallinan & Schmieg, LLP Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff WELLS FARGO BANK, N.A., SB/M WELLS FARGO HOME COURT OF COMMON PLEAS MORTGAGE, INC. Plaintiff : VS. JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN CIVIL DIVISION : NO.: 2012-1182 : CUMBERLAND COUNTY Defendant(s) r NOTICE OF SHERIFF'S SALE OF REAL PROPERTY M TO: JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN . < 329 WEST PENN STREET 71 ' CARLISLE, PA 17013-2249` * *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 329 WEST PENN STREET, CARLISLE, PA 17013-2249 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 $79,753.85 obtained by WELLS FARGO BANK, N.A., SB/M WELLS FARGO HOME MORTGAGE, INC. (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 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.) 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 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 J SHORT DESCRIPTION By virtue of a Writ of Execution NO. 2012-1182 WELLS FARGO BANK, N.A., SB/M WELLS FARGO HOME MORTGAGE, INC. vs. JEFFREY D. KAUFFMAN CHARISE M. KAUFFMAN owner(s) of property situate in the 4TH WARD OF THE BOROUGH OF CARLISLE, Cumberland County, Pennsylvania, being (Municipality) 329 WEST PENN STREET, CARLISLE, PA 17013-2249 Parcel No. 05-20-1798-018 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $79,753.85 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT certain lot of ground with the improvements thereon erected, situate in the Fourth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point on the northern line of West Penn Street, the said point being in the center line of a certain 3 foot wide alley or area-way and about 78 feet 2 inches West of the western line of a certain public alley extending North and South between Penn and Lincoln Streets; thence by the center line of the said 3 foot alley in a northerly direction along property late of Robert Thompson, a distance of 169.35 feet to the line of a 16 foot wide alley; thence along the southern line of the said alley in a western direction, a distance of 18 feet to the line of other property late of Robert Thompson; thence by the latter property in a southerly direction, a distance of 169.35 feet to the line of West Penn Street; thence by the said street in an easterly direction, a distance of 18 feet to the point and place of beginning. Including right to Grantees, their heirs, or assigns, to use the 3 foot area-way or alley between the property herein conveyed and the property immediately joining it on the East, jointly with the owner and occupants of the property immediately adjoining on the East, as set forth in Deed Book 8M 589 in the Recorder of Deeds Office for Cumberland County. TITLE TO SAID PREMISES VESTED IN Jeffrey D. Kauffman and Charise M. Kauffman, husband and wife, by Deed from Leon E. Kauffman, single man, individually, dated 09/08/1997, recorded 09/12/1997 in Book 164, Page 415. PREMISES BEING: 329 WEST PENN STREET, CARLISLE, PA 17013-2249 PARCEL NO. 05-20-1798-018 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-1182 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., s/b/m WELLS FARGO HOME MORTGAGE, INC., Plaintiff (s) From JEFFREY D. KAUFFMAN and CHARISE M. KAUFFMAN (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 oi'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: $79,753.85 L.L.: $.50 Interest from 4/26/12 to Date of Sale ($13.11 per diem) -- $1,743.63 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $201.25 Other Costs: Plaintiff Paid: Date: 6/l/2012 David D. Buell, Prothonota (Sea]) Deputy REQUE 7`ING PARTY: Name: MELISSA J. CANTWELL, 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. 308912 AFFIDAVIT OF SERVICE (FHLMC) PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK, N.A., S/B/M WELLS FARGO HOME MORTGAGE, INC. PHS # 288642 DEFENDANT SERVICE TEAM/ Ixh JEFFREY D. KAUFFMAN COURT NO.: 2012-1182 CHARISE M. KAUFFMAN SERVE JEFFREY D. KAUFFMAN AT: TYPE OF ACTION 329 WEST PENN STREET XX Notice of Sheriffs Sale CARLISLE, PA 17013-2249 SALE DATE: September 5, 2012 ou r'n ys. C= SERVED e Served and made known to JEFFREY D. KAUFFMAN, Defendant on the y of U-U 2 t C'X3 63v, d clock _,b. M., at 319W. N ST. CAAWSa- 64, in the manner described below: _ Defendant personally served. j Adult family member with whom Defendant(s) reside(s). 37- . .• Relationship is w (i=ce x Ga - 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 *AS Height 9S" Weight ;QX6 Race W Sex -P Other h a competent adult, hereby verify that 1 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 unswom falsification to authorities. c--? / /I DATE: & (1 Lf- NAME PRINTED NAME: Ronald Moll TITLE: Process Server 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 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. Hiakos, 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 Y -V -4 C3 CD AFFIDAVIT OF SERVICE (FHLMC) PLAINTIFF CUMBERLAND COUNTY WELLS FARGO BANK, N.A., S/B/M WELLS FARGO HOME MORTGAGE, INC. PHS # 288642 DEFENDANT SERVICE TEAM/ lxh JEFFREY D. KAUFFMAN COURT NO.: 2012-1182 CHARISE M. KAUFFMAN SERVE CHARISE M. KAUFFMAN AT: TYPE OF ACTION C "r] 329 WEST PENN STREET XX Notice of Sheriffs Sale CARLISLE PA 17013-2249 rn , SALE DATE: September 5, 20 12 Z t,J) ? SERVED Served and made known to CHARISE M. KAUFFMAN, Defendant on the N'uday of 1,1 E ' 201 t L.LSV, o clock ?. M., at 3,17 W, ph/,tt &t CAALIsu in the manner described below: i/ Defendant personally served. - Adult family member with whom Defendant(s) reside(s). -C 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 465 Height " Weight `1-D Race w Sex P Other c.? f?1 G Ca .. O --11 r 3> I, Ronald Moll , 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 unswom falsification to authorities. -? _ DATE: & Il b- NAME: UY::.. .. ?j1 PRINTED NAME: TITLE: Process Server 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 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 :.i~ w~-GF~"{t e_w°a~ ~a~~THQN ,~. .~._ 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 Attorney for Plainti~~~ ~~~ ~ 3 ~M ~M~ERIAND C ~~t~'dSYLYA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., S/B/M WELLS CUMBERLAND COUNTY FARGO HOME MORTGAGE, INC. Plaintiff, COURT OF COMMON PLEAS v• CIVIL DIVISION JEFFREY D. KAUFFMAN No.: 2012-1182 CHARISE M. KAUFFMAN Defendant(s) 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 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 M~iLRetu~n Receipt stamped by the U.S. Postal Service is attached heret Date: ~ ~ ~ ~ ~ Z~ Allison F. WeliS;'$sZ] 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. 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N C~°m N;~`~ ~ ~CwCC^C •~.-~bn .~:.c~ R~ ~' ° z ~ o a o ;b a, ~ J ~ V ~ ~` ~ ~ ° a ~ V. ~ ~. m o ~ `G ~ a. ~ ~ a ~ ~ =r : Y ~~~_ N !11 ~ ~ ~ a c ~ c g~ O~ ai A~ ~: ~"m 2 N n -• ~_~ -~ ~ ~ ~ - Q ~~^ A w ~ 3~ y~o rr8 AD 2' ~ c a y ~. si u'a ~ ~ _c y ^° v " "~~ °' w ' c ~ o ~ ? o r r: rn ..o c f' 3 x a ...,i :+: = ~ ~- ~ N FILED-OFFICE Or THE PROTHONOTAI�?y 013MAY -2 Phelan Hallinan,LLP CUMBERLAND COUNTY Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 PENNSYLVANIA One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 WELLS FARGO BANK, N.A., SB/M WELLS Court of Common Pleas FARGO HOME MORTGAGE,INC. Plaintiff Civil Division vs CUMBERLAND County JEFFREY D.KAUFFMAN No.2012-1182 CHARISE M.KAUFFMAN Defendant PRAECIPE TO THE PROTHONOTARY: ❑ Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ❑Please mark the above referenced case Settled,Discontinued and Ended. Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ❑Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑Please Vacate the Judgment entered. Date: PHELAN HALLINAN,LLP By: Jonathan Lobb,Esq.,Id.No.312174 Attorney for Plaintiff PHS#288642 50 Phelan-Hallinan,LLP Attorney for Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 WELLS FARGO BANK, N.A., S/B/M WELLS Court of Common Pleas FARGO HOME MORTGAGE,INC. Plaintiff Civil.Division V. CUMBERLAND County JEFFREY D. KAUFFMAN No.2012-1.1.82 CHARISE M.KAUFFMAN Defendant PHS#288642 CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s)on the date listed below: JEFFREY D. KAUFFMAN CHARISE M.KAUFFMAN 329 WEST PENN STREET CARLISLE,PA 17013-2249 Date: r 1r3 PHELAN HALLINAN,LLP By: Jona Lobb,Esq.,Id.No.312174 Attorney for Plaintiff