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Home My WebLink About12-1206 lJ E ? d0 j- ? i i J • ?! C U t?t?ENR $ YdL. VAN I Af# T' Defendants 285890 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 10)0 6-vil O? CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE 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., S/B/M TO WACHOVIA BANK, N.A.. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 V. Plaintiff EDtARDO E. MARTIN A/K%A EDUARDO MARTIN MICHELLE L. MARTIN A/K/A MICHELLE MARTIN 149 ELM STREET CARLISLE, PA 17013 File. 285890 CkW I1(oU S3 ? Q44 w"-7isag 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 #: 285890 1. Plaintiff is WELLS FARGO BANK, N.A., S/B/M TO WACHOVIA BANK, N.A 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: EDUARDO E. MARTIN A/K/A EDUARDO MARTIN MICHELLE L. MARTIN A/K/A MICHELLE MARTIN 149 ELM STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 10/15/2002 EDUARDO E. MARTIN and MICHELLE L. MARTIN made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR GREENPOINT MORTGAGE FUNDING, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book 1778, Page 0716. By Assignment of Mortgage recorded 07/28/2010 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201020403. 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 atlached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 07/01/2011 and each month thereafter are due and unpaid, and by the terms File #: 285890 of said mortgage, upon failure of mortgagor to make such payments after a date specified 6 by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage as of 11130/2011: Principal Balance $111,617.07 Interest $2,699.53 06/01/2011 through 11/30/2011 Late Charges $211.98 Property Inspections $100.00 Escrow Deficit $1,968.62 TOTAL $116,597.20 7 8 Plaintiff is not seeking a judgment of personal liability (or an in personam 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. The mortgage premises are vacant and abandoned. File #: 295890 WHEREFORE. Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $116,597.20, 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, LIT By: R ert sick, Esquire Attornev for Plaintiff File # 2858W LEGAL DESCRIPTION ALL THAT CERTAIN parcel or tract of land situate in the Township of North Middleton, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point at the southwesterly corner of lands now or formerly of E. E. Brunner and thence by the northern line of Lots No. 9 and 10 of the Development of Walton Avenue, North 85 degrees 04 minutes 50 seconds West, 125.0 feet to a point; thence by lands now or formerly of Edward G. Brunner, et ux, and/or James William Brown and Bonnie Lou Brown. his wife North 00 degrees 08 minutes 53 seconds East 147.06 feet to a point; thence South 87 degrees 19 minutes 42 seconds East, 125.0 feet to a point; thence by lands now or formerly of E. E. Brunner South 00 degrees 15 minutes 50 seconds West, 151.99 feet to a point, the place of BEGINNING. THIS description is taken from a Subdivision Plan for Edward B. Brurmer, surveyed by Noel B. Smith, Registered Surveyor, dated June 22, 1973. BEING the same property which John H. Jakomas and Charlotte A. Jakomas, husband and wife, by deed dated December 15, 1989 and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book I-34, Page 113, granted and conveyed unto Dennis L. Husler and Consolacion Husler, husband and wife, grantors herein. TOGETHER with and subject to easeme3nts, rights-of-way and restrictions of prior record. AND the said GRANTORS hereby warrant specially the property herein conveyed. PARCEL NUMBER: 29-17-1585-067A PROPERTY ADDRESS: 119 WALTON AVENUE, CARLISLE, PA 17013-1244 032-PA-V3 PHIS: 285890 VERIFICATION Tracy Archuleta, 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 A/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 hV, 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. DATE: Name:Martin File #:285890 Cam' ?. V Name: Tracy Archuleta "Title: Vice President Loan Documentation 032-PA-V3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff h Jody S Smith Chief Deputy Richard W Stewart Solicitor 7nr? aa? .,n , ?. L„ 152 F11 Wells Fargo Bank, NA vs. Eduardo E. Martin (et al.) Case Number 2012-1206 SHERIFF'S RETURN OF SERVICE 03/05/2012 08:40 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 5, 2012 at 2040 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Michelle Lynn Martin, by making known unto David Bupp, adult in charge at 149 Elm Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. di RO RT BITNER, DEPUTY 03/12/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Eduardo E. Martin, but was unable to locate them in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Eduardo E. Martin. Request for service at 149 Elm Street, Carlisle, Pennsylvania 17013 the Defendant was not found. Deputies were advised, Eduardo E. Martin moved to Harrisburg, Pennsylvania. However, The Carlisle Postmaster is still delivering the Defendant's mail to this address. 03/21/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Michelle Lynn Martin, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Michelle Lynn Martin. Request for service at 119 Walton Avenue, Carlisle, Pennsylvania 17013 is vacant. The Carlisle Postmaster advised, Michelle Lynn Martin's new address is 149 Elm Street, Carlisle, Pennsylvania 17013. 03/21/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Eduardo E. Martin, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Eduardo E. Martin. Request for service at 119 Walton Avenue, Carlisle, Pennsylvania 17013 is vacant. The Carlisle Postmaster advised, Eduardo E. Martin's new address is 149 Elm Street, Carlisle, Pennsylvania 17013. SHERIFF COST: $103.00 March 21, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ;n) Goun S cIe She i f e ecanfi. I ,, PHELAN HALLINAN & SCHMIEG, LLP John M. 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., S/B/M TO WACHOVIA BANK, N.A. Plaintiff vs. EDUARDO E. MARTIN A/K/A EDUARDO MARTIN MICHELLE L. MARTIN A/K/A MICHELLE MARTIN Defendants rv R tEt P?'` - 7 k J a S E?l'?.. AN D t. O U g ".; PENNSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 2012-1206 CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. & SCHMIEG, LLP By: C-- Jo . Kolesnik, Esq., Id. No. 308877 tornev for Plaintiff Date: April 30, 2012 /kpl, Svc Dept. File# 285890 OLM, 75 af?y it 14 /l ?2644 7 20ol7y-) 9o SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank, NA VS. Eduardo E. Martin (et al.) OFF 4E -HF,6t+ERIKF F LED-OFFJG`L TF E PRQTHONQTW 'Y HFE2012 MAY 22 AM 9: 08 CUMBERLAND COUNTY PENNSYLVANIA Case Number 2012-1206 SHERIFF'S RETURN OF SERVICE 05/07/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Eduardo E. Martin, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 05/11/2012 01:00 PM - Dauphin County Return: And now May 11, 2012 at 1300 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Eduardo E. Martin by making known unto himself personally, at 1845 Derry Street, Harrisburg, Pennsylvania 17104 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 May 18, 2012 SO ANSWERS, RbNN? R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. otftt of theerrff William T. Tully Solicitor Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Duignan Chief Dep Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin WELLS FARGO BANK, N.A., S/B/M TO WACHOVIA BANK, N.A. VS EDUARDO E. MARTIN Sheriff s Return No. 2012-T-1379 OTHER COUNTY NO. 2012-1206 And now: MAY 11, 2012 at 1:00:00 PM served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon EDUARDO E. MARTIN by personally handing to EDUARDO E. MARTIN 1 true attested copy of the original REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE and making known to him/her the contents thereof at 1845 DERRY STREET HARRISBURG PA 17104 Sworn and subscribed to before me this 14TH day of May, 2012 -)P*Z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires A 17 2014 So Answers, By?,G, Deputy Sheriff Deputy: DARIN S SH] Sheriffs Costs: $41.25 12 FiLED-OFF'CE Ad`s, PHELAN HALLINAN & SCHMIEG, AFPJti Attorney for Plaintiff Christy Donati, Esq., Id. No.306628 ml JUL -5 ?? t0' 45 1617 JFK Boulevard, Suite 1400 CQ?NTY One Penn Center Plaza CUMBERLAIQ Philadelphia, PA 19103E?€NSYLVANIA 215-563-7000 WELLS FARGO BANK, N.A., S/B/M TO WACHOVIA BANK, N.A. VS. EDUARDO E. MARTIN A/K/A EDUARDO MARTIN MICHELLE L. MARTIN A/K/A MICHELLE MARTIN CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 2012-1206 CIVIL 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 EDUARDO E. MARTIN A/K/A EDUARDO MARTIN, and MICHELLE L. MARTIN A/K/A MICHELLE MARTIN, 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 $116,597.20 $116,597.20 I hereby certify that (1) the Defendants' last known addresses are 119 WALTON AVENUE, CARLISLE, PA 17013-1244,1845 DERRY ST, HARRISBURG, PA 17104-1234,1 and 149 ELM ST, CARLISLE, PA 17013-1921, and (2) that notice has been given in accordant with Rule Pa.R.C.P 237.1. Date ' =? t2 Christy Don Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATE DATE: S -1 1 ) 19, PHS # 285890 PROTHONOTARY (0 api A 101032 s3 X-7 Sys NM?(%Ael 285990 PHELAN HALLINAN & SCHMIEG, LLP Christy Donati, Esq., Id. No.306628 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A., SB/M TO WACHOVIA BANK, N.A. VS. EDUARDO E. MARTIN A/K/A EDUARDO MARTIN MICHELLE L. MARTIN A/K/A MICHELLE MARTIN Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 2012-1206 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knc of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the Unite States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act f Congress of 1940, as amended. (b) that defendant EDUARDO E. MARTIN A/K/A EDUARDO MARTIN is over 18 years of age and the Defendant's last known addresses are 119 WALTON AVENUE, CARLISLE, PA 17013-1244 and 1845 DERRY ST, HARRISBURG, PA 17104-1234. (c) that defendant MICHELLE L. MARTIN A/K/A MICHELLE MARTIN is over 18 years of age and the Defendant's last known addresses are 119 WALTON AVENUE, CARLISLE, PA 17013-1244 and 149 ELM ST, CARLISLE, PA 17013-1921. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date ?Z- Christy Ddn'atl, Esquire Attorney for Plaintiff 285 (Rule of Civil Procedure No. 236) - Revised WELLS FARGO BANK, N.A., S/B/M TO WACHOVIA BANK, N.A. : CUMBERLAND COUNTY : COURT OF COMMON PLEAS VS. EDUARDO E. MARTIN A/K/A EDUARDO MARTIN MICHELLE L. MARTIN A/K/A MICHELLE MARTIN : CIVIL DIVISION : No. 2012-1206 CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on 9- By: If you have any questions concerning this matter please contact: Phelan Hallinan & Schmieg, LLP Christy Donati, 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 HA VE PREVIOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT A SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONL Y ENFOR CEMENT OFA LIEN AGAINST PROPERTY. ** 285890 WELLS FARGO BANK, N.A., SB/M TO WACHOVIA BANK, N.A. Plaintiff V. EDUARDO E. MARTIN A/K/A EDUARDO MARTIN MICHELLE L. MARTIN A/K/A MICHELLE MARTIN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 2012-1206 CIVIL CUMBERLAND COUNTY TO: MICHELLE L. MARTIN, A/K/A MICHELLE MARTIN 149 ELM ST CARLISLE, PA 17(113-1921 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 HHUNG 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 I Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE LIBERTY AVENUE /CARLISLE. PA 17013 (717) 249-3166 M ttt Trushwt Esquire Artor fot miff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 285890 WELLS FARGO BANK, N.A., S/B/M TO WACHOVIA BANK, N.A. Plaintiff V. EDUARDO E. MARTIN A/K/A EDUARDO MARTIN MICHELLE L. MARTIN A/K/A MICHELLE MARTIN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 2012-1206 CIVIL CUMBERLAND COUNTY TO: EDUARDO E. MARTIN, A/K/A EDUARDO MARTIN 1845 DERRY ST HARRISBURG, PA 17104-1234 DATE OFNOTICE: r'9)1Vb'60- THIS FIRM IS A T 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. UPORTANT 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 I 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: gorAttorne wocid, Esquire Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 285890 WELLS FARGO BANK, N.A., S/B/M TO WACHOVIA BANK, N.A. Plaintiff EDUARDO E. MARTIN A/K/A EDUARDO MARTIN MICHELLE L. MARTIN A/K/A MICHELLE MARTIN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 2012-1206 CIVIL CUMBERLAND COUNTY TO: MICHELLE L. MARTIN, A/K/A MICHELLE MARTIN 1 19 WALTON AVENUE CARLISLE, PA OI 1244 DATE OF NOTICE: 0 a- 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 TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse I 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: the Brus wd, Esquires Attorney Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 285890 WELLS FARGO BANK, N.A., SB/M TO WACHOVIA BANK, N.A. Plaintiff V. EDUARDO E. MARTIN A/K/A EDUARDO MARTIN MICHELLE L. MARTIN A/K/A MICHELLE MARTIN Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 2012-1206 CIVIL CUMBERLAND COUNTY TO: EDUARDO E. MARTIN, A/K/A EDUARDO MARTIN 119 WALTON AVENUE CARLISLE, PA 1701P-12+ DATE OF NOTICE: (/-) / I q fx) THIS FIRM IS AMA T 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 TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse I 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: atth B wood, Esquire Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 285890 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIltE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIIZE - H) # 310321 JOSEPH F. RIGA, ESQUIRE - H) # 57716 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, NA s/b/m to Wachovia Bank, N.A. Plaintiff v. Eduardo E Martin a/k/a Eduardo Martin Michelle L. Martin a/k/a Michelle Martin Defendant Attorneys for Plaintiff Cumberland County Court of Common Pleas No. 2012-1206 Civil ENTRY OF APPEARANCE TO THE PROTHONOTARY: _._ r.,.,~ __~ ~ ~-'= „~ :r'~' r, e:.:' .~ ~ - ~~' _~, ~~ .. _, ,- -: ~~ c-r ~,- _... :.:~: ; '. ~.:. - ~ k`i? Kindly enter my appearance on behalf of the Plaintiff, Wells Fargo Bank, NA in the above-captioned matter. l ^/ `r~ti2~ MARL S. WEISBERG, ESQUHtE Attorney for Plaintiff McCAB1~, WEISBERG AND CONWAY, P.C. B~: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARL S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIItE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIItE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 JOSEPH F. RIGA, ESQUIRE - ID # 57716 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, NA s/b/m to Wachovia Bank, N.A. Attorneys for Plaintiff Cumberland County Court of Common Pleas Plaintiff v. No. 2012-1206 Civil Eduardo E Martin alk/a Eduardo Martin Michelle L. Martin a/k/a Michelle Martin Defendant CERTIFICATE OF SERVICE I, Marc S. Weisberg, Esquire, attorney for Plaintiff, hereby certify that a true and correct copy of Plaintiff's Entry of Appearance was served on the below parties on the f~ /'~~ by the United states mail, first class: Eduardo E Martin a/k/a Eduardo Martin Michelle L. Martin a/k/a Michelle Martin 119 Walton Avenue Carlisle, PA 17013 Date: ~ 2 ~~--- MAR .WEISBERG, ESQUIRE Attorney for Plaintiff