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PHELAN HALLINAN & SCHMIEG, LLP
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.
RACHAEL E. MARTE
6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
Defendant
289681
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
TERM
NO. /ol - 134o4 OCUMBERLAND COUNTY
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 289681
G
4/03.15 PO A 27Y
c`t li6aa y7
,et -2'707Q
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 #: 289681
1. Plaintiff is
WELLS FARGO BANK, N.A.
3476 STATEVIEW BOULEVARD
FORT MILL, SC 29715
2. The name(s) and last known address(es) of the Defendant(s) are:
RACHAEL E. MARTE
6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
On 01/31/2008 RACHAEL E. MARTE made, executed and delivered a mortgage upon
the premises hereinafter described to PLAINTIFF which mortgage is recorded in the
Office of the Recorder of CUMBERLAND County, in Instrument No. 200803973. 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 #: 289681
6.
The following amounts are due on the mortgage as of 01/25/2012:
Principal Balance $302,606.81
Interest $2,415.31
through 01/25/2012
Late Charges $359.76
Property Inspections $55.00
Escrow Deficit $3,299.79
TOTAL $308,736.67
7
8
9.
Plaintiff is not seeking a judgment of personal liability (or an in ersonam 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.
The action does not come under Act 6 of 1974 because the original mortgage amount
exceeds the dollar amount provided in the statute.
File #: 289681
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$308,736.67, 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.
PHELAN HALLINAN & SCHMIEG, LLP
By:
A
Esquire Id., No. 80193
File #: 289681
LEGAL DESCRIPTION
ALL of that certain lot or tract of land situate in Hampden Township, Cumberland County, Commonwealth
of Pennsylvania, more particularly bounded and described as follows, to wit:
Beginning at a point on the Eastern right-of-way line of Edgeware Road in the dividing line of Lot #155 and
Lot # 156 as shown on hereinafter mentioned Plan of Recording:
THENCE by aforementioned dividing line South 88 degrees 30 minutes 00 seconds East, 125.12 feet to a
point on the Western line of Lot #140 Hampden Court Phase 3, recorded in Planbook 54 page 74; thence
by aforementioned line South 12 degrees 54 minutes 12 seconds East, 92.92 feet to a point on the dividing
line of Lot #156 and Lot #157; thence by aforementioned dividing line North 88 degrees 30 minutes 00
seconds West, 148.24 feet to a point on the Eastern right-of-way North 01 degrees 30 minutes 00 seconds
East, 90.00 feet to a point being the place of BEGINNING.
BEING Lot # 156 as on Plan of Recording of Hampden Court Phase 5, recorded in Plan Book 70, Page 20.
CONTAINING 12,301.21 square feet
ALSO BEING 6204 Edgeware Road. Also having a part of a 30 foot sanitary sewer and storm easement
along the Northern line (dividing line of Lot #155 and Lot #156).
BEING KNOWN as Parcel # 10-19-1606-171.
PROPERTY ADDRESS: 6204 EDGEWARE ROAD, MECHANICSBURG, PA 17050-5212
PARCEL # 10-19-1606-171
File #: 289681
VERIFICATION
Geeta Sheth, hereby states that l e/she is Vice President Loan Documentation of
WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this
matter, that ?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'1"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.
CTCAirrx s I,--C
Name: Geeta Sheth
DATE: f c, bra T-?? i
Title: Vice President Loan Documentation
032-PA-V3 PHS: 289681
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson _
Sheriff -
Jody S Smith
Chief Deputy 2012 MAR _8 AM 8:54
Richard W Stewart "'UMBERLA D of
Solicitor PENNSYLVANIA fl
?
Wells Fargo Bank, N.A. Case Number
vs.
Rachael E. Marte 2012-1364
SHERIFF'S RETURN OF SERVICE
03/02/2012 05:52 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 2,
2012 at 1752 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Rachael E. Marte, by making known unto Jalorma Richards, Daughter of
Defendant at 6204 Edgeware Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its
contents and at the same time handing to her personally the said true and correct copy of the same.
u
ROBE T BITNER, DEPUTY
SHERIFF COST: $38.00
March 06, 2012
SO ANSWERS,
RbNI`V R ANDERSON, SHERIFF
PHELAN HALLINAN & SCHMIEG, LLP - Attorney for Plaintiff
Matthew Brushwood, Esq., Id. No.310592 i;r i ,, 11?? J
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza ! ;
t?, E R L D C 0 U 14I
Philadelphia, PA 19103 t.6e'S't 'a`"??1?
215-563-7000
WELLS FARGO BANK, N.A. : CUMBERLAND COUNTY
VS.
: COURT OF COMMON PLEAS
RACHAE'L E. MARTE : CIVIL DIVISION
: No. 12-1364
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 RACHAEL E. MARTE,
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
TOTAL
$308,736.67
$308,736.67
I hereby certify that (1) the Defendant's last known address is 6204 EDGEWARE
ROAD, MECHANICSBURG, PA 17050-5212, and (2) that notice has been given in accordance
with Rule P .R.C. 237.1.
Date
at e shwood, Esquire M kk-xktn, Su
Atto or Plaintiff l 1 Q -?
DAMAGES ARE HEREBY ASSESSED AS INDICATE
?x??`a,,,l ec
DATE: S 1,9 -l 11), )-2
PHS # 289681 PROTHONOTARY
289681
PHELAN HALLINAN & SCHMIEG, LLP
Matthew Brushwood, Esq., Id. No.310592
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Attorney for Plaintiff
Philadelphia, PA 19103
215-563-7000
WELLS FARGO BANK, N.A.
VS.
RACHAEL E. MARTE
: CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
CIVIL DIVISION
: No. 12-1364
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 RACHAEL E. MARTE is over 18 years of age and resides at
6204 EDGEWARE ROAD, MECHANICSBURG, PA 17050-5212.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date
atthe r wood, Esquire
Attorn r Plaintiff
289681
(Rule of Civil Procedure No. 236) - Revised
WELLS FARGO BANK, N.A. : CUMBERLAND COUNTY
VS. : COURT OF COMMON PLEAS
RACHAEL E. MARTE
: CIVIL DIVISION
: No. 12-1364
Notice is given that a Judgment in the above captioned matter has been entered
against you on S Opt I?;) .
By:
Oil
lr--)., 12)c3t"o
If you have any questions concerning this matter please contact:
Phelan Hallinan & Schmieg, LLP
Matthew Brushwood, Esquire
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
* * THIS IRM IS A DEBT COLLECTOR A TTEMPTING TO COLLECT A DEBT AND
ANY INF RMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU
HAVE PR VIOUSLYRECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND
SHOULD 80T BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT
ONLYEN)'ORCEMENT OFA LIENAGAINST PROPERTY**
289681
WELLS FARGO BANK, N.A.
V.
Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 12-1364
RACHAEL E. MARTE
Defendant(s)
CUMBERLAND COUNTY
TO: RACHAEL E. MARTE
6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
DATE OF NOTICE: yls-&
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
APPEAlkANCE 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 WI'T'HIN 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
By:
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
. 1,/,?,,. j'717) 249-3166
;2& Michael Kolesnik, Esquire
orney for Plaintiff
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
PHS # 289681
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-1364 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 RACHAEL E. MARTE
(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: $308,736.67 L.L.: $.50
Interest FROM 5/30/2012 TO DATE OF SALE ($50.75 PER DIEM) - $9,642.50
Atty's Comm: % Due Prothy: $2.25
Atty Paid: 189.25 Other Costs:
Plaintiff Paid:
Date: 8/6/2012
1
David D. Bu 11, Prothonot
(Seal)
Deputy
REQUESTING PARTY:
Name: MATTHEW BRUSHWOOD, ESQUIRE
Address: PHELAN HALLINAN & SCHMIEG, LLP
1617 JFK BOULEVARD, SUITE 1400
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 310592
PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
WELLS FARGO BANK, N.A.
Plaintiff
V.
RACIIAEL E. MARTE
Defendant(s)
To the Prothonotary:
Issue writ of execution in the above matter:
Amount Due
Interest from 05/30/2012 to Date of Sale
($50.75 per diem)
TOTAL
Note: Please attach description of property.
PHS # 289681
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CIVIL DIVISION
NO.: 12-1364
CUMBERLAND
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atthew Brushwood, Esq., Id. No.310592
Attorney for Plaintiff
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LEGAL DESCRIPTION
ALL of that certain lot or tract of land situate in Hampden Township, Cumberland County,
Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit:
Beginning at a point on the Eastern right-of-way line of Edgeware Road in the dividing line of Lot #1
and Lot #156 as shown on hereinafter mentioned Plan of Recording:
THENCE by aforementioned dividing line South 88 degrees 30 minutes 00 seconds East, 125.12 feet t a
point on the Western line of Lot # 140 Hampden Court Phase 3, recorded in Planbook 54 page 74; then e
by aforementioned line South 12 degrees 54 minutes 12 seconds East, 92.92 feet to a point on the
dividing line of Lot #156 and Lot #157; thence by aforementioned dividing line North 88 degrees 30
minutes 00 seconds West, 148.24 feet to a point on the Eastern right-of-way North 01 degrees 30 min tes
00 seconds East, 90.00 feet to a point being the place of BEGINNING.
BEING Lot # 156 as on Plan of Recording of Hampden Court Phase 5, recorded in Plan Book 70,
20.
CONTAINING 12,301.21 square feet
ALSO BEING 6204 Edgeware Road. Also having a part of a 30 foot sanitary sewer and storm
along the Northern line (dividing line of Lot #155 and Lot #156).
TITLE TO SAID PREMISES VESTED IN Rachael E. Marte, a single person, by Deed from
E. Speelman, a single person and Jalorma Yanich, a single person, dated 01/31/2008, recorded
02/08/2008 in Instrument Number 200803972.
PREMISES BEING: 6204 EDGEWARE ROAD, MECHANICSBURG, PA 17050-5212
PARCEL NO. 10-19-1606-171
PHELAN HALLINAN & SCHMIEG, LLPF Attorneys for Plaintiff
Matthew Brushwood, Esq., Id. No.310592 Pf??OTt?ONO CA'
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza ImI NUG -6
Philadelphia, PA 19103 C4tjY
215-563-7000 ?? ????, ALV
WELLS FARGO BANK, N.A. COURT OF COMM
Plaintiff
CIVIL DIVISION
V.
NO.: 12-1364
RACHAEL E. MARTE
Defendant(s)
CUMBERLAND C
CERTIFICATION
The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above
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. 3 9143
PLEAS
This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
authorities. _
By: V
lan H ma & Schmieg, LLP
I P
tthew wood, Esq., Id. No.310592
Attornev for Plaintiff
,--WELLS FARGO BANK, N.A. COURT OF COMM(
Plaintiff
FILED-U FICL
-rCIE PROrtNONOTAt? ? ,. CIVIL DIVISION
'?? •
V. 2012 AUG '6? ??' Z? NO.: 12-1364
RACHAEL E. MARTE
Defendant(s) CUMBERLAND CO A ?Y
CUMBERLAND CO
PHS # 289681
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
for the Writ of Execution was filed, the following information concerning the real property located at 6204 EDGEWARE P
MECHANICSBURG, PA 17050-5212.
1. Name and address of Owner(s) or reputed Owner(s):
Name Address (if address cannot be reasonably
ascertained, please so indicate)
RACHAEL E. MARTE 6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
2. Name and address of Defendant(s) in the judgment:
Name Address (if address cannot be reasonably
ascertained, please so indicate)
SAME AS ABOVE
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to
Name Address (if address cannot be
reasonably ascertained, please indicate)
HSBC Bank Nevada, NA.
1111 Town Center Drive
Las Vegas, NV 89193
HSBC Bank Nevada, NA. C/O James
Warmbrodt, ESQ.
WELTMAN WEINBERG ET AL
436 SEVENTH AVE STE 1400
PITTSBURGH, PA 15219-1827
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,
sale.
Name Address (if address cannot be
reasonably ascertained, please indicate)
PLEAS
Praecipe
sold:
by the
.A* 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
Domestic Relations of
Cumberland County
6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
13 North Hanover Street
Carlisle, PA 17013
Commonwealth of Pennsylvania
Department of Welfare
Internal Revenue Service Advisory
U.S. Department of Justice
U.S. Attorney for the Middle District of PA
Federal Building
P.O. Box 2675
Harrisburg, PA 17105
1000 Liberty Avenue Room 704
Pittsburgh, PA 15222
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 persc
knowledge or information and belief. I understand that false statements herein are made subject to
of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authoriti
Date:
? W? ?-
By:
h lan Hallinan\&Scl mieg, LLP
Matthew Brushwood, Esq., Id. No.310592
Attorney for Plaintiff
penalties
WELLS FARGO BANKJt42!9O f ?N't' ? t
2Q42 BUG ?? AM ?Y
??3MBE? S VaN A
RACHAEL E. MARTE
: COURT OF COMMON
Plaintiff CIVIL DIVISION
: NO.:12-1364
Defendant(s) CUMBERLAND CO
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: RACHAEL E. MARTE
6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
"THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION I
WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANIS
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ENFORCEMENT OF A LIEN AGAINST PROPERTY."
AINED
Y
Your house (real estate) at 6204 EDGEWARE ROAD, MECHANICSBURG, PA 17050-5212 is
scheduled to be sold at the Sheriffs Sale on 12/05/2012 at 10:00 AM in the Cumberland County Cou house,
South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $308,736.67 obtained by ELLS
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 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, cost 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 j dgm
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good ca se.
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 'I'U NAVE Y V U K rKVrEK
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
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 properly 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) d ys after
the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection i his
office. This schedule will state who will be receiving that money. The money will be paid out in acco dance
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 of that certain lot or tract of land situate in Hampden Township, Cumberland County,
Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit:
Beginning at a point on the Eastern right-of-way line of Edgeware Road in the dividing line of Lot #1
and Lot #156 as shown on hereinafter mentioned Plan of Recording:
THENCE by aforementioned dividing line South 88 degrees 30 minutes 00 seconds East, 125.12 feet t a
point on the Western line of Lot #140 Hampden Court Phase 3, recorded in Planbook 54 page 74; then
92.92 feet to a point on the
by aforementioned line South 12 degrees 54 minutes 12 seconds East,
dividing line of Lot #156 and Lot #157; thence by aforementioned dividing line North 88 degrees 30
minutes 00 seconds West, 148.24 feet to a point on the Eastern right-of-way North 01 degrees 30 minu es
00 seconds East, 90.00 feet to a point being the place of BEGINNING.
BEING Lot # 156 as on Plan of Recording of Hampden Court Phase 5, recorded in Plan Book 70, Pa
20.
CONTAINING 12,301.21 square feet
ALSO BEING 6204 Edgeware Road. Also having a part of a 30 foot sanitary sewer and storm ea
along the Northern line (dividing line of Lot #155 and Lot #156).
TITLE TO SAID PREMISES VESTED IN Rachael E. Marte, a single person, by Deed from
E. Speelman, a single person and Jalorma Yanich, a single person, dated 01/31/2008, recorded
02/08/2008 in Instrument Number 200803972.
PREMISES BEING: 6204 EDGEWARE ROAD, MECHANICSBURG, PA 17050-5212
PARCEL NO. 10-19-1606-171
~~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
WELLS fAKGO BANK. N.A.
Plaintiff
Court of Common }'leas
Civil Division
~.
RACHAIL E. MARTS
Defendant
CUMBERLAND County
No.: 12-1364
RULE
ANU 1~~OW. this~~~~ day of Mfr' ~~~~ X2012, a Rule is entered upon the Defendant
to sho~~~ cause ~~~hv 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
Plaintiffs 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
,.
J.
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C'~p;es ~ ,~~~ i%~~,a
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~ _ _ __
Allison F. Wells. Esq., Id. No.309519
Phelan Hallman & Schmieg, LLP
1617 JFK E3oulevard, Suite 1400
Philadelphia, PA 19103
~TGL: (215) 563-7000
FAX: (215) 563-3459
RACHAEL E. MARTS RACHAEL E. MAR~CE
6204 EDGEWARE ROAD 12 NOTTINGHAM DR
MECHANICSBURG. PA 17050-5212 MECHANICSBURG_ PA 17050-2644
RACHAEL E. MARTS
6204 EDGEWEAR ROAD
MECHAMCSBURG. PA 17050
289681
289681
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PHELAN HALLINAN & SCHMIEG, LL,P „ ` !~ "'''~
by: Allison F. Wells, Esquire, Atty. LD. No. 309519 ATTORNEY FOR PLAINTIFF
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
15) 563-7000
WEI LS FARGO BANK, N.A. Court of Common Pleas
Plaintiff
Civil Division
~-.
R.ICIIAI!:L 1:. ~IARTE
Cumberland Count}'
Defendant
No.: 12-1364
PRAECIPE TO SUBSTITUTE EXHIBIT
To the Prothonotary:
Please attach the following Concurrence letter and Certificate of Mailing as Exhibit "B"
to Plaintiff s Motion to Reassess Damages which was filed with the court on or about October
1.2. 201?.
DATE: YI/
Phelan
A~. Wells, Esquire
Attorney for Plaintiff
EXHIBIT "B"
PHELAN HALLINAN & SCHMIEG, LLP
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103
(215)563-7000
FAX#: (215) 563-3459
Phelan Hallman & Schmieg, LLP
Representing Lenders in
Pennsylvania and Ne~~~ Jersey
October 2.:?012
RACHAF,L E. MARTS
6204 EDGEWARE ROAD
MECHANICSF3t1RG, PA 17050-5212
lZ£~ WELLS FARCO BANK, N.A. v. RACHAEL E. MARTS
Premises Address: 6204 EDGEWARE ROAD MECHANICSBURG, PA 170~Ca
C(:"MRFRLAND County CCF', No. 12-1364
bear Defendant.
Enclosed please find a true and correct copy of my proposed Motion to Reassess D~nages
and Order. In accordance with Cumbe-nand County Local Rule 20&.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 10/09/2012.
Should you have further questions or concerns, please do not hesitate to contact nle.
Othe,-wise, please be guided accordingly.
Verti~ truly yours, .-~~"""`
:111is~~n~ .., _~.,}fl. 1~,>:3t1t1.~i 19
,lttorney for 1'~'f
Enclosure
89681
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By: 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
v.
RACHAEL E. MAR'TE
Cumberland County
No.: 12-1364
Defendant
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of Plaintiffs Praecipe to Substitute Exhibit
was sent to the following individuals on the date indicated below.
RACHAEL E. MARTS
6204 EDGEWARE ROAD
MECfIANICSBURG, PA 17050-5212.
RACHAEL E. MARIE
12 NOTTINGHAM DR
MECHANICSBtJRG, PA 17050-2.644
RACHAEL E. MARIE
6204 EDGEWEAR ROAD
MECHANICSBURG. PA 17050
DATE: ~
Phelan Hallinan &~ g, LP
/-'/"
By:
Allis s, Esq., Id. No. 309519
ATTORNEY FOR PLAINTIFF
Phelan Hallir.~an &Schmieg, LLP
.ltistin ~F; . Koheski, Esq., Id. No.200392
1617 .IFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
2 I -5(i ~-7000
WELLS FAH:GO BANK, N.A.
Plaintiff
,~I,, _.. ~,a -,
A~['~RNEY FOR PLAINTIFF
t ,~~U. ~'
~Ya, ~?~,_~ 1.
Court of Common Pleas
Civil Division
vs.
RACHAEI. l~. MARTS
Defendant
CUMBERLAND County
No.: 12-1364
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's October 17, 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 L,elow,
KACHAEL E. MARTE
6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
RACHAEL E. MARTS
6204 EDGI~,WEAR ROAD
MECHANICSBURG, PA 17050
RACHAEL E. MARTE
12 NOTTINGHAM DR
MECHANICSBURG, PA 17050-2644
Phelan Hallinan &Schmieg, LLP
DATI~: _~~ By. -
Jus ' F. ob ski, Esq., Id. No.200392.
A rney for Plaintiff
28968]
Phelan Hallinan & Schmieg, LLP
Melissa J. Cantwell, Esq., Id. No.308~~~ ~:`O~' `9 ~ ~~~ ~TTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400 ~_~~~,~~~~,~ ~~~~-~:
One Penn Center Plaza ~'~~SYLYAt~IA
Philadelphia, PA 19103
215-563-7000
WELLS FARGO BANK, N.A. Court of Common Pleas
Plaintiff
Civil Division
vs.
CUMBERLAND County
RACHAEL E. MARTE
No.:12-1364
Defendant
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 October 12, 2012.
2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy
of its proposed Motion to Reassess Damages and Order to the Defendant on October 2, 2012 and
requested the Defendant's Concurrence. Plaintiff did not receive any response from the
Defendant. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and
certificate of mailing are attached hereto, made part hereof, and marked as Exhibit "A".
3. A Rule was issued by the Honorable Christylee L. Peck on or about October 17,
2012 directing the Defendant to show cause by November 6, 2012 why the Motion to Reassess
Damages should not be granted. A true and correct copy of the Rule is attached hereto, made
part hereof, and marked Exhibit "B".
4. The Rule to Show Cause was timely served upon all parties on November 1,
2012 in accordance with the applicable rules of civil procedure. A true and correct copy of the
Certificate of Service is attached hereto, made part hereof, and marked Exhibit "C".
5. Defendant failed to respond or otherwise plead by the Rule Returnable date of
November 6, 2012.
289681
WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show
Cause absolute and grant Plaintiffls Motion to Reassess Damages.
helan llinan & Sc ieg, LLP
DATE: By:
Melissa J. Cantwell, Esq., Id. No.308912
Attorney for Plaintiff
289681
Exhibit "A"
289681
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
October 2, 2012
RACHAEL E. MARTE
6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
Representing Lenders in
Pennsylvania and New Jersey
RE: WELLS FARGO BANK, N.A. v. RACHAEL E. MARTE
Premises Address: 6204 EDGEWARE ROAD MECHANICSBURG, PA 17050
CUMBERLAND County CCP, No. 12-1364
Dear Defendant,
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 10/09/2012.
Should you have further questions or concerns, please do not hesitate to contact me.
Otherwise, please be guided accordingly.
Very truly yours,
~.
Alliaon o. 19
Attorney for. P aintiff
Enclosure
289681
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Exhibit "B"
289681
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
WELLS FARGO BANK, N.A. Court of Common Pleas
Plaintiff
. Civil Division
v;
CUMBERLAND County
3
RACHAEL E. MARTE .
No.: ]2-1364
a
Defendant
RULE
AND NOW, this~,~. day of ~ ~¢ 2012, a Rule is entered upon the Defendant
to show cause why an Order should not be entered granting Plaintiffs Motion to Reassess
Damages.
Defendant shall have twenty (20) days from the date of this Order to file a response to
Plaintiffs 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 j j/
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2896'81
Exhibit "C"
289681
Phelan Hallinan & Schmieg, LLP
Justin F. Kobeski, Esq., Id. No.200392
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
WELLS FARGO BANK, N.A.
Plaintiff
vs.
RACHAEL E. MARTS
Defendant
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
. CUMBERLAND County
. No.:12-1364
CERTIFICATION_UF :~I:KVICE
I hereby certify that a true and correct copy of the Court's October 17, 2012 Rule
directing the Defendant to show cause as to why Plaintiff s Motion to Reassess Damages should
not be granted was served upon the following individual on the date indicated below.
RACHAEL E. MARTS
6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
RACHAEL E. MARTS
6204 EDGEWEAR ROAD
MECHANICSBURG, PA 17050
DATE; ~ j ~~ [~
RACHAEL E. MARTS
12 NOTTINGHAM DR
MECHANICSBURG, PA 17050-2644
Phelan Hallinan 8c Schmieg, LLP
By;
Ju T`. b ski, Esq., Id. No.200392
A rney for Plaintiff
289681
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.
Plaintiff
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
vs.
CUMBERLAND County
RACHAEL E. MARTE
No.:12-1364
Defendant
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of Plaintiff s Motion to Make Rule Absolute
was served upon the following individual on the date indicated below.
RACHAEL E. MARTE
6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
RACHAEL E. MARTE
6204 EDGEWEAR ROAD
MECHANICSBURG, PA 17050
RACHAEL E. MARTE
12 NOTTINGHAM DR
MECHANICSBURG, PA 17050-2644
DATE:
helan allinan c ieg, LLP
By:
e issa J. Cantwell, s ., . No.308912
Attorney for Plaintiff
289681
J
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.
Plaintiff
vs.
Court of Common Pleas
~ <-.~
Civil Division ,,,o
rn
CUMBERLAND Coi +~
-,;~ 3 _.
a ~.
a ~.
_,~
RACHAEL E. MARTS
Defendant
. ,,,~.~
. ~-
No.:12-1364 v~
2
7~" ~.
•--i
ORDER
AND NOW, this %'~~~. day of ~ ~~~~'~ 12, upon consideration of Plaintiff s
~ :~~.
c_.,,a ~',}~ ;
c~ ~ _ -_
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:
Principal Balance $302,606.81
Interest Through December 5, 2012 $7,634.13
Per Diem $16.58
Late Charges $359.76
Legal fees $1,450.00
Cost of Suit and Title $578.75
Property Inspections $160.00
Mortgage Insurance Premium/ Private Mortgage Insurance $2,743.65
Non Sufficient Funds Charge $20.00
Escrow Deficit $6,470.15
TOTAL $322,023.25
Plus interest at six percent per annum.
Note: The above figure is not a payoff quote. Sheriff s commission is not included in the above
figure.
~S~Cr~~ BY THE COURT:
/ man 1-~all~nan ~ ~S'rl~~ ~~ ~ r~~
~ 12ac~,el ~. /1~I~r~-~r J.
~~;~s N+~'i • ~~p/ ~ ll j~~~ 289681
1~~
_ _
I i ! _.
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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
. ~. ~ :.
Attorney for Plaintiff
..f.,;rl.!P~SY! ~!r;,~l,~
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.
Plaintiff,
v.
RACHAEL E. MARTE
Defendant(s)
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
CIVIL DIVISION
No.: 12-1364
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1
COMMONWEALTH OF PENNSYLVANIA )
PHILADELPHIA COUNTY ) SS:
As required by Pa. R.C.P. 3129.1(x) Notice of Sale has been given to Lienholders
and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of
the persons or parties named, at that address, set forth on the Affidavit and as amended if
applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return
Receipt stamped by the U.S. Postal Service is atta~i d herej(n Exhi "A~
McTa J. Cantwell, Esqui
201, Attorney for Plaintiff
Date: NOV 16
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not
be sold in the absence of a representative of the plaintiff at the Sheriff s Sale. The sale
must be postponed or stayed in the event that a representative of the plaintiff is not present
at the sale.
PHS # 289681
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AFFIDAVIT OF SERVICE (FNMA)
PLAINTIFF CUMBERLAND COUNTY
WELLS FARGO BANK, N.A. '
PHS # 289681
DEFENDANT SERVICE TEAM/ lxh
RACHAEL E. MARTS COURT NO.: 12-1364
SERVE RACHAEL E. MARTS AT: TYPE OF ACTION
12 NOTTINGHAM DR XX Notice of Sheriff s Sal e z~.
`
MECHANICSBURG, PA 17050-2644 SALE DATE: December 5, 2012 ~ ~ ''1
`
SERVED ~~'t :
~'~-
~
Served and made known to RACHAEL E. MARTS, Defendant on the ~~'°day of 6C.'T48 F.~ , 20 ~~~ rj -:~
7 "
t?~ = ~7 , o clock ~,. M., at , in the manner described below: ~
~' ~ ~,~~
Defendant personally served. FCfFA'Nk-st3~ ~ (~1~~ <a ~ .t,..~,~,
_
~ Adult family member with whom Defendant(s) reside(s). ~ ~ ~ ~ "°"
Relationship is _~" H'f>~ ~, ~ c~ t.W.+ ~.,:'
'
_ 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). ..C C.J
_ Agent or person in charge of Defendant's office or usual place of business,
an officer of said Defendant's company.
Other:
Description: Age ~6 Height 5 , ~ Weight i« Race w Sex ~' Other
~~~nald P~Ioll
I, , 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 falsification to authorities. ~ ANC/CJ ~~~~~
DATE: f~ 17 I ~ NAME:
PRINTED NAME: ROZIaId 1Vlolj
TITLE:
Process Scrver
NOT SERVED
On the day of , 20_; at o clock _. M., I, , a competent adult hereby state that
Defendan-~OT FO cause:
_ Vacant ~ Does Not Exist _ Moved _ Does Not Reside (Not Vacant)
_ No Answer on at at
_ Service Refused
Other: n
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn('jU~~
falsification to authorities.
BY:
PRINTED NAME:
ATTORNEY FOR PLAINTIFF
Lawrence T. Phelan, Esq., Id. No. 32227
Francis S. Hallman, 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
2~
Phelan Hallinan, LLP Attorney For Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Cf f
y CO -!
z- ?F
I WELLS FARGO BANK, N.A. Court of Common Pleas
Plaintiff .
Civil Division
vs
CUMBERLAND County
RACHAEL E. MARTE
Defendant No. 12-1364
PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF
PURSUANT TO Pa.R.C.P., 2352
TO THE PROTHONOTARY:
Kindly substitute US BANK NA AS LEGAL TITLE TRUSTEE FOR TRUMAN 2012 SC2
TITLE TRUST as successor Plaintiff for the originally named Plaintiff.
The material facts on which the right of succession and substitution are based as follows:
US BANK NA AS LEGAL TITLE TRUSTEE FOR TRUMAN 2012 SC2 TITLE
TRUST is the current holder of the mortgage by virtue of that certain Assignment of
Mortgage, which Assignment was recorded on 12/28/2012 in Instrument No.
201240470 of the Recorder of Deeds Office in and for CUMBERLAND County.
Kindly amend the information on the docket accor ' g
Date: it By:
Allison . Z
PHS # 289681
yrfan, Esq., Id/No.309519
for Plaintiff
?? sso-18
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. Court of Common Pleas
Plaintiff
Civil Division
vs
CUMBERLAND County
RACHAEL E. MARTE
Defendant No. 12-1364
PRAECIPE TO MARK JUDGMENT TO USE PLAINTIFF
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please mark the judgment in the above-captioned matter to the use of US BANK NA AS
LEGAL TITLE TRUSTEE FOR TRUMAN 2012 SC2 TITLE TRUST, located 7515 IRVINE
CENTER DRIVE IRVINE, CA 92618
Date: PHELAN LAN, By:
Allison d. No.309519
for
PHS # 289681
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf of US BANK NA AS LEGAL TITLE
TRUSTEE FOR TRUMAN 2012 SC2 TITLE TRUST.
Date: L CL--1 PHELAN INAN, LLP
By:
Allis F. term i, Esq., Id. No.309519
ornev or Plaintiff
PHS # 289681
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorney for Plaintiff
WELLS FARGO BANK, N.A. Court of Common Pleas
Plaintiff Civil Division
V. CUMBERLAND County
RACHAEL E. MARTE No. 12-1364
Defendant PHS # 289681
CERTIFICATION OF SERVICE
I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe to mark
judgment to US BANK NA AS LEGAL TITLE TRUSTEE FOR TRUMAN 2012 SC2 TITLE
TRUST and substitution of party plaintiff was served by regular mail to the person(s) on the date
listed below:
RACHAEL E. MARTE
6204 EDGEWARE ROAD
MECHANICSBURG, PA 17050-5212
Date:
ptvi9-- Z? PHELAN INAN, LLP
By:
Allison . Zuckerm , Esq., Id. No.309519
AUomey r Plaintiff
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
�,r-.
Ronny R Anderson {- ` tl`ED_i✓F FI .�
Sheriff (10y��ttr at�'uurbr i t THE PROTHO�l b :I}y
Jody S Smith
Chief Deputy 2013 MAR 20 AM Ifl: 49
,�
Richard W Stewart CUMBERLAND COUNTY
Solicitor WiCE OF THE$4ERIFF PENNSYLVANIA
Wells Fargo Bank, N.A.
Case Number
vs.
Rachael E. Marte 2012-1364
SHERIFF'S RETURN OF SERVICE
09/21/2012 05:44 PM-Deputy Ryan Burgett, 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 6204 Edgeware Road, Hampden Township, Mechanicsburg, PA 17050,
Cumberland County.
10/12/2012 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and
inquiry for the within named Defendant,to wit: Rachael E. Marte, but was unable to locate the Defendant
in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above
titled action, as"Not Found"at 6204 Edgeware Road, Mechanicsburg, PA 17050, address is vacant.
10/18/2012 04:35 PM-Deputy Michelle Gutshall, 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 JALORMA
RICHARDS-DAUGHTER,who accepted as"Adult Person in Charge"for Rachael E. Marte at 12
Nottingham Drive, Mechanicsburg, PA 17050, Cumberland County.
12/05/2012 As directed by Francis S. Hallinan,Attorney for the Plaintiff, Sheriffs Sale Continued to 1/9/2013
01/09/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on January 9, 2013 at 10:00 a.m. He
sold the same for the sum of$1.00 to Attorney Francis Hallinan, on behalf of US Bank NA as Legal Title
Trustee for Truman 2012 SC2 Title Trust, being the buyer in this execution, paid to the Sheriff the sum of
SHERIFF COST: $1,094.26 SO ANSWERS,
March 18, 2013 RbNtrY R ANDERSON, SHERIFF
±c)CountySude Sheriff,Teleosofl,Inc.
t WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS
Plaintiff
CIVIL DIVISION
V.
NO.: 12-1364
RACHAEL E. MARTE
Defendant(s) -
CUMBERLAND COUNTY
PHS#289681
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 6204 EDGEWARE ROAD,
MECHANICSBURG,PA 17050-5212.
1. Name and address of Owner(s)or reputed Owner(s):
Name Address(if address cannot be reasonably
ascertained,please so indicate)
RACHAEL E.MARTE 6204 EDGEWARE ROAD
MECHANICSBURG,PA 17050-5212
2. Name and address of Defendant(s)in the judgment:
Name Address(if address cannot be reasonably
ascertained,please so indicate)
SAME AS ABOVE
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)
HSBC Bank Nevada,NA. 1111 Town Center Drive
Las Vegas,NV 89193
HSBC Bank Nevada,NA.C/O James WELTMAN WEINBERG ET AL
Warmbrodt,ESQ. 436 SEVENTH AVE STE 1400
PITTSBURGH,PA 15219-1827
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)
l .
None.
7. 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)
TENANVOCCUPANT 6204 EDGEWARE ROAD
MECHANICSBURG,PA 17050-5212
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 228 Walnut Street,Suite 220
U.S.Attorney for the Middle District of PA PO Box 11754
Federal Building 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 unworn falsification to authoriti
Date: By:
h lan Hallinan mieg,LLP
Matthew Brushwood,Esq.,Id.No310592
Attorney for Plaintiff
f
WELLS FARGO BANK,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
VS. NO.: 12-1364
RACHAEL E. MARTE
Defendant(s) CUMBERLAND COUNTY
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: RACHAEL E. MARTS
6204 EDGEWARE ROAD
MECHANICSBURG,PA 17050-5212
"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 6204 EDGEWARE ROAD,MECHANICSBURG,PA 17050-5212 is
scheduled to be sold at the Sheriff's Sale on 12/05/2012 at 10:00 AM in the Cumberland County Courthouse,
South Hanover Street,Carlisle,PA 17013 to enforce the court judgment of$308,736.67 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 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: 215-563-7M 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 YO IiJ 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 of that certain lot or tract of land situate in Hampden Township, Cumberland County,
Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit:
Beginning at a point on the Eastern right-of-way line of Edgeware Road in the dividing line of Lot#155
and Lot#156 as shown on hereinafter mentioned Plan of Recording:
THENCE by aforementioned dividing line South 88 degrees 30 minutes 00 seconds East, 125.12 feet to a
point on the Western line of Lot#140 Hampden Court Phase 3,recorded in Planbook 54 page 74;thence
by aforementioned line South 12 degrees 54 minutes 12 seconds East,92.92 feet to a point on the
dividing line of Lot#156 and Lot#157;thence by aforementioned dividing line North 88 degrees 30
minutes 00 seconds West, 148.24 feet to a point on the Eastern right-of-way North 01 degrees 30 minutes
00 seconds East,90.00 feet to a point being the place of BEGINNING.
BEING Lot# 156 as on Plan of Recording of Hampden Court Phase 5,recorded in Plan Book 70,Page
20.
CONTAINING 12,301.21 square feet
ALSO BEING 6204 Edgeware Road.Also having a part of a 30 foot sanitary sewer and storm easement
along the Northern line(dividing line of Lot#155 and Lot#156).
TITLE TO SAID PREMISES VESTED IN Rachael E.Marte,a single person,by Deed from Rachael
E. Speelman,a single person and Jalorma Yanich,a single person,dated 01/31/2008,recorded
02/08/2008 in Instrument Number 200803972.
PREMISES BEING: 6204 EDGEWARE ROAD,MECHANICSBURG,PA 17050-5212
PARCEL NO. 10-19-1606-171
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) N0, 12-1364 Civil
COUNTY OF CUMBERLAND) 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 RACHAEL E. MARTE
(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: $308,736.67 L.L.: $.50
Interest FROM 5/30/2012 TO DATE OF SALE($50.75 PER DIEM)-$9,642.50
Atty's Comm: % Due Prothy:$2.25
Arty Paid: 189.25 Other Costs:
Plaintiff Paid:
Date: 8/6/2012
I
David D.Buell,Prothonotary—
(Seal)
Deputy
REQUESTING PARTY:
Name: MATTHEW BRUSHWOOD,ESQUIRE
Address: PHELAN HALLINAN&SCHMIEG,LLP
1617 JFK BOULEVARD,SUITE 1400
PHILADELPHIA,PA 19103 'TRUE Wpy FROM RECORD
In Testimony whereof,I hereunto set my hand
Attorney for: PLAINTIFF end of said Cou t C disie,Pa.
day of 2t
Telephone: 215-563-7000 This rothenota-y
Supreme Court ID No.310592 ✓ / 1
1
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CUMBERLAND LAW JOURNAL
Writ No. 2012-1364 Civil Term PREMISES BEING: 6204 EDGE-
WARE ROAD,MECHANICSBURG,PA
Wells Fargo Bank,N.A. 17050-5212.
VS. PARCEL NO. 10-19-1606-171.
Rachael E. Marte
Atty.:Francis S.Hallinan
ALL of that certain lot or tract of
land situate in Hampden Township,
Cumberland County,Commonwealth
of Pennsylvania, more particularly
bounded and described as follows,
to wit:
Beginning at a point on the East-
ern right-of-way line of Edgeware
Road in the dividing line of Lot#155
and Lot#156 as shown an hereinafter
mentioned Plan of Recording:
THENCE by aforementioned di-
viding line South 88 degrees 30
minutes 00 seconds East, 125.12
feet to a point on the Western line
of Lot #140 Hampden Court Phase
3,recorded in Planbook 54 page 74;
thence by aforementioned line South
12 degrees 54 minutes 12 seconds
East,92.92 feet to a point on the di-
viding line of Lot#156 and Lot#157;
thence by aforementioned dividing
line North 88 degrees 30 minutes 00
seconds West, 148.24 feet to a point
on the Eastern right-of-way North 01
degrees 30 minutes 00 seconds East,
90.00 feet to a point being the place
of BEGINNING.
BEING Lot # 156 as on Plan of
Recording of Hampden Court Phase
5,recorded in Plan Book 70,Page 20.
CONTAINING 12,301.21 square
feet.
ALSO BEING 6204 Edgeware
Road.Also having a part of a 30 foot
sanitary sewer and storm easement
along the Northern line(dividing line
of Lot#155 and Lot#156).
TITLE TO SAID PREMISES VEST-
ED IN Rachael E. Marte, a single
person, by Deed from Rachael E.
Speelman, a single person and Ja-
lorma Yanich,a single person,dated
01/31/2008,recorded 02/08/2008
in Instrument Number 200803972.
61
� 1
i
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:
October 26, November 2 and November 9,2012
i
Affiant ftutber 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.
I&Marie Coyne,qtor
SWORN TO AND SUBSCRIBED before me this
da of November, 2012
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND;COUNTY
My Commission Expires Apr 28,2014
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CONI'AtNW12X.21 agaan foes
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having a part of a36fip nskmy sewer
and stoma a tabtW&Axtl em
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MU M SAD MOO S VESTED
IN Radrsel F.Mnrta,a siagto paraen,by
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Yanich,a single pawn,dated 01/31iI^
recorded
M=mbmmtmWN=ba
200803972.'
PREM[SBS BOW 6M K*EWARE
ROAD,MECHAN1(b'BURG,PA 17050-
5212
PARCEL NO.10.19.1606.171
The Patriot-News Co.
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050 Now you know
Inquiries -717-256-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
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.
4
F$UBLICATION COPY r This ad ran on the date(s)shown below:
4
10/26112
11102/12
11/09112
. . . . . . . . . . . . . . . . . .
Swom nd ubsc d fore t 19 of vember, 2012 A.D.
Notary'Public
M LT I OF PENNSYLVANIA
N04081 so
Sheft L.Chvenia,Notary public
Lower Pliftn'rWp.,Dauphin county
My top" PQ_ft_9_ft Nov.26,201S
M
TA110N OF NOTARIES
Fax Server 12/5/2012 9: 28 : 08 AM PAGE 1/001 Fax Server
Phelan Hallinan,LLP
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
Fax: (215) 563-7009
Representing Lenders in
Foreclosure Manager Pennsylvania and New Jersey
December 5,2012
Office of the Sheriff
Cumberland County Courthouse
One Courthouse Square
Carlisle,PA 17013
Attn:Real Fstate Department
Fax Number:717-240-6397
Re: WELI,
9JEAXLKLBANK,N.A.v.
6204 EDGWARE ROAD MECHANICSBURG, PA 17050-5212
Dear Sir/Madam:
Please Postpone the Sheriff Sale of the above referenced property, which is scheduled for
December 5,2012 due io the following: HAMP Certification 10-02.
WN
Thank you for your cooperation in this matter.
Very Truly Yours,
Kathryn McGurl for
Phelan Hallinan,LLP
?HS#289681
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I,Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which US Bank NA as Legal Title Trustee for Truman 2012'SC2 Title Trust is the
grantee the same having been sold to said grantee on the 9th day of Janes A.D.,2013,under and by
virtue of a writ Execution issued on the 6th day of August,A.D.,2012,out of the Court of Common
Pleas of said County as of Civil Term,2012 Number 1364, at the suit of Wells Faro Bank,N.A. against
Rachael E. Marte is duly recorded as Instrument Number 201308891.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this 1;70 day of
A.D. a n 13
R rder of Deeds
Caft?A
NJ 9B*nftFkdVwdNdJvL=4