HomeMy WebLinkAbout12-1508 cl)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV/!?IIA?:.-, - 4-
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WELLS FARGO BANK, N.A., CIVIL DIVISION ?n !)
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Plaintiff, NO.. a-??a?
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VS
.
TYPE OF PLEADING '' =
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Gerald Thompson;
CIVIL ACTION - COMPLAINT
Defendant. IN MORTGAGE FORECLOSURE
TO: DEFENDANT
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED
AGAINST YOU.
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
COUNSEL OF RECORD FOR THIS PARTY:
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3476 Stateview Blvd., MAC # X7801-013, Ft. Mill, SC 29715
AND THE DEFENDANT:
791 Baltimore Pike
Gardners. PA 17324-8803
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
791 Baltimore Pike ardners PA 17324-9803
Municipality: S ddle
C ?
ATTORNEY PLAINTIFF
ATTY FILE NO.: XFP 163288
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire
Pa. I.D. #55650
Kimberly A. Bonner, Esquire
Pa. I.D. #89705
Joel A. Ackerman, Esquire
Pa I.D. #202729
Ashleigh Levy Marin, Esquire
Pa I.D. #306799
Ralph M. Salvia, Esquire
Pa I. D. #202946
Jaime R. Ackerman, Esquire
Pa I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
office@zuckergoldberg.com
File No.: XFP- 163288/bga
o?r?- ? 1 b3.? S p c?
etc- 3 a i 3 a a
Zucker, Goldberg & Ackerman, LLC
XFP-163288
i
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S)
DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF
WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE
DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT
OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF
THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING
FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW
PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY
(20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE
MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE
RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND
ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR
RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION
OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU
SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS
SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A
DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE.
Zucker, Goldberg & Ackerman, LLC
XFP-163288
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Gerald Thompson;
CIVIL DIVISION
NO..
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim 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 SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
Plaintiff,
Defendant(s).
Zucker, Goldberg & Ackerman, LLC
XFP-163288
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
VS. NO..
Gerald Thompson;
Defendant(s).
AVISO
LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las
siguientes paginas, debe tomar accion dentro de los pr6ximos veinte (20) dias despues de la notificaci6n
de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia
esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su
contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso
puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la
demanda 0 cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en
contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para
usted.
LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN
ABOGADO 0 NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE
PUEDE ENCONTRAR ASISTENCIA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
Zucker, Goldberg & Ackerman, LLC
XFP-163288
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
VS. NO.:
Gerald Thompson;
Defendant(s).
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC,
and files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff") located at 3476
Stateview Blvd., MAC # X7801-013, Ft. Mill, SC 29715.
2. Defendant, Gerald Thompson, is an individual whose last known address is 791
Baltimore Pike, Gardners, PA 17324-8803.
3. On or about March 31, 2008, Gerald Thompson executed a Note in favor of Sovereign
Bank in the original principal amount of $140,577.00.
4. On or about March 31, 2008, as security for payment of the aforesaid Note, Gerald
Thompson made, executed and delivered to Sovereign Bank, organized and existing under the laws of
the United States of America a Mortgage in the original principal amount of $140,577.00 on the
premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of
Deeds of Cumberland County on April 7, 2008, Instrument #200810840. A true and correct copy of
said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit
"A", attached hereto and made a part hereof.
5. The Mortgage was assigned by Sovereign Bank to Wells Fargo Bank, N.A., plaintiff
herein, pursuant to an assignment of mortgage dated April 10, 2008 and recorded on June 16, 2008
in the Office of the Recorder of Deeds for Cumberland County, Instrument #200820083.
6. The aforesaid Mortgage was amended and increased in principal amount of
$142,828.61 pursuant to a certain Modification Agreement by and between Wells Fargo Bank, N.A.
and Defendant, Gerald Thompson, which is unrecorded at this time. The terms of said modification
set forth the interest rate at 4.625% with a new monthly payment and interest amount of $ 734.34
Zucker, Goldberg & Ackerman, LLC
XFP-163288
commencing August 1, 2011 and continuing thereon with the due date of obligation July 1, 2041. A
true and correct copy of said Modification Agreement is marked Exhibit "B", attached hereto and
made a part hereof.
7. Defendant is in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest being contractually due for
the September 2011 payment, and pursuant to the terms of the aforesaid Mortgage, after written
notice of said default to Defendant(s), the entire principal balance and accrued interest due
thereunder has been accelerated.
8. Gerald Thompson is the record and real owner of the aforesaid mortgaged premises.
9. Plaintiff was not required to send Defendant(s) written notice of Plaintiff's intention
to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of
this action for the reason that the original principal balance of the aforesaid Mortgage is more than
the original principal balance threshold of the Act, and therefore:
(a) said Mortgage is not a "residential mortgage" as defined in 41 P.S. §101;
(b) the Defendant(s) is/are not "residential mortgage debtor(s)" as defined in 41 P.S.
§101, and;
(c) the mortgage premises is not "residential real property" as defined in 41 P.S. §101.
10. Plaintiff was not required to send Defendant(s) written Notice pursuant to 35 P.S.
§1680.403 (c) (Homeowners' Emergency Mortgage Assistance Act of 1983, - Act 91 of 1983), prior to
commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal
Housing Administration under Title II of the National Housing Act (12 U.S.C. §§1707 - 1715(z) - 18) [35
P.S. §1680.401(a)(3).].
11. The amount due and owing Plaintiff by Defendant(s) is as follows:
Principal $142,644.76
Interest through 01/30/2012 $3,273.07
Escrow Advance $313.08
Late Charges $181.56
Inspection Fees $20.00
Total $146,432.47
Zucker, Goldberg & Ackerman, LLC
XFP-163288
plus interest on the principal sum ($142,644.76) at the daily per diem amount of $18.07, and all other
additional amounts authorized under the Mortgage, actually and reasonably incurred by Plaintiff,
including but not limited to, late charges, costs (including escrow advances) and Plaintiff's attorneys'
fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add
such additional sums to the above amount due and owning when incurred.
12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is
not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in
a separate legal action if such right exists. If Defendant(s) have received a discharge of personal
liability under the aforesaid Note in a bankruptcy proceeding, this action is in no way an attempt to
re-establish such liability.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of
$146,432.47, with interest thereon at the daily per diem amount of $18.07 plus additional late
charges, and costs (including additional escrow advances), additional attorneys' fees and costs and
for foreclosure and sale of the mortgaged premises.
ZUCKER, GOL RG $rACK M , LLC
BY:
Dated: Sc t A. Dietterick, Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh Levy Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP-163288/bga
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
Zucker, Goldberg & Ackerman, LLC
XFP-163288
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
XFP-163288
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Ingo
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Prepared By:
Laura Radawiec ?t •
101 s. George Street, York, PA
17401
(717) 771-9435
Return To:
Sovereign Sank, MCS-10-6438-CA5
601 Penn Street
Reading, PA 19601
Parcel Number:
40392209002
Premises:
791 Baltimore Pike
Gardners, PA 17324
(Space Above This Tine Vor Recording Data]
Commonwealth of Pennsylvania FHA Case No.
PURCHASE MONEY MORTGAGE -
THIS MORTGAGE ("Security Instrument") is given on March 31, 2008
The Mortgagor is Gerald Thompson ?r
("Borrower"). This Security ]nstrtunent is given to Sovereign Bank
which is organized and existing under the laws of The United States of America , and
whose address is 1130 Berkshire Blvd., Wyomissing, PA 19610
("Lender"), Borrower owes Lender the principal sum of
One Hundred Forty Thousand Five Hundred Seventy Seven And Zero/100.J
Dollars (U.S. $ 140,577.00 t?
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This debt is evidenced by Borrower's note dated the same date as this Security Instrument
("Note"), which provides r monthly payments, with the full debt, if not paid earlier, due and payable on
April 01, 2038 . This Security Instrument secures to Lender: (a) the repayment
of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the
Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security
of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this
Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to
the Lender the following described property located in Cumberland
County, Pennsylvania:
See attached
which has the address of 791 Baltimore Pike / (Strxtl
Gardners [Ci[y], Pennsylvania 17324 [Zip Codc]
("Property Address");
TOGETHER WITH all the improvements now or hereafter erected on the property, and all
easements, appurtenances and fixtures now or hereafter a part of the properry. All replacements and
additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this
Security Instrument as the "Property."
BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has
the right to mortgage, grata and convey the Property and that the Property is unencumbered, except for
encumbrances of record. Borrower warrants and will defend generally the title to the Property against all
claims and demands, subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform
covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real
property.
Borrower and Lender covenant and agree as follows:
UNIFORM COVENANTS.
1. Payment of Principal, Interest and )Late Charge. Borrower shall pay when due the principal of,
and interest on, the debt evidenced by the Note and late charges due under the Note.
2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each
monthly payment, together with the principal and interest as set forth in the Note and any late charges, a
sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold
payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In
any year in which the Lender must pay a mortgage insurance premium to the Secretary of Housing and
Urban Development ("Secretary"), or in any year in which such premium would have been required if
Lender the Security Instrument, each monthly payment shall also include either: (i) a sum for the
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annual mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead
of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable
amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are
called "Escrow Items" and the sums paid to Lender are called "Escrow Funds."
Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to
exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate
Settlement Procedures Act of 1974, 12 U.S,C Section 2601 et seq. and implementing regulations, 24 CFR
Part 3500, as they may be amended from time to time ("RESPA"), except that the cushion or reserve
permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are
available in the account may not be based on amounts due for the mortgage insurance premium.
If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA,
Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held
by Lender at any time are not sufficient to pay the Escrow Items when due, Lender may notify the
Borrower and require Borrower to make up the shortage as permitted by RESPA.
The Escrow Funds are pledged as additional security for all sums secured by This Security Instrument.
If Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with
the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium
installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund
any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by
Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a),
(b), and (c).
3. Application of Payments, All payments under paragraphs 1 and 2 shall be applied by Lender as
follows;
First, to the mortgage insurance premium to be paid by Lender to the Secretary or to The monthly
charge by the Secretary instead of the monthly mortgage insurance premium;
Second, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and
other hazard insurance premiums, as required;
Third, to interest due under the Note;
Fourth, to amortization of the principal of the Note; and
Fifth, to late charges due under the Note.
4, Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the
Property, whether now in existence or subsequently erected, against any hazards, casualties, and
contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in
the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the
Property, whether now in existence or subsequently erected, against loss by floods to the extent required
by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance
policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in
a form acceptable to, Lender.
In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may [Hake proof of
loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and
directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly.
All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the
reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts
applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair
of the damaged Property. Any application of the proceeds to the principal shall nor extend or postpone the
due date of the monthly payments which are referred to in paragraph 2, or change the amount of such
payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness
under the Note and this Security Instrument shall be paid to the entity legally entitled thereto_
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In the event of foreclosure of this Security Instrument or other transfer of title to the Property that
extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force
shall pass to the purchaser.
5, Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan
Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal
residence within sixty days after the execution of this Security Instrument (or within sixty days of a later
We or transfer of the Property) and shall continue to occupy the Property as Borrower's principal
residence for at least one year after the date of occupancy, unless Lender determines that requirement will
cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond
Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not
commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate,
reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned
or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or
abandoned Property. Borrower shall also be in default if Borrower, during the loan application process,
gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with
any material information) in connection with the loan evidenced by the Note, including, but not limited to,
representations concerning Borrower's occupancy of the Property as a principal residence. If this Security
Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires
fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger
in writing.
6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in
connection with any condemnation or other taking of any part of the Property, or for conveyance in place
of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the
indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such
proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any
delinquent amounts applied in the order provided in paragraph 3, and then to prepayment of principal. Any
application of the proceeds to the principal shall not extend or postpone the due date of the monthly
payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess
proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security
Instrument shall be paid to the entity legally entitled thereto.
7, Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all
governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower
shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would
adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish
to Lender receipts evidencing these payments,
If Borrower fails to make these payments or the payments required by paragraph 2, or fails to
perform any other covenants and agreements contained in this Security Instrument, or there is a legal
proceeding that may significantly affect Lender's rights in the property (such as a proceeding in
bankruptcy, for condemnation or to enforce laws or regulations), then Under may do and pay whatever is
necessary to protect the value of the Property and Lender's rights in the Property, including payment of
taxes, hazard insurance and other items mentioned in paragraph 2.
Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower
and be secured by this Security Instrument. These amounts shall bear interest from the date of
disbursement, at the Note rate, and at the option of Leader, shall be immediately due and payable,
Borrower shall promptly discharge any lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable
to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal
proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures
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from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security
Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority
over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall
satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice.
8. Fees. Lender may collect fees and charges authorized by the Secretary.
9. Grounds for Acceleration of Debt.
(a) Default. Lender may, except as limited by regulations issued by the Secretary, in the case of
payment defaults, require immediate payment in full of all sums secured by this Security
Xnstrument if:
(i) Borrower defaults by failing to pay in full any monthly payment required by this Security
Instrument prior to or on the due date of the next monthly payment, or
(ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations
contained in this Security Instrument.
(b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including
Section 341(d) of theGJatn-St. Germain Depository Institutions Act of 1982, 12 U.S.C.
1701j-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all
sums secured by this Security Instrument if.
(i) All or part of the Property, or a beneficial interest in a trust owning all or part of the
Property, is sold or otherwise transferred (other than by devise or descent), and
(ii) The Property is not occupied by the purchaser or grantee as his or her principal residence,
or the purchaser or grantee does so occupy the Property but his or her credit has not been
approved in accordance with the requirements of the Secretary.
(c) No Waiver. If circumstances occur that would permit Lender to require immediate payment in
full, but Lender does not require such payments, Lender does not waive its rights with respect to
subsequent events.
(d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary
will limit Lender's rights, in the case of payment defaults, to require immediate payment in full
and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure
if not permitted by regulations of the Secretary.
(e) Mortgage Not Insured, Borrower agrees that if this Security Instrument and the Note are not
determined to be eligible for insurance under the National Housing Act within 60 days from the
date hereof, Lender may, at its option, require immediate payment in full of all sums secured by
this Security Instrument. A written statement of any authorized agent of the Secretary dated
subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the
Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this
option may not be exercised by Lender when the unavailability of insurance is solely due to
Lender's failure to remit a mortgage insurance premium to the Secretary.
10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment
in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This
right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument,
Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including,
to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and
reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding.
Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall remain
in effect as if Lender had not required immediate payment in full. However, Lender is not required to
permit reinstatement if: (i) Lender has accepted reinstatement after the commencement of foreclosure
proceedings- within two years immediately preceding the commencement of a current foreclosure _
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proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii)
reinstatement will adversely affect the priority of the lien created by this Security InsuUment.
11. Borrower Not Rcicased; Forbearance By Lender Not a Waiver. Extension of the time of
payment or modification of amortization of the sums secured by this Security Instrument granted by Lender
to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or
Borrower's successor in interest, Lender shall not be required to commence proceedings against any
successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums
secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's
successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver
of or preclude the exercise of any right or remedy.
12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and
agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and
Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint
and several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is
co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the
Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums
secured by this Security Instrument; and (e) agrees that Lender and any other Borrower may agree to
extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument
or the Note without that Borrower's consent.
13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by
delivering it or by mailing it by first class mail unless applicable law requires use of another method. The
notice shall be directed to the Property Address or any other address Borrower designates by notice to
Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any
address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall
be deemed to have been given to Borrower or Lender when given as provided in this paragraph.
14. Governing Law; Severability. This Security Instrument shall be governed by Federal law and
the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this
Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions
of this Security Instrument or the Note which can be given effect without the conflicting provision. To this
end the provisions of this Security Instrument and the Note are declared to be severable.
15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security
Instrument.
16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage,
or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone
else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding
two sentences shall not apply to the presence, use, or storage on the Property of small quantities of
Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to
maintenance of the Property.
Borrower shall promptly give Lender written notice of any investigation, claim„ demand, lawsuit or
other action by any governmental or regulatory agency or private party involving the Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns,
or is notified by any governmental or regulatory authority, that any removal or other remediation of any
Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary
remedial actions in accordance with Environmental Law,
As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or
hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other
flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials
containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16,
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"Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that
relate to health, safety or environmental protection,
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and
revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues
and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However,
prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement to the Security
Instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the
benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an
assignment for additional security only.
If Lender gives notice of breach to Borrower; (a) all rents received by Borrower shall be held by
Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security
instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each
tenant of the Property shall pay all rents due and unpaid to Lender or Lrender's agent on Lender's written
demand to the tenant.
Borrower has not executed any prior assignment of the rents and has not and will not perform any act
that would prevent Leader from exercising its rights under this paragraph 17.
Lender shall not be required to enter upon, take control of or maintain the Property before or after
giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any
time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other
right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured
by the Security lasmument is paid in full.
18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9,
Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to
collect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, but
not limited to, attorneys' fees and costs or title evidence.
If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary
requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial
power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C.
3791 et seq.) by requesting a foreclosure commissioner designated under the Act to commence
foreclosure and to sell the Property as provided in the Act. Nothing in the preceding sentence shall
deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or
applicable law.
19. Release. Upon payment of all sums secured by this Security Instrument, this Security instrument
and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge
and satisfy this Security Instrument without charge to Borrower, Borrower shall pay any recordation costs.
20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or
defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or
future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale,
and homestead exemption.
21, Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one
hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security
Instrument.
22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to
Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage.
23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is
entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time
under the Note.
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24. Riders to this Security Xastrument. If one or more riders are executed by Borrower and
recorded together with this Security Instrument, the covenants of each such rider shall be incorporated into
and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s)
were a part of this Security Instrument. [Check applicable box(es)].
? Condominium Rider ? Growing Equity Rider ? Other [specify]
? Planned Unit Development Rider ? Graduated Payment Rider
This is a contract under seal and may be enforced under 42 PA. C.S. Section 5529(b),
BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security
s ent and in any rider(s) stated by Borrower and rded with it.
Wi ses; ?
(Seal)
rald Thompson -Borrower
(Seal)
-Borrower
(Seal) (Seal)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
(Seal) (Seal)
-Borrower -Borrower
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COMMONWEALTH OF PENNSYLVANIA, Cumberland County ss:
On this, 31st day of March, 2008 before me, the undersigned officer,
personally appeared Gerald Thompson
Imown to me (or satisfactorily proven) to be the
person(s) whose name is/are subscribed to the within instrument and acknowledged that he/she/they
executed the same for the purposes herein contained,
IN WITNESS WHEREOF, I hereunto set my hand d fficial seal.
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA
Notarial Sea!
Connie L. Wertz, Notary Public
Hampden Twp.. Cumberland County
My Commission Expires Apr. B, 2010
Membor, Pennsylvania Assocla(fon of Nolaries
Notary Public
Tide of Officer
Certificate of Residence f\Ri W.Lrfl-
1, , do hereby certify that the correct address of
the within-named Lender is 1130 Berkshire Blvd. 0,omissinq, PA 19610
Witness my hand this 31st day of Marc 08
kvid of Lcndcr
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EXHIBIT "A"
ALL THAT CERTAIN piece or parcel o and and the improvements thereon erected, situate in
South Middleton Township, Cumbp nd County, Pennsylvania, bounded and described in
accordance with a survey and pn thereof dated April 1971, prepared by T.O. Bietsch,
Registered Surveyor, as follows:
BEGINNING at a point in the approximate center line of Legislative Route 94, said point being on
line of lands now or late of H.H. McKee; thence by land now or late of H.H. McKee, North 60'/.
degrees East 379 feet to a stake: thence by lands now or late of Tony Mack, North 33% degrees
West 70 feet to a stake; thence by lands now or formerly of Retta I. Tuckey, South 71 degrees 50
minutes West 229 feet more or less to a point; thence by land now or late of Retta I. Tuckey,
South 60'/, degrees West 104 feet more or less to a point in the approximate center line of
aforesaid Legislative Route 94; thence on the center line of same, South 9 degrees East 124.5
feet to a point, the Place of BEGINNING-
UNDER AND SUBJECT to covenants, conditions, reservations, restrictions, easements, and right
of ways of record.
BEING KNOWN AND NUMBERED as 791 Baltimore Pike, Gardners, Pennsylvania.
BEING THE SAME PREMISES which Bryan A. Overstreet and Kristen N. Overstreet, by deed to
be recorded simultaneously herewith In the Office of the Recorder of Deeds of Cumberland
County, granted and conveyed unto Gerald R. Thompson.
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ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 200810840
Recorded On 4/712008 At 1.:1,9:56 FM
* Instrument Tyne - MORTGAGE
Invoice Number - 18128 User ID - AF
* Mortgagor - THOMPSON, GERALD
* Mortgagee - SOVEREIGN BANK
* Customer - SECURED LAND
* FEES
STATE WRIT TAX
STATE JCS/ACCESS TO
JUSTICE
RECORDING FEES
RECORDER OF DEEDS
AFFORDABLE HOUSING
COUNTY ARCHIVES FER
ROD ARCHIVES FEE
TOTAL PAID
$0.50
$10.00
$23.50
$11.50
$2.00
$3.00
$50.50
Y Certify this to be recorded
in Cumberland County PA
c4 cvy? .
" a RECORDER O D EDS
y?
"- Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
* Total Pages - 11
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
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EXHIBIT B
Zucker, Goldberg & Ackerman, LLC
XFP-163288
Welts Fargo Home Mortgage
1C W01 ), , ,'_1U
•
220%, tldwnod Narkway
E • . fie 3irn?inyiia 35209
Tel: 8 77 325 41 14 Tull Free
LOAN MODIFICA`TION AGREEMENT
LOAN NUMBER:
PROPERTY ADDRESS'7n Baltimoie Pike
Gardners PA 17324
THIS LOAN MODIFICATION AGRrFMENT ("Agreement"), made on
June 13, 2011, by and between Gerald Thompson and
and (the "Borrower (s) 11) and
Wells Fargo Bank, N A (the "Lender",
together with the Borrower(s), the "Parties")
WITNESSETH
WHEREAS, Borrower has requested and Lender has agreed, subject to the
following terms and conditions, to a loan modification as follows:
NOW THEREFORE, in consideration of the covenants hereinafter set forth
and for other good and valuable consideration, the receipt and
sufficiency of which are hereby acknowledged by the Parties, it- is agreed
as follows (notwithstanding anything to the contrary in the Note and
Security Instrument dated 03/31./2008.)
1. BALANCE. As of June 13, 2011, the amount payable under the Note
and Security Instrument (the "Unpaid Principal Aalance") is U-S.
$ 136,299.64.
2. EXTENSION. This Agreement hereby modifies the following terms of the
Note and Security Instrument described herein above as follows:
A. The current contractual due date has been extended from 12-01-1.0
to 08/01/2011. The first modified contractual due date is on
08/01/2011.
B, The maturity date has been extended from 04-38 (month/year) to
07/01/2041.
C. The amount of interest to be included (capitalized) will be U.S.
$ 5,906.32.
The amount: of the Escrow Advance to be capitalized will be U.S. $1,637.43.
The amount: of Recoverable Expenses* to be capitalized will be
U.S. $0.00.
The modified Unpaid Principal Balance is U.S. $ 142,828.61.
* Recoverable Expenses may include, but are not limited to: Title,
Attorney fees/costs, BPO/Appraisal, and/or Property Preservation/
Property Inspections
D. The Borrower(s) promises to pay Lhe Unpaid Principal Balance plus
interest, to the order of the Lender. znterest will be charged on the
Unpaid Principal Balance of U.S. $ 142,828.61. The Borrower(s) promises
to make monthly payments of principal and interest of U.S. $ 734.34,
at a yearly rate of 4.6250, not including any escrow deposit, if
applicable. if on the maturity date the Borrower(s) still owes an amount
under the Note and Security Instrument, as amended by this Agreement,
Borrower(s) will pay this amount in full on the maturity date.
LM521/WU8%1
wells Faiyu Nome Mortgage is a division of Wells Fargo Bank, N.A. NMLSR ID ?9901
Together we'll go far
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Wells Fargo Home Mortgage
MAC MA52-(Pu
220 V/iluI'-;ood PaIKway
Al .?57.09
Tel H;:% 3?5'1'.i1011 V PC
Borrower agrees that certain amounts owed
waived, or addressed as part of this Agreement,
until paid. These amounts owed are referenced in
this Agreement, which is incorporated herein, an
the return of this executed Agreement. If these
paid with the return of this executed Agreement,
this Agreement void.
will not be capitalized,
and will remain owed
the Cover Letter to
d are to be paid with
amounts owed are not
then Lender may deem
.3. NOTE AND SECURITY INSTRUMENT. Nothing in this Agreement shall be
understood or construed to be a satisfaction or release, in whole or iri
part of the Borrower's obligations under Lhe Note or Security Instrument.
Further, except as otherwise specifically provided in this Agreement, the
Note and Security Instrument will remain unchanged, and Borrower and
Lender will be bound by, and shall comply with, all of the terms and
provisions thereof, as amended by this Agreement.
4. The undersigned Borrower(s) acknowledge receipt acid acceptance of the
Loan Modification Settlement Statement. Borrower(s) agree with the
information disclosed in and understand that I/we am/are responsible for
payment of any outstanding balances outlined in the Loan Modification
Settlement.
5. The undersigned Borrower(s) acknowledge receipt and acceptance of the
Bcrrcwer Acknowledgements, Agreements, and Disclosures Document (BARD).
6. If included, the undersigned Borrower(s) acknowledge receipt and
acceptance of the Truth in Lending statement.
7. If included, the undersigned Borrower(s) acknowledge receipt and
acceptance of the Special Flood Hazard Area (SF'HA).
8. ThaL (he/she/they) (is/are) Lhe Borrower(s) on the above-referenced
Mortgage Loan serviced by Wells Fargo Bank, N A.
That (he/she/they).have experienced a financial hardship or change in
financial circumstances since Lhe origination of (his/her/their)
Mortgage Loan,
That (he/she/they) did not intentionally or purposefully default on the
Mortgage Loan in order to obtain a loan modification.
LM521/WU8/2
Wells N'yo home Mongage is a division of Wells Fargo Bank, NA. NMLSR 10399801
Together we'll go far
044 - _- 4---- ? - W-- - ?
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Wells Fargo Home Mortgage
MAC W0152-010
220 Wildwood Parkway
Bitminyltam, AL 35209
Tel: 877 325 4114 Toll Free
CORRECTION AGREEMENT. The undersigned borrower(s), for and in
consideration of the approval, closing and funding of this
Modification, hereby grants Wells Fargo Bank, N A, as
lender, l.i.mited power of attorney to correct and/or initial all
typographical or clerical errors discovered in the Modification
Agreement required to be signed. In the event this limited power of
attorney is exercised, the undersigned will be notified and receive
a copy of the document executed or initialed on their behalf. This
provision may not be used to modify the interest rate, modify t_he
Lerm, modify the outstanding principal balance or modify the
undersigned's monthly principal. and interest payments as modified by
this Agreement. Any of these specified changes must be executed
directly by the undersigned. This limited power of attorney shall
automatically terminate in 12?0i Oays from the closing date of the
undersigned's Modification. (M (Borrower(s) initial)
IN WITNESS WHEREOF, the Parties hereto have executed this Agreement as
the date first above written.
By signinq_ this Agreement .1 hereby consent to being contacted concerning
this loan at any cellular or mobile telephone number I may have. This
includes text messages and telephone calls including the use of
automated dialing systems to contact my cellular or mobile telephone.
You will not be billed by your cellular or mobile carrier for any text
messages you may receive from Wells Fargo, however, any calls we place
Lo your cellular or mobile phone will incur normal airtime charges
assessed by your mobile carrier.
as o s day
rald Thompson
Signature
`, ? a?112? 11
ells Fargo Bank, N A
of 20:?_..,..
Signature
Name : Halimo Adem
Vice Pf?sident Loan Uoewnentation
Its:
LM527/WU8i3
Wells Farc,o Home Mortgage is a division of Wells Fargo Bark, N.A. NMLSH Ill 399801
Together we'll go far
4?
%.
VF RIFICA'TION
Justina Luna, hereby states that h she is Vice President Loan Documentation of
WLLL.S FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this
matter. that he . he 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 hi Ze 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: _724-26L ?.-.
03--PA-V')
XI'P-163288
"Title: Vice President Loan Documentation
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Wells Fargo Bank, N.A.
vs.
Gerald R. Thompson
Case Number
2012-1508
SHERIFF'S RETURN OF SERVICE
03/21/2012 11:24 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on March
21, 2012 at 1124 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Gerald R. Thompson, by making known unto Jamie Thompson, Daughter
in Law of Defendant at 411 3rd Street, New Cumberland, Cumberland County, Pennsylvania 17070 its
contents and at the same time handing to her personally the said true and correct copy of the same.
TIM BLAqX, DEPUTY
03/26/2012 08:19 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 26,
2012 at 2019 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Gerald R. Thompson, by making known unto Deborah Thompson, Wife of
Defendant at 791 Baltimore Pike, Gardners, Cumberland County, Pennsylvania 17324 its contents and at
the same time handing to her personally the said true and correct copy of the same.
SHERIFF COST: $72.00
March 28, 2012
RYAN BURGETT, PUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
vs.
Gerald Thompson;
Defendant(s).
TO THE PROTHONOTARY:
NO.: 2012-1508 CIVIL
PRAECIPE TO SETTLE AND DISCONTINUE
Please mark the case filed at the above-captioned term and number SETTLED and
DISCONTINUED, without prejudice.
Respectfully Submitted:
ZUCKER, GOLDBERG &AAM
L
Scott A. 94/ettBrick?, Esq , A 0'#55650
Kimberl A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP-163288/ka
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX