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Home My WebLink About12-1628l..FO - r luL P ROT HoNO TAR" 2012 MAR 14 AM 10' [ 9 rU PENNSYLVAN A T`? 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. JEANNE A. SHEARER 416 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 Defendant 249324 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM us,& civil NO. 0613- COUNTY CUMBERLAND CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 249324 (3) -'J 7S al Q.wi 4% 1 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 249324 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: JEANNE A. SHEARER 416 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 12/16/2005 DON PAUL SHEARER, ATTORNEY IN FACT made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE, ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR TAYLOR, BEAN & WHITAKER MORTGAGE CORP. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book 1936, Page 24. The PLAINTIFF is now the mortgagee and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 05/01/2010 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 #: 249324 6. The following amounts are due on the mortgage as of 11/10/2011: Principal Balance $116,311.92 Interest $13,092.07 04/01/2010 through 11 / 10/2011 Property Inspections $380.00 Escrow Deficit $4,541.73 Corporate Advance Credit $( 12.80) TOTAL $134,312.92 7. Plaintiff is not seeking a judgment of personal liability (or an in ep rsonam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $134,312.92, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. AN & SCHMIEG, LLP By: Robe-M. Cusick, Esquire Idn No. 80193 Attorney for Plaintiff File #: 249324 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the western line of Front Street on the line dividing Lots Nos. 36 and 37 on the hereinafter mentioned Plan of Lots; thence in a westerly direction along said last mentioned line 153.46 feet, more or less, to a point on the eastern line of River Alley; thence in a southerly direction 62 1 /2 feet, more or less, to a point in the center of Lot No. 34 on the Plan hereinafter mentioned; thence in an easterly direction along the line at right angles to Front Street 153.62 feet more or less, to a point on Front Street; thence in a northerly direction along Front Street 62 1/2 feet to the point or place of BEGINNING. BEING Lots Nos. 35 and 36 and the northern 12 1/2 feet of Lot No. 34 on Edgewater Plan No. 3, recorded in the Recorder's Office in and for Cumberland County in Plan Book 1, Page 71. HAVING thereon erected a dwelling house now known as No. 422 North Front Street, Wormleysburg, Pennsylvania. PROPERTY ADDRESS: 422 NORTH FRONT STREET, WORMLEYSBURG, PA 17043- 1114 PARCEL # 47-19-1588-107 File #: 249324 VERIFICATION Brent Alban, hereby states tha&she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter, tha&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 o is/ er 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. -T: - Name: Brent Alban DATE: ? 1 ? t Z Title: Vice President Loan Documentation 032-PA-V3 File #: 249324 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff tt?.- • OFF-ICE •??"it pi 4?uut?ty t.?, PR t ? Jody S Smith ° THON() iiR l;' Chief Deputy ??{{ r1 ??: ?$ Richard W Stewart Solicitor WtigkftntAN' C NIA 0 TY Wells Fargo Bank, N.A. Case Number vs. Jeanne A. Shearer 2012-1628 SHERIFF'S RETURN OF SERVICE 03/26/2012 07:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 26, 2012 at 1950 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jeanne A. Shearer, by making known unto Don Shearer, Son of Defendant at 422 N. Front Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the same. RO ERT BITNER, DEPUTY 04/09/2012 05:55 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 9, 2012 at 1755 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jeanne A. Shearer, by making known unto herself personally, at 416 N. Front Street, Wormleysburg, Cumberland County, Pennsylvania 17043 its contents and the same time handing to her personally the said true and correct copy of the same. y" NOAH CLINE, DEPUTY SHERIFF COST: $76.45 April 12, 2012 SO ANSWERS, RON ? R ANDERSON, SHERIFF PHELAN HALLINAN & SCHMIEG, LLP Matthew Brushwood, Esq., Id. No.310592 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. VS. Attorney for Plaintiff CUMBERLAND COUNTY : COURT OF COMMON PLEAS JEANNE A. SHEARER CIVIL DIVISION . Ja r - - ? No. 2012-1628-CIVIL - - 3 PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TOE '' ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JEANNE A. SHEARER, 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 $134,312.92 $134,312.92 I hereby certify that (1) the Defendant's last known addresses are 416 NORTH FRONT STREET, WORMLEYSBURG, PA 17043-1114 and 422 NORTH FRONT STREET, WORMLE'YSBURG, PA 17043-1114, and (2) that notice has been given in accordance with Rule Pa.R.C. 237.1. Date Ma w rushwood, Esquire $1(0,5o P,0 A'n`/ Atto y for Plaintiff ®r 119 1188 DAMAGE'S ARE HEREBY ASSESSED AS INDICATED. Np{?? Wiled DATE: o??/ /a a.A • PHS a 249324 PROTHONOTARY 249324 PHELAN HALLINAN & SCHMIEG, LLP Matthew Brushwood, Esq., Id. No.310592 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. VS. JEANNE A. SHEARER Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 2012-1628-CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the folloiwing 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 JEANNE A. SHEARER is over 18 years of age and resides at 416 NORTH FRONT STREET, WORMLEYSBURG, PA 17043-1114 and 422 NORTH FRONT STREET, WORMLEYSBURG, PA 17043-1114. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date Z , R, lef_= Matth B hwood, Esquire Attorn r Plaintiff 249324 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Defendant NO. 2012-1628-CIVIL JEANNE A. SHEARER TO: IFANNE A. SHEARER 422 NORTH FRONT STREET WORMLEYSBUR. -', PA 17043-1114 14") KTWT? DATE OF NOTICE: CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: geatIl-, 3B? iwf:'cid Esquire Attornei or Plaintiff Phelan Haltinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 249324 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. Defendant NO. 2012-1628-CIVIL JEANNE A. SHEARER TO; JEANNE A. SHEARER 416 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 DATE OF NOTICE: 614?))?' CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE I$ SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE Ai LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: attheu shwood, Esquire Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS 4 249324 (Rule of Civil Procedure No. 236) - Revised WELLS LARGO BANK, N.A. CUMBERLAND COUNTY VS. COURT OF COMMON PLEAS JEANNE'A. SHEARER CIVIL DIVISION No. 2012-1628-CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on 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 RM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INF RMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PR VIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD OT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLYEN ORCEMENT OFA LIENAGAINST PROPERTY** 249324 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-1628 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK Plaintiff (s) From JEANNE A. SHEARER (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: $134,312.92 L.L.: $.50 Interest FROM 5/25/2012 TO DATE OF SALE ($22.08 PER DIEM) - $4,305.60 Atty's Comm: % Due Prothy: $2.25 Atty Paid: 227.70 Other Costs: Plaintiff Paid: Date: 8/3/2012 David D. Bu 11, Prothonotary (Seal) Deputy REQUESTING PARTY: Name: JOHN MICHAEL KOLESNIK, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BLVD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 308877 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WELLS FARGO BANK, N.A. Plaintiff V. JEANNE A. SHEARER Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 05/25/2012 to Date of Sale ($22.08 per diem) TOTAL COURT OF COM CIVIL DIVISION NO.: 2012-1628-C] : CUMBERLAND PLEAS --a S M CD ?-n -rm $134,312.92 $4,305.60 $138,618.52 c-> c _"rrn C Z= rnr Z w v mn zo 25 y,c .. Z C.0 Note: Please attach description of property. PHS # 249324 ?o. tr r' 103• ? u JV a ? All elan Hallinan & Schmieg, LLP John Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff WfJ 4 4 Z%Al v v co ? rx (n a., ? ?'" C7 ? V) a ? E" C7 c WpuD wOZpG W 3 a? Wob. a O < WaCa O zz o "o O ?¢NO w z o> o ?? z o 0 o? x a ? x a Q ?? Ww ? a Z W r - E- 00 00 0 M ?z ab •? W ?occ ?xa ?! W w LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the western line of Front Street on the line dividing Lots Nos. 36 and 37 on th hereinafter mentioned Plan of Lots; thence in a westerly direction along said last mentioned line 153.46 f et, more or less, to a point on the eastern line of River Alley; thence in a southerly direction 62 1 /2 feet, mo or less, to a point in the center of Lot No. 34 on the Plan hereinafter mentioned; thence in an easterly direction along the line at right angles to Front Street 153.62 feet more or less, to a point on Front Street; thence in northerly direction along Front Street 62 1/2 fcct to the point or place of BEGINNING. BEING Lots Nos. 35 and 36 and the northern 12 1/2 feet of Lot No. 34 on Edgewater Plan No. 3, recorded in the Recorder's Office in and for Cumberland County in Plan Book 1, Page 71. TITLE TO SAID PREMISES VESTED IN Jeanne A. Shearer, by Deed from Paul E. Shearer and Jeanne A. Shearer, his wife, dated 03/25/1976, recorded 04/22/1976 in Book 26N, Page 778. PREMISES BEING: 422 NORTH FRONT STREET, WORMLEYSBURG, PA 17043-1114 PARCEL NO. 47-19-1588-107 PHELAN HALLINAN & SCHMIEG, LLP John Michael Kolesnik, Esq., Id. HLED-OFFICE 1617 JFK Boulevard, Suite 1400 `'' ?OTHONOT'? One Penn Center Plaza ?012 AUG -3 AM 10: 31 Philadelphia, PA 19103 Attorneys for Plaintiff) 215-563-7000 CU RLANQ CM- TY '94NSYLVAIMA WELLS FARGO BANK, N.A. Plaintiff V. JEANNE A. SHEARER Defendant(s) COURT OF COM CIVIL DIVISION NO.: 2012-1628-C] CUMBERLAND PLEAS 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. 39 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn 1 authorities. Pl Hallinan & Schmieg, LLP n Michael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff to WELLS FARGO BANK, N.A. Plaintiff t-LO-t3F I"?.z i Of THE PROTHONOTAR r' V. 2012 AUG -3 AM 10: 31 JEANNE A. SHEARER Defendant(s) PENNSYLVANIA COURT OF COMMON CIVIL DIVISION NO.: 2012-1628-CIVIL CUMBERLAND COU PHS # 249324 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 th Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 422 NORTH FRONT S REET, WORMLEYSBURG, PA 17043-1114. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) JEANNE A. SHEARER 416 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 422 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 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 e sold: Name Address (if address cannot be reasonably ascertained, please indicate) Citibank South Dakota NA CITIBANK SOUTH DAKOTA NA C/O YALE D. WEINSTEIN, ESQ. 701 East 60th Street North Sioux Falls, SD 57117 BURTON NEIL & ASSOCIATES PC 1060 ANDREW DR STE 170 WEST CHESTER, PA 19380 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 aff?cted by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Commonwealth of Pennsylvania Bureau of Individual Taxes Inheritance Tax Division Department of Public Welfare, TPL Casualty Unit, Estate Recovery Program Domestic Relations of Cumberland County 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 422 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 6th Floor, Strawberry Sq. Dept 280601 Harrisburg, PA 17128 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 13 North Hanover Street Carlisle, PA 17013 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 may 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 th penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. Date: By: [allinan & Schmieg, LLP hael Kolesnik, Esq., Id. No.308877 for Plaintiff WELLS FARGO BANK, N.A. ICS 43" I H E PROTHONOTARY 2012 AUG -3 AM 10: 31 CUERLANO COUNTY JEANNE A. SHEARER PENNSYLVANIA : NO.: 2012-1628-CIVIL Defendant(s) : CUMBERLAND NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JEANNE A. SHEARER 416 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 "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 BANIH THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ENFORCEMENT OF A LIEN AGAINST PROPERTY." JEANNE A. SHEARER 422 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 Your house (real estate) at 422 NORTH FRONT STREET, WORMLEYSBURG, PA 17043-1 scheduled to be sold at the Sheriff s Sale on 12/05/2012 at 10:00 AM in the Cumberland County Court South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $134,312.92 obtained by V% FARGO BANK, N.A. (the mortgagee) against you. In the event the sale is continued, an announcemei 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: STAINED '.UPTCY, INLY 114 is house, ELLS t will be .1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 xl 30. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the j if the judgment was improperly entered. You may also ask the Court to postpone the sale for good ca 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 ou will have of stopping the sale. (See notice on page two on how to obtain an attorney.) COURT OF COMMON (PLEAS Plaintiff : CIVIL DIVISION YUU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HA 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 put 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 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 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 i 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 tIjT- 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 i after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT BA 17E A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED B LO 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 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 2012-1628-CIVIL WELLS FARGO BANK, N.A. vs. JEANNE A. SHEARER owner(s) of property situate in the BOROUGH OF WORMLEYSBURG, Cumberland County, Pennsylvania, being (Municipality) 422 NORTH FRONT STREET, WORMLEYSBURG, PA 17043-1114 Parcel No. 47-19-1588-107 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $134,312.92 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Borough of Wormleysburg, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the western line of Front Street on the line dividing Lots Nos. 36 and 37 on the hereinafter mentioned Plan of Lots; thence in a westerly direction along said last mentioned line 153.46 fe more or less, to a point on the eastern line of River Alley; thence in a southerly direction 62 1/2 feet, more less, to a point in the center of Lot No. 34 on the Plan hereinafter mentioned; thence in an easterly directio along the line at right angles to Front Street 153.62 feet more or less, to a point on Front Street; thence in a northerly direction along Front Street 62 1/2 feet to the point or place of BEGINNING. BEING Lots Nos. 35 and 36 and the northern 12 1/2 feet of Lot No. 34 on Edgewater Plan No. 3, recorded in the Recorder's Office in and for Cumberland County in Plan Book 1, Page 71. TITLE TO SAID PREMISES VESTED IN Jeanne A. Shearer, by Deed from Paul E. Shearer and Jeanne A. Shearer, his wife, dated 03/25/1976, recorded 04/22/1976 in Book 26N, Page 778. PREMISES BEING: 422 NORTH FRONT STREET, WORMLEYSBURG, PA 17043-1114 PARCEL NO. 47-19-1588-107 L.,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WELLS FARUO BANK. N.A. Plaintiff Court of Common Pleas Civil Division v. JEANNE A. SHEARER Defendant CUMBERLAND County No.: 2012-1628-CIVIL RULE AND NOW, this_/~• ~~~ day of ~~~ °~ ~~=X2012, a Rule is entered upon the Defendant to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant shall have twenty (20) days from the date of this Order to file a response to Plaintiff s Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. ~ Pti~laH ~ ~l; ~ H ~ S~ ,~,, ; ~S ~p; i° S vt~ . 'lid lO~i~ ~i a ~°/~ BY THE COURT -~ ~~, ~~ ~~ r~t~~~~ ~.-~ J. <«a ~: .~ 249324 Allison F. Wells, Lsq.. Id. Nc~.~0951~i Phelan Hallman & Schmieg. LI.P l t> 17 JFK Boulevard. Suite 1 ~l)0 PD~iladelphia, PA 19103 Tf:L: (215)563-7000 FAX: (215) 563-3459 JEANNE A. SHEARER 416 NORTH FRONT STREET WORMLEYSBt1RG, PA 17043-11.14 .TEANNE A. SHEARER 422 NORTH FRONT STREET WORMLEYSBURG, PA 17043-11.14 249324 249324 Phelan Hallinan & 5chmieg, LLP Justin F, Kobeski, E',sq., Id. No.200392 ~ ~~~ ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 ~ , :- , , , ~; ' ;' ~~ ; One Penn Center Plaza ~ ~ ~ = `, `~ ` ''~` ~' l ~~`~ Philadelphia. PA 19103 ? 15~-563-7000 WELLS FARGO BANK, N.A. Plaintiff vs. JEANM~, ~~. SHEARER Court of Common fleas Civil Division CUMBERLAND County No.:2012-1628-CP~'11 Defendant CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's October 17, 201 ? .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 belo~~. JEANNE A. SHEARER JEANNE A. SHEARER 416 NORTH FRONT STREET 422 NORTH FRONT STREF,T WORMLEYSBURG, PA 17043-1114 WORIVILEYSBURG, PA 1704 ~-11 14 Phelan Hallinan Schn~ieg, LLP DATE: ^ ~-~ ' BY~ ----- J . Kob ski, Esq., Id. No.200392 A orney for Plaintiff 249324 Phelan Hallinan & Schmieg, LLP X4;1 ~ ~~~~:~ -~ ~~ IQ~ ~: I Melissa J. Cantwell, Esq., Id. No.3Q.~~~.. ~„ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 ~ ` .:~~.~~° ~' ~- ~ ~'~ C C C C N ~i One Penn Center Plaza `' ~ ~~'~ a Y LV~ P~ 1 ~ ~~ Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. Court of Common Pleas Plaintiff Civil Division vs. CUMBERLAND County JEANNE A. SHEARER No.:2012-1628-CIVIL 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 3, 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. 249324 WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiff's Motion to Reassess Damages. helan Hallinan & Schmieg, LLP NQ'~1 (18 1011 DATE: By: 'ssa J. antwe ., Id. No.308912 Attorney for Plaintiff 249324 Exhibit "A" 249324 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 New Jersey October 3, 2012 JEANNE A. SHEARER 416 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 RE: WELLS FARGO BANK, N.A. v. JEANNE A. SHEARER Premises Address: 422 NORTH FRONT STREET WORMLEYSBURG, PA 17043 CUMBERLAND County CCP, No. 2012-1628-CIVIL 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 ynuJ r~,_,..--~---""'_';/" fl~sa~}ts, Esq., Id. No.309519 Attorney for Plaintiff Enclosure 249324 i' I~ t ~. ~'{ ~ ~; ~' ~" 11 N • ~ ' 'i '-~ ~ ~~ -~ ,~ - ~~ z ..~ ~ ~ '~ i ~ p ~ ~ ~ ~ ~i, ~ v~. ~'"~ ~r ~' ~ ~ ~ ~` ~~ ; a ~~ ~~ ~~~ ~~~.~ ~. 8~ ~ gtt ~ yy n A ~K •• .. 1 ~~. Y `~ ' a _~ ~ 3 ru lad ~ YTi ~:. q r ~. Y ... ' ~~ y .,~~, ,d f 4~ r l~ 3 _. ~ . 1 .- r ~_ .v.' 4... r .. . ~~~- 5. l y `~ ~ ~ i "~ ~ ~ 3 ~ r q` '~` .~ 7 t¢f J{t i, ` ~ ~ } f { c ~ ~, 4 ~ ~ , i r < t ~ ~~ } _,. '3 fir: t "t` w .` r ~.- ~ ?w ~ ~ ~ + ;+ Exhibit "B" 249324 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 JEANNE A. SHEARER No.:2012-1628-CIVIL Defendant ~f 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 Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY THE COURT t~F y~ ~~~Ft -~.~ - J -_.~ t ti C~ti.7 ~' ? C"? .,:; ." ; ^~..1 f ~ __ ~.. C -. ~. ..... :_..t} 249324 Exhibit "C" 249324 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 ATTORNEY FOR PLAINTIFF Court of Conunon Pleas : Civil Division vsr: CUMBERLAND County JEANNE A. SHEARER : No.:2012-1628-CIVIL Defendant CERTIFICATION OF SEKVICE 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. JEANNE A. SHEARER 416 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 JEANNE A. SHEARER 422 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 Phelan Hallinan ' - Schmieg, LLP DATE: ~._ 1 l~ ~I~/ ~ By: Ji rc7 sl:, Esq., Id. No.200392 oriiey for Plaintiff 249324 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 JEANNE A. SHEARER No.:2012-1628-CIVIL 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. JEANNE A. SHEARER 416 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 JEANNE A. SHEARER 422 NORTH FRONT STREET WORMLEY5BURG, PA 17043-1114 Phelan H in ieg, LLP DATE: NOU 0 8 2012 By. ' a J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff 249324 .~-'/' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~..~ WELLS FARGO BANK, N.A. Plaintiff VS. : JEANNE A. SHEARER Defendant G -° Court of Common Pleas ., ~~ z Civil Division r ~' ~, -<..~ G~ CUMBERLAND County ~~ p'~ No.: 2012-1628-CIVIL -+ -< ORDER AND NUW, this / y~tl~ day of /J~s~'n~~2012, upon consideration of Plaintiff s ~,> f_",y~ r+~ c.n "Q c .~ c, #motionQ 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 Interest Through December 5, 2012 Legal fees Cost of Suit and Title Property Inspections Escrow to be paid prior to December 5, 2012 Escrow Deficit TOTAL Plus interest at six percent per annum. $116,311.92 $21,804.84 $1,750.00 $1,315.75 $555.00 $1,946.70 $6,400.91 $150,085.12 Note: The above figure is not a payoff quote. Sheriff s commission is not included in the above figure. ~.S~C~r~%~FF ~ c~ z°4 K wG ~- ..Sr~rC/ ~~L BY THE COURT: ~~ J. 249324 »•i '"!_ " ; f ~'ti C" ca <~a ._,.-i C~:: v `'. (. j~ ~~'i PHELAN HALLINAN & SCHMIEG, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for P1~inhff ? f' ~` ~" ~~ l t ~'' i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS v. CIVIL DIVISION JEANNE A. SHEARER Defendant(s) No.:2012-1628-CIVIL 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 attached hereto Exhibit "A". A ,Esquire // ~ Attorney for 'ff Date: (( J ~' 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 # 249324 WELLS FARGO BANK, N.A. , Plaintiff v. JEANNE A. SHEARER Defendant(s) , COURT OF COMMON PLEAS CIVIL DIVISION NO.: 2012-1628-CIVIL CUMBERLAND COUNTY PHS # 249324 AMENDED AFFIDAVIT PURSUANT TO RULE 31291 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 422 NORTH FRONT STREET, WORMLEYSBURG, PA 17043-1114. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if addre be b ss cannot reasona ly ascertained, please so indicate) JEANNE A. SHEARER 416 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 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) Citibank South Dakota NA 701 East 6llth Street North Sioux Falls, SD 57117 CITIBANK SOUTH DAKOTA NA BURTON NEII, & ASSOCIATES PC C/O YALE D. WEINSTEIN, ESQ. 1060 ANDREW DR STE 170 WEST CHESTER, PA 19380 Wells Fargo Bank, N.A. 1 Home Campus Des Moines, IA 50328 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate} None. 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 Commonwealth of Pennsylvania Bureau of Individual Taxes Inheritance Tax Division 422 NORTH FRONT STREET WORMLEYSBURG, PA 17043-1114 6th Floor, Strawberry Sq. Dept 280601 Harrisburg, PA 17128 Department of Public Welfare, TPL Casualty Unit, Estate Recovery Program Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.5. Attorney for the Middle District of PA Federal Building P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 13 North Hanover Street Carlisle, PA 17013 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 personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: sy: Phelan Hallina chmie , LLP Attorney for Plaintiff f~lr~~w~~ ~~~ ~. ~, ~~ R~ ~ a ..r ~9 x. ~~ ~" ~ ~ , ~'~" ~~' ~ ~ ~ ~' :~ ~~ ~~ '~ '' -~ ~~ ~ m ~.,~~., ~~~t ~. ;~r~ ~ .~~ ~~ z Oa~ m c~ n ~, Q ~ ~~~ ~~~-~ °~ ..~ ~b `~ ~ `~ ~ ~! 1 ~.. ! ~nR ,;., t. ~'~+, ~,. r. , ~ . ~ a~;atP e + . 'gig '~ 77 't