HomeMy WebLinkAbout12-1797"THIS IS NOT AN ARBITRATION CASE"
"AN ASSESSMENT OF DAMAGES HEARING IS NOT REQUIRED"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, NA CIVIL DIVISION
Plaintiff, ISSUE NO.: --`
217 vs. TYPE OF PLEADING: r`'r? r `-=:-'
CIVIL ACTION - COMPLAIN T
Matthew E. Waters; EJECTMENT
Defendant. CODE- ?r' -
FILED ON BEHALF OF: F_?-!
Wells Fargo Bank, N.A.
COUNSEL OF RECORD FOR THIS r Q PARTY: -`'
Scott A. Dietterick, Esquire; Pa. I.D. 455650
Kimberly A. Bonner, Esquire; Pa. I.D. #89705
Joel A. Ackerman, Esquire; Pa I.D. 4202729
Ashleigh Levy Marin, Esquire; Pa I.D.
#306799
Ralph M. Salvia, Esquire; Pa I.D. #202946
Jaime R. Ackerman, Esquire; Pa I.D. #311032
ZUCKER, GOLDBERG & ACKERMAN,
LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500, (908) 233-1390 FAX
office a zLickerg
goldherg.coni
File No.: XFP- 144008/gg
TO: Defendant(s)
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.
Scott A. Dietterick, Esquire
Kimberly A. Bonner, Esquire
Joel A. Ackerman, Esquire
Ashleigh Levy Marin, Esquire
Ralph M. Salvia, Esquire
Jaime R. Ackerman, Esquire (25?)
Attorneys for Plaintiff (QvA % 16 3. ?S'Pd
CaA?
LC_4,?a111
?Aa-7 at, )s
, ucker_ tiokff r_7 A, %0?erinan. Ilk'
?, I P-1 44008
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, NA
: CIVIL DIVISION
Plaintiff,
vs. NO..
Matthew E. Waters;
Defendant.
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
/ticker. (r(>Idbo- t ackermar. 1J,(-
X F ('-1 14008
1.1400S[W ;?,1.32012'4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, NA
Plaintiff,
Vs.
CIVIL DIVISION
NO.:
Matthew E. Waters;
Defendant
AVISO
LISTED HA SIDO DEMONDADO/A EN CORTE. Si usted desea defenderse de las demandas
que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro do los
proximos veinte (20) dias despues de la notifacacion de esta Demanda y Aviso radicando
personalmente o por medio de un abogado una comperencencia escrita y redicanco en la Courte
por escrito sus defensas de, y objecciones a, los demandas presentadas aqui en contra suya. Se le
advierte de que si usted falla de tomar accion como se describe anteriormente, el caso puede
proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier
otra reclamacion o remedio solicitado por el demandante puede ser dictado en contra suya por la
Corte sin mas aviso adicional. Usted puede perder dinero O propieded u otros derechos
importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABAGADO IMMEDIATAMENTE. SI
USTED NO TIENE UN ABOGADO O NO PUEDE PAGARLE A UNO, LLAME A VAYA A
LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR
ASISTENCIA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
LAWYER REFERRAL
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
/ucker. C.?aldtier> <? W,erwin. 11 C
\ 1 P-144008
1440()ht)I1")0--1( 0-113'01-2P5
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, NA
vs.
Matthew E. Waters:
CIVIL DIVISION
Plaintiff,
NO..
Defendants.
CIVIL ACTION - COMPLAINT IN EJECTMENT
AND NOW, comes Wells Fargo Bank, NA, by its attorneys, Zucker, Goldberg &
Ackerman, LLC, and files this Complaint in Ejectment as follows:
1. The Plaintiff, Wells Fargo Bank, NA, which has its principal place of business at
3476 Stateview Boulevard, Fort Mill, SC 29715.
2. The Defendant, Matthew E. Waters, is an adult individual residing within the
Commonwealth of Pennsylvania at 18 South Locust Lane, Mechanicsburg, PA 17050.
3. By Sheriff's Deed dated January 26, 2012, recorded on February 8, 2012, Instr#
201203961, the Sheriff of Cumberland County has conveyed to Plaintiff, all that certain lot of
piece of ground, with improvements erected thereon, and as more fully described in the Deed
and as purchased by Plaintiff at Sheriff Sale on November 2, 2011. A true and correct copy of
the recorded deed is incorporated herein as Exhibit "A".
4. On March 29, 2011 Defendant was served personally by the Sheriff of
Cumberland County as owner of the aforesaid premises with amended Notice of Sheriffs Sale
scheduling the sale for November 2, 2011. A true and correct copy of Plaintiffs Affidavit of
Service is incorporated herein as Exhibit "B".
5. By letter, dated February 17, 2012, Defendant and all other Current Occupants, if
any, were notified by counsel for the Plaintiff to vacate the premises, via Certified Mail, Return
Receipt Requested and First Class U.S. Mail, postage pre-paid, with a Certificate of Mailing. A
true and correct copy of the letter, Certified Mail Receipt and Certificate of Mailing are
incorporated herein as Exhibit "C".
6. To date, Defendant has failed or refused to vacate the premises, and therefore,
Defendant is occupying, using and enjoying the premises without right and Claim of Title.
7. Defendant has unjustly and unlawfully retained possession of the premises to the
detriment of Plaintiff.
WHEREFORE, Plaintiff demands judgment against Defendant for possession of the
premises known as 18 South Locust Lane, Mechanicsburg, PA 17050, together with such other
relief as this Honorable Court may deem necessary and appropriate.
ZUCKER, GOLDBERG & ACKERMAN, LLC
BY: ci-? Aw Yk k-,--'
Dated: March 2012 Scott A. Eil tt 'c , Esquire; PA I.D. #55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. 4202729
Ashleigh Levy Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. 4202946
Jaime R. Ackerman. Esquire; PA I.D. 4311032
Attorneys for Plaintiff
XFP-144008/gg
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
THIS IS ANA TTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED
FOR THAT PURPOSE.
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 201203961
Recorded On 2/8/2012 At 1:17:23 PM * Total Pages - 6
* Instrument Type - DEED-SHERIFF'S
Invoice Number -101664 User ID - RZ
* Grantor - WATERS, MATTHEW E
* Grantee - WELLS FARGO BK N A
`Customer - ZUCKER GOLDBERG & ACKERMAN LLC
*7EES
;STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $23.50
JUSTICE
RECORDING FEES - $12.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
CUMBERLAND VALLEY SCHOOL $0.00
DISTRICT
SILVER SPRING TOWNSHIP $0.00
TOTAL PAID $63.00
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
° RECORDER O D DS
• - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
002JW9f
?I) I?III?II?IIIVIII ?IIII?
" EXHIBIT A"
39?'l
tf
Tax Parcel No. 38-15-1275-047
Know all Men by these Presents
That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of
Pennsylvania, for and in consideration of the sum of S 1.00 (One Dollar), to me in hand
paid, do hereby grant and convey to Wells Fargo Bank, NA.
2010-7138 Civil Term
Wells Fargo Bank, N.A.
Vs
Matthew E. Waters
Atty: Scott A Dietterick
ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER
SPRING, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED
AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE CORNER OF LOT #93 AND A CUL-DE-SAC AT THE
END OF LOCUST LANE, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF
LOTS; THENCE ALONG SAID LOT #93, SOUTH EIGHT (8) DEGREES FORTY-FOUR (44)
MINUTES TWO (2) SECONDS EAST, FIFTY-ONE AND FIFTY-FIVE HUNDREDTHS
(51.85) FEET TO A POINT; THENCE ALONG LINE OF SAID LOT #93, SOUTH THIRTY-
FOUR (34) DEGREES TWENTY-ONE (21) MINUTES NINE (9) WEST, ONE HUNDRED
FORTY-NINE AND TWENTY-FOUR HUNDREDTHS (149.24) FEET TO A POINT ON THE
LINE OF SILVER SPRING TOWNSHIP PARK, AS SHOWN IN THE HEREINAFTER
MENTIONED PLAN OF LOTS; THENCE ALONG LINE OF SAID SILVER SPRING
TOWNSHIP PARK, NORTH FIFTY-FIVE (55) DEGREES THIRTY-EIGHT MINUTES
FIFTY-ONE (51) SECONDS WEST, SIXTY-FOUR AND EIGHTY-THREE HUNDREDTHS
(64.83) TO A POINT ON THE CORNER OF LOT #91, AS SHOWN IN THE HEREINAFTER
MENTIONED PLAN OF LOTS; THENCE ALONG SAID LOT #91, NORTH FOURTEEN (14)
DEGREES THIRTY-FOUR (34) MINUTES ELEVEN (11) SECONDS WEST, ONE
HUNDRED NINETY AND TWENTY-THREE HUNDREDTHS (190.23) FEET TO A POINT
ON THE CORNER OF LOT #82, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN
OF LOTS; THENCE ALONG SAID LOT #82, NORTH FIFTY-SIX (56) DEGREES TWELVE
(12) MINUTES EAST, ONE HUNDRED FIFTY (150) FEET TO A POINT ON THE SOUTH
SIDE OF LOCUST LANE, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF
LOTS; THENCE ALONG SAID LOCUST LANE, SOUTH THIRTY-THREE (33) DEGREES
FORTY-EIGHT (48) MINUTES EAST, THIRTEEN ARID FIFTY-FIVE HUNDREDTHS
(13.55) FEET TO A POINT ON THE CUL-DE-SAC IN A SOUTHERLY DIRECTION, ON A
CURVE TO THE LEFT, HAVING A RADIUS OF SEVENTY-FIVE (75) FEET, AN ARC ARE
DISTANCE OF ONE HUNDRED FIFTY-ONE AND TWENTY-THREE HUNDREDTHS
(151.23) FEET TO A POINT ON THE CORNER OF LOT #93 AFORESAID, THE PLACE OF
BEGINNING. CONTAINING.72 ACRES, MORE OR LESS, BEING LOT #92 IN TILE
SUBDIVISION PLAN OF WHITE BIRCH FARMS, SECTIONS 1 AND 2, AS SHOWN IN
THE PLAN BOOK 44, PAGE 91, AND RECORDED IN THE CUMBERLAND COUNTY
RECORDERS OFF ICE.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND
NUMBERED AS 18 SOUTH LOCUST LANE, MECHANICSBURG, PA, 17050.
BEING THE SAME PREMISES WHICH JOSHUA D. MASSIE AND NICOLE L.
MASSIE, HUSBAND AND WIFE, BY DEED DATED JUNE 14, 2007 AND RECORDED
JUNE 15, 2007 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED
BOOK VOLUME 280, PAGE 2431, GRANTED AND CONVEYED UNTO MATTHEW E.
WATERS.
TAX MAP NO.; 38-15-1275-047.
The same having been sold by me to the said grantee on the 2nd day of November,
Anno Domini Two Thousand and Eleven (2011) after due advertisement according to
law, under and by Virtue of a Writ of Execution issued on the 1st of January Anno
Domini 2011 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as
of Civil Term, Two Thousand and Ten (2010) Number 7138 at the suit of Wells Fargo
Bank, NA, vs. Matthew E. Waters.
In Witness Whereof, I have hereunto affixed my signature this
Anno Domini Two Thousand and Twelve (2012)
Commonwealth of Pennsylvania, ss.
County of Cumberland
26th day of January
Before the undersigned, David D. Buell, Prothonotary of the Court of Common
Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson,
Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts
Set forth in the foregoing Deed are true, and that he acknowledged the same in order that
Said deed might be recorded. Witness my hand and seal of said Court, this 2 6thday
of January
.?? s. ?- Ct)Lr f,
??Irrlt,s t0
Anno Domini Two Thousand and Twelve (2012)
My camrjul n 94*0 nn part MAWN a1 yip. am-
I hereby certify that the residence
And Post Office address of the
Within Grantee is
3476 Stateview Bouldvard
Fort Mill, SC 29715
fzV
Sohcrtor
XFP-144008
REV-18, EX04-10)
pennsywanla
DEPARTMENT OF REVENUE
BUREAU OF DOMDUAL TAXES
PO BOX 2801110
NARRgeURG, PA 17129-0003
REALTY TRANSFER
TAX
STATEMENT OF
RECORDER'S USE ONLY
Tax Paid O -
(Book Number2a1 Z 0.19&1
Number
{ V 11 TIP joate Recorded -2_
Complete each section and file In duplicate with Recorder of heeds when (1) the U valuelconsideration Me not set forth in the deed, (2) when the
deed is without consideraxon, or by gift, or (3) a tax exemption Is claimed. A Statement of Value is not required if the transfer is wholly exempt from
tax based on family relationship or pubic utltfy easement. If more space is needed, attach additional sheet(s).
Name Zucker, Goldberg & Ackerman, LLC Telephone Number 908-233-8500 Ext. 329
Street Address City State Zip Code
200 Sbeff ellll Street Mountainside NJ 07092
M I
Grantor(syussor(s) Grantee(s)/Lessee(s)
Sheriff of CUMBERLAND County Wells Fargo Bank, NA
Street Address Street Address
One Courthouse Square 3476 Stateview Boulevard
City State Zip City State Zip
Carlisle PA 117013-3397 Fort Mill ISC 129715
Street Address City, Township, Borough
18 South Locust Lane TOWNSHIP OF SILVER SPRING
County School District Tax Parcel Number
CUMBERLAND Cumberland Valle School District 38-15-1275-047
1. Actual Cash Consideration 2 Other Consideration 3. Total Consideration
S 1,200,87 0 = S 1,200.87
4. County Assessed Value 5, Common Level Ratio Factor 6. Fair Market Value
$117,640.00 X 1.00 $117,640.00
1 a. Amount of Exemption Claimed
100%
lb. Percentage of Grantor's Interest in Real Estate 1 c. Percentage of Grantor's interest conveyed
100% 100%.
Check Appropriate Box for Exemption Claimed
? Will or intestate succession _
(Name of Decedent) (Estate File Number)
? Transfer to a trust (Attach complete copy of trust agreement identifying all beneficiaries.)
? Transfer from a trust. Date of transfer into the trust
If trust was amended attach a copy of original and amended trust.
? Transfer between principal and agent/straw party. (Attach complete copy agency/straw party agreement)
? Transfers to the Commonwealth, the United States, and instrumentalities by gift, dedication, condemnation or lieu of condemnation. (If
condemnation or in lieu of condemnation, attach copy of resolution.)
® Transfer from mortgagor to a holder of a mortgage in default. (Attach copy of Mortgage and note/Assignment)
? Corrective or confirmatory deed (Attach complete copy of prior deed being corrected or confirmed)
? Statutory corporate consolidation, merger or division (Attach copy of articles.)
® Other (Please explain exemption claimed, if other than listed above.): 100% exemption for transfer to a holder of a mortgage in
default through Judicial Sale, pursuant to 72 P.S.-1102-C.3 (1)
Under penalties of law, I declare that I have examined this Statement, Including accompanying information, and to the best of my
knowledge and belief, It Is true, corrsct and complete.
spas. d omrapm,aw% uru II 11 t a R A X, - ?? - V E
FAILURE TO COIWLVT'ktAS FORM PROPERLY OR ATTACH APPLICABLE DOCUMENTATION MAY RESULT IN THE
RECORDER'S REFUSAL TO RECORD THE DEED
LEONARD B. ZUCKER
MICHAEL S. ACKERMAN
JOEL ACKERMAN'
FRANCES GAMBARDELLA
BRIAN C. NICHOLAS 0
STEVEN D. KROL
CHRISTOPHER G. FORD
DENISE CARLON A
CHRISTINE E. POTTER
RYAN S. MALC
1ENEE K. CICCARELLI A
JAMES R. FREESWICK A
ASHLEIGH L. LEVY E
DOUGLAS J. McDONOUGH
TIMOTHY J. ZIEGLER
STEPHANIE WOLCHOK
HYUN S. OH
ELIZABETH P. RIZZO
ROBERT D. BAILEY
• ALSO MEMBER OF NY, PA AND CA BAR
0 ALSO MEMBER OF NYAND ME BAR
4 ALSO MEMBER OF NY BAR
f ALSO MEMBER OF PA BAR
XFP-144008
Prothonotary of Cumberland County
Cumberland County Courthouse
Carlisle, PA 17013-3387
May 11, 2011
Re: Wells Fargo Bank, NA
vs. Matthew E. Waters
Premises: 18 South Locust Lane, Mechanicsburg PA 17050.
Docket No.: 10-7138
Dear Sir or Madam:
Enclosed for filing please find an original of an Affidavit of Service of Defendant/Owner and Other Parties of
Interest regarding the above referenced matter. Please file the original and return a time-stamped copy of
the extra face page which is enclosed in the self-addressed stamped envelope.
If you have any questions or concerns, please do not hesitate to contact Dan Schlesinger of our office at
(908) 233-8500 ext. 326.
Very Truly Yours,
ZUCKER, GOLDBERG & ACKERMAN, LLC
Daniel Schlesinger, Legal Assistant
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
Email: Office@zuckergoldberg.com
File No.: XFP-144008
(908) 233-8500; (908) 233-1390 FAX
dsc
enclosures
cc: Sheriff of Cumberland County (w/encl.)
ZUCKER, GOLDBERG & ACKERMAN, LLC FOUND50IN 1923
ATTORNEYS AT LAW AS ZUCKER & GOLDBERG
200 SHEFFIELD STREET- SUITE 101 MAURICE 1. ZUCKER 1918-1979)
LOUIS D. GOLDBERG 1923-1967)
P.O. BOX 1024 LEONARD H. GOLDBERG 1929.1979!
MOUNTAINSIDE, NJ 07092-0024 BENJAMIN WEISS 1949-19811
TELEPHONE: 908 -2 33 -8500
FACSIMILE: 908-233-1390
E-MAIL: office@zuckergoldberg.com Pennsylvania Office:
P.O. Box 650
Hershey, PA 17033
For payoff/reinstatement figures
Please send your request to: zuckergoldberg.com/pr OF COUNSEL:
SCOTT A. DETTERICK MB RLYAI BONNER, ESC, Y
REPLY TO NEW JERSEY ADDRESS KI
Y MEMBER OF PA BAR ONLY
''EXHIBIT B"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, NA, CIVIL DIVISION
Plaintiff, NO.: 10-7138
vs.
TYPE OF PLEADING
Matthew E. Waters
Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE
Defendants. OF DEFENDANT/OWNER AND
OTHER PARTIES OF INTEREST
FILED ON BEHALF OF:
Wells Fargo Bank, NA
COUNSEL OF RECORD FOR THIS PARTY:
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 L. Levy, Esquire- PA I.D. #306799
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
office@zuckergoldberg.com
File No.: XFP- 144008/dsc
Zucker, Goldberg & Ackerman, LLC
XFP-144008
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, NA, CIVIL DIVISION
Plaintiff, NO.: 10-7138
VS.
Matthew E. Waters
Defendant.
Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF
DEFENDANTIOWNER AND OTHER PARTIES OF INTEREST
I, Daniel Schlesinger, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys
for Plaintiff, Wells Fargo Bank, NA, being duly sworn according to law depose and make the following
Affidavit regarding the service of Plaintiffs Notice of Sheriff's Sale of Real Property in this matter on
Defendant/Owner and Other Parties of Interest as follows:
1. Defendant, Matthew E. Waters, is the record owner of the real property.
2. On or about March 29, 2011, Matthew E. Waters was served with Plaintiff's Notice of
Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland
County, at the address of the mortgaged premises, being 18 South Locust Lane, Mechanicsburg PA
17050. A true and correct copy of said Notice and Proof of Service are marked Exhibit "A", attached
hereto and made a part hereof.
3. On or about April 7, 2011, Plaintiffs counsel served all other parties in interest with
Plaintiff's Notice of Sheriffs Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class
U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and
Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof.
Zucker, Goldberg & Ackerman, LLC
X FP-144008
Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of
Interest were served with Plaintiff's Notice of Sheriffs Sale of Real Property in accordance with Pa.R.C.P.
3129.2.
ZUCKER, GOLDBERG & ACKERMAN, LLC
Attorneys for Plaintiff
Dated: May 11, 2011
L SCHLESINGER,
Paralegal/Legal Assistant
Sworn to and subscribed before
jry day of May, 2011
Public
MY COM ISSION EXPIRES:
EDWARD J. SCHWAHL 11
Commission #.2383239
Notary Public, State OJ Now Jersey
MY C6rnmissioo::Ex•pifes
Mqr;h 09,2014
Zucker, Goldberg & Ackerman, LLC
XFP-144008
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
X F P-144008
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
v?ttT??? at tatnGrr?t?jb
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor OFFICE ;>F ;E sKERtFF
Wells Fargo Bank, N.A.
vs. Case Number
Matthew E. Waters 2010-7138
SHERIFF'S RETURN OF SERVICE
03/17/2011 07:30 PM - Deputy Michael Barrick, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action,
upon the property located at 18 South Locust Street, Mechanicsburg, PA 17050, Cumberland County.
03129/2011 09:00 PM - Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Real
Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the
same time personally handing a true copy to a person representing themselves to be the Defendant, to
wit: Matthew E. Waters at 18 S. Locust Lane, Silver Spring Township, Mechanicsburg, PA 17050,
Cumberland County.
SHERIFF COST: $898.94
May 05, 2011
SO ANSWERS,
RONNNY R ANDERSON, SHERIFF
(r, cok trysmts She,& Teleosott, ine
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, NA, CIVIL DIVISION
Plaintiff,
vs. : NO.: 10-7138
Matthew E. Waters
Defendant.
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Matthew E. Waters
18 South Locust Lane
Mechanicsburg, PA 17050
TAKE NOTICE.
That the Sheriffs Sale of Real Property (Real Estate) will be held at the
Cumberland County Courthouse, I Courthouse Square, Carlisle, PA 17013 on
06/01/2011 at I0:00am prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description
consisting of a statement of the measured boundaries of the property, together with a
brief mention of the buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A").
The LOCATION of your property to be sold is:
18 South Locust Lane, Mechanicsburg, PA, 17050
The JUDGMENT under or pursuant to which your property is being sold is
docketed to:
No. 10-7138
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS
PROPERTY ARE:
Matthew E. Waters
Zucker, Goldberg & Ackerman, LLC
XFP-144008
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or
governmental or corporate entities or agencies being entitled to receive part of the
proceeds of the sale received and to be disbursed by the Sheriff (for example to banks
that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff
thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with
this schedule will, in fact, be made unless someone objects by filing exceptions to it,
within ten (10) days of the date it is filed. Information about the Schedule of Distribution
may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County,
One Courthouse Square, Carlisle, PA 17013-3387.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF
YOUR PROPERTY.
It has been issued because there is a Judgment against you. It may cause your
property to be held, to be sold or taken to pay the Judgment. You may have legal rights
to prevent your property from being taken. A lawyer can advise you more specifically of
these rights. If you wish to exercise your rights, you must act promptly.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO
OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET FREE LEGAL ADVICE.
Lawyer Referral Service of the
Cumberland County Bar Association
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
THE LEGAL RIGHTS YOU MAY HAVE ARE:
I. You may file a petition with the Court of Common Pleas of
Cumberland County to open the Judgment if you have a meritorious defense against
the person or company that has entered judgment against you. You may also file a
petition with the same Court if you are aware of a legal defect in the obligation or the
procedure used against you.
2. After the Sheriffs Sale, you may file a petition with the Court of
Common Pleas of Cumberland County to set aside the sale for a grossly inadequate
price or for other proper cause. This petition must be filed before the Sheriffs Deed
is delivered.
Zucker, Goldberg & Ackerman, LLC
XFP-144008
3. A petition or petitions raising the legal issues or rights mentioned
in the preceding paragraphs must be presented to the Court of Common Pleas of
Cumberland County. The petition must be served on the attorney for the creditor or
on the creditor before presentation to the Court and a proposed order or rule must be
attached to the petition. If a specific return date is desired, such date must be
obtained from the Court Administrator's Office, Cumberland County Courthouse,
One Courthouse Square, Carlisle, PA 101presentation of the
petition to the Court. ZUCKERf
j%DANkGf8j `4ERMAN,LLC
Dated: December 28, 2010 BY:
Scott A. a erick, squire; PA T.D. #55650
Kimberly Bonner, Esquire; PA.I.D. #89705
Joel A. Ackerman, Esquire; PA I. D. #202729
Ashleigh L. Levy, Esquire; PA I.D. #306799
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
File No.: XFP-144008
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND
VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO.
Zucker, Goldberg & Ackerman, LLC
XFP-144008
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING,
COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED
AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE CORNER OF LOT #93 AND A CUL-DE-SAC AT THE END OF
LOCUST LANE, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE
ALONG SAID LOT #93, SOUTH EIGHT (8) DEGREES FORTY-FOUR (44) MINUTES TWO (2)
SECONDS EAST, FIFTY-ONE AND FIFTY-FIVE HUNDREDTHS (51.85) FEET TO A POINT;
THENCE ALONG LINE OF SAID LOT #93, SOUTH THIRTY-FOUR (34) DEGREES TWENTY-ONE
(21) MINUTES NINE (9) WEST, ONE HUNDRED FORTY-NINE AND TWENTY-POUR
HUNDREDTHS (149.24) FEET TO A POINT ON THE LINE OF SILVER SPRING TOWNSHIP
PARK, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG
LINE OF SAID SILVER SPRING TOWNSHIP PARK, NORTH FIFTY-FIVE (55) DEGREES
THIRTY-EIGHT MINUTES FIFTY-ONE (51) SECONDS WEST, SIXTY-FOUR AND EIGHTY-
THREE HUNDREDTHS (64.83) TO A POINT ON THE CORNER OF LOT #91, AS SHOWN IN THE
HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID LOT #91, NORTH
FOURTEEN (14) DEGREES THIRTY-FOUR (34) MINUTES ELEVEN (11) SECONDS WEST, ONE
HUNDRED NINETY AND TWENTY-THREE HUNDREDTHS (190.23) FEET TO A POINT ON THE
CORNER OF LOT 482, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS;
THENCE ALONG SAID LOT #82, NORTH FIFTY-SIX (56) DEGREES TWELVE (I2) MINUTES
EAST, ONE HUNDRED FIFTY (150) FEET TO A POINT ON THE SOUTH SIDE OF LOCUST
LANE, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG
SAID LOCUST LANE, SOUTH THIRTY-THREE (33) DEGREES FORTY-EIGHT (48) MINUTES
EAST, THIRTEEN ARID FIFTY-FIVE HUNDREDTHS (13.55) FEET TO A POINT ON THE CUL-
DE-SAC IN A SOUTHERLY DIRECTION, ON A CURVE TO THE LEFT, HAVING A RADIUS OF
SEVENTY-FIVE (75) FEET, AN ARC ARE DISTANCE OF ONE HUNDRED FIFTY-ONE AND
TWENTY-THREE HUNDREDTHS (151.23) FEET TO A POINT ON THE CORNER OF LOT #93
AFORESAID, THE PLACE OF BEGINNING. CONTAINING.72 ACRES, MORE OR LESS, BEING
LOT #92 IN TILE
SUBDIVISION PLAN OF WHITE BIRCH FARMS, SECTIONS I AND 2, AS SHOWN IN THE PLAN
BOOK 44, PAGE 91, AND RECORDED IN THE CUMBERLAND COUNTY RECORDERS OFF ICE.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED
AS 18 SOUTH LOCUST LANE, MECHANICSBURG, PA, 17050.
BEING THE SAME PREMISES WHICH JOSHUA D. MASSIE AND NICOLE L. MASSIE,
HUSBAND AND WIFE, BY DEED DATED JUNE 14, 2007 AND RECORDED JUNE 15, 2007 IN
AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 280, PAGE
2431, GRANTED AND CONVEYED UNTO MATTHEW E. WATERS.
TAX MAP NO.: 38-15-1275-047.
T.uckur. tioldbcrp & 1ckcmuui. I.LC
YF'11-144008
EXHIBIT B
Zucker, Goldberg & Ackerman, LLC
XFP-144008
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, NA, : CIVIL DIVISION
Plaintiff, NO.: 10-7138
VS.
Matthew E. Waters
Defendant. .
NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST
PURSUANT TO Pa.R.C.P. 3129(b)
TO:
CUMBERLAND COUNTY TAX CLAIM BUREAU UNKNOWN SPOUSE
Cumberland County Courthouse 18 South Locust Lane
One Courthouse Square Mechanicsburg, PA 17050
Carlisle, PA 17013
COMMONWEALTH OF PENNSYLVANIA PA DEPT. OF REVENUE- INHERITANCE TAX
DEPARTMENT OF WELFARE DIVISION
P.O. Box 2675 Dept. 280601
Harrisburg, PA 17105 Harrisburg, PA 17128-0601
UNKNOWN TENANT OR TENANTS CUMBERLAND COUNTY DOMESTIC RELATIONS
18 South Locust Lane OFFICE
Mechanicsburg, PA 17050 Domestic Relations Section
13 N. Hanover Street
CUMBERLAND COUNTY ADULT PROBATION PO Box
320
2
1 COURTHOURSE SQUARE
Carlisle
, 17013
CARLISLE, PA 17013-3387
TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common
Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will
be exposed to Public Sale in:
the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013
On 06/01/2011 at 10,00am, the following described real estate which Matthew E. Waters are the
owners or reputed owners and on which you may hold a lien or have an Interest which could be affected
by the sale of:
18 South Locust Lane,
Mechanicsburg, PA 17050
Cumberland County
(SEE LEGAL DESCRIPTION ATTAQZ ED AS EXHIBIT "A").
Zucker, Goldberg & Ackerman, LLC
XFP-144008
144008D I004CO404201 I P I
The said Writ of Execution has been issued on a judgment in the action of
Wells Fargo Bank, NA
vs.
Matthew E. Waters, et al
Plaintiff
Defendant(s)
at EX. NO. 10-7138 in the amount of $117241.23 plus Interest and costs.
Claims against property must be filed at the office of the Sheriff before above sale date.
Claims to proceeds must be made with the Office of the Sheriff before distribution.
Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days
from the sale date.
Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the
Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of
the Sheriff.
If you have any questions or comments with regard to the 5 riffs Sale or this Notice, you
should contact your attorney as soon as possible. I. i11
Dated: 1
ZUCKER GOQ)BEJkG VIACKERBViAN, LLC
BY: ?.Z___
Scott Die Brick, Esquire; PA I.D. #55650
Kimbe,iyA. onner, Esquire; PA I.D. #89705
Joel A, rman, Esquire; PA I.D. #202729
Ashleigh L. Levy, Esquire; Pa I.D. #306799
200 Sheffield Street, Suite 301
Mountainside, NJ 07092
File No.: XFP-144008
(908) 233-8500; (908) 233-1390 FAX
E-mail: Office@zuckergoldberg.com
Zucker, Goldberg & Ackerman, LLC
XFP-144008
144008D 1004CO404201 I P2
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING,
COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED
AS FOLLOWS, TO WIT;
BEGINNING AT A POINT ON THE CORNER OF LOT #93 AND A CUL-DE-SAC AT THE END OF
LOCUST LANE, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE
ALONG SAID LOT #93, SOUTH EIGHT (8) DEGREES FORTY-FOUR (44) MINUTES TWO (2)
SECONDS EAST, FIFTY-ONE AND FIFTY-FIVE HUNDREDTHS (51.85) FEET TO A POINT;
THENCE ALONG LINE OF SAID LOT #93, SOUTH THIRTY-FOUR (34) DEGREES TWENTY-
ONE (21) MINUTES NINE (9) WEST, ONE HUNDRED FORTY-NINE AND TWENTY-FOUR
HUNDREDTHS (149.24) FEET TO A POINT ON THE LINE OF SILVER SPRING TOWNSHIP
PARK, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG
LINE OF SAID SILVER SPRING TOWNSHIP PARK, NORTH FIFTY-FIVE (55) DEGREES
THIRTY-EIGHT MINUTES FIFTY-ONE (51) SECONDS WEST, SIXTY-FOUR AND EIGHTY-
THREE HUNDREDTHS (64.83) TO A POINT ON THE CORNER OF LOT #91, AS SHOWN IN THE
HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID LOT #91, NORTH
FOURTEEN (14) DEGREES THIRTY-FOUR (34) MINUTES ELEVEN (11) SECONDS WEST, ONE
HUNDRED NINETY AND TWENTY-THREE HUNDREDTHS (190.23) FEET TO A POINT ON THE
CORNER OF LOT #82, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS;
THENCE ALONG SAID LOT #82, NORTH FIFTY-SIX (56) DEGREES TWELVE (12) MINUTES
EAST, ONE HUNDRED FIFTY (150) FEET TO A POINT ON THE SOUTH SIDE OF LOCUST
LANE, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG
SAID LOCUST LANE, SOUTH THIRTY-THREE (33) DEGREES FORTY-EIGHT (48) MINUTES
EAST, THIRTEEN ARID FIFTY-FIVE HUNDREDTHS (13.55) FEET TO A POINT ON THE CUL-
DE-SAC IN A SOUTHERLY DIRECTION, ON A CURVE TO THE LEFT, HAVING A RADIUS OF
SEVENTY-FIVE (75) FEET, AN ARC ARE DISTANCE OF ONE HUNDRED FIFTY-ONE AND
TWENTY-THREE HUNDREDTHS (151.23) FEET TO A POINT ON THE CORNER OF LOT #93
AFORESAID, THE PLACE OF BEGINNING. CONTAINING.72 ACRES, MORE OR LESS, BEING
LOT #92 IN TILE
SUBDIVISION PLAN OF WHITE BIRCH FARMS, SECTIONS I AND 2, AS SHOWN IN THE PLAN
BOOK 44, PAGE 91, AND RECORDED IN THE CUMBERLAND COUNTY RECORDERS OFF ICE.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 18 SOUTH
LOCUST LANE, MECHANICSBURG, PA, 17050.
BEING THE SAME PREMISES WHICH JOSHUA D. MASSIE AND NICOLE L. MASSIE, HUSBAND
AND WIFE, BY DEED DATED JUNE 14, 2007 AND RECORDED JUNE 15, 2007 IN AND FOR CUMBERLAND
COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 280, PAGE 2431, GRANTED AND CONVEYED UNTO
MATTHEW E. WATERS.
TAX MAP NO.: 38-15-1275-047.
Zucker, Goldberg & Ackerman, LLC
((Field2»-((Field h»
((Field) »DI004C02/12/2008P3
Page 1 of 4
(JNI EDSTMES Certificate Of
POSTAL SERVICEe Mailing
To pay fee, affix sPmpy or molar poslaae
here.
This Certif ate oftJaMin6provideserkleemthat mallhas beenpresented to USPS•forma f. This form may ba used ford omesik
artd International "I.
"pm' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-144008/sde TEAM C
T": CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Here
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITED ST13TES Certificate Of
Mailing
ere. foe, afliastampsormetarpostage
To pay
POSTAL SERVICE h
hero.
This CarOfkate of h%Mn6 provides avlderwe That mall has been presented to USPSe for mAind. TMs form may be wed for domestic
and imemational mall.
From: Scott A. Dietterick, Esquire
.wo Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101 T
Mountainside, NJ 07092
XFP-144008/sde TEAM C
To: COMMONWEALTH OF PENNSYLVANIA Postmark Here
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
County of P.Q.: CUMBERLAND
PS Form $817, April 2007 PSN 7530-02-000-9065
POSTAL CERT OF MAILING: NOTICE TO LIEN HOLDERS
Page 2 of 4
UNITEDSTATES Certificate Of
P4STlJL SERVICES Mailing
To pay fee, affix stamps or rnatar postage
Hera.
inn ¦ ?
This CerMcab of Mail Ing prwMes evidence that mall has bean presented to USPS' for melting. This form may be vsed for domestic
and international mail.
Pont' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-144008/sde TEAM C
To- UNKNOWN TENANT OR TENANTS Postmark Here
18 South Locust Lane
Mechanicsburg, PA 17050
County of P.Q.; CUMBERLAND
i i rr?wrwe a ra e?ea?ra?aaae????re s+?^?
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES Certificate Of
POSTAL SERVICEe Mailing
To pay sea, aft stamps or meter postage
here.
This Cert0cate of Mailing provides evidence that mil has been presented to USPS' for mallMg. TMs form may be used for domestic
and mtemati-I mail.
"em: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC _
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-144008/sde TEAM C
CUMBERLAND COUNTY ADULT PROBATION Postmark Here
1 COURTHOURSE SQUARE
CARLISLE, PA 17013-3387
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530.02-000-9065
POSTAL CERT OF MAILING NOTICE TO LIEN HOLDERS
Page 3 of 4
UNITED STATES Certificate Of
POSTAL SERVICES Mailing
To pay fire, afw iamps or meter postage
I+erf.
This Certificate of M alkS proyWas srAdenee that mal bas been prosenved to vsPse for matIng. This form may he used for domestic
and tntematlonai mall.
Prom: Scott A, Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, Ni 07092
XFP-144008/sde TEAM C
To' CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Ivitmork Here
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 753002-000-9065
UNITED STATES Certificate Of
To pay fee,afgs stamps a mater postage
VIOPOSMSERVICE Mailing
Mre.
Thts Cortlflate of h4alittq provldu Nldfnn tMt meq Mi been presented to USPS* for magkq. Yh4 form maybe wsad for domestic
and kft wtknal mail,
I"vom: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, N1 07092
XFP-144008/sde TEAM C
To' PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Postmark Here
Dept. 280601
Harrisburg, PA 17128-0601
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
POSTAL CERT OF MAILING: NOTICE TO LIEN HOLDERS
Page 4 of 4
UNITEDSTdTES
V??POSTAL SERVICE
Certificate Of
Mailing
To pay fee, effix stamps or major pwt age
here,
This CettlUrete of hAl4ne provides evIdente that moo has been presented to UPS, for malling. yhis form maybe used for domestic
and International mag.
ffem? Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-1411008/sde TEAM C
Tot UNKNOWN SPOUSE
18 South Locust Lane
Mechanicsburg, PA 17050
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
Postmark Here
POSTAL CERT OF MAILING: NOTICE TO LIEN HOLDERS
Page 1 of 4 ?P
02 1M $ 01.150
000428z036 APR07 2011.
VIG UNITED STATES MAILED FROM ZIPCODE 0 7092
POSTAL SERVICES ??.T,?...,._?...?_. .
hate.
This CMifltate of Waling provides evidence that mall has been Presented to USP5e fw mallre. This form may be used for domestic
and intamationai mal.
From' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-144008/sdeTEAM C
T' CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Here
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITEDSTATES
POSTQt 3ERVICEe
ThlsCoatkoeofMalNmprovldasevWwcothatmall haabeanpresentedwUSPS farmailtng,Th[slormmaybeused fordomestk
and International mall.
"om' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
"Opo
o?
02 1M $ 01.15°
0064282035 APR 0 7 2011.
MAILED FROM ZIPCODE 07092
XFP-144008/sde TEAM C
T°` COMMONWEALTH OF PENNSYLVANIA Postmark
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
County of P.Q.: CUMBERLAND
PS Form 3817, Aprll 2007 PSN 7530-02-000.9065
ONE Ip
f --^.
f
Jet
`-"OsPS - 0
POSTAL CERT OF MAILING: NOTICE TO LIEN HOLDERS
eoes
Page 2 of a if MWEV Novo"
02 Ik4
/? 0004282036 0 q 50
UNITEDSTATErS - MAILE0 FROM Z A
pcoDE PR O 0 2092
P2POSTQZ SERVICE
s here.
This WOW* of Ulalgnt proeWas evidence that mill Rat Men presented to VSPse for milling. This form may be used for domestic
end 11¢anationai map.
rrom: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-144008/sde TEAM C
UNKNOWN TENANT OR TENANTS Postmark Here
18 South Locust Lane
Mechanicsburg, PA 17050
County of P.Q.: CUMBERLAND
PS Form $817, April 2007 PSN 7530-02-000.9065
-Opcksk
`r, =-M.
w mamma gee, pnaev teovees
UNITED StATES 0212 $ O'i.15°
0004282036 APF207 2011.
.MAILED FROM ZIPCODE 0 7092
POSTAL SERVICES
This Certificate of AAaNng prevWeseaidence that mall has been presented to VSPSa for mailing. This form may be used for domestic
and international mall.
"°rn? Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-144008/sde TEAM C
T' CUMBERLAND COUNTY ADULT PROBATION
1 COURTHOURSE SQUARE
CARLISLE, PA 17013-3387
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02.000.9065
??;,.?AINSlO?
Here At i? U d.v ss
SAS .. d`i
POSTAL CE:RT OF MAILING: NOTICE TO LIEN HOLDERS
Page 3 of 4
49 'OSO,
a2 Ike
1Z U1 V1TEDSTA TES 0004282038 APR.0.7 201.1.
MAILED FROM ZIP CODE 0 70 92 .
OnC"r I SERVICE
This CertWkste otMalft provides evidence that resell has been presented to USP5' for malting. This form maybe used far domestic
and international mall.
p'°mt Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-144008/sde TEAM C
To: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Postmark Here
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
?,?gPofft
. ?g
n?a?®
? •e.eemt? tatttattr tawires
UNITEDST13TES oao4a 0 042 4'[.13°
s2ase AP>z.ot 2011.
iN0jnC-rAi SERVIC MAILED FROM ZIPCODE 0 7082. .
j
This Certificate of Mailing provides evidence that malt has been presented to USPSe for mailing. This form may be used for domestic _
.f' /.
?I N,
a nd International mag.
ffomScott A. Dietterick, Esquire ,
l
l r.1
?t•
..... ..... -'
c/o Zucker, Goldberg & Ackerman, LLC ( i
200 Sheffield Street, Suite 101 ?7)
Mountainside, NJ 07092
XFP-144008/sde TEAM C `
T°` PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Postmark Her (?`?S ^ o ?O?v
Dept. 280601
Harrisburg, PA 17128-0601
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
POSTAL CERT OF MAILING: NOTICE TO LIEN HOLDERS
Page 4of4
i
OP-09 i
if
UNITEDSTATES 02 1M $ 01.160
0004292036 APR.o7 201.9.
SMAILEDFROM
POSTAL SERVICE4 Z1PC0,E.0 70 2
l
Tfrfs Certi6ta4e of Ma lln`provides andante that rrw l has been prementad to USPS for mallry. Ms form n -
and international mail
From c.--.aa n nS..aa.. ?: --1. c-......... i
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-144008/sde TEAM C
Ter UNKNOWN SPOUSE Pustrtwork Here
18 South Locust Lane
Mechanlcsbur& PA 17050
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
!? 'h ?.-tom !?S ? II
i
POSTAL CERT OF MAILING: NOTICE TO LIEN HOLDERS
LEONARD B. ZUCKER
MICHAEL S. ACKERMAN
JOEL ACKFI MAN'
ALSO MEMBER OF NY, PA AND CA BAR
• ALSO MEMBER OF NY PA AND ME BAR
0 ALSO MEMBER OF NY AND ME BAR
A ALSO MEMBER OF NY BAR
£ ALSO MEMBER OF PA BAR
ZUCKER, GOLD ER & ACKERMAN,
LLC
ATTORNEYS AT LAW
200 SHEFFIELD STREET- SUITE 101
P.O. BOX 1024
MOUNTAINSIDE, NJ 07092-0024
TELEPHONE: 908-233-8500
FACSIMILE: 908-233-1390
E-MAIL: office@zuckergeldberg.com
For payoff/reinstatement figures
Please send your request to: zuckergoldberg. com/pr
REPLY TO NEW JERSEY ADDRESS
XFP-144008 FPhnlarv IT 2012
Matthew E. Waters Matthew E. Waters
and/or Tenant(s) known or unknown at: And/or Tenant(s) known or unknown at:
18 South Locust Lane-Unit # 18 South Locust Lane-Unit #
Mechanicsburg, PA 17050 Mechanicsburg, PA 17050
DEMAND FOk PUSSENNI1u1v ur
PROPERTY
FOUNDED IN 1923
AS ZUCKER & GOLDBERG
MAURICE J. ZUCKER 1918-1979
LOUIS D. GOLDBERG 1923-1967
LEONARD H. GOLDBERG 1929-197BENJAMIN WEISS 1,949-19811
Pennsylvania Office:
P.O. Box 650
Hershey, PA 17033
OF COUNSEL:
SCOTT A. DIETTERICK ESQ. ¥
KIMBERLY A. BONNER: ESQ. ¥
RALPH M. SALVIA, ES Q. ¥
¥ MEMBER OF PA BAR ONLY
Property Address: 18 South Locust Lane ®?®
Mechanicsburg, PA 17050
Sale Date: November 2, 2011 719 6 9008 9111 3004 0166
Dear Tenant:
On November 2, 2011, the property located at 18 South Locust Lane, Mechanicsburg, PA
17050 was sold before the Courthouse door of Cumberland County, Pennsylvania during the
legal hours of sale. You are hereby notified that possession is demanded by Wells Fargo Bank,
NA, which was the highest bidder at the sale, and now owns the property.
If you are the former owner of the property, the child, spouse, or parent of the
former owner, and you do not immediately relinquish possession, dispossessory proceedings
will be initiated in the Court of Cumberland County, PA, to evict you.
If you are a tenant of the former owner of the property, and not the child, spouse, or
parent of the former owner of the property, you may be entitled to additional rights as
provided by the Protecting Tenants at Foreclosure Act of 2009, including the right to remain in
the property for 90 days from the date of receipt of this notice, before dispossessory proceedings
are initiated against you. In order for us to determine on behalf of WELLS FARGO BANK,
N.A. what rights you may have under the Protecting Tenants at Foreclosure Act of 2009, you
must immediately forward us the following:
(a) a copy of your written lease (if an oral lease you must provide us a summary of the
terms of your oral lease, including: the term of the lease, monthly rental amount and
all other relevant lease terms);
(b) proof of your alleged monthly rental amount (proof may in the form of a copy of your
lease showing the rental mount, or, if an oral lease, copies of cancelled checks or
money orders);
"EXHIBIT C11
Zucker, Goldberg & Ackerman, LLC
Page 2
(c) proof that all monthly rental payments due under the lease have been paid to date
(proof may be in the form of copied of cancelled checks, money orders or a signed
statement from your landlord stating that you have paid your rent in full as required
by your lease);
(d) the names of all occupants of the property who are over the age of 18 years of age;
and
(e) indicate whether you are Section 8 tenant
For any questions regarding your rights as a post-foreclosure tenant, contact Gamalielle
Geffrard at (908) 233-8500 ext 375. Please note that you may wish to consult an attorney to help
you determine what rights you may have, if any, under the Protecting Tenants at Foreclosure Act
of 2009.
the Service Mew
jh',H law firm itni
ter:
eS.
7378
em,ber?a zucl?ergoidberg.com
All questions regarding the property should be addressed to the undersigned:
Very truly yours,
ZUCKER, GOLDBERG & ACKERMAN, LLC
Gamalielle Geffrard- ext. 375
I
TENANT QUESTIONNAIRE Our File #: XFP-144008
PROPERTY ADDRESS: 18 South Locust Lane, Mechanicsburg, PA 17050
YOUR NAME (Please Print Clearly):
TELEPHONE NUMBER WHERE YOU CAN BE EASILY REACHED: ( )
NUMBER OF PEOPLE LIVING WITH YOU: # ADULTS # CHILDREN
NAME OF OTHER ADULTS LIVING WITH YOU:
1. 2.
3. 4.
YOUR FLOOR/UNIT#
HOW LONG HAVE YOU LIVED AT THIS PROPERTY?
HOW MUCH DO YOU PAY MONTHLY FOR RENT?
DO YOU PAY FOR ANY UTILITIES? WATER GAS PSE&G
WHO WERE YOU PAYING YOUR RENT TO?
ARE YOU RELATED TO THE FORMER OWNER?
DO YOU HAVE HELP FROM SECTION 8 OR OTHER AGENCY TO PAY YOUR RENT?
NO YES IF YES, PLEASE PROVIDE COPY OF YOUR
SECTION 8 CONTRACT AND NAME/TELEPHONE NUMBER OF YOUR CASE WORKER.
ARE YOU INTERESTED IN RECEIVING INFORMATION ABOUT BUYING THIS HOME FROM
THE NEW OWNER? (The price of the home would be based on fair market value and the current
condition of the home).
Yes, I am interested
No, I do not want to buy.
DO YOU PLAN TO MOVE OUT WITHIN THE NEXT: (please circle one)
15 days 30 days 60 days 90 days
ARE YOU INTERESTED IN ENTERING INTO A MONTH TO MONTH LEASE AGREEMENT
WITH THE NEW OWNER? Yes No
Please check here if you have moved out
I have moved out and removed all of my personal belongings- you may take possession of my
unit.
1 moved out, but need to get back in to get the rest of my things- please contact me.
Please sign and date this form here: Dated:
200 Sheffield Street, Suite 101 t
Mountainside, NJ 07092
XFP-144008/sfa TEAM D
Y'
`t"
T° Matthew E. Waters and/or Tenant(s) known or unknown at: Postmark "ere
18 South Locust Lane
Mechanicsburg, PA 17050
County of P.Q.: CUMBERLAND
PS Fort 3817, April 2007 PSN 7530-02-000-9065
is PO
lie
pnvEV +sotares
02 1M $ 01.1r
UNITED STATES 0004282036 FE13 17 2001 2
MAILED FROM Ziprr tea`
UNITEDSTATES' ? ta0{IVBS
?{ 02 000442 282036 FEB i 7 2
AMPOSTAL RVKEs
MAILED FRO ZiP%OE 0 70 101
his Certificate of Mailing provides evitle°tx that mail has been presented to USPS®for maiiirg. This form i
and international mail. r<
Fromm: Ashleigh Levy Marin, Esquire -?
c/o Zucker, Goldberg & Ackerman, LLC
4OS P4_
ruz 1'aL
This Certificate of Milling provides evidence that mail has been presented to USPS® for mailing. This form may be used for domestic , -
and international mail.
eg
cry
Page 1 of 1
. . . M
VERIFICATION
I, ))/ )? W ?) On , 6)C:? I 't le),
depose and say subject to the penalties of 18 Pa.C.S, sec. 904G?.l'? relatmig to unstK
falsification to authorities that the facts set forth in the foregoing pleading are true and correct to
the best of my information, knowledge and belief.
By: 71pl Fargo Bank, N. %
Namte: iD./.??
Title:
MELISSA WILSON
VIce President Loan Documentation
Our File No: 144008
Borrower Name: Matthew E. Waters
?i?C?IIMg?
MAR 16 2012 1??
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
L01 Q 30 AM 11
0 '?- N 4S y
Wells Fargo Bank, N.A. Case Number
vs.
Matthew E. Waters 2012-1797
SHERIFF'S RETURN OF SERVICE
03/26/2012 05:36 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 26,
2012 at 1736 hours, he served a true copy of the within Complaint in Ejectment, upon the within named
defendant, to wit: Matthew E. Waters, by making known unto himself personally, at 18 S. Locust Lane,
Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to
him personally the said true and correct copy of the same.
SHERIFF COST: $38.00
March 28, 2012
ROB T BITNER, DEPUTY
SO ANSWERS,
RON ~ R ANDERSON, SHERIFF
c, Coun t' Sr-e-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A., CIVIL DIVISION ,C,
Plaintiff No.: 12-1797
vs. ISSUE NUMBER: >'. -71
Matthew E. Waters
TYPE OF PLEADING:
Defendant(s).
I Hereby certify that the last known address
of Defendant(s) is/are:
18 South Locust Lane, Mechanicsburg, PA
17050
Attorney for Plaintiff
PRAECIPE FOR DEFAULT JUDGMENT
(Ejectment)
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
Plaintiff
COUNSEL OF RECORD FOR THIS PARTY:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire- Pa I.D.# 55650
Kimberly A. Bonner, Esquire- Pa I.D. 489705
Joel A. Ackerman, Esquire- Pa I.D. #202729
Ashleigh L. Marin, Esquire-Pa I.D. 4306799
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
Atty File No.: XFP-144008
W*N 16A
Zucker, Goldberg & Ackerman, LLC
X F P-144008
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A. Docket No.: 12-1797
Plaintiff,
Execution No.:
vs.
Matthew E. Waters
Defendant(s).
PRAECIPE FOR DEFAULT JUDGMENT (EJECTMENT)
TO: PROTHONOTARY
SIR/MADAM:
Please enter a default judgment in the above-captioned case in favor of Plaintiff and
against Defendant(s), Matthew E. Waters, for possession of the premises known as 18 South
Locust Lane, Mechanicsburg, PA 17050.
ZUCKER, GOLDBERG & SACKERMAN, LLC
BY:
Dated: Ashleigh L. Marin, Esquire; PA I.D. 4306799
(J Attorneys for Plaintiff
XFP-144008/gg
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
Zucker, Goldberg & Ackerman, LLC
XFP-144008
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Plaintiff,
Matthew E. Waters
Defendant(s).
: Docket No.: 12-1797
Execution No.:
AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF
NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT
COMMONWEALTH OF PENNSYLVANIA
SS:
COUNTY OF CUMBERLAND
I, the undersigned attorney for the plaintiff in the above action, being duly sworn
according to law, do hereby depose and say that the statements made herein are true in and
correct to the best of my knowledge, information, and that:
1) The Defendant is not in the military service of the United States of America to the
best of my knowledge, information and belief as evidenced by the attached copies;
2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa.
R.C.P. 237:1 and that the time limits provided for that notice have expired.
ZUCKER, GOLDBERG & ACKERMAN, LLC
BY:
Dated: e? if r? ? Ashleigh L. a in, Esquire; PA I. 97 799
Attorneys for Plaintiff
XFP-144008/gg
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
Sworn to and subscribed before me
This 2 ay of 1`? l
20 %
Notary PuY#l
My Commissio xpires:
EDWARD J. SCHWAHL II
Commission k 2383239
N?ctary Public, State of New Jersey
1? My Commission Expires
March 09, 2014
Zucker. Goldberg & Ackerman, LLC
XFP-144008
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Wells Fargo Bank, N.A. Docket No.: 12-1797
Plaintiff,
vs.
Execution No.:
Matthew E. Waters
Defendant(s)
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Matthew E. Waters
18 South Locust Lane
Mechanicsburg, PA 17050
[ ] Plaintiff
[?] Defendant
[ ] Additional Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the above captioned
proceeding on S1 1 \ a
[ ] A copy of the Order or Decree is enclosed,
or
[ti'] The judgment is as follows: for possession of the premises known as 18 South
Locust Lane, Mechanicsburg, PA 17050.
'Ifr-othonot-ary
luckier. {ioldho,-, & '.ckcrman, 1.AV
?F?t'-I4-at1Cl8
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT PERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING,
COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED
AS FOLLOWS, TO WIT:
BEGINNIN AT A POINT ON THE CORNER OF LOT #93 AND A CUL-DE-SAC AT THE END OF
LOCUST LANE, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE
ALONG SAD LOT #93, SOUTH EIGHT (8) DEGREES FORTY-FOUR (44) MINUTES TWO (2)
SECONDS AST, FIFTY-ONE AND FIFTY-FIVE HUNDREDTHS (51.85) FEET TO A POINT;
THENCE ALONG LINE OF SAID LOT #93, SOUTH THIRTY-FOUR (34) DEGREES TWENTY-ONE
(21) MINUT ES NINE (9) WEST, ONE HUNDRED FORTY-NINE AND TWENTY-FOUR.
HUNDRED S (149.24) FEET TO A POINT ON THE LINE OF SILVER SPRING TOWNSHIP
PARK, AS HOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG
LINE OF SAID SILVER SPRING TOWNSHIP PARK, NORTH FIFTY-FIVE (55) DEGREES
THIRTY-EIGHT MINUTES FIFTY-ONE (51) SECONDS WEST, SIXTY-FOUR AND EIGHTY-
THREE HUNDREDTHS (64.83) TO A POINT ON THE CORNER OF LOT #91, AS SHOWN IN THE
HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID LOT #91, NORTH
FOURTEEN (14) DEGREES THIRTY-FOUR (34) MINUTES ELEVEN (11) SECONDS WEST, ONE
HUNDRED INETY AND TWENTY-THREE HUNDREDTHS (190.23) FEET TO A POINT ON THE
CORNER OP LOT #82, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS;
THENCE ALONG SAID LOT #82, NORTH FIFTY-SIX (56) DEGREES TWELVE (12) MINUTES
EAST, ONE HUNDRED FIFTY (150) FEET TO A POINT ON THE SOUTH SIDE OF LOCUST
LANE, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG
SAID LOCUST LANE, SOUTH THIRTY-THREE (33) DEGREES FORTY-EIGHT (48) MINUTES
EAST, THIRTEEN ARID FIFTY-FIVE HUNDREDTHS (13.55) FEET TO A POINT ON THE CUL-
DE-SAC IN 1A SOUTHERLY DIRECTION, ON A CURVE TO THE LEFT, HAVING A RADIUS OF
SEVENTY-DIVE (75) FEET, AN ARC ARE DISTANCE OF ONE HUNDRED FIFTY-ONE AND
TWENTY-TtMj
HUNDREDTHS (151.23) FEET TO A POINT ON THE CORNER OF LOT 093
AFORESAID, THE PLACE OF BEGINNING. CONTAINING .72 ACRES, MORE OR LESS, BEING
LOT #92 IN TILE
SUBDIVISION PLAN OF WHITE BIRCH FARMS, SECTIONS I AND 2, AS SHOWN IN THE PLAN
BOOK 44, PAGE 91, AND RECORDED IN THE CUMBERLAND COUNTY RECORDERS OFF ICE.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED
AS 18 SOUTH LOCUST LANE, MECHANICSBURG, PA, 17050.
SING THE SAME PREMISES WHICH JOSHUA D. MASSIE AND NICOLE L. MASSIE,
HUSBAND D WIFE, BY DEED DATED JUNE 14, 2007 AND RECORDED JUNE 15, 2007 IN
AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 280, PAGE
2431, GRANTED AND CONVEYED UNTO MATTHEW E, WATERS.
TAX MAP NO.: 38-I5-1275-047.
/.uckor. (ialdhcrg Lk AeLcnitui. I.f.('
XV1'•144(ft
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
IV at ic:nbrr114p
?12SAI .}
OFFICE OF THE SHERIFF
I 4?Fco$
Wells Fargo Bank', N.A.
vs. Case Number
2012-1797
Matthew E. Waters
SHERIFF'S RETURN OF SERVICE
03126/2012 05:36 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 26,
2012 at 1736 hours, he served a true copy of the within Complaint in Ejectment, upon the within named
defendant, to wit: Matthew E. Waters, by making known unto himself personally, at 18 S. Locust Lane,
Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to
him personally the said true and correct copy of the same.
SHERIFF COST: $38.00
March 28, 2012
ROB RT BITNER, DEPUTY
SO ANSWERS,
4z W"1afz--1
RON R ANDERSON, SHERIFF
(c} CountySuite Shenff, Telaosoft, Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Matthew E. Waters
Plaintiff,
Defendant.
CIVIL DIVISION
NO.: 12-1797
IMPORTANT NOTICE
TO
Matthew E. Waters
18 South Locust Lane
Mechanicsburg, PA 17050
DATE OF NOTICE: 4/19/2012
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 again you. Unless
you act within e'en (10) 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
notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone
the following office to find out where you can get legal Help.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 9901-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Matthew E. Waters
TO:
Plaintiff,
Defendant.
Matthew E. Waters
18 South Locust Lane
Mechanicsburg, PA 17050
CIVIL DIVISION
NO.: 12-1797
AV!SOI VIFCiRTAlV'IE
FECHA DIEL AVISO:4/19/2012
I];"= =A EN RFP 4 E Lk PC E li?L FALLADO IM TCAIAR LA ACCKTC
ENT EgM CASSO A I1 L E=, 'ILDvF- ACICICN I II I:F
LCD PRqMMDG DEEZ (KC E V S ICE LA FECHA DE EgIE A-%M SSE PLEEEr I:ICTAR
UNFAILEDENCt INTIRASUVA SINLLEVAR-'EA[" OUNAMSrAYL1S=FUE E
PII SU PPCFEEEAD Y C9RCS E?? R ANIES tl!=
I I --VAR ES= D00LM3gM Il ATA 413vT E A SU A.B0Cv1JDQ SI L)S= NC
TIENIE 1<N AEOCADO O NO PCEI:E PAGAR LNQ VAYA O r r ANEF LA CHCr4A
A13AJO k,11CADA PARA QLFl- LE P4KFOvEN DC PLEDE ClMsNH:?ILM AY[
Tom. 4 .
NIMCE+ TODI+ CII D &I-ANVVM T SUMCE
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
ZUCEER, GDLDEERG&AC I
By-- S+=A. ?idtaick
Soott A Dietteridi, EsgLire
Attomeys far Fi aLnhff
PAID. # 55650
200 Sheffield Street, Suite 301
F.O. 13cpc 1024
Mo utani l ide, NT 07092-0024
(717) 533-3560
FIRST CMASS U S_ MAIL, POSTAGE FR'EPAID
144008
Results as of: May-17-2012 10:31:33
Department of Defense Manpower Data Center
SCRA 2.1
. is uant to micemcmbll= Civil Relief Act
Last Name: WATERS First Name: MATTHEW Active Duty Status Date May-17-2012
Activ Duty End Date Status Service Component
On Active Duty On Active Duty Status Date
NA No NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date
NA No NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NCAA, Public Health, and
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
rte, r?.
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
2
W2
WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.)
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.
VS.
MATTHEW E. WATERS
18 South Locust Lane
Mechanicsburg, PA 17050
Attorney's
Plaintiff's
Prothonotary
No. 12-1797 Civil Term-
$ 186.75
$ 2.25
Costs
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND:
To the Sheriff of Cumberland County, Pennsylvania
(1) To satisfy the judgment for possession in the above matter you are directed to deliver
possession of the following described property to: (Plaintiff (s))
WELLS FARGO BANK, N.A.
being: (Premises as follows):
18 South Locust Lane, Mechanicsburg, PA 17050
(2) To satisfy the costs against the defendant (s) you are directed to levy upon any
property of the defendant (s) and sell his/her (or their) interest therein.
kdl
David D. Buell, Prothonotary,
Common Pleas Court of Cumberland County, PA
Date 512 12
(Seal)
2 of 2
No 12-1797 Civil Term
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.
MATTHEW E. WATERS
vs.
WRIT OF POSSESSION
P.R.C.P. 3160-3165 ETC.
Costs
Att'y $ 186.75
Plff (s) $
Prothy $ 2.25
Sheriff $
Plaintiff (s) attorney name and address:
ASHLEIGH L. MAR1N, ESQUIRE - ID#306799
ZUCKER, GOLDBERG & ACKERMAN, LLC
200 SHEFFIELD STREET, SUITE 101
MOUNTAINSIDE, NJ 07092
908-233-8500
Attorney for Plaintiff (s)
By virtue of this writ, on the
named
appurtenances, and
Sworn and subscribed to before me this
Day of
Prothonotary
Where papers may be served
day of . I caused the within
to have possession of the premises described with the
So Answers,
Sheriff
By
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
f
Jr
tcLifdD COU
Wells Fargo Bank, N.A. Docket No.: 12-1797 _ViWS`? yat???
Plaintiff,
Execution No.:
vs.
Matthew E. Waters
Defendant(s).
PRAECIPE FOR WRIT OF POSSESSION
To the Prothonotary of Cumberland County:
Please issue a Writ of Possession in the above-referenced matter for Plaintiffs possession
of the real property known and numbered as 18 South Locust Lane, Mechanicsburg, PA 17050
and more particularly described on Exhibit "A" attached hereto.
ZUCK,?_?„GOLDBERG & ACKERMAN, LLC
11
BY: ? j V V1 r f
U q A\-
-Dated: May , 12012 ,
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 L
Esquire; PA I
#306799
Marin
D
.
.
,
.
? a Ralph M. Salvia, Esquire; PA I.D. #202946
o?
3$ • C9F Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
Q 3. S it it XFP-144008/gg
? 200 Sheffield Street, Suite 101
Mountainside, NJ 07092
a (908) 233-8500; (908) 233-1390 FAX
g -? 5
4 ' Email: Office@zuckergoldberg.com
W .
,.,S
Zucker, Goldberg & Ackerman, LLC
X F P-144008
97S -7 V)j t'? 6? ?, , Jitw,/
Docket No.
12-1797
Wells Fargo Bank, N.A.
Plaintiff
vs.
Matthew E. Waters
Defendant(s)
Where papers may be served: 18 South Locust Lane Mechanicsburg, PA 17050
Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
908-233-8500
Zucker, Goldberg & Ackerman, LLC
XFP-144008
Exhibit "A"
LEGAL DESCRIPTION
ALL THAT'CERTAIN TRACT OF LAND SITUATE IN THE TOWNSHIP OF SILVER SPRING,
COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED AND DESCRIBED
AS FOLLOWS, TO WIT:
BEGINNING AT A POINT ON THE CORNER OF LOT #93 AND A CUL-DE-SAC AT THE END OF
LOCUST LANE, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE
ALONG SAID LOT #93, SOUTH EIGHT (8) DEGREES FORTY-FOUR (44) MINUTES TWO (2)
SECONDS EAST, FIFTY-ONE AND FIFTY-FIVE HUNDREDTHS (51.85) FEET TO A POINT;
THENCE ALONG LINE OF SAID LOT #93, SOUTH THIRTY-FOUR (34) DEGREES TWENTY-ONE
(21) MINUTES NINE (9) WEST, ONE HUNDRED FORTY-NINE AND TWENTY-FOUR.
HUNDREDTHS (149.24) FEET TO A POINT ON THE LINE OF SILVER SPRING TOWNSHIP
PARK, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG
LINE OF SAID SILVER SPRING TOWNSHIP DARK, NORTH FIFTY-FIVE (55) DEGREES
THIRTY-EIGHT MINUTES FIFTY-ONE (51) SECONDS WEST, SIXTY-FOUR AND EIGHTY-
THREE HUNDREDTHS (64.83) TO A POINT ON THE CORNER OF LOT #91, AS SHOWN IN THE
HEREINAF'T'ER MENTIONED PLAN OF LOTS; THENCE ALONG SAID LOT #91, NORTH
FOURTEEN (14) DEGREES THIRTY-FOUR (34) MINUTES ELEVEN (11) SECONDS WEST, ONE
HUNDRED (NINETY AND TWENTY-THREE HUNDREDTHS (190.23) FEET TO A POINT ON THE
CORNER OF LOT 482, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS;
THENCE ALONG SAID LOT #82, NORTH FIFTY-SIX (56) DEGREES TWELVE (12) MINUTES
EAST, ONE', HUNDRED FIFTY (150) FEET TO A POINT ON THE SOUTH SIDE OF LOCUST
LANE, AS SHOWN IN THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG
SAID LOCUST LANE, SOUTH THIRTY-THREE (33) DEGREES FORTY-EIGHT (48) MINUTES
EAST, THIRTEEN ARID FIFTY-FIVE HUNDREDTHS (I3.55) FEET TO A POINT ON THE CUL-
DE-SAC IN A SOUTHERLY DIRECTION, ON A CURVE TO THE LEFT, HAVING A RADIUS OF
SEVENTY-DIVE (75) FEET, AN ARC ARE DISTANCE OF ONE HUNDRED FIFTY-ONE AND
TWENTY-THREE HUNDREDTHS (15I.23) FEET TO A POINT ON THE CORNER OF LOT #93
AFORESAID, THE PLACE OF BEGINNING. CONTAINING.72 ACRES, MORE OR LESS, BEING
LOT 492 IN TILE
SUBDIVISION PLAN OF WHITE BIRCH FARMS, SECTIONS 1 AND 2, AS SHOWN IN THE PLAN
BOOK 44, PAGE 91, AND RECORDED IN THE CUMBERLAND COUNTY RECORDERS OFF ICE.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED
AS 18 SOUTH LOCUST LANE, MECHANICSBURG, PA, 17050.
BEING THE SAME PREMISES WHICH JOSHUA D. MASSIE AND NICOLE L. MASSIE,
HUSBAND AND WIFE, BY DEED DATED JUNE 14, 2007 AND RECORDED JUNE 15, 2007 IN
AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED HOOK VOLUME 280, PAGE
2431, GRANTED AND CONVEYED UNTO MATTHEW E, WATERS.
TAX MAP NO.: 38-15-1275-047.
7.uckur. Goldberg S@ Aacnimi. i.I.C
XV11-1 4 41108
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
#,?trtitr Qt 41c1146"t,,Q??d
OF P CE OF THE S ? E RIFF
FILED-OFFICE
O; THE PROTWROTAily
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
2912 JUN 27 PM 12: Q8
CUMAND COF9NiY
PE* STLWANtA
Wells Fargo Bank, N.A. i
vs.
Matthew E. Waters
Case Number
2012-1797
SHERIFF'S RETURN OF SERVICE
06/27/2012 02:35 PM - Mark Conklin, Deputy Sheriff, being duly sworn according to law, states that on June 26, 2012
at 1435 hours, he served the requested Writ of Possession by "personally" handing a true and attested
copy to a person representing themselves to be the Defendant, to wit:Matthew E. Waters at the
Cumberland County Sheriffs Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, PA
17013, and informed Defendant of contents of same. Defendant was advised he has 10 days to vacate
the premises.
SHERIFF COST: $70.25
June 27, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
Ili countys.1ite Sh;2nrt. TE! OSOft. nC.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
? R Anderson `_ 1:1
riff T
, r
,,,.,.?i Q
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
U J111 17 JUL I I AN 8: 14
CUMBERLAND COON-F',
PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Matthew E. Waters
Case Number
2012-1797
SHERIFF'S RETURN OF SERVICE
06/27/2012 02:35 PM - Mark Conklin, Deputy Sheriff, being duly sworn according to law, states that on June 26, 2012
at 1435 hours, he served the requested Writ of Possession by "personally" handing a true and attested
copy to a person representing themselves to be the Defendant, to wit:Matthew E. Waters at the
Cumberland County Sheriff's Office, 1 Courthouse Square, Room 303, Carlisle, Cumberland County, PA
17013, and informed Defendant of contents of same. Defendant was advised he has 10 days to vacate
the premises.
07/09/2012 By virtue of this writ, Sheriff Ronny R. Anderson caused the within named Plaintiff to have possession of
the premises described as 18 S Locust Lane, Silver Spring Township, Mechanicsburg, Cumberland
County, PA 17050.
SHERIFF COST: $112.92 SO ANSWERS,
July 10, 2012 RON R ANDERSON, SHERIFF
4k --.,f s--?ssr