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Home My WebLink About12-1983f a 1, ll? ! H`??40 (At'. 1'. PHELAN HALLINAN & SCHMIEG, LLP Robert W. Cusick, Esq., Id. No.80193 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff V. STACY R. HART ROBERT A. HART 57 WOODMYRE LANE ENOLA, PA 17025-1552 Defendants 12 AR23 Ai'l10:GT, I'fa 'iLLi?LA?? 0 tC?O±UNT`? i %_IINJ 3 LYAN14 293694 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. ao (a- l 9 8 3 ?iv ?t CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 293694 are! 1168,7:5 pa Ck-N Ii?aas2 ?( R ?- a? 3a?a 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 4: 293694 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: STACY R. HART ROBERT A. HART 57 WOODMYRE LANE ENOLA, PA 17025-1552 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 10/30/2003 STACY R. HART and ROBERT A. HART made, executed and delivered a mortgage upon the premises hereinafter described to THE WASHINGTON SAVINGS BANK, FSB which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book 1843, Page 4577. By Assignment of Mortgage recorded 01/12/2007 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book 733, Page 2611.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(8); 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 09/01/2011 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 293694 6. The following amounts are due on the mortgage as of 03/07/2012: Principal Balance $125,207.64 Interest $4,036.44 08/01/2011 through 03/07/2012 Late Charges $86.28 Property Inspections $55.00 Escrow Deficit $240.54 Suspense Balance Credit ($745.00) TOTAL $128,880.90 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 $128,880.90, 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. & SCHMIEG, LLP By: RobertCusicl Attorney for Plaintiff File #: 293694 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situated in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania more particularly bounded and described as follow, to wit: BEGINNING at a point on the western dedicated right-of-way line of Woodmyre Lane at the dividing line of Lot #T-33 and Lot #T-32; thence by line of Lot #T-33 and passing through the center of a partition wall South seventy-seven degrees nineteen minutes thirty-seven seconds West (S 77 degrees 19 minutes 37 seconds W), one hundred twelve and seventy-four hundredths (112.74) feet to a point; thence by line of lands of Westwood Village due North twenty and forty- nine hundredths (20.49) feet to a point at the dividing line of Lot #T-31 and Lot #T-32; thence by line of Lot #T-31 and passing through the centerline of a partition wall North seventy-seven degrees nineteen minutes thirty-seven seconds East (N 77 degrees 19 minutes 37 seconds E), one hundred seventeen and fifty-four hundredths (117.54) feet to a point on the western right-of-way line of Wood.myre Lane; thence by said right-of-way line South thirteen degrees fifty-four minutes forty-one seconds East (S 13 degrees 54 minutes 41 seconds E), eleven and zero hundredths (11.00) feet to a concrete monument; thence by same by a curve to the left having a radius of one hundred fifty and zero hundredths (150.00) feet and an arc length of nine and two hundredths (9.02) feet, said curve also having a chord bearing and distance of South fifteen degrees thirty-eight minutes three seconds East (S 15 degrees 38 minutes 03 seconds E), nine and two hundredths (9.02) feet to a point at the dividing line of Lot 4T-33 and Lot #T-32, the place of BEGINNING. File #? 293694 BEING Lot #T-32 on the Final Subdivision Plan for Westwood Hills, Phase III, recorded in Plan Book 81, Page 54. SUBJECT to a 25 foot wide Drainage and Pedestrian Easement as shown on the above mentioned subdivision plan. SUBJECT to other conditions and restrictions as set forth on the above mentioned plan. PROPERTY ADDRESS: 57 WOODMYRE LANE, ENOLA, PA 17025-1552 PARCEL # 09-12-2992-195 File #: 293694 VERIFICATION Brent Alban, hereby states tha he/ he is Vice President Loan Documentation of WELLS F ARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter, tha het he is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of?s// 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: _? 22 Z? l 2 -- Title: Vice President Loan Documentation 032-PA-V3 File #: 293694 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4'50'jr Oat ?,in!;frf4 4 rr Or-T AK I' Jody S Smith Chief Deputy Richard W Stewart Solicitor 2012 APR 17 AM 9: 25 C,F. C ANA COUNTY SYlVAH1A Wells Fargo Bank, N.A. vs. Stacy R. Hart (et al.) Case Number 2012-1983 SHERIFF'S RETURN OF SERVICE 04/03/2012 05:44 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 3, 2012 at 1744 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Stacy R. Hart, by making known unto herself personally, at 57 Woodmyre Lane, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. RONALD HOOVER, DEPUTY 10 04/03/2012 05:44 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on April 3, 2012 at 1744 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Robert A. Hart, by making known unto Stacy R. Hart, Wife of Defendant at 57 Woodmyre Lane, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $59.00 April 10, 2012 RONALD HOOVER, DEPUTY SO ANSWERS, 1 RON R ANDERSON, SHERIFF '.?, j U?, t 3'V ? l i?:3 i i?a:• ' PHELAN HALLINAN & SCHMIEG', `LLP ,_ , Attorney for Plaintiff r Matthew Brushwood, Esq., Id. No.3101' -J 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. VS. STACY R. HART ROBERT A. HART ?i,', oEEnLAI@ COU111.,, JAb1A `iF1SYl CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION No. 2012-1983-CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against STACY R. HART, and ROBERT A. HART, 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 $128,880.90 $128,880.90 I hereby certify that (1) the Defendants' last known address is 57 WOODMYRE LANE, ENOLA, PA 17025-1552, and (2) that notice has been given in accore with Rule Pa.R.C.P 237.1. Date M hew ru ood, Esquire Attorney or Plaintiff a,,k % L'k-?? 57 ?3 DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 's on- PHS # 293694 PROTHONOTARY 293694 PHELAN HALLINAN & SCHMIEG, LLP Matthew Brushwood, Esq., Id. No.310592 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS VS. STACY R. HART ROBERT A. HART : CIVIL DIVISION : No. 2012-1983-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 following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant STACY R. HART is over 18 years of age and the defendant's last known address is 57 WOODMYRE LANE, ENOLA, PA 17025-1552. (c) that defendant ROBERT A. HART is over 18 years of age and the defendant's last known address is 57 WOODMYRE LANE, ENOLA, PA 17025-1552. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date ood, Esquire J MM ew 01?aintiff C Attorney 293694 (Rule of Civil Procedure No. 236) - Revised WELLS FARGO BANK, N.A. CUMBERLAND COUNTY VS. COURT OF COMMON PLEAS STACY R. HART ROBERT A. HART CIVIL DIVISION No. 2012-1983-CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on o <' . c3t4 By: 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 FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLY ENFORCEMENT OFA LIENAGAINST PROPERTY. ** 293694 STACY R. HART 57 WOODMYRE LANE ENOILA, PA 17025-1552 WELLS FARGO BANK, N.A. V, STACY R. HART ROBERT A. HART Plaintiff Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 2012-1983-CIVIL CUMBERLAND COUNTY TO: STACY R. HART 57 WOODMYRE LANE ENOLA, PA 17025-1552 DATE OF NO'T'ICE: 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) 2` 9-3166 By: hary Jones c? ' e Attorney for Plaintiff Phelan Hallinan & Schtnieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 pHS # 293694 ROBERT A. HART 57 WOODMYRE LANE ENOLA, PA 17025-1552 WELLS FARGO BANK, N.A.. V. Plaintiff STACY R. IIART ROBERT A. HART Defendant(s) TO: ROBERT A. HART 57 WOODMYRE LANE ENOLA, PA 17025-1552 DATE OF NOTICE: COURT OF COMMON PLEAS CIVIL DIVISION NO. 2012-1983-CIVIL 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 I Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE, 2 LIBERTY AVENUE CARLISLE, PA 17013 (7 7)249-3166 B y; nary Janes sire Attorney for aintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 293694 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-1983 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A. Plaintiff (s) From STACY R. HART, ROBERT A. HART (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: $128,880.90 L.L.: $.50 Interest FROM 5/26/2012 TO DATE OF SALE ($21.19 PER DIEM) - $4,110.86 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $210.25 Other Costs: Plaintiff Paid: Date: B/15/2012 '-~ ~'`~ ""1 David D. Buell, Prothonot (Seal) Deputy REQUESTING PARTY: Name: JOHN MICHAEL KOLESNIK, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 308877 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 WELLS FARGO BANK, N.A. Plaintiff COURT OF PLEAS CIVIL DIVISION v STACY R. HART ROBERT A. HART Defendant(s) To the Prothonotary: NO.. CUMBERLAND UNTY Issue writ of execution in the above matter: Amount Due Interest from 05/26/2012 to Date of Sale ($21.19 per diem) TOTAL $128,880.90 4 110.86 c"s ~ ro N". ~ ~ 9. t-' `n G~" t.n $132,991.76 ~o s~ ~t'~ ~ 1" O ~~ x .. Phel allinan & Schmieg, LLP -i -t d '~ J Michael Kolesnik, Esq., Id. No.308877 ttornev for Plaintiff --.; ~~ ~~ ~~ Z~ art,-; "~ Note: Please attach description of property. PHS # 293694 U Q~~~a4.5d~d o 59. oo C.B~ )D3. ~ S u'• ~4 . So « u a . s~ ~~ " s a 10.95 tea. as ~e ~. ~, . so~- Ck~ lats3~ ~~~, a 3 ss (~r;l ~J ~f SS'uCc~ v c0 ~ u] N z~ (,7~ N z~ a~ ~-a~, ~ H N _7 O Phi N ~ O ¢ ~ 3 ~ ~ a ¢ Q a E- ~o.¢.a wo.¢.a b ¢3o co3o -~ ~~z o~z ~ O ~ a a ~z' a• v w z O w a z w ~H x 00 ~ °~ `' F" ~, ~ ~ rte. '" O H ~ ~ ~ C7 ~ ~ ~ 0 ~ o4 .b ~ c ~ d ~ ,. ~" L O ~ w W o ~~ ~ 1 W a '~'~ ~ ~ w w V 3 > ~ a a w 0 M a ° z ~b ~~ s w ~ o .~. ~xa ~~~° s a LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situated in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania more particularly bounded and described as follow, to wit: BEGINNING at a point on the western dedicated right-of--way line of Woodmyre Lane at the dividing lin of Lot #T-33 and Lot #T-32; thence by line of Lot #T-33 and passing through the center of a partition wall South seventy-seven degrees nineteen minutes thirty-seven seconds West (S 77 degrees 19 minutes 37 seconds W), one hundred twelve and seventy-four hundredths (112.74) feet to a point; thence by line of 1 nds of Westwood Village due North twenty and forty-nine hundredths (20.49) feet to a point at the dividing 1' e of Lot #T-31 and Lot #T-32; thence by line of Lot #T-31 and passing through the centerline of a partition wall North seventy-seven degrees nineteen minutes thirty-seven seconds East (N 77 degrees 19 minutes 3 seconds E), one hundred seventeen and fifty-four hundredths (117.54) feet to a point on the western right way line of Woodmyre Lane; thence by said right-of--way line South thirteen degrees fifty-four minutes fc one seconds East (S 13 degrees 54 minutes 41 seconds E), eleven and zero hundredths (11.00) feet to a concrete monument; thence by same by a curve to the left having a radius of one hundred fifty and zero hundredths (150.00) feet and an arc length of nine and two hundredths (9.02) feet, said curve also having chord bearing and distance of South fifteen degrees thirty-eight minutes three seconds East (S 15 degrees minutes 03 seconds E), nine and two hundredths (9.02) feet to a point at the dividing line of Lot #T-33 an~ Lot #T-32, the place of BEGINNING. BEING Lot #T-32 on the Final Subdivision Plan for Westwood Hills, Phase III, recorded in Plan Book 8 Page 54. SUBJECT to a 25 foot wide Drainage and Pedestrian Easement as shown on the above mentioned subdivision plan. SUBJECT to other conditions and restrictions as set forth on the above mentioned plan. TITLE TO SAID PREMISES IS VESTED IN Robert A. Hart and Stacy R. Hart, h/w, by Deed from Village Homes at Westwood Glen, Inc., a Pennsylvania Corporation, dated 10/30/2003, recorded 11/05/2003 in Book 260, Page 1106. PREMISES BEING: 57 WOODMYRE LANE, ENOLA, PA 17025-1552 PARCEL N0.09-12-2992-195 PHELAN HALLINAN & SCHMIEG, LLP John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 ~ ~ ~ ~ ~ _ ~ ~: ~- ~ One Penn Center Plaza ~~ F~~fi~ ~RO~HONOTAt ,' Philadelphia, PA 19103 215-563-7000 ZC1~Z Af~~ E ~ Q~ ~ t ~ ~~ WELLS FARGO BANK, N.A. Plaintiff v. STAGY R. HART ROBERT A. HART Defendant(s) ~!1 i~RLAND CQlJMTY ~~INSYLVANIA CERTIFICATION Attorneys for Plaintiff COURT OF COM CIVIL DIVISION N0.:2012-1983-C: CUMBERLAND t 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: (X) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant ` ( ) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn i authorities. By: PLEAS 3 to Phe Hallinan & Schmieg, LLP J Michael Kolesnik, Esq., Id. No.308877 ttorney for Plaintiff r' WELLS FARGO BANK, N.A. Plaintiff `.~~~_~~-l.l~ ~~~ ~~~ ~~arNOra~r~~ v. 2G12 AUG I S AM l f ~ 05 STACY R. HART ~~M~Q~~LAND GQUNTY • ROBERT A. HART ENNSYLVAN(A • Defendant(s) COURT OF COMM01~1 PLEAS CIVIL DIVISION NO.: 2012-1983-CIVIL CUMBERLAND CO PHS # 293694 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 57 WOODMYRE LAN , ENOLA, PA 17025-1552. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) STACY R. HART 57 WOODMYRE LANE ENOLA, PA 17025-1552 ROBERT A. HART 57 WOODMYRE LANE ENOLA, PA 17025-1552 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 a sold: Name Address (if address cannot be reasonably ascertained, please indicate) Pride Acquisitions, LLC 100 Herricks Road Suite 200 Mineola, NY 11501 PRIDE AQUISITIONS, LLC C/O FRANCIS X. 804 WEST AVENUE GRIMES, ESQ. JENKINTOWN, PA 19046 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) PSECU P.O. Box 67013 Harrisburg, PA 17106-7013 PSECU C/O UNITED GENERAL TITLE INS. 27 INWOOD RD FISERV ROCKY HILL, CT 06067 Secretary of Housing and Urban Development 451 Seventh Street Southwest Washington, DC 20410 SECRETARY OF HOUSING AND URBAN 3476 STATEVIEW BLVD DEVELOPMENT C/O WELLS FARGO HOME MAC #X7801-03K MORTGAGE ATTN: KELLY LEAKE FORT MILL, SC 29715 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) EAST PENNSBORO TOWNSHIP 13 DULLES DR E CAMP HILL, PA 17011-1108 6. Name and address of every other person who has any record interest in the property and whose interest may be sale. Name Address (if address cannot be reasonably ascertained, please indicate) VILLAGE HOMES AT WESTWOOD GLEN, 1190 DILLERVILLE RD INC. LANCASTER, PA 17601 VILLAGE HOMES AT WESTWOOD GLEN, 114 FOXSHIRE DR INC. C/O ROBERT BOWMAN LANCASTER, PA 17601-36 VILLAGE HOMES AT WESTWOOD GLEN, INC. VILLAGE HOMES AT WESTWOOD GLEN, INC. VILLAGE HOMES AT WESTWOOD GLEN, INC. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) 614 BRISBAIN LN ENOLA, PA 17025-1553 658 BRISBAIN LN ENOLA, PA 17025-1553 605 BRISBAIN LN ENOLA, PA 17025-1557 TENANT/OCCUPANT 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 by the which may 57 WOODMYRE LANE ENOLA, PA 17025-1552 l3 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 Boz 11754 Harrisburg, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my persona 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 unsworn falsification to authoyi~gA ~, Date: ~'L By: ~Illnan & Schmieg, LLP hael Kolesnik, Esq., Id. No.308877 for Plaintiff ~-'WELLS FARGO BANK, N.A. i= ~~~ ~~ ~ ~~ .~~~ Tf~E PRO~fiONDTAi~'( STAGY R. HART ROBERT A. HART 2012 AUG 15 AM i i ~ G S vs. C~lM6ERLAND COUNtY PENNSYLVANIA N0.:2012-1983-CIVIL CUMBERLAND CO Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: STAGY R. HART ROBERT A. HART 57 WOODMYRE LANE ENOLA, PA 17025-1552 * *THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY WFORMATION O TAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN B UPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT NLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 57 WOODMYRE LANE, ENOLA, PA 17025-1552 is scheduled to sold at the Sheriffs Sale on 12/05/2012 at 10:00 AM in the Cumberland County Courthouse, South Hanove Street, Carlisle, PA 17013 to enforce the court judgment of $128,880.90 obtained by WELLS FARGO B N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said ale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, cost and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 zl 30. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the if the judgment was improperly entered. You may also ask the Court to postpone the sale for good c 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.) EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. COURT OF COMMON FLEAS Plaintiff CIVIL DIVISION 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find ~ut 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 cdmpazed 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 but if this has happened, you may ca11215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the prope~y 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 shaze of the money which was paid for your house. A proposed schedule f distribution of the money bid for your house will be prepazed by the Sheriff not later than thirty (30) d ys after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection i his office. This schedule will state who will be receiving that money. The money will be paid out in acc rdance with this schedule unless exceptions (reasons why the proposed distribution is wrong) aze filed with th 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 after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA E 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 N0.2012-1983-CIVIL WELLS FARGO BANK, N.A. vs. STACY R. HART ROBERT A. HART owner(s) of property situate in the EAST PENNSBORO TOWNSHIP, Cumberland County, Pennsylvania, being (Municipality) 57 WOODMYRE LANE, ENOLA, PA 17025-1552 Parcel No. 09-12-2992-195 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $128,880.90 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevazd, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situated in East Pennsboro Township, Cumberland County, Commonwealth of Pennsylvania more particulazly bounded and described as follow, to wit: BEGINNING at a point on the western dedicated right-of--way line of Woodmyre Lane at the dividing line Lot #T-33 and Lot #T-32; thence by line of Lot #T-33 and passing through the center of a partition wall South seventy-seven degrees nineteen minutes thirty-seven seconds West (S 77 degrees 19 minutes 37 seconds W), one hundred twelve and seventy-four hundredths (112.74) feet to a point; thence by line of lan of Westwood Village due North twenty and forty-nine hundredths (20.49) feet to a point at the dividing ling of Lot #T-31 and Lot #T-32; thence by line of Lot #T-31 and passing through the centerline of a partition wall North seventy-seven degrees nineteen minutes thirty-seven seconds East (N 77 degrees 19 minutes 37 seconds E), one hundred seventeen and fifty-four hundredths (117.54) feet to a point on the western right-o way line of Woodmyre Lane; thence by said right-of--way line South thirteen degrees fifty-four minutes for one seconds East (S 13 degrees 54 minutes 41 seconds E), eleven and zero hundredths (11.00) feet to a concrete monument; thence by same by a curve to the left having a radius of one hundred fifty and zero hundredths (150.00) feet and an arc length of nine and two hundredths (9.02) feet, said curve also having a chord bearing and distance of South fifteen degrees thirty-eight minutes three seconds East (S 15 degrees 3 minutes 03 seconds E), nine and two hundredths (9.02) feet to a point at the dividing line of Lot #T-33 and Lot #T-32, the place of BEGINNING. BEING Lot #T-32 on the Final Subdivision Plan for Westwood Hills, Phase IIl, recorded in Plan Book 81, Page 54. SUBJECT to a 25 foot wide Drainage and Pedestrian Easement as shown on the above mentioned subdivision plan. SUBJECT to other conditions and restrictions as set forth on the above mentioned plan. TITLE TO SAID PREMISES IS VESTED IN Robert A. Hart and Stacy R. Hart, h/w, by Deed from Village Homes at Westwood Glen, Inc., a Pennsylvania Corporation, dated 10/30/2003, recorded 11/05/2003 in Book 260, Page 1106. PREMISES BEING: 57 WOODMYRE LANE, ENOLA, PA 17025-1552 PARCEL NO.09-12-2992-195 PHELAN HALLINAN & SCHMIEG, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 191.03 215-563-7000 Attorney for Plaintiff ~ ~~ . _:. `.7 ~ ' ,,~ T ~ »~ _r~ . ,,... fi..- ,, - ,_ ~`x.1 L~,' _ ~1 ~^ ( 1 °' . ~;~~ ~ _ ~ r ~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CUMBERLAND COUNTY Plaintiff, v. STAGY R. HART ROBERT A. HART Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION No.:2012-1983-CIVIL AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) 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 Certifi~~l-~i}~eturn Receipt stamped by the U.S. Postal Service is attached hereto Exh' . ison uire Attorney for Plain ~ f Date: 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 # 293694 M M ~. t F I ~~ I I'~ I I ~I 81 ~ ~ ~ ~ !, . ~1. <~ ~: ~~ `$ b. ' ~+ ; w, a v ~, x ,~ ~~ ., *. t ~ ~ , SHERIFF'S OFFICE OF CUMBERLAND COUNTY { Ronny R Anderson C r I f,14 0 T it CN` k, Sheriff ��g t+'at ltafhrr/.�� Jody S Smith - 4, 2013 APR —2 AM IO: 5 Chief Deputy Al CUMBERLM40 COU14 i Richard W Stewart Solicitor OFFXE OF THE s�ERJF; P ENNS Y LVA M A Wells Fargo Bank, N.A. Case Number vs. Stacy R. Hart{et al.} 2012-1983 SHERIFF'S RETURN OF SERVICE 09/27/2012 04:28 PM -Deputy Shawn Gutshall, being duly sworn according to law,states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description,and Sale Handbill in the above titled action, upon the property located at 57 Woodmyre Lane, East Pennsboro Township, Enola, PA 17025, Cumberland County. 10/02/2012 08:00 PM-Deputy Shawn Gutshall, being duly sworn according to law,served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be STACY R HART-WIFE, who accepted as"Adult Person in Charge"for Robert A. Hart at 57 Woodmyre Lane, East Pennsboro Township, Enola, PA 17025, Cumberland County, 10/02/2012 08:00 PM-Deputy Shawn Gutshall, being duly sworn according to law,served the requested Real Estate Writ, Notice and Description,in the above titled action,by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant,to wit: j Stacy R. Hart at 57 Woodmyre Lane, East Pennsboro Township, Enola, PA 17025, Cumberland County. 11/28/2012 As directed by Daniel Schmieg,Attorney for the Plaintiff, Sheriffs Sale Continued to 3/6/2013 02/21/2013 As directed by Daniel Schmieg,Attorney for the Plaintiff, Sheriffs Sale Continued to 4/3/2013 03/28/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned"stayed", per letter of instruction from Attorney. SHERIFF COST: $863.84 SO ANSWERS, March 28, 2013 RbNW R ANDERSON, SHERIFF (c}CeurtySuite Shentd,Teleosoft ' c. 'WELLS FARGO BANK,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. NO.: 2012-1983-CIVIL STACY R. HART ROBERT A. HART Defendant(s) CUMBERLAND COUNTY PHS#293694 AFFIDAVIT PURSUANT TO RULE 3129.1 . , theatc the PraeE�ipe for the Writ of Execution was filed,the following information concerning the real property located at 57 WOODMYRE LANE,ENOLA, PA 17025-1552. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained,please so indicate) STACY R.HART 57 WOODMYRE LANE ENOLA,PA 17025-1552 ROBERT A.HART 57 WOODMYRE LANE ENOLA,PA 17025-1552 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) Pride Acquisitions,LLC 100 Herricks Road Suite 200 Mineola,NY 11501 PRIDE AQUISITIONS,LLC C/O FRANCIS X. 804 WEST AVENUE GRIMES,ESQ. JENKINTOWN,PA 19046 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) Harrisburg,PA 17106-7013 PSECU C/O UNITED GENERAL TITLE INS. 27 INWOOD RD FISERV ROCKY HILL,CT 06067 Secretary of Housing and Urban Development 451 Seventh Street Southwest Washington,DC 20410 SECRETARY OF HOUSING AND URBAN 3476 STATEVIEW BLVD DEVELOPMENT C/O WELLS FARGO HOME MAC#X7801-03K MORTGAGE'ATTN:'KELLY LEAKE FORT MILL,SC 29715 f 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) EAST PENNSBORO TOWNSHIP 13 DULLES DR E CAMP HILL,PA 17011-1108 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) VILLAGE HOMES AT WESTWOOD GLEN, 1190 DILLERVILLE RD INC. LANCASTER,PA 17601 VILLAGE HOMES AT WESTWOOD GLEN, 114 FOXSHIRE DR INC.C/O ROBERT BOWMAN LANCASTER,PA 17601-36 VILLAGE HOMES AT WESTWOOD GLEN, 614 BRISBAIN LN INC. ENOLA,PA 17025-1553 VILLAGE HOMES AT WESTWOOD GLEN, 658 BRISBAIN LN INC. ENOLA,PA 17025-1553 VILLAGE HOMES AT WESTWOOD GLEN, 605 BRISBAIN LN INC. ENOLA,PA 17025-1557 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 57 WOODMYRE LANE ENOLA,PA 17025-1552 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle,PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg,PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh,PA 15222 U.S. Department of Justice 228 Walnut Street,Suite 220 U.S. Attorney for the Middle District of PA PO Box 11754 Federal Building Harrisburg,PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to autho S. Date: IZ By: Phela2#11inan&Schmieg,LLP FJoh c ae, Kolesnik,Esq.,Id.No.308877 ey for Plaintiff WELLS FARGO 13;kNK,,N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION VS. NO.: 2012-1983-CIVIL STACY R. HART ROBERT A. HART CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: STACY R. HART ROBERT A. HART 57 WOODMYRE LANE ENOLA,PA 17025-1552 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house(real estate)at 57 WOODMYRE LANE,ENOLA,PA 17025-1552 is scheduled to be sold at the Sheriffs Sale on 12/05/2012 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$128,880."obtained by WELLS FARGO BANK,N.A. (the mortgagee)against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFFS SALE To prevent this Sheriffs Sale,you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. ------------- You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be'able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property- 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty(30)days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong)are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO.2012-1983-CIVIL WELLS FARGO BANK,N.A. VS. STACY R. HART ROBERT A. HART owner(s)of property situate in the EAST PENNSBORO TOWNSHIP, Cumberland County,Pennsylvania, being (Municipality) 57 WOODMYRE LANE,ENOLA,PA 17025-1552 Parcel No.09-12-2992-195 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $128,880.90 Phelan Hallman&Schmieg,LLP Attorney for Plaintiff 1617 JFK Boulevard,Suite 1400 Philadelphia,PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situated in East Pennsboro,Township,Cumberland County, Commonwealth of Pennsylvania more particularly bounded and described as follow,to wit: BEGINNING at a point on the western dedicated right-of-way line of Woodmyre Lane at the dividing line of Lot#T-33 and Lot#T-32;thence by line of Lot#T-33 and passing through the center of a partition wall South seventy-seven degrees nineteen minutes thirty-seven seconds West(S 77 degrees 19 minutes 37 seconds W),one hundred twelve and seventy-four hundredths(112.74)feet to a point;thence by line of lands of Westwood Village due North twenty and forty-nine hundredths(20.49)feet to a point at the dividing line of Lot#T-31 and Lot#T-32;thence by line of Lot#T-31 and passing through the centerline of a partition wall North seventy-seven degrees nineteen minutes thirty-seven seconds East(N 77 degrees 19 minutes 37 seconds E),one hundred seventeen and fifty-four hundredths(117.54)feet to a point on the western right-of- way line of Woodmyre Lane;thence by said right-of-way line South thirteen degrees fifty-four minutes forty- one seconds East(S 13 degrees 54 minutes 41 seconds E),eleven and zero hundredths(11.00)feet to a concrete monument;thence by same by a curve to the left having a radius of one hundred fifty and zero hundredths(150.00)feet and an arc length of nine and two hundredths(9.02)feet,said curve also having a chord bearing and distance of South fifteen degrees thirty-eight minutes three seconds East(S 15 degrees 38 minutes 03 seconds E),nine and two hundredths(9.02)feet to a point at the dividing line of Lot#T-33 and Lot#T-32,the place of BEGINNING. BEING Lot#T-32 on the Final Subdivision Plan for Westwood Hills,Phase HI,recorded in Plan Book 81, Page 54. SUBJECT to a 25 foot wide Drainage and Pedestrian Easement as shown on the above mentioned subdivision plan. SUBJECT to other conditions and restrictions as set forth on the above mentioned plan. TITLE TO SAID PREMISES IS VESTED IN Robert A.Hart and Stacy R.Hart,h/w,by Deed from Village Homes at Westwood Glen,Inc.,a Pennsylvania Corporation,dated 10/30/2003, recorded 11/05/2003 in Book 260,Page 1106. PREMISES BEING: 57 WOODMYRE LANE,ENOLA,PA 17025-1552 PARCEL NO.09-12-2992-195 WRIT OF EXECUTION and/or ATTACHMENT ,COMMONWEAI:TH OF PENNSYLVANIA) NO. 12-1983 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due WELLS FARGO BANK,N.A.Plaintiff(s) From STACY R.HART,ROBERT A.HART (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: $128,88090 L.L.: $.50 Interest FROM 5/26/2012 TO DATE OF SALE($21.19 PER DIEM)-$4,110.86 Atty's Comm: % Due Prothy:$2.25 Atty Paid:$210.25 Other Costs: Plaintiff Paid: Date: 8/15/2012 David D. B ell,Prot'onq (Seal) Deputy REQUESTING PARTY: Name:JOHN MICHAEL KOLESNIK,ESQUIRE Address: PHELAN HALLINAN&SCHMIEG,LLP 1617 JFK BOULEVARD,SUITE 1400 PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF TRUE COPY FROM RECORD In Testimony whereof,I here unto se',my nand Telephone:215-563-7000 and the seat of said Court at Carlisle, Pa. This day of Supreme Court ID No.308877 On August 21,. 2012 the She I up o- the defendant's interest in the re � o t + Penns oro Township, Cum,beviand Co, �nty, Ai-Am, n and numbered 57 Woodm yrel Lainejnola, PA S-fW described on Exhibit "A" f H d; ' this reference in o: rated- eln. Date: August 21, 2012 By: . Claudia:Brewbaker, Real Estate . dsifqw W8 LISRVIN JAIb3HS 3HI 3O 33 3.4fl CUMBERLAND LAW JOURNAL Writ No. 2012-1983 Civil Term WELLS FARGO BANK,N.A. vs. STACY R. HART Robert A.Hart Atty.:Daniel Schmieg By virtue of a Writ of Execu- tion NO. 2012-1983-CML, WELLS FARGO BANK, N.A. vs. STACY R. HART, ROBERT A. HART, owners) of property situate in the EAST PENNSBORO TOWNSHIP, Cumber- land County, Pennsylvania, being 57 WOODMYRE LANE. ENOLA, PA 17025-1552. Parcel No.09-12-2992-195. Improvements thereon:RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT:$128,880- .90. 47 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid,being duly sworn, according to law,deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 26, November 2 and November 9,2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. (,Lisa MaAe Coyne, fditor SWORN TO AND SUBSCRIBED before me this 9 dav of November. 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. 2020 Technology Pkwy e a rlo ews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co.. a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland. State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949 respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true, and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s)shown below: 10/26/12 2012-1983 C" WELLS FARGO BANK, A. 11/02/12 ,A STACY R.HART � 11/09/12 Rob*n A.Hart Ath►: Qanlel Schmlag , By virtue of a Writ of Execution NO. `" .. . . . . . . 2012-1983-CML '} j WELLS FARGO BANK,N.A. t VS.STACYR.HART Sworn to and subscribed befipr e,tfiis day of November. 2012 A.D. ROBERT A.HART r o-er(s)of property situate in the EAST ' PENNSBORO TOWNSHIP,Cumberland - County,Pennsylvania,being N Ott ry Public d 57 WOODMYRE LANE.EN LA PA 17025-1552 Parcel No.09-12-2992-195 CQf 6b'IOhV`JEALTH�_ pV[t-'1YL'a 1� — - Notarial Seal (Acreage or street address) ____ gh;t�liC Improvements thereon:RESIDhNT1AL Shereie t_.()wen`' tnY,t,u'h DWELLING a Lower NaAo TvvP, ° JtJDGI�NTAMOUNT:$128,880.90 My Ca_2!iS5icm Fxpi!ES ra A;; O'c IP:'10' y vn r�ruF, HLED-OFFICE OF THE PROTHOINOTAR`( Phelan Hallinan,LLP 2013 JUL -3 AN 10- 08 Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza CUMBERLAND COUNTY Philadelphia,PA 19103 PENNSYLVANIA 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division vs CUMBERLAND County STACY R.HART ROBERT A.HART No.2012-1983-CIVIL Defendant PRAECIPE TO THE PROTHONOTARY: ❑ Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ❑ Please mark the above referenced case Settled,Discontinued and Ended. Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑ Please Vacate the Judgment entered. Date: PHE AN HA LLP Y: CAM-son F.Zuczkern)k(n,Esq.,Id.No.309519 Attorney for Plaintiff PHS#293694 r Phelan Hallman,LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 1.91.03 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County STACY R. HART No. 2012-1983-CIVIL ROBERT A. HART Defendant PHS#293694 CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: STACY R. HART ROBERT A. HART 57 WOODMYRE LANE ENOLA,PA 17025-1552 Date: ?AI *gLIIn AN ,L P F. Zuckerman,Esq.,Id. No.309519 Attorney for Plaintiff