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HomeMy WebLinkAbout12-2249a It IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., Plaintiff, CIVIL DIVISION NO.: /a - ga v avit-W)w VS. LINDA A. BRUNNER; Defendant. TO: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAYBE ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3476 Stateview Blvd.. MAC # X7801-013. Ft. Mill. SC 29715 AND THE DEFENDANT: 30 Wyrick Avenue ShipMnsburg PA 17257-1734 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 30 Wyrick Avenue. Shi=nsburg PA 17257-1734 Municipality: Shiuoenbure ? ATTORNEY FOR PLAINTIFF ATTY FILE NO.: XFP 164961 TYPE OF PLEADING CIVIL ACTION - COMPLAINT ==T - r IN MORTGAGE FORECLOSUI, `° ` - --r c-? FILED ON BEHALF OF: Wells Fargo Bank, N.A. ? 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 Levy Marin, Esquire Pa I.D. #306799 Ralph M. Salvia, Esquire Pa I.D. #202946 Jaime R. Ackerman, Esquire Pa I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckereoldbere.com File No.: XFP-164961/trk S 4103.75 PO A7Ty C# 3351olle 12-a 73 5s8 r IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. LINDA A. BRUNNER; Defendant(s). 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 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. LINDA A. BRUNNER; Defendant(s). AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar accion dentro de los pr6ximos veinte (20) dias despu6s de la notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR LINO, LLAME 0 VAVA 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. LINDA A. BRUNNER; Defendant(s). CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff") through its servicing agent WELLS FARGO BANK, N.A. located at 3476 Stateview Blvd., MAC # X7801-013, Ft. Mill, SC 29715. 2. Defendant, LINDA A. BRUNNER, is an individual whose last known address is 30 Wyrick Avenue, Shippensburg, PA 17257-1734. 3. On or about May 7, 2009, LINDA A. BRUNNER executed a Note in favor of Sierra Pacific Mortgage Company, Inc., A California Corporation in the original principal amount of $135,088.00. 4. On or about May 7, 2009, as security for payment of the aforesaid Note, LINDA A. BRUNNER made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for Sierra Pacific Mortgage Company, Inc. a Mortgage in the original principal amount of $135,088.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on May 26, 2009, Instrument #200917136. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof. 5. The Mortgage was assigned by Mortgage Electronic Registration Systems, Inc. as nominee for Sierra Pacific Mortgage Company Inc. to Wells Fargo Bank NA, plaintiff herein, pursuant to an assignment of mortgage dated September 14, 2011 and recorded on September 22, 2011 in the Office of the Recorder of Deeds for Cumberland County, Instrument #201126265. Zucker, Goldberg & Ackerman, LLC XFP-164961 6. Defendant is in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest being contractually due for the August 2011 payment, and pursuant to the terms of the aforesaid Mortgage, after written notice of said default to Defendant(s), the entire principal balance and accrued interest due thereunder has been accelerated. 7. LINDA A. BRUNNER, single woman is the record and real owner of the aforesaid mortgaged premises. 8. On October 2, 2011, Defendant(s) were mailed a Notice of Intention to Foreclose Mortgage, in compliance with Act 6 of 1974, 41 P.S. §101, et seq. 9. Plaintiff was not required to send Defendant(s) written Notice pursuant to 35 P.S. §1680.403 (c) (Homeowners' Emergency Mortgage Assistance Act of 1983, - Act 91 of 1983), prior to commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C. §§1707 - 1715(z) - 18) [35 P.S. §1680.401(a)(3).]. 10. The amount due and owing Plaintiff by Defendant(s) is as follows: Principal $121,298.28 Interest through 03/12/2012 $3,803.46 Escrow Balance ($34.40) Late Charges $1,210.10 Inspection Fees $90.00 Total $126,367.44 plus interest on the principal sum ($121,298.28) at the daily per diem amount of $14.95, and all other additional amounts authorized under the Mortgage, actually and reasonably incurred by Plaintiff, including but not limited to, late charges, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums to the above amount due and owning when incurred. 11. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in Zucker, Goldberg & Ackerman, LLC XFP-164961 a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability under the aforesaid Note in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $126,367.44, with interest thereon at the daily per diem amount of $14.95 plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GOLDBERG & ACKERMAN, LLC ? BY: oukLkw? Dated: hI Scott A. Dietterick, Esquire; PA I.D. #55650 v Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh Levy Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-164961/hp 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP-164961 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-164961 This Instrument Was Prepared By: LITZ, VALERIE SIERRA PACIFIC M7RTG4X QritPANY, DC. 50 MW Font C VR=, STS 200 FOLSOM, CA 95630 926-932-2700 After Recording Return To: MF-,DSLWDC DEP WMW ALL STAR TITLE ? so C!V'¢s, sT5 ' 200 3514 BEDFORD AVENUE FOL 95630 SUITE 202 9 -932- BALTIMORE, MD 21208 Parcel Number: 36-36-2424-004 Eby- a(0 9? Premises: 30 WYRICK AVE SHIPPENSBURG, PA 17257 V?111191II oo,EI. Loan Number: I 1 ISpace Above This Line For Recording Data] FHA Case No. Commonwealth of Pennsylvania MORTGAGE MIN: THIS MORTGAGE ("Security Instrument") is given on 14AY 7, 2009 The Mortgagor is LINDA A BRUNNER, ("Borrower"). This Security Instrument is given to Mortgage Electronic Registration Systems,. Inc. ("MERS"), (solely as nominee for Lender, as hereinafter defined, and Lender's successors and assigns), as mortgagee. MERS is organized and existing under the laws of Delaware, and has an address and telephone number of P.O. Box 2426, Flint, MI 48501-2026, tel. (888) 679-MERS. SIERRA PACIFIC MORTGAGE COMPANY, INC. , ("Lender") is organized and existing under the laws of CALIFORNIA and has an address of 50 IRON POINT CIRCLE, STE 200, FOLSOM, CA 95630 FHA Pennsylvania Mortgage with MERS - 4/96 (Amended 6/02) DRAW.MERS.PA.FHA.DT.I.WPF (DEEDS\FHA-MERS\PAMERSDT.FHA) Page I of9 r? Borrower owes Lender the principal sum of a E HENFM TIYIRTY-FTVE 7HO[15 M EIGHT Y-EIGHT and ND/100- - - - - Dollars (U.S. $ 135, 088. 00 ). This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on JUNE 1, 2 02 4 . This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely as nominee for Leader and Lender's successors and assigns) and to the successors and assigns of MERS, the following described property located in CUMBERLAND County, Pennsylvania: LEGAL DESCRIPTION ATTACHED HERETO AND MADE A PART HEREOF. which has the address of 30 WYRICK AVE ISaeeil, SHIPPENSBURG [city), Pennsylvania 17257 IZip Code) ("Property Address"); TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." Borrower understands and agrees that MERS holds only legal title to the interests granted by Borrower in this Security Instrument; but, if necessary to comply with law or custom, MERS, (as nominee for Lender and Lender's successors and assigns), has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but not limited to, releasing or canceling this Security Instrument. BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform coves ? nts for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. Borrower and Lender covenant and agree as follows: UNIFORM COVENANTS. 1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under Paragraph 4. In any year in which the Lender must pay Loan No: FHA PenWlvania Mortgage with MERS - 4/96 (Amended 6/02) DRAW. MERS. PA. FHA.DT.2. WPF (DEEDSWHA•MERSTAMERSDT.FHA) Page 2 of9 P a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also include either: (I) a sum for the annual mortgage in-trance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds." Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 et seq. and implementing regulations, 24 CFR Part 3500, as they may be amended from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA, Lender shall account to borrower for the excess funds as required by RESPA. If the amounts of funds held by Lender at any time are not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by RESPA. The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium Installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments. All payments under paribraphs 1 and 2 shall be applied by Lender as follows: First, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; Second, to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Third, to interest due under the Note; Fourth, to amortization of the principal of the Note: and Fifth, to late charges due under the Note. 4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This Insurance shall be maintained in the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the Properly, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to Loan No : I 1 FHA Pennsylvania Mortpp with MERS - 4/96 (Amended 6/02) DRAW.MERS.PA.FHA.DT.3.WPF (DEEDWHA•MERSWAMERSDT.FHA) Page J 0r9 3'? in paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. In the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies In force shall pass to the purchaser. 5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requirement i& ill cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order provided in paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity M7,ally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower falls to make these payments or the payments required by paragraph 2, or fails to perform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in paragraph 2. Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement, at the Note rate, and at the option of Lender, shall be immediately due and payable. Loan No: FHA Pennsylvania Mortgage with MERE - 4/96 (Amended N02) DRAW.MERS.PA.FHA.DT.A.WPF (DEEDWHA-MERSIPAMERSDT.FHA) Page 4 of9 Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien In a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien: or (c) secures from the holder of the Hen an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8. Fes. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations Issued by the Secretary, in the case of payment defaults, require immediate payment in full of all sums secured by this Security Instrument if: (i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument prior to or on the due date of the next monthly payment, or (ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including Section 341(d) of the Garn-St. Germain Depository Institutions Act of 1982, 12 U.S.C. 1701]-3(d)) and with the prior approval of the Secretary, require immediate payment in ful" of all sums secured by this Security Instrument if. (() All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, Is sold or otherwise transferred (other than by devise or descent), and 01) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approved in accordance with the requirements of the Secretary. (c) No Waiver, If circumstances occur that would permit Lender to require immediate payment in full, but Lender does not require such payments, Lender does not waive its rights with respect to subsequent events.. (d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary will limit Lender's rights in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lender's fallure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorney's fees and Loan No. FHA Pennsylvania Mortgage with MERS - 4/% (Amended 6/02) DRAW, MERS.PA.FHA. DT-5.WPF (DEEDSIFHA-MERSIPAMERSDT.FHA) Page 5 of9 f 16 a expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall remain in effect as if Lender had not required immediate payment in full. However, Lender is not required to permit reinstatement If: (1) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors In Interest. Any forbearance by Lender in exercising any right of remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-sigding this Security Instrument only to mortgage, grant and convey that Borrower's Interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. 13. Notices, Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law: Severability. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property Is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower'$ Copy, Borrower shall be given one conformed copy of the Note and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Properly of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority that any removal or other remediation of any Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial action in accordance with Environmental Law. FHA Pennsylvania Moatpge with MERS - 4/96 Loan No:( (Amended 602) DRAW.MERS.PA.FHA.DTAMPF (DEEDSTHA-MERSWAMERSDT.FHA) Page 6 of9 As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws and laws of the jurisdiction where the property is located that relate to health, safety, or environmental protection. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; i. rd (c) each tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights under this paragraph 17. Lender shall not be required to enter upon, take control of or maintain the Property before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full. 18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9, Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to odilect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, but not limited to, attorney's fees and costs of title evidence. If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicisl power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C. 3731 etsdq.) by requesting a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extent to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. Loan No : L FHA Pennsylvania Mortgage with MERS . 4/96 (Amended 6102) DRAW.MERS.PA.FHA.1YT.7.WPF (DEEDSTHA-MERSTAMERSDT.FHA) Page 7of9 IPD DP? 23. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants of each such rider shall be incorporated Into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)] ( J Condominium Rider [ ] Graduated Payment Rider [ j Growing Equity Rider ( ] Planned Unit Development Rider [ ] Adjustable Rate Rider [ ] Rehabilitation Loan Rider [ J Non-Owner Occupancy Rider [ ] Other (specify) This is a contract under seal and may be enforced under 42 PA C.S. Section 5539(b). BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security Instrument and in any rider(s) executed by Borrower and recorded with it. 'Je4't' (.( (Seal) LINDA A BRUNNER -Borrower Witness(es): (Seal) -Borrower _,_ (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower _- (Seal) -Borrower FHA Pennsylvania Mortgage with MERS - 4/% (Amended 6/02) DRAW.MERS.PA.FHA.DTIMPF (DEEDSWHA-MERWAMERSDT.FHA) Page 9 of9 '51*f a- (N(+A C county ss: On this _?0- day of Mal Zpp°)i before me, the undersigned officer, personally appeared Cinota fi . 4( vontr known to me (or satisfactorily proven) to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged that he/she/thty executed the same for the purposes herein contained. IN WITNESS WHEREOF, 1 hereunto set my hand and official seal. My Comma tltEitpi ?- 3 S?O ll ';=0 My C11-0? N0mfy public- COMMISSION Tote of Ofliccr = m EXPIRES. a 3/1/2011'• •`?+p' ; OgE: COJ?t?t?'' '!!l111/11111ti1?tt Certificate of Residence 1, LITZ, VALERIE , do hereby certify that the correct address of the within-named Mortgagee is P.O. Box 2026, Flint, MI 48501-2026. Witness my hand this 7th day of MAY .2009 /S/LITZ, VALERIE Agent of Lender Loan No : 1__ I FHA PenrWivsnin Mortpp with MERE. 4/96 DRAW.MERS.PA.FHA.DT.9.WPF (DEEDSIFHA•MERSWAMERSDT.FHA) (Amended 6/02) Page 9 of9 q 91 * i Exhibit A All that certain lot or parcel of land situate in the County of Cumberland, Commonwealth of Pennsylvania, and being more particularly described as follows: THE SAID LOT BEING BOUNDED ON THE EAST BY SHIPPEN STREET: ON THE SOUTH BY LOT NO. 23; ON THE WEST BY LAND NOW OR FORMERLY OF H. H. HOY; ON THE NORTH BY LOT NO.21. SAID LOT HAVING A FRONTAGE ON 75 FEET ON SHIPPEN STREET AND AN EVEN DEPTH OF 200 FEET FROM THE CENTER OF SHIPPEN STREET TO LAND NOW OR FORMERLY OF H. H. HOY. PARCEL #: 36-36-2424-004 THE IMPROVEMENT ARE BEING NOW COMMONLY KNOWN AS 30 WYRICK AVENUE, SHIPPENSBURG, PA 17257. BEING property which, by Deed dated May 31, 2002, and recorded among the Land Records of the County of Cumberland, Commonwealth of Pennsylvania, in Liber No. 252, folio 476, was granted and conveyed by MYRA L. YINGLING unto LINDA A. BRUNNER. W, L if ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200917136 Recorded On 5/26/2009 At 11:42:19 AM * Total Pages - I I * Instrument Type - MORTGAGE Invoice Number - 44318 User ID - MSW * Mortgagor - BRUNNER, LINDA A * Mortgagee - MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC * Customer - ALL STAR TITLE * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $23.50 RECORDER OF-DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 Certification Page DO NOT DETACH This page is now part of this legal document. ROD ARCHIVES FEE $3-.00 TOTAL PAID $60.50 I Certify this to be recorded in Cumberland County PA RECORDER O 4EDS t - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 111111111111111111111111111 40 • op VERIFICATION Linda Duncan, hereby states that h /sh is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter, that he s e 's 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 his er .nformation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: ?td I i 112- Name: Brunner File #: 164961 Ij4d9i Name: Linda D can Title: Vice President Loan Documentation 032-PA-V3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?HE PROTNQNO)?,pr`, Jody S Smith r Chief Deputy _ `012 APR 20 AM 8: 45 Richard W Stewart Solicitor ????????? ???ND' PE SYLVANIA Wells Fargo Bank, N.A. vs. Case Number Linda A. Brunner 2012-2249 SHERIFF'S RETURN OF SERVICE 04/13/2012 06:08 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2012 at 1808 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Linda A. Brunner, by making known unto herself personally, at 30 Wyrick Avenue, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. S HAL , EPUTY SHERIFF COST: $48.00 April 18, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF 1 re IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~ , ' ~ ~' Wells Fargo Bank, N.A. CIVIL DIVISION ~~ Z 70' ~ M -~. ~ -e~ ~y Plaintiff, 2r- c7 --- •:~i ~~ NO.: 12-2249-CIVILTERM ~p ~, ~? ~ LINDA A. BRUNNER; ~,G a Defendant(s). ~''~ -< -~;. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to Plaintiffs Complaint within the appropriate time limits from service thereof, and assess Plaintiffs damages as follows: Amount as set forth in Complaint Interest from Complaint date through 08/07/2012 Late Charges TOTAL $126,367.44 $2,197.65 $174.00 $128,739.09 plus interest on the judgment amount ($128,739.09) from August 8, 2012, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known address is: Dated: '~~I~ BY: l ^ 30 Wyrick Avenue Shippensburg, PA 17257- 1734 i ZUCKER, n, Esquire; PA I.D. #202729 Asfileigh L. Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA I.D. #311032 ~~~ ~ Attorneys for Plaintiff (,~MI.~' XFP-164961 C'~,{~• ; 200 Sheffield Street, Suite 101 ~ a Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX ~a'~ Email: Office@zuckergoldberg.com DAMAGES ARE HEREBY ASSESSED AS INDICATED Date froth ~ ~ Q~ ~/D ~ ~~399 ~~,~.~.d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION vs. LINDA A. BRUNNER; Plaintiff, N0.:12-2249-CIVILTERM Defendant(s). AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY COUNTY OF UNION SS: I, the undersigned attorney for the plaintiff in the above action, being duly sworn according law, do hereby depose and say that the statements made herein are true in and correct to the best my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the b~ 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 237.1 and that the time limits provided for that notice have expired. Dated: Sworn~a This Notary Public ZUCKER, GOLB AC , L r~ BY: . - Joel erman, Esquire; P .D. #202729 Ash igh L. Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-164961 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: OfficeCa zuckergoldberg.com nd ubscribed before m y of Qw t `L- res: SHEREZA DEONARINE Notary 10~ 2407261 J~ My Commission Expires 4/'1212016 Zucker, Goldberg & Ackerman, XFP-164 Department of Defense Manpower Data Center ~~ Bayport Purstumt to Sorvic~mcm~ers Civil. Relief Act Last Name: BRUNNER First Name: LINDA A Active Duty Status As Of: Aug-07-2012 Results as of :Aug-07-2012 8:53:07 SCI~A 2.2.2 AtiNtaAMyt~Wa Aa1W~~puQ'EnQt>aOY. !lwgWS flar~Mar~ethporflat rn +~. Duly l7n Aoirl Doty SHtia o.fr NA NA No NA This resPon~ rotbeb the k~dWWuals' actNe duy slaws bated on the Actlve DuH 3fatus Date tart Ad9va Wq* 1YNtki 3tyl thys d AoBw,t ~ BBSMA Dana AWve Duty $Oart Data ACOve Outy End Ogle ffitaAis ~^'~ ~P'~^t NA NA No NA This response reflects whxe the indMdual fart active duty stales within 387 days preceding the Active Duty Status Dete TM of FNalkMr tJrrl WM NCNMd d a FuWro ~P to AtAive Ouly on AotMs Duty Bhtl» DaOe Drdtr NotllloaYen start DaM Ortlar NptllOatlon EM !Tale Status Strvica Camponsnt NA NA No NA This response reflects whether the Individual or Nslher unk has receWed tart' notl8catbn to report for stews 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 s tus of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, nd Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. rhoy, ~a ,,c..~_~- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligit~ility Reporting System (DEERS) database which is the offidal source of data on eligibility for military medical care and other eligibility systems. ', The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on alive duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any fam ly member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled t the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.miUfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty stat s date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c . This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for a~ duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certifipte is defined in acx:ordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods ss than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authoriaed by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency dedared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position i the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Re rve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services peri ds. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of se ice. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who hav not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the CFL extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualfied legal counsel to ensure that all rights guaranteed to Service members under the are protected WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: GSPEAIKF66 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA j Wells Fargo Bank, N.A. vs. LINDA A. BRUNNER; Plaintiff, ' Defendant(s). CIVIL DIVISION NO.: 12-2249-CIV I LTE RM NOTICE OF ORDER, DECREE OR JUDGMENT TO: LINDA A. BRUNNER 30 Wyrick Avenue Shippensburg, PA 17257-1734 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ~ ~(,Q ~~" [ ] A copy of the Order or Decree is enclosed, or [~] The judgment is as follows: $128,739.09 plus costs. Pro notary Zucker, Goldberg & Ackerman, XFP-164 'r SHERIFFS OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Jody S Smith Ch1~Deputy Richard W Stewart saw FAQ ~ ~~4I o of ~ s /(o `~q~~ Weld Fargo t3ank, NA. Case Nurnber ~• 2012-2248 t~nda A. Brunner SHERIFF'S RETURN OF SERVICE 04113J2012 06:08 PM - Shawn Gutsha~, Deputy St~'f, who being duly swum according to law, states that on Apri! 13, 2012 at 1808 hours, he served a true copy. of the w Complaint in Mortgage Foreclosure, upon the . within named defiendar~~ to wit' Liridi! ~C."Brunner, by mekhrg known unto herself P~'~~Y~ at ~} Wyridc Avenue, Shlppensburg, Cumba~nd County, Pennsyhrania 17257 its contents and at the same time handing to her personalty the said true and correct copy of the same. ~,.,, SHERIt=F COST: 548.00 SO ANSWERS, ~~~`~'_ April 18, 2012 RON R ANDERSON, SHERIFF 1~1 CourllY&+M SheriR. TM~a~dt. lrc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Welly Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. LINDA A. BRUNNER TO: LINDA A. BRUNNER 30 Wyrick Avenue Shippensburg, PA 17257-1734 DATE OF NOTICE: 5/14/2012 NO.: 12-2248-CIVI LTERM 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 again you. Unless you act within Ten (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) 880-9108 Phone (800) 880-8108 (717) 248-3166 (717) 249-3166 Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. LINDA A. BRUNNER TO: LINDA A. BRUNNER 30 Wyrick Avenue Shippensburg, PA 17257-1734 Defendant. NO.: 12-2249-CIVILTERM AV ~~ O- Il I i +F C Y tTA t y '. ~ FECHA DEL AVISO:S/14/2012 Lb"IID STA INR1~7~SA PCB HA FALLADO I~ TAR LA A(xlCi~ ~I'.h1~.1A SST S~IE C'A.yQ A NII~ [~.E LbTID 'IC1VE ~,fJCICN I~TI'i~7 I~ LCJ~S PVt~ L>~ (lUj IIAS I~ LA FEC~~i4I~E~lEA, SE PC~E IICTAR LI~TFALUDINC~IIRA SUVA SINLLEV~A C..ABiDL~TA VlSTAY Lb1F~1 PC~I.'>E PII~">ER. SU PROD Y ~7IR~ DIS IMaC.~'A1~TIF~ L151H) ~>~ LLEVAR BS'iE DOCx11~TTIi7 Il~ATANSVIE A SU ABOC~ADQ SI L}S'TS71`~ 'IIHViE LN ABOCtADO O 1VG PCELE PAi~~4R LNC~ VAYA O Li.~~lV.E LA Q~CIl~Io, AB41p0 Il~L>EC.~ FARA ~~ I.E DCi~LE Pf~~ CX~1S~[.IR AYC~, I~JC~4I. Cumberlaruf County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 3. Bedford Street Carlia~, PA 17013 Phone (800)'980-9108 (717) 249-3166 ~LTC3~t, C~OIDE~t~C" &AC~~IIZAN BY Solt A Diatteridc, Esquire Attameys far Plaintiff PA LD_ # 55650 200 Sheffield Street, Suite 301 P_ O_ Baa;1024 Maar~air~side, NJ 07092-0024 (717) 533-3560 F1RS-T GCA.~S U S~ MAII., P~OIa TAGS Pl7EPAID 164961 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 12-2249-CIVILTERM vs. TYPE OF PLEADING Linda A. Brunner; Pa. R.C.P. RULE 3129.2(C)AFFIDAVIT OF SERVICE Defendant. OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: Wells Fargo Bank, N.A. 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. Marin, Esquire- PA I.D.#306799 Ralph M.Salvia, Esquire- PA I.D. #202946 Jaime R.Ackerman, Esquire- PA I.D.#311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 C� (908) 233-8500 _ (908) 233-1390 FAX M office @zuckergoIdberg.com � - File No.:XFP- 164961/dsc � r* - � 5;C= mfr C:) ;:0 Zucker, Goldberg&Ackerman, LLC XFP-164961 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 12-2249-CIVILTERM VS. Linda A. Brunner; Defendant. Pa.R.C.P. RULE 3129(c)AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Daniel Schlesinger, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriffs Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Linda A. Brunner, single woman, is the record owner of the real property. 2. On or about February 21, 2013, Defendant Linda A. Brunner was served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, via Certified Mail, no receipt requested at 30 Wyrick Avenue, Shippensburg, PA 17257. 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 16, 2013, Plaintiffs counsel served all other parties in interest with Plaintiffs Notice of Sheriffs Sale according to Plaintiff's 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 XFP-164961 Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of Interest were served with Plaintiffs Notice of Sheriffs Sale of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER, GOLDBERG &ACKERMAN, LLC Attorneys for P ' Dated: May 2, 2 DANIEL S GER Paralegal/Legal Assistant Sworn to nd subscribed fore me this day of May, 2013 ary Public SHE Publi� �01NewN Jersey Notary ID#2407261 My Commission Expires 4/1212016 Zucker, Goldberg&Ackerman, LLC XFP-164961 EXHIBIT A Zucker, Goldberg&Ackerman, LLC XFP-164961 Zucker,Goldberg&Ackerman,LLC PO Box 1219 Mountainside,NJ 07092-1219 7196 9006 9296 5462 6669 20130215-102 �I�II�III1111�1�1��1111��1�1��1����1�11�1111�11'I�I'Illll'�'�I�I� Linda A. Brunner 2612 Banbury Ln Chambersburg, PA 17202-8136 PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, NO.: 12-2249-CIVILTERM VS. LINDA A. BRUNNER; Defendant. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 LINDA A. BRUNNER 30 Wyrick Avenue Shippensburg, PA 17257-1734 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/5/2013 at 10:00am 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: 30 Wyrick Avenue,Shippensburg,PA,17257-1734 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-2249-CIVILTERM THE NAME(S)OF THE OWNER(S)OR REPUTED OWNER(S)OF THIS PROPERTY ARE: LINDA A.BRUNNER,Single Woman Zucker,Goldberg&Ackerman,LLC XFP-164961 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: 1. 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. 64 Zucker,Goldberg&Ackerman,LLC XFP-164961 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 Sheriff's Deed is delivered. 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 17013-3387, before presentation of the petition to the Court. ZUCKER GOLDBERG& KERMAN, LLC Dated: a3 J'� BY: '✓ Scott A.Die rick, Esquire; PA I.D.#55650 Kimberly A.Bonner, Esquire; PA.I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 y Jaime R.Ackerman, Esquire; PA I.D.#311032 d 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 i File No.:XFP-164961 (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. ®R Zucker,Goldberg&Ackerman,LLC XFP-164961 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND, WITH A ONE AND ONE HALF STORY FRAME DWELLING HOUSE AND GARAGE ERECTED THEREON,SITUATE IN THE TOWNSHIP OF SHIPPENSBURG,COUNTY OF CUMBERLAND,AND STATE OF PENNSYLVANIA,AND BEING KNOWN AS LOT NO. 22 AS SHOWN IN THE PLAN OF LOTS RECORDED IN PLAN BOOK 4, PAGE 50,AND KNOWN AS JOHN A. WYRICK'S DEVELOPMENT: THE SAID LOT BEING BOUNDED ON THE EAST BY SHIPPEN STREET;ON THE SOUTH BY LOT NO. 23;ON THE WEST BY LAND NOW OR FORMERLY OF H. H. HOY; ON THE NORTH BY LOT NO,21. SAID LOT HAVING A FRONTAGE ON 75 FEET ON SHIPPEN STREET AND AN EVEN DEPTH OF 200 FEET FROM THE CENTER OF SHIPPEN STREET TO LAND NOW OR FORMERLY OF H. H.HOY. HAVING thereon erected a dwelling house being known and numbered as 30 Wyrick Avenue, Shippensburg, PA, 17257-1734. ' BEING the same premises which Myra L.Yingling,single,by Deed dated May 31,2002 and recorded June 7,2002 in and for Cumberland County,Pennsylvania, in Deed Book Volume 252,Page 476,granted and conveyed unto LINDA A. BRUNNER,single woman. Tax Map No.: 36-36-2424-004. I i i Zucker,Goldberg&Ackerman,LLC XFP-164961 2_tAide Number . . ON A Received try Flea Prtnt Clearly) ME of De C. D ,0 llI 7196 9006 9296 5462 666L9: X c I D. Is d9livery address d fl Weni from item 1? Yes J a J If YES.enter dethrery address below. L 3. Service Type CERTIFIED MAIL '' 4. Restricted Delivery? (Extra Fee) 1�Yes 7 �• N 1. Article Addressed to- Linda A. Brunner r,. Reference information 2612 Banbury Ln 164961 Chambersburg, PA 17202-8136 FANOSS 2/15/2013 7196 9006 9296 5462 6669-102 L � 3811.January 2005 Domestic Retum Receipt UNITED STATES POSTAL SERVICE First-Class Mail Postage&Fees Paid USPS Permit No.G10 ���lurr�rli�r�rl,ulilrlrr�i�nl�n��ui�rl�rrr���if _ Zucker, Goldberg & Ackerman, :LLC �r P4 Box 9076 Temecula, CA 92589-9076 'r n .i � �yv EXHIBIT B Zucker, Goldberg&Ackerman, LLC XFP-164961 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, NO.: 12-2249-CIVILTERM VS. LINDA A.BRUNNER; Defendant, NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P.3129(b) TO: UNKNOWN TENANT OR TENANTS UNKNOWN SPOUSE 30 Wyrick Avenue 30 Wyrick Avenue Shippensburg,PA 17257-1734 Shippensburg,PA 17257-1734 COMMONWEALTH OF PENNSYLVANIA PA DEPT.OF REVENUE-INHERITANCE DEPARTMENT OF WELFARE TAX DIVISION P.O. Box 2675 Dept, 280601 Harrisburg,PA 17105 Harrisburg,PA 17128-0601 CUMBERLAND COUNTY TAX CLAIM CUMBERLAND COUNTY DOMESTIC BUREAU RELATIONS OFFICE Cumberland County Courthouse Domestic Relations Section One Courthouse Square 13 N. Hanover Street Carlisle,PA 17013 PO Box 320 Carlisle,PA 17013 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.,AS NOMINEE FOR SIERRA MORTGAGE ELECTRONIC PACIFIC MORTGAGE COMPANY,INC. REGISTRATION SYSTEMS,INC.,AS P.O.Box 2026 NOMINEE FOR SIERRA PACIFIC Flint,MI 48501-2026 MORTGAGE COMPANY,INC. 50 Iron Point Circle, Suite 200 THE LOMAS AND NETTLETON COMPANY Folsom,CA 95630 2001 Eyron Tower Dallas,TX 75201 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 Zucker,Goldberg&Ackennan,LLC XFP-164961 16496 1 D I 004CO3072013P I On 6/5/2013 at 10:00am,the following described real estate which LINDA A.BRUNNER,single woman 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: 30 Wyrick Avenue, Shippensburg,PA 17257-1734 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). i Zucker,Goldberg&Ackerman,LLC XFP-164961 164961 D 1004C03072013P2 The said Writ of Execution has been issued on a judgment in the action of Wells Fargo Bank,N.A. Plaintiff VS. LINDA A.BRUNNER,et a] Defendant(s) at EX.NO. 12-2249-CIVILTERM in the amount of$128739.09 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 Sheriffs Sale or this Notice,you should contact your attorney as soon as possible. ZUCKER,GOLDBERG&ACKERMAN,LLC Dated: BY: Sco A'bietferick,Esquire; PA I.D. #55650 Kimberly A.Bonner,Esquire; PA I.D.#89705 Joel A.Ackerman,Esquire; PA I.D.#202729 Ashleigh Levy Marin,Esquire; Pa T.D.#306799 Ralph M. Salvia; PA I.D.#202946 Jaime R.Ackerman,Esquire;PA I.D.#311032 200 Sheffield Street, Suite 301 Mountainside,NJ 07092 File No.:XFP-164961 (908)233-8500;(908)233-1390 FAX E-mail: Office @zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XFP-164961 164961D1004CO3072013P3 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND, WITH A ONE AND ONE HALF STORY FRAME DWELLING HOUSE AND GARAGE ERECTED THEREON, SITUATE IN THE TOWNSHIP OF SHIPPENSBURG,COUNTY OF CUMBERLAND,AND STATE OF PENNSYLVANIA,AND BEING KNOWN AS LOT NO.22 AS SHOWN IN THE PLAN OF LOTS RECORDED IN PLAN BOOK 4, PAGE 50,AND KNOWN AS JOHN A. WYRICK'S DEVELOPMENT: THE SAID LOT BEING BOUNDED ON THE EAST BY SHIPPEN STREET;ON THE SOUTH BY LOT NO.23;ON THE WEST BY LAND NOW OR FORMERLY OF H.H. HOY;ON THE NORTH BY LOT NO.21. SAID LOT HAVING A FRONTAGE ON 75 FEET ON SHIPPEN STREET AND AN EVEN DEPTH OF 200 FEET FROM THE CENTER OF SHIPPEN STREET TO LAND NOW OR FORMERLY OF H. H.HOY. HAVING thereon erected a dwelling house being known and numbered as 30 Wyrick Avenue, Shippensburg,PA, 17257-1734. BEING the same premises which Myra L.Yingling,single,by Deed dated May 31,2002 and recorded June 7,2002 in and for Cumberland County,Pennsylvania, in Deed Book Volume 252,Page 476,granted and conveyed unto LINDA A.BRUNNER,single woman. Tax Map No.: 36-36-2424-004. Zucker,Goldberg&Ackerman,LLC ((Field2))-((Field 1)) «Field 1»Q I 004CO2/12/200SP4 Page 1 of 5 NOTICE TO LIENHOLDERS � 5PONN UNITEDSTATES : prtt�r # POSTAL.--- � 02 1M $ 01-200 0004282036 APR 16 2013 ThIsCartificate of Malling pmldes evidence that mall has been presented to USP59 for mank - MAILED FROM ZIP CODE 07092 and international mall.. "on" Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC W 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 XFP-164961/sde TEAM C To: Postmark Here tp�Q9 ` UNKNOWN TENANT OR TENANTS 0 30 Wyrick Avenue Shippensburg, PA 17257-1734 County of P.Q.:CUMBERLAND s i PS Form 3817,April 2007 PSN 7530-02-000-9065 i i NVS PC � �wttacr� UNITED STATES 02 IM $ 01-200 V,AA— nn }� t 0004282036 APR16 2013 1 Pt?ST L$ERVICEs MAILED FROM ZIPCODE 07092 This Certificate of Mating provides evidence that mail has been presented to LISPS-for mining.This form may ba usea and International mall. FfO1n` Scott A. Dietterick,Esquire i c/o Zucker,Goldberg&Ackerman,LLC was 200 Sheffield Street,Suite 101 CIO Mountainside, NJ 07092 XFP-164961/sde TEAM C Ogg To: COMMONWEALTH OF PENNSYLVANIA Postmark Here DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 2 of 5 NOTICE TO LIENHOLDERS �Q~ PN' ®PrMLv 50VL%s ! UNITEDSTATES 02 1M $ 01.20 _ m 0004282036 APR16 2013 ` POSTAL SERVICEa - MAILED FROM ZIPCODE 07092 This Certificate of Mating provides evidence that mall hes been presented to LISPS•for mallkv This f and International mall. r7om Scott A. Dietterick,Esquire c/o Zucker,Goldberg&Ackerman, LLC wFs 200 Sheffield Street,Suite 101 Ln Mountainside, NJ 07092 to 9 e _ XFP-164961/sde TEAM C p) t To' CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Here 090 Cumberland County Courthouse One Courthouse Square Carlisle,PA 17013 I i' County of P.Q.:CUMBERLAND ' PS Form 3817,April 2007 PSN 7530.02-000-9065 Spft' 9 � PIYNFV HOWFS UNITED STATES a 02 1M $ 01020° I�C?STIL SERVICES `` 0004282036 APR 16 2013 MAILED FROM 23P CODE 0 70 92 This Certificate of Malling pmldes evidence that mall has been presented to LISPS•for mailing,Th and International mall. Fr°m' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC w200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-164961/sde TEAM C T0' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,INC.,AS Postmark Here NOMINEE FOR SIERRA PACIFIC MORTGAGE COMPANY, INC. P.O. Box 2026 Flint, MI 48501-2026 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i i Page 3 of 5 NOTICE TO LIENHOLDERS cFSr 6�P U 1TED; T/1TES_ • 0 2 1M 01.200 Sif.�^F. 0004282036 7-1p CO E Y 07082 - MAILED FROM Z r This Certificate of Malling proyidas eviderce that mall has been presented to USP5e for mailing.This fi r s r and International mall. .�F%S ��//�� From: Scott A. Dietterick,Esquire ��/� r �`�o c/o Zucker, Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 APR 1 6 200 Mountainside, NJ 07092 �� XFP-164961/sde TEAM C To' THE LOMAS AND NETTLETON COMPANY Postmark Here LISPS 2001 Eyron Tower Dallas,TX 75201 County of P.Q.:CUMBERLAND ' PS Form 3817,April 2007 PSN 7530-02-000-9065 4v�o PQ • A �"r' 02 1Aq $ 01.200 OOOA282036 I NITER�+ A � APR 16 2013 i:J; .7 ,«i MAILED FROM�p GapE o 70 92 A+QST/1L SLRVICEs ��.r._.._. here. 7 This Certificate of Mating provides evidence that mail has been presented to LISPS•for mallirg.Thfs form may be used for domestic and International mail. 5��1 LD I/� From: Scott A. Dietterick, Esquire ,�� ,0 0 c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 APR 1 201 Mountainside, NJ 07092 XFP-164961/sde TEAM C ``\,�✓/'' To' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS Postmark Here LISPS NOMINEE FOR SIERRA PACIFIC MORTGAGE COMPANY, INC. 50 iron Point Circle,Suite 200 Folsom,CA 95630 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000.9065 j. Page 4 of 5 NOTICE TO LIENHOLDERS og� z 02 IM• a �prnua[,r rtowEs i UNtTEL?'MTES a 0004282036 A R 16 201 POSTAL SERV C MAILED FROM Zip CODE 07092 Thts Corot sate of Malting provides evklence that mat has been presented to USP5e for maiing.This form maybe used for domes* and International malL 'em" Scott A. Dietterick, Esquire LD c/o Zucker,Goldberg&Ackerman,LLC � -t J��o 200 Sheffield Street,Suite 101 `''o Mountainside, NJ 07092 APR 1 6 290 XFP-164961/sde TEAM C To: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Postmark Here Domestic Relations Section VSFtS 13 N.Hanover Street r PO Box 320 Carlisle, PA 17013 r i a County of P.Q.: CUMBERLAND ' PS Form 3817,April 2007 PSN 7530-02-000-9065 ",ay 60WE5 O UNITEDSTATES $ 01.200 02 1M APR 16 2013 t V��POSZALSERVICE, 0004282036 MAILED FROM ZiPCODE 07092 This Certifkate of Mai@tg provides evidence that mall has been presented to LISPS*for maling.Thls for and International mag. From: Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman,LLC ,- iV_ b�_ 200 Sheffield Street,Suite 101 L13'oo Mountainside, NJ 07092 XFP-164961/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 Page 6 of 6 NOTICE TO LIENHOLDERS _ II1V1D:,ST/ITE,'S 02 IM $ 01.20° E. - A0004282036 AP R16 209 OMSERVICL: M41 FpFROM ZIPGOOE 07092 This Certificate of Mailing provides evidence that malt has been presented to USPSe for mapUte.This form may and Intematlonal mall. Prom: Scott A. Dietterick, Esquire �,�FtEL3.N�0 c/o Zucker,Goldberg&Ackerman, LLC o 200 Sheffield Street,Suite 101 i Mountainside, N1 07092 AM XFP-164961/sde TEAM C To: Pomark Here UNKNOWN SPOUSE st 30 Wyrick Avenue VSPS Shippensburg, PA 17257-1734 i County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065. I i S i { SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ILED Sheriff 'H E P R 0 T H.0 N 0 IFA R Y Jody S Smith ° Chief Deputy �n -.4 2013 AUG 27 # Richard W Stewart CUMBERLAND COUNTY Solicitor OFFICE OFFPEWERIFF PENNSYLVANIA , Wells Fargo Bank, N.A. Case Number vs. Linda A. Brunner 2012-2249 SHERIFF'S RETURN OF SERVICE 04/02/2013 07:20 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 30 Wyrick Avenue, Shippensburg Township, Shippensburg, PA 17257, Cumberland County. 04/02/2013 07:20 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Linda A. Brunner, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 30 Wyrick Avenue, Shippensburg, PA 17257, property is vacant, defendant left forwarding at post office of: 2612 Banbury Lane, Chambersburg, PA 17202. 04/12/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Linda A. Brunner, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Franklin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 05/14/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Franklin County upon Linda A. Brunner, personally, at the Franklin County Sheriffs Office, 157 Lincoln Way East, Chambersburg, PA 17201 So Answers: Jonathan Nalewak, Deputy Sheriff. 06/05/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on June 5, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Scott Dietterick, on behalf of Wells Fargo Bank, NA, being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $1,059.85 SO ANSWERS, 6Z ylooaz__� August 19, 2013 RON R ANDERSON, SHERIFF 0 (c)CountySuite Sheriff,Teleosoft,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 12-2249-CIVILTERM VS. Execution No.: LINDA A. BRUNNER; Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action,sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 30 Wyrick Avenue,Shippensburg, PA 17257-1734. 1. Name and Address of Owner(s)or Reputed Owner(s): LINDA A. BRUNNER, SINGLE WOMAN 30 Wyrick Avenue Shippensburg, PA 17257-1734 2. Name and Address of Defendant(s) in the Judgment: LINDA A. BRUNNER 30 Wyrick Avenue Shippensburg, PA 17257-1734 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, N.A. Plaintiff 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff /,s;i;;r.:;;zl tiscre.k.,lckcnnan. 11C XH1-1049)] 4 u THE LOMAS AND NETTLETON COMPANY 2001 Eyron Tower Dallas,TX 75201 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC.,AS NOMINEE FOR SIERRA PACIFIC MORTGAGE COMPANY, INC. P.O. Box 2026 Flint, MI 48501-2026 AND 50 Iron Point Circle,Suite 200 Folsom,CA 95630 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 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: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 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: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 30 Wyrick Avenue Shippensburg, PA 17257-1734 UNKNOWN SPOUSE 30 Wyrick Avenue Shippensburg, PA 17257-1734 /uck r.6oldN.ri,&,\ckerman. H C X F F-164961 PA DEPT.OF REVENUE-INHERITANCE TAX DIVISION Dept.280601 Harrisburg, PA 17128-0601 1 verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ZUCKER CK RMAN, L Dated: BY: GOLDBERG? 3115 Scott A. 6i erick, Esquire; PA I.D.#55650 Kimberly A. Bonner, Esquire; PA.I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M. Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.:XFP-164961 (908)233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com &Ack-crinan,1.1 C X1 11-164961 } Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND, WITH A ONE AND ONE HALF STORY FRAME DWELLING HOUSE AND GARAGE ERECTED THEREON, SITUATE IN THE TOWNSHIP OF SHIPPENSBURG,COUNTY OF CUMBERLAND,AND STATE OF PENNSYLVANIA, AND BEING KNOWN AS LOT NO. 22 AS SHOWN IN THE PLAN OF LOTS RECORDED IN PLAN BOOK 4 PAGE 50,AND KNOWN AS JOHN A. WYRICK'S DEVELOPMENT: ' THE SAID LOT BEING BOUNDED ON THE EAST BY SHIPPEN STREET; ON THE SOUTH BY LOT NO.23; ON THE WEST BY LAND NOW OR FORMERLY OF H. H. HOY; ON THE NORTH BY LOT NO. 21. SAID LOT HAVING A FRONTAGE ON 75 FEET ON SHIPPEN STREET AND AN EVEN DEPTH OF 200 FEET FROM THE CENTER OF SHIPPEN STREET TO LAND NOW OR FORMERLY OF H. H. HOY. HAVING thereon erected a dwelling house being known and numbered as 30 Wyrick Avenue, Shippensburg, PA, 17257-1734. BEING the same premises which Myra L. Yingling, single, by Deed dated May 31, 2002 and recorded June 7, 2002 in and for Cumberland County, Pennsylvania, in Deed Book Volume 252, Page 476, granted and conveyed unto LINDA A. BRUNNER, single woman. Tax Map No.:36-36-2424-004. Zucker,Goldberg&Ackerman, LLC XFP-164961 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 12-2249-CIVILTERM LINDA A. BRUNNER; Defendant. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 LINDA A. BRUNNER 30 Wyrick Avenue Shippensburg, PA 17257-1734 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/5/2013 at 10:00am 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: 30 Wyrick Avenue,Shippensburg, PA, 17257-1734 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-2249-CIVILTERM THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: LINDA A. BRUNNER,Single Woman Zucker,Goldberg&Ackerman,LLC XFP-164961 f �Y n 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: 1. 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. Zucker,Goldberg&Ackerman, LLC XFP-164961 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 Sheriff's Deed is delivered. 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 17013-3387, before presentation of the petition to the Court. ZUCKER GOLDBZE-RKtGj && KERMAN, LLLLCL/ Dated: BY: Scott A. Die `rick, Esquire; PAI.D.#55650 Kimberly A. Bonner, Esquire; PA.I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D. #311032 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 File No.:XFP-164961 (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-164961 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND, WITH A ONE AND ONE HALF STORY FRAME DWELLING HOUSE AND GARAGE ERECTED THEREON, SITUATE IN THE TOWNSHIP OF SHIPPENSBURG, COUNTY OF CUMBERLAND, AND STATE OF PENNSYLVANIA, AND BEING KNOWN AS LOT NO. 22 AS SHOWN IN THE PLAN OF LOTS RECORDED IN PLAN BOOK 4, PAGE 50,AND KNOWN AS JOHN A. WYRICK'S DEVELOPMENT: THE SAID LOT BEING BOUNDED ON THE EAST BY SHIPPEN STREET; ON THE SOUTH BY LOT NO. 23; ON THE WEST BY LAND NOW OR FORMERLY OF H. H. HOY; ON THE NORTH BY LOT NO. 21. SAID LOT HAVING A FRONTAGE ON 75 FEET ON SHIPPEN STREET AND AN EVEN DEPTH OF 200 FEET FROM THE CENTER OF SHIPPEN STREET TO LAND NOW OR FORMERLY OF H. H. HOY. HAVING thereon erected a dwelling house being known and numbered as 30 Wyrick Avenue, Shippensburg, PA, 17257-1734. BEING the same premises which Myra L. Yingling,single, by Deed dated May 31, 2002 and recorded June 7, 2002 in and for Cumberland County, Pennsylvania, in Deed Book Volume 252, Page 476,granted and conveyed unto LINDA A. BRUNNER, single woman. Tax Map No.: 36-36-2424-004. Zucker,Goldberg&Ackerman, LLC XFP-164961 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-2249 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK,NA, Plaintiff(s) From LINDA A. BRUNNER (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: $128,739.09 L.L.:$.50 Interest from 8/8/2012 to Date of Sale -- S6,386.86 Atty's Comm: Due Prothy: $2.25 Atty Paid:$196.75 Other Costs: Plaintiff Paid: Date: 2/7/2013 David D.Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name: JAIME R. ACKERMAN, ESQUIRE Address: ZUCKER,GOLDBERG& ACKERMAN,LLC 200 SHEFFIELD STREET,SUITE 101 MOUNTAINSIDE,NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No.311032 g R U C f ,(r a ry E In Testirnony whE':reof: S h--, urdQ s6l.rnv hand and the seal of saie.Co�uDrt/at Carli i , 'Pa'2 This day of�. 20 /-R Prothontt On March 12, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Shippensburg Township, Cumberland County, PA, Known and numbered as, 30 Wyrick Avenue, Shippensburg, Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 12, 2013 By: 1 Real Estate Coordinator x � CUMBERLAND LAW JOURNAL Writ No. 2012-2249 Civil WELLS FARGO BANK, N.A. vs. LINDA A. BRUNNER Atty.:Jaime R.Ackerman ALL THAT CERTAIN tract of land, with a one and one half story frame dwelling house and garage erected thereon, situate in the Township of Shippensburg, County of Cumber- land,and State of Pennsylvania,and being known as Lot No.22 as shown in the Plan of Lots recorded in Plan Book 4,Page 50,and known as John A.Wyrick's Development: THE SAID LOT being bounded on the east by Shippen Street; on the south by Lot No. 23; on the west by land now or formerly of H.H.Hoy;on the north by Lot No. 21. SAID LOT having a frontage on 75 feet on Shippen Street and an even depth of 200 feet from the center of Shippen Street to land now or for- merly of H. H. Hoy. HAVING thereon erected a dwell- ing house being known and num- bered as 30 Wyrick Avenue, Ship- pensburg,PA, 17257-1734. BEING the same premises which Myra L. Yingling, single, by Deed dated May 31, 2002 and recorded June 7,2002 in and for Cumberland County,Pennsylvania,in Deed Book Volume 252,Page 476,granted and conveyed unto LINDA A.BRUNNER, single woman. Tax Map No.: 36-36-2424-004. 23 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: April 12, April 19 and April 26, 2013 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. sa Mari6 Coyne, Ed' or SWORN TO AND SUBSCRIBED before me this Cl�z of A ril 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. - a 2020 Technology Pkwy the atr1*otwXews 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 Marianne Miller, 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: 2012-2249 Civil 04/16/13 ELLS FARGO BANK,NA 04/23/13 VS. c LINDA A.BRUNNER 04/30/13 Atty. Jaime R Ackerman ALL THAT CERTAIN TRACT OF . . . . . . . . . . . . . . . . . . . . . . . . LAND,WITH A ONE AND ONE HALF STORY FRAME DWELLING HOUSE AND GARAGE ERECTED THEREON, SITUATE IN THE TOWNSHIP of Sworn to and subscryNryPublic this 13 day of May, 2013 A.D. SHIPPENSBURG, COUNTY OF �I] +1 CUMBERLAND, AND STATE OF `//,IL/I PENNSYLVANIA,AND BEING KNOWN AS LOT NO. 22 AS SHOWN IN THE PLAN OF LOTS RECORDED IN PLAN BOOK 4, PAGE 50,AND KNOWN AS JOHN A.WYRICK'S DEVELOPMENT. THE SAID LOT BEING BOUNDED ON THE EAST BY SHIPPEN STREET;ON COMMONWEALTH OF PENNSYLVANIA THE SOUTH BY LOT NO.23;ON THE WEST BY LAND NOW OR FORMERLY Notarial Seal OF H. H. HOY; ON THE NORTH BY Holly Lynn Warfel,Notary Public LOT NO.21. Washington Twp.,Dauphin County SAID LOT HAVING A FRONTAGE ON My Commission Expires Dec.12,2016 75 FEET ON SHIPPEN STREET AND AN MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES EVEN DEPTH OF 200 FEET FROM THE CENTER OFSHIPPENSrREEf To LAND NOW OR FORMERLY OF H.N.HOY COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: 1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Wells Fargo Bank,NA is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2013, under and by virtue of a writ Execution issued on the 7th day of February, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 2249, at the suit of Wells Fargo Bank, -NA against Linda a. Brunner is duly recorded as Instrument Number 201328468. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this of &_, A.D. Ij Ulf Recorder of Deeds e or Of county,carw PA ar My Co ov tn1missil Expires the Fat Monday of Jan,2014