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HomeMy WebLinkAbout12-2353IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAMA rm... WELLS FARGO BANK, N.A., CIVIL DIVISION - °1 i Plaintiff, NO.: if a-a3:S 77- e; VS. TYPE OF PLEADING =r' ;_-; &,I- Jeffrey L. Moore; CIVIL ACTION - COMPLAINT " Defendant. IN MORTGAGE FORECLOSURE TO: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3476 Stateview Blvd., MAC # X7801-013 Ft. Mill, SC 29715 AND THE DEFENDANT: 17 Circle Drive Mechanicsburg, PA 17055-6140 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTEDA THIS LIEN IS ATTORNEY ATTY FILE NO.: XFP 158688 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(@zuckergoIdberg.com File No.: XFP-158688/bga s C?? 003.75 ?d Zucker, Goldberg & Ackerman, LLC XFP-158688 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Jeffrey L. Moore; 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 Zucker, Goldberg & Ackerman, LLC XFP-158688 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.. Jeffrey L. Moore; Defendant(s). AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar accion dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI 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 LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-158688 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Jeffrey L. Moore; Defendant(s). CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff") located at 3476 Stateview Blvd., MAC # X7801-013, Ft. Mill, SC 29715. 2. Defendant, Jeffrey L. Moore, is an individual whose last known address is 17 Circle Drive, Mechanicsburg, PA 17055-6140. 3. On or about June 23, 2008, Jeffrey L. Moore executed a Note in favor of Integrity Home Funding, LLC in the original principal amount of $107,153.00. 4. On or about June 23, 2008, as security for payment of the aforesaid Note, Jeffrey L. Moore, a single person, made, executed and delivered to Integrity Home Funding, LLC, organized and existing under the laws of Delaware a Mortgage in the original principal amount of $107,153.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on June 26, 2008, Instrument #200821564. 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 Integrity Home Funding, LLC to Wells Fargo Bank, N.A., plaintiff herein, pursuant to an assignment of mortgage dated June 23, 2008 and recorded on June 26, 2008 in the Office of the Recorder of Deeds for Cumberland County, Instrument #200821565. 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 July 2011 payment, and pursuant to the terms of the aforesaid Mortgage, after written notice of Zucker, Goldberg & Ackerman, LLC XFP-158688 said default to Defendant(s), the entire principal balance and accrued interest due thereunder has been accelerated. 7. Jeffrey L. Moore, single, is the record and real owner of the aforesaid mortgaged premises. 8. Plaintiff was not required to send Defendant(s) written notice of Plaintiff's intention to foreclose said Mortgage pursuant to 41 P.S. §403 (Act 6 of 1974) prior to the commencement of this action for the reason that the original principal balance of the aforesaid Mortgage is more than the original principal balance threshold of the Act, and therefore: (a) said Mortgage is not a "residential mortgage" as defined in 41 P.S. §101; (b) the Defendant(s) is/are not "residential mortgage debtor(s)" as defined in 41 P.S. §101, and; (c) the mortgage premises is not "residential real property" as defined in 41 P.S. §101. 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 $103,083.87 Interest through 04/04/2012 $5,205.04 Escrow Advance $1,346.14 Suspense Balance ($337.18) Late Charges $275.06 Inspection Fees $140.00 Total $109,712.93 plus interest on the principal sum ($103,083.87) at the daily per diem amount of $16.95, 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. Zucker, Goldberg & Ackerman, LLC XFP-158688 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 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 $109,712.93, with interest thereon at the daily per diem amount of $16.95 plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. Dated: ?/P I+ 1 ZUCKER, GOLD?A-AC,KERMAN, BY: Scott A. P'fefferidk, EsgWevPA Y.D. #55650 Kimb y 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-158688/bga 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoIdberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP-158688 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-158688 i E . e Prepared By: INTEGRITY HOME FUNDING, LLC 111 CONTINENTAL DR, SUITE 114, NEWARK, DE 197130000 Return To: WFHM FINAL DOCS X9999-OIN 1000 BLUE GENTIAN ROAD EAGAN, MN 55121 Parcel Number: Premises: 411 MILLER AVE NEW CUMBERLAND [Space AlIove This Line For Recording Data) FHA Case No. Commonwealth of Pennsylvania MORTGAGE -? THIS MORTGAGE ("Security Instrument") is given on JUNE 23, 2008 The Mortgagor is JEFFREY L MOORE, A SINGLE PERSON ("Borrower"). This Security Instrument is given to INTEGRITY HOME FUNDING, LLC INTEGRITY HOME FUNDING, LLC which is organized and existing under the laws of THE STATE OF DELAWARE , and whose address is P.O. BOX 11701, NEWARK, NJ 071014701 ("Leader"). Borrower owes Lender the principal sum of ONE HUNDRED SEVEN THOUSAND ONE HUNDRED FIFTY THREE AND 00/100 Dollars (U.S. $ ********107,153 .00 NMFL #0642 (PAFM) Rev 4/24/2006 F11A Pennsylvania Mortgage- 4/96 410, -4R(PA) (o5oe) VMP Mortgage Solutiona Inc. , Papa 1 of a Irwtida: C 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 anl payable on JULY 01, 2038 . This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Hoirower's covens and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to the Lender the following described property located in CtJMURLMD County. Pennsylvanian **Rzz ATTACKED which has the address of 411 MILLSR AVE IS-1 KW CUMBERLAND icityl,Pennsylvada 17070 lyroCO&I ("Property Address"); TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances and fixtures new 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 COVENANTS that Borrower is lawfully seized.of the estate bereby 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 ddend generally the title to :the Property ayainst:all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property- Borrower and Lender covettant and agree AS follows: UNIFORM COVENANTS. 1. Payment of PrindpaL Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by die Note and late cbarges due under the Note, 2. Montdrly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly payment, together with the principal and imerest as set forth in the Note and any late charges, a sum for "(0) taxes and special assessments levied or to be levied against the Property, (b) lew-bold payments or ground rents on the Property, and (c) premiums for insurance requited under paragraph 4, in any year in which the Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary'), or in any year in which such premium would have been required if Lauder still held the Security Instrument, each monthly payment shall also include either, (I) a SUM for the Hx,k ?.t`L?ar 9ft-4RIPAI oocaet PR. 2 r 0 amnat mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by die Secretary . Except for the monthly charge by the Secretary; these item are called "Escrow It=" and the sums paid to Lender are called "Escrow Funds.' Lender may, at any time, collect and hold amounts for Escrow Item 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 1474, 12 U.S.C. Section 7641 et seq. and implementing regulations, 24 CPR Part 3300, 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 tray 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 rop red by RFSPA. If the amounts of 1lmds 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 Lander 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. Applieatton of Payments. All payments under paragrapbs 1 and 2 shall be applied by Lender as follows= EjW, to the mortgage insurance prernium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mottgop insurance premiun Socond, to any taxes, special assessments, leasehold payments or ground rents, and fire, }food and other hazard Insurance premiums, as required; jhd, to interest due under the Note; ftgth, to amortization of the principal of the Note; and Pifth, to late charges dim under the Note. 4. Fire, Flood and Other Hazard Insurance. 3orrower 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 shalt also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance polices and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a fmmacceptable to, Lender. In the event of loss, Borrower shall give Lender inmuediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized auxl directed to make payment for such lass directly to Lender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may he 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 die damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are refCrr+ed to in paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the ctuity legally entitled thereto. dft awn- PA) .taeoam o.c*3s. l in the event of foreclosure of this Security instrument or other transfer of title to the Property that extoguishes 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 AppNt aflon; 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, tralm Lender determines that requirement will cause undue hudahip for Borrower, or unless extett"ting circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower stall 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 ad 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, repreSent3tion3 Concerning Borrower's occupancy of the Property as a principal residence. If this Security Inarument is on a leasehold, Borrower shall coaply 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. f. 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 (Vote and this Security Instrument, first to any delinquent amounts applied in the order provided in paragraph 1, 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 ptot:eeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's nights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by paragraph 2, or faits to perform any other covenams 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 io:prowct 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 as 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. Borrower shall promptly discharge any Gen 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 mater 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 enforeenwrit of the lien; or (c) socures 44AR OA) mm) rq. a a s from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security hasttwerent. 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 tabs one or more of the actions set forth above within 10 days of the giving of notice. $. Fees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations issued by the Secrewry, in the case of payment defaults, require immediate payment in full of all sums secured by &a 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-3t. Germain Depository Institutions Act of 1992, 12 U.S' C. 1701j-3(d)) and with the prior approval of the Secretary, require dmmediatepayment in full of all sums secured by this Security Instrumemi if; (i) All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, is sold or otherwise uansfcrred (other than by devise or descent), aM (ii) The Property is not occupied by the purchaser or gramee as his or her principal' residence, or the purchaser or grantee does so occupy the Property but his or her credit has not hem V. in aceordanee 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 regutlations issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require immediate payment in fait and foreclose if not paid. This Security Instrument does not authorize acctleratiou 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 shoed subsequent to 60 days from the date hereof, declining to irwre this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility- Notwithstanding the foregoing, this option may not be exercised by lender when the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to time Secretary. 10. Reinstatement. Borrower has a tight to be reinstated if Lender has required immediate payment in fall 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 dump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall remain in effect as if Lender had not requited immediate, payment in full. However, Lender is not required to permit reinstatement if. (0 Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosuire dft-4RIPA) towat f4pae oe s proceeding, (n) reinstatement will preclude foreclosure on different grounds in the fugue, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance 8y Leader Not a Waiver. Extension of the time of payment or modification of amortizadoa of the sutras 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 sucT=or in interest. Lender shall not be required to comme= proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint and Several Liabllky; Co-Signers. The tovettants and agreetneras of this Security instrument shall bind and benefit the successors and assigns of Leader and Borrower, subject to the provisions of paragraph 9(b). Borrower's covewntss and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does trot execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instmmem; (b) is not personally obligated to pay the sums secured by this Security Instntment•, and (c) agrees that Lender and any other Borrower my 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 mall unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by naive 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 "I 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 am the law of the jurisdiction in which the Property is located. In the event that any provision or clause, of this Security Justmment or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security instrument or the Note which can be given effect without the conflicting provision.. To this end the provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument, 16. Hazardous Subamces. 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 elf any. EavironmenW Law. The preceding two sebttnces shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to mauitenarce 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 Enviromnental Law of which Borrower has actual knowledge. If Borrower learns; or is notified by any governmental or regulatory authority, that any removal or other retncdiation of any Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Bnviromnerwl Law. As used in this paragraph 16, `Hazardous Sulm"nces" art those substances defined as toxic or hazardous substances by Bnvironmental Law and the following substance: gasoline, rerowne, other flammable or toxic petroleum pmihtcts, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or forwaldehydc, and radioactive materials. As used in this paragraph 16, t 4plPAl manor rq. s cr e iMraK J 'Pavirournotal Law' means<federal laws and laws of the jurisdiction' when the Property is located that relate to health, safety or environmental protection. NON-UNIFORM COVENANTS. Borrower and Lender further eoveaut and agree as follows: 11. Assignment of Rents. Borrower unconditionally asaigas 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 Leader 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 assignmm for additional security only. If Lender gives notice of breach to Borrower: (a) all rem received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each itnant 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 bas 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. Tender 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 may 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 payrneatIn full under parngrapb 9, Lender may foreclose this Security Instrument by judicial pnxeedtng. Lender shall be eadded to collect all expensts incurred In pursuing the remedies provided in this paragraph 18, Including, but not lhrnited to, attorneys' fees and costs of title evidence. If the Lender's Interest In this Security tnOmmeat is held by the Secretary and the Secretary regains immediate payment in full under Paragraph 9, the Secretary mny invoke the eon4judicial power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act's (12 U.S.C. 3751 er seq.) by regeestiag a forectasure commissioner designated under the Act to commence foreclosure and to sell the Property as provided In the Act. Noddog In the preceding sentence altar[ deprive the Secretary of any rights otherwise available to a Leader under this Paragraph 19 or applicable taw. 19. Release. Upon paymcot of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such oecuirtmoa, Lender shah! discharge and satisfy thus Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and relents 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 thm'attathment, levy and sale, and homestead exemption. 21. Reitsstaternent Period. Borrower's time to reinstate provided in paragraph 10 shall extend 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 Bontoursto acquire title to the Property, this Security Instrument al It be a purchase money mortgage. 23. interest Rate After Judgment. Borrower agrees that the interest tote 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. iduac _h,?.flt?. dft-40{PA)eoeoan vp. 7 0 t 0 24, Riders to ttils Security b tstrumwt 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 ant! shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) a part of this Security Lnstnmcnt. [( k applicable box(es)]. Condominium Rider ?J Growing Bquity Rider ? Other [spec) j 11 Planned Unit Development Rider ? Graduated Payment Rider BY SIGMN OW, Borrower ttcsepts and agrees to the terms contained in this Security Ins"Ument And - at?y ' s) executed by Borrower and recorded with it. Witnesseg: ?? III lat.= (Seal) 8tlonuwer -(W -Borrower (Seal) (Seat) -BOrwwer -Borrower (Seal) (Seri)' Borrower _Borrower (Seal); (Sea!) Borrower Bonowet ARIPAi (ows) a r s t e L „ COMMONWEALT11 OF PENNSYLVANIA, Onthis, 43RD dayof JUN'; 2006 personally appeared JBIPYRZY L MOORS kntrwn to me,(or 9d3ficto90y pro-) to be the person(s) whose' name istare subscribed to the within insitument and acknowledged that 4e sWthey executed the same fdr the purposes herein contained. IN WITNESS WHMMEQP, I hereunto set my hand and off l My Commission Expires: Tittc of Offer NOTARIAL 384E REM L. MURRAY, Th=160A {tcun,k am. 00"bsrh? MyCemrn*1anExpLmflea il.2009 Cerfifteatte of Raidence County sst, before me, the undersigned officer, I, , do hereby cert}>Fy that the correct address of the within-named Lender is P.O. HDx 11701, NZWARX, NJ 071014701 Witness my hand this 23RD day, of JM 2006 , AaeM of'I:cnder 4k-4nlPAI away P"s 1 -1$ , • li Exhibit A ALL that certain tract or parcel of land and premises, situate, lying and being in the Borough of New Cumberland, in the County of Cumberland, and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the northern line of Miller Avenue, said point being one hundred thirty and ninety-five hundredths (130.95) feet in a westerly direction from the western line of Reno Street; thence along the northern fine of Miller Avenue south forty- four (44) degrees thirty (30) minutes west, twenty-five (25) feet to a point; thence through the center of a partition wall, separating the premises 411 Miller Avenue and 413 Miller Avenue, and beyond, north forty-five (45) degrees thirty (30) seconds West, fifty-four and forty bundredths (54.40) feet to a stake on line of lands now or We of Jacob Zimmerman; thence north forty-four (44) degrees thirty (30) minutes east, twenty-five (25) feet to a stake on the blue of lands now or late of Stanley and Francis Dodson; thence south forty-five (45) degrees thirty (30) minutes east, fifty-four and forty hundredths (54.40) feet to a point on the northern line of Miller Avenue, the place of BEGINNING BEING the easterly 5.95 feet of the southern portion of Lot No. 28 and the westerly 14.05 feet of the southern portion of Lot No. 29, Block "M", Plan of Buttorff's Addition,; recorded In the Cumberland County Recorder's OfAce in Deed Book "N", Volume 5, Page 493 HAVING thereon erected a two and one-half story semi-detaehed brick and frame dwelling house known as 411 Miner Avenue, New Cumberland, PA. ? , , 40 VERIFICATION Florence Gomez, hereby states that he/& Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter, that he es authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of hi er i formation 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: Y-5 I-r- I , NAME: Moore FILE #: 158688 032-PAN3 Title: Vice President Loan Documentation FORM 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) I eC? # e D ono 1?J?? vs. .20i.2 Carrbeddrd boon Defendant(s) a ' ?35 Civil --?re-l/Y" 7?,nnsylvgtw NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conferee ;e in an effort to resolve this matter with your lender. If you do not bave a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attLehed hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Date FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete-your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different) City: Phone Numbers: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: _ State: Zip: Yes ? No [.] Listing date: Price: $_ Realtor Phone: Yes ? No ? State: Zip: Home: Office: Cell: Other: How long? State: Zip: Home: Cell: Office: Other: How long? First Mortgage Lender: _ Type of Loan: Loan Number: _ Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount, $ Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: Is the loan in Bankruptcy? Yes [] No ? . If yes, provide names, location of court, case number & attorney: Assets_ Amount Owed: Value: Home: $ _ ? $ Other Real Estate: $ $ Retirement Funds: $ _ $ Investments: $ _ $ Checking: $ _ $ Savings: $ $ Other: $ $ Automobile #1: Model: Amount owed: Value: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles mQtore cles : Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Year: Year: 2. 3. _ Additional Income Description (not wages): I . monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrov ^sr Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) FEXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2n lviortgage Utilities Car Payment(s) Condo/Nei h. Fees _ Auto Insurance Med. not covered Auto fuel/re airs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Money Day/Child Care/Tuit. _ Other Expenses ------ Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling A gency? Yes ? No ? If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax:- 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name):__.___ Contact: Phone: I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information to lender and lender's counsel: Y Proof of income V( Past 2 bank statements V Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) FORM 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) VS. Defendant(s) : CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date FORM 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) CIVIL ACTIOI-, vs. NO. Defendant(s) CASE MANAGEMENT ORDER AND NOW, this day of , 20 , the defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the dis retion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation C )nference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lend( a deed in lieu of foreclosure; entering into a loan modification or a reverse nortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Zucker, Goldberg & Ackerman, LLC XFP-158688 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor V 'S SHERIFF'S OFFICE OF CUMBERLAND COUNTT - © - ?. co 00 Wells Fargo Bank, N.A. vs. Jeffrey L. Moore Case Number 2012-2353 SHERIFF'S RETURN OF SERVICE 05/07/2012 04:43 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 7, 2012 at 1643 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jeffrey L. Moore, by making known unto Bill Moore, Father of Defendant at 17 Circle Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. Request for service at 411 Miller Avenue, New Cumberland, Pennsylvania 17070 is vacant. SHERIFF COST: $43.00 May 09, 2012 RYAN BURGETT, DE SO ANSWERS, l RON R ANDERSON, SHERIFF C7j C N -? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV c .. .rn :0 ?- ! -ern 35 F_ .-- CD ?y. Wells Fargo Bank, N.A., CIVIL DIVISION Q 4C) ? Q Zo C) Plaintiff No.: 12-2353-CIVIL C CD --4r" VS. ISSUE NUMBER: Jeffrey L. Moore; Defendant(s). Mortgaged Premises: 411 Miller Avenue, New Cumberland, PA 17070- 1867 TYPE OF PLEADING: PRAECIPE FOR ENTRY OF JUDGMENT BY D (MORTGAGE FORECLOSURE) FILED ON BEHALF OF: Wells Fargo Bank, N.A. Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa I.D.# 55650 Kimberly A. Bonner, Esquire- Pa I.D. #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, N1 07092 (908) 233-8500 Atty File No.: XFP-158688 C k. ? Praecipe for Entry of Judgmen Zucker, Goldberg & Ackerman, LLB XFP-158681 ULT ia?3 a- 1 17?5`f ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 12-2353-CIVIL VS. ' Jeffrey L. Moore; 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 Plaintiff's Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as follows: Amount as set forth in Complaint $109,712.93 Interest from Complaint date through 06/21/2012 $1,305.15 Late Charges $51.40 TOTAL $111,069.48 plus interest on the judgment amount ($111,069.48) from June 22, 2012, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 17 Circle Drive address is: Mechanicsburg, PA 17055- 6140 ZUCKER, GOLBERG & ACKERMAN, LLC Dated: U -M I, BY; r)f-\n Uln ,?- Joel . ckerman, Esquire; PA I.D. #202729 L!I I Ashleigh L. Marin, Esquire; PA I.D. #306799 ? Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-158688 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@z ergol erg.c DAMAGES ARE HEREBY ASSESSED AS INDICATED Date Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 12-2353-CIVIL vs. Jeffrey L. Moore; 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 t law, do hereby depose and say that the statements made herein are true in and correct to the best c my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the be! 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.I 237.1 and that the time limits provided for that notice have expired. ZUCKER, GOLBERG & ACKERMAN, LLC Dated: BY: n Joel A. ckerman, squire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-158688 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Sworn to and subscribed before me This Z D day of :1 ?k r4- I` 20 % Z_ Notary lic My Commission Expires: EDWARD J. SCHWAHL II l? Commission # 2383239 Notary Public, State of New Jersey My Commission Expires March eg, 2014 Zucker, Goldberg & Ackerman, XFP-158 Department of Defense Manpower Data Center Status Report Furst to Servicemtembers (Civil Relief Act Last Name: MOORE First Name: JEFFREY L Active Duty Status As Of: Jun-21-2012 Results as of : Jun-21-2012 11:59:40 SCRA 2.2.1 Active Daly SW Date A bm Duly End Date status SerAm CernporleM On Active Duty On Active Dt4 31" Doe NA NA No NA This response reflects the individuals' active duty status based on the Active Duty Status Date left Active Duty Within 367 Days of Active Duty status Date Active Duty start Date Active Duty Erd Date Status Service component NA NA No NA This response reflects where the indvdual left active duty status within 367 days preceding the Active Duty Status Date The Mornber or Hte/Mer unit Was NoWed of a Future CsIWp to Arrive poly on Active Duty Status Date Order Notifikisdan Mad Date Order Noilkadon End Oats status Servir» CDMPMOM NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Heal Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. hhj A and of Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Th13 Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official 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 at seq, as amended) (SCRA) (formerly kno% n 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 active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family 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 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: hftp://www.defenselink.miUfaglpis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty st us 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( ). 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 certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less 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 authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared 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 erve 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 not 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 pan 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 CRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the S RA 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: P5VB151H88 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 12-2353-CIVIL Jeffrey L. Moore; Defendant(s). NOTICE OF ORDER, DECREE OR JUDGMENT TO: Jeffrey L. Moore 17 Circle Drive Mechanicsburg, PA 17055-6140 [ ) Plaintiff [V] Defendant [ j Additional Defendant You are hereby notified t at In Order, Decree or Judgment was entered in the above captioned proceeding on [ j A copy of the Order or Decree is enclosed, or [V) The judgment is as follows: $111,069.48 plus co o? Zucker, Goldberg & Ackerman, XFP-158 SHERIFF'S OFFICE OF CUMBERLAND COUNTTeroi Ronny R Anderson Sheriff t 4uurf?rr???i yitr 00% r } S '? Jody S Smith e "- Chief Deputy Co o Richard W Stewart Solicitor a=:.°r c'?fr?,.: Wells Fargo Bank, N.A. vs. Case Number Jeffrey L. Moore 2012-2353 SHERIFF'S RETURN OF SERVICE 05/07/2012 04:43 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 7, 2012 at 1643 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jeffrey L. Moore, by making known unto Bill Moore, Father of Defendant at 17 Circle Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. Request for service at 411 Miller Avenue, New Cumberland, Pennsylvania 17070 is vacant. RYAN BURGETT, SHERIFF COST: $43.00 May 09, 2012 SO ANSWERS, R ANDERSON, SHERIFF r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION VS. Jeffrey L. Moore Defendant. NO.: 12-2353-CIVIL IMPORTANT NOTICE TO: Jeffrey L. Moore 17 Circle Drive Mechanicsburg, PA 17055-6140 DATE OF NOTICE: 6/11/2012 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within 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) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. Jeffrey L. Moore TO: Jeffrey L. Moore 17 Circle Drive Mechanicsburg, PA 17055-6140 Defendant. NO.: 12-2353-CIVIL ANV-- EVARCRTANM FECHA DEL AVISO:6/11/2012 LL= =A ENRLffiIZA PCRQUF- HA FALL AM M TUAAR LA AM(IN IN E M CA-";',Q A NIIVC S QLE DYED TC1VE AMCN I&NM IJE Los PRCVMVM D? (1C? DIAS EE IA FDCFA 1CEESIEANM, SE PLJa:E E1CTAR UNFALUO FN OCNI LA SUYA SN IIFUARSEA CABO LNA VISTA Y LMM R?B::>E Pmt SU PRCFEEIND Y OIRCZS L'1F117C HDS MCUTANIFS USIFD DES IT EVAR ESIE DOG-DAE1% L7 INAIDATAN&?TM A SU A13C7C AM S[ LN ED NC ITENIE UN ABOCv DO 0 NO PIELE PAGAR LNQ VAYA O LLANE LA C1,FICEIgA ABATO R\UCADA PARA QE LE RNMEUvEN DCIgE PCFI AYL]- 4 T F1C" A . NOI.ICET0E@!271U &LANV M S1f kACE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 ZUCE11? GOLDBMG & AC ERMAIV BY ck=jk Dieth97cC Scott A Dietteridr, Empire Attorneys far Plaintiff PA ID_ # 55650 200 SheffiddStreet, Suite 301 P_ O. Baer 1024 Mop r tairmde, NJ 07092-0024 (717) 533-3560 FIRST' CLASS U S` MAIL, PCS rAGE PFT PAM 158688 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION File No. 12-2353-CIVIL Wells Fargo Bank, N.A., Amount Due $111,069.48 Plaintiff, Interest from 6/22/2012 to date of sale $4,707.44 vs. - -~ ._ ,,:.- ' Costs `°' Jeffrey L. Moore; - ~.. ' °~ " Defendant. r ~~ r~' -' ' ,,~, -.~ .~ - THE PROTHONOTARY OF THE SAID COURT: "c ~` ~ y ~. The undersigned hereby certifies that the below does not arise out of a retail installment sale;~etraC~of "~ account based on a confession ofjudgment, but if it does, it is based on the appropriate original proceeding fi~i~+d :. pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens described in the attached ex ibit. DATE: ~ ,~ Signature: / Print Name: Sco A. D a~~ ~d8.s~o~ a~ ~~ a cl ~ S ~~ G ~ , ~~, a y 3 . o~ ~ ~2 ~ 5 (( << I Q Il ll ~ to . S real estate of the defendant(s) Esquire K~r'hberly A. Bonner, Esquire Joel Ackerman, Esquire Ashleigh L. Marin, Esquire Ralph M. Salvia, Esquire Jaime R. Ackerman, Esquire eJ Address: Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 Supreme Court ID No.: 55650 89705 202729 ~ ~ 306799 ' S ~ 202946 ~ : S 311032 DI.~_ ~ ~ / n /~ ~~ CJF-~`~ ~ l `Z ~ V TZ~ ~g3(.oSl ~-~ of R~ ~s~d Exhibit "A" LEGAL DESCRIPTION ALL that certain tract ar parcel of land. and premises, situate, lying: and bcing in the Borough of New Cumberland, in the County of Cumberland, and Commanweaith of Pennsylvania, snore particularly described as follows; BEGTNNIFNC at a point on the northern line of Miller Avenue, said point being one hundred thirty and ninety-five hundt~edths (134.95) feet in a westerly direction from the western line of Reno Street; thence slung the northern line of Miller Avenue south forty-four (44}degrees thirty (34) minutes west, twenty-five (25} feet to a point; thence through the center of a partition wall, separating the premises 411 Miller Avenue and 413 Miller Avenue, and beyond, north forty-five (45) degrees flatly (30) seconds west, fifty-four and forty hundredths (54.40) feet to a stake online of lands now ar late of Jacob Zimmerman; thence north forty- four (44) degrees thirty (30) minutes east, twenty-five (25) feet to a stake on the line of tends now or late of Stahl. }+ and Francis Dodson; thence south forty-five (45) degrees ihirty (30} minutes east, filly-four and forty hundredths (54.40) feet tv a point on the northern line of Miller Avenue, the place of BEGINNING. BUNG the easterly 5.95 feet of the southem portion of Lot No. 28 and the westerly 19.OS feet of the southern portion. of Lot No. 29, Block "M", Plan of i3uttorff's Addition, recorded in the Cumberland County Recorder's Office in Deed Book "N", Volume 5, Page 498. HAVING thereon erected a dwelling house being known and numbered as 411 Miller Avenue, New Cumberland, PA, 17070-1867. BEING the same premises which Bernadette A. Kowalczyk, by Deed dated June 23, 2008 and recorded June 26, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume 200821563, Page , granted and conveyed unto Jeffrey L. Moore, single individual. Tax Map No.: 25-24-0811-253. Zucker, Goldberg & Ackerman, LLC XFP-158688 • ,~ _..:? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVL~Nsl~'D- `. P:~ ~~a _ ~' Wells Fargo Bank, N.A., CIVIL DIVISION ~ ~, ;='. Plaintiff, NO.: 12-2353-CIVIL 7~""LL ~. 4== ~~~ vs. - v-- c= Execution No.: ._. Jeffrey L. Moore; . 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 411 Miller Avenue, New Cumberland, PA 17070-1867. 1. Name and Address of Owner(s) or Reputed Owner(s): JEFFREY L. MOORE, SINGLE, 17 Circle Drive Mechanicsburg, PA 17055-6140 2. Name and Address of Defendant(s) in the Judgment: JEFFREY L. MOORE 17 Circle Drive Mechanicsburg, PA 17055-6140 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 INTEGRITY HOME FUNDING, LLC P.O. Box 11701 Newark, NJ 07101-4701 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 411 Miller Avenue New Cumberland, PA 17070-1867 UNKNOWN SPOUSE 17 Circle Drive Mechanicsburg, PA 17055-6140 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I 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. Dated: 1~.'YG! ~~ ZUCKER GOLD~,,R'G & ACKERM , LLC ~~~~ ~ BY: ~ Scott ie teri c, quire; PA I.D. #55650 Ki rly 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-158688 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Exhibit "A" LEGAL DESCRIPTION ALL that certain tract or parcel of land and premises, situate, lying. and being in the Borough of New Cumberland, in the County of iCumberland, and Commonwealth of Pennsylvania, more particularly described as follows _ BE611N1~11~FG at a paint on the northeFn line of Miller Avenue, said point being one hundred thirty and ninety-five hundredths (130.15) feet in a westerly direction from the western line of Reno Street; thence along the northem-litte of Miller Avenue south forty-four (44) degrees _ thirty (30) minutes west, twenty-five (a5) feet to a point; thence through the center of a - partition wall, separating the premises ~F11 Miller Avenue and 413 Miller Avenue, and beyond, north forty-five (45}degrees thirty (30) seconds west, fifty-four and forty hundredths (54.40) feet to a stake online of lands >~tow or late of Jacob Zimmerman; thence north forty- four (44} degrees thirty (30) minutes east, twenty-five (25) feat to a stake on the line of lands : now or late of Stanlay and Francis Dod,on; thence south forty-five (45) degrees thirty (30} minutes east, fifty-four and forty hundredths (54.40) feet to a point on the northern line of - Ivliller Avenue, the place of BEGINNING. BEII•IG the easterly 5.95 feet of the southern portion of Lot No, 28 and the westerly 14.05 feet of the southern portion of Lot No. 29, Block "M", Plan of Buttorff's Addition, recorded - in the Cumberland County Recorder's Office in Deed Book "N", Volume S, Page 498. HAVING thereon erected a dwelling house being known and numbered as 411 Miller Avenue,-New Cumberland, PA, 17070-1867. BEING the same premises which Bernadette A. Kowalczyk, by Deed dated June 23, 2008 and recorded June 26, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume 200821563, Page, granted and conveyed unto Jeffrey L. Moore, single individual. Tax Map No.: 25-24-0811-253. Zucker, Goldberg & Ackerman, LLC XFP-158688 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. Jeffrey L. Moore; Plaintiff, Defendant. CIVIL DIVISION NO.: 12-2353-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Jeffrey L. Moore 17 Circle Drive Mechanicsburg, PA 17055-6140 AND 411 Miller Avenue New Cumberland, PA 17070-1867 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 03/06/2013 at 10:OOam 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: 411 Miller Avenue, New Cumberland, PA, 17070-1867 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-2353-CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Jeffrey L. Moore 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 Zucker, Goldberg & Ackerman, LLC XFP-158688 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. 2. After the Sheriff's 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. Zucker, Goldberg & Ackerman, LLC XFP-158688 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. Dated: ~~~ ~~ ZUCKER GOLDBERG &/kCKERMAN, LLC Scott ietterick, 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-158688 (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-158688 Exhibit "A" LEGAL DESCRIPTION AI.I. that certain tract or parcel of land and premises, situate, lying and bcing in the Borough of Naw Cumberland, in the County of Cumberland, and Commonwealth of t'erutsylvania, more particularly described as follows: BEGINNING at a paint on the northern tine of Miller Avenue, said point being one hundred thirty and ninaty-five hundredths (130.95) feet in a westerly direction from the western line of Reno Street; thence along tha northern line of Miller Avenue south forty-four {4a} degrees thirty (30) miueites west, twenty-five (25} feet to a point; thence thxough the center of a partition wall, separating the premises 411 Miller Avenue and 4i3 Miller Avenue, and beyond, north forty-five (45}degrees thirty (30) seconds avast, fifty-four and forty hundredths (54.40} feet to a stake online of lands now ar late of Jacob Zimmerman; thence north forty- four (44) degrees thirty (30) minutes cast, twenty-five (25) feet to a stake on the line of lands now or late of Stanley and Francis Dodson; thence south forty-five {45) degrees thirty (30} minutes east, fifty-four and forty hundredths (54.44) feet to a point on the northern line of Miller Avenue, the place of HE(3IlVNING. BRING the easterly 5.95 fact of the southern portion of Lot Nv. 2$ and the westerly 19.05 feet of the southarn portion of 1:.ot No. 29, Block "M", Plan of Buttorff's Addition, recorded in the Cumberland County Recorder's Office in Deed Book "N", Volume 5, Page 498. HAVING thereon erected a dwelling house being known and numbered as 411 Miiier Avenue, New Cumberland, PA, 17070-1867. BEING the same premises which Bernadette A. Kowalczyk, by Deed dated June 23, 2008 and recorded June 26, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume 200821563, Page , granted and conveyed unto Jeffrey L. Moore, single ind'+vidual. Tax Map No.: 25-24-0811-253. Zucker, Goldberg & Ackerman, LLC XFP-158688 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-2353 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK, N.A., Plaintiff (s) From JEFFREY L. MOORE (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: $111,069.48 L.L.: $.50 Interest FROM 6/22/2012 TO DATE OF SALE - $4,707.44 Atty's Comm: Due Prothy: $2.25 Atty Paid: $194.25 Other Costs: Plaintiff Paid: Date: 11 /29/12 (Sea!) :iEQUESTING 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 12-2353-CIVIL VS. TYPE OF PLEADING Jeffrey L. Moore; 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 (908)233-8500 (908)233-1390 FAX office @zuckergoldberg.com File No.:XFP- 158688/dsc rrjw xw -I =30 70 art r- car—�3, Co —i to > -< Zucker,Goldberg&Ackerman, LLC XFP-158688 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 12-2353-CIVIL Jeffrey L. Moore; Defendant. I 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 Plaintiffs Notice of Sheriffs Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant,Jeffrey L. Moore,single individual, is the record owner of the real property. 2. On or about December 20,2012, Defendants Jeffrey L. Moore was served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, via Certified Mail, return receipt requested at 17 Circle Drive, Mechanicsburg, PA 17055. 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 January 15, 2013, Plaintiffs counsel served all other parties in interest with Plaintiffs Notice of Sheriffs Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit"B",attached hereto and made a part hereof. Zucker,Goldberg&Ackerman, LLC XFP-158688 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 Plaintiff Dated:April 3, 2013 - DANIEL SCHLESINGER Paralegal/Legal Assistant Sworn to and subscribed before me this 3 day of April, 2013 li C , N tary Public MY COMMISSION EXPIRES: PAUL C.NADRATOWSKI Notary Public of New Jersey ID#2407850 My Commission Expires 4/27/2018 Zucker, Goldberg&Ackerman, LLC XFP-158688 EXHIBIT A Zucker, Goldberg&Ackerman, LLC XFP-158688 Zucker,Goldberg$Ackerman,LLC PO Box 1219 Moun ainsift NJ 07092-1219 7196 9006 9296 3941 9170 20121214-102 0-111-lnn-lllil1il Ill. 111-1111111 Jeffrey L. Moore 17 Circle Dr Mechanicsburg, PA 17055-6140 Ems PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, vs. NO.: 12-2353-CIVIL ' Jeffrey L. Moore, Defendant, NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Jeffrey L. Moore 17 Circle Drive Mechanicsburg, PA 17055-6140 AND 411 Miller Avenue New Cumberland,PA 17070-1867 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 03/06/2013 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: 411 Miller Avenue,New Cumberland,PA,17070-1867 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No.12-2353-CIVIL THE NAME(S)OF THE OWNER(S)OR REPUTED OWNER(S)OF THIS PROPERTY ARE: Jeffrey L. Moore 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 Zucker,Goldberg&Ackerman,LLC XFP-158688 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. ; 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. Zucker,Goldberg&Ackerman,LLC XFP-158688 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&A&ERMAN LLC Dated: ��ij/a BY: Scott ietterick,Esquire; PA I.D.#55650 KimbLArlyA.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 E. Mountainside,NJ 07092 File No.:XFP-158688 (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-158688 Exhibit"A" LEGAL DESCRIPTION ALL that O t'On tract or parcel of land and premises,situate:ly*and being in the Borough of New Cumberland,in-*e Cottaty of Ctunberhnd,and Co»rtnoWMWth of Pennsylvania, more ptaticuiatly described at;follows: UGROiifil W at a PQiRt oa the arnthem litre of Mille Avenue,said point being one hundred thirty and nWtY-fNc Wmkedths(130.95)few in a westerly direction horn the western line of Rena 9hvct,*U"&1=9 the nortltern line of Millar Avenue south forty-four(44)degrees Oft(30)mil W054 twa►ty-five(25)feet to a point,thence ftw*dw cenW of a Pattitiou W#A UPW#dnS the premises 411 Miller Avow and 413 Miller Avenue,and *Wd,north,fty-five(45)dileg m thirty(30)sus west,flk-four aW forty hundredths (54.40)feet to a stake on line of lands now or late of Jacob Zimrnanaw;them north forty- four(44)dqpvw ddM(30)minutes east,twenty-five(25)feet to a stake on the line of lands now or ho of Studay and Francis Dodson;them south forty-five(45)degrees thirty(30) mirrutatl fit,fTSy-f+,00r-Mill fly llutrtiredths.(54.40)feat to a pointon the northern line of Miller Avenue,thaplace of BEOINNIN Bli M the easterly 5,95 feet d-3he souther portion of Lot No.28 and the westerly 1 9.05 feat of the southern portibn of Lot No.29,Block"M",Plan of BUUD fi's Addition,recorded i in the Cutberland County Recorder's Office in Deed Hook"N",Volume 5,Page 498. HAVING thereon erected a dwelling house being known and numbered as 411 Miller Avenue, New Cumberland,PA,17070-1867. BEING the same premises which Bernadette A. Kowalczyk,by Deed dated June 23, 2008 and recorded June 26,2008 in and for Cumberland County,Pennsylvania,In Deed Book Volume 200821563,Page, granted and conveyed unto Jeffrey L.Moore,single individual. Tax Map No.: 25-24-0811-253. Zucker,Goldberg&Ackerman,LLC XFP-158688 2. Article Number 7P-:by P gPC4arhri B. Date of Delivery. r 7196 9006 9296 3941 9170 X AAgeMt rr D. Is delivery address different from rlem 17 Yes It YES,enter dehvery address below: No 3. Service Type MW OM MAIL 4. Reetrictied Delivery? bra Fee) Yes 1. Arti ieAddressedI.. Jeffrey L.Moore Reference Information 17 Circle Dr 158688 Mechanicsburg,PA 17055-6140 PANOSS L121t4MI2 7196 9006 9296 3941 9170-302 PS Form 3811,January 2005 Domestic Return Receipt UNITED STATES POSTAL SERVICE First-Class Mail Postage&Fees Paid LISPS Permit No.G-10 Zucker, Goldberg&Ackerman, LLC PO Box 9076 Temecula, CA 92589-9076 EXHIBIT B Zucker,Goldberg&Ackerman, LLC XFP-158688 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION VS. Plaintiff, NO.: 12-2353-CIVIL Jeffrey L.Moore; x Defendant. ! NOTICE TO L "OLDERS An Qj=LUM IN INTEREST PURSUANT TO Pa jLC.P,3129(b1 TO: UNKNOWN TENANT OR TENANTS UNKNOWN SPOUSE 411 Miller Avenue 17 Circle Drive New Cumberland,PA 17070-1867 Mechanicsburg,PA 17055-6140 i 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 t Cumberland County Courthouse Domestic Relations Section One Courthouse Square 13 N.Hanover Street Carlisle,PA 17013 PO Box 320 i INTEGRITY HOME FUNDING,LLC Carlisle,PA 17013 P.O.Box 11701 Newark,NJ 07101-4701 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 i On 03/06/2013 at 10:00am,the following described real estate which Jeffrey L.Moore,single individual 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: 411 Miller Avenue, New Cumberland,PA 17070-1867 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). Zucker,Qoldberg&Ackerman,LLC i XFP-158688 158688DIO04COI022013PI The said Writ of Execution has been issued on a judgment in the action of 3 Wells Fargo Bank,N.A. Plaintiff VS. Jeffrey L.Moore,et al Defendant(s) at EX.NO. 12-2353-CIVIL in the amount of$111069.48 plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty(30)days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten(10)days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriffs Sale or this Notice,you should contact your attorney as soon as possible. ZUCKER,GOLDBERG&ACKERMAN,LLC Dated: BY qmau-k�A Scott A. Metterick,Esquire; PA I.D.#55650 Kimberly A.Bonner,Esquire; PA I.D.#89705 Joel A.Ackerman,Esquire; PA I.D.#202729 { Ashleigh L.Marin,Esquire; Pa I.D.#306799 Ralph M.Salvia; PA I.D.#202946 Jaime R.Ackerman,Esquire;PA I.D.#311032 F 200 Sheffield Street,Suite 301 Mountainside,NJ 07092 File No.: XFP-158688 (908)233-8500;(908)233-1390 FAX E-mail: Office @zuckergoldberg.com s r F 1 {t I Zucker,Goldberg&Ackerman,LLC j XFP-158688 1586=100401022013P2 i Exhibit"A" LEGAL DESCRIPTION i ALL.,th+ec:cxt�lra.trac�:or oflsnd and.. ... yid n8.. Sh pt+grirses,.si.. 1 sad bel :ui the Borvu Af Nevi► �In the CounW of Cumberland;anit Common of pparuaylvW4. i mmw pbrdly described-#A fbllows: BRUENPOG.at a:Out on the northern line,of Miller Avenue,said point bdq one hundred thirty 044 WWIIY-five lumdredd a(130:95)fat in a westerly dirwtion frmn the vmto n line of RO WSUV04 d"40 along the northern line of Miller Avenue South forty fur(44)degroes x(30)- was, fi"M)feet to a point;thence tlireugh de cer<ter,of a PartWvo.vwdl,$Voting the premises 411.War Argue and 413.M1iler.Ave me,and d;, h*-five(45)den -Uty(30)secorib w ,..gityrtt>uir.eud:forty hutodtvdths (54:48 feOc�o a ;ottai of :now or tale:of Jacob Zirurnmvi i;&am north fi V- : ' mss;twenty 8i�(2:S)!list.to a ataloe on the tide of leads now qs 110W.-.6 q.and t?t de:Dodsow thence south fortriflve(4S)dogma thirty(30) � ! Y: _:00. h' feet.to a point any the r�rQrem lint of !' 1�iller Avenue;to place`of BBCi1NN1Nt'i, BE 4G tlte.e4slaiy S:95 feet of the southern portion of Lot No.28 snd the westerly 19.OS fact of do soud'iorn portion of Lot No.29,Block"M",Plan of ButlortFs Addition,recorded i in the Cumberland County Recorder's Office in Deed Book"N",Voluroe S;Page 498. HAVING thereon erected a dwelling house being known and numbered as 411 Miller Avenue, New Cumberland, PA, 17070-1867. BEING the same premises which Bernadette A.Kowalczyk,by Deed dated June 23,2008 and recorded June 26,2008 in and for Cumberland County,Pennsylvania,in Deed Book Volume 200821563,Page, . granted and conveyed unto Jeffrey L.Moore,single individual. s Tax Map No.:25-24-0811-253. r i 's i { t i i i I f Zucker,Goldberg&Ackerman,LLC XFP-158688 158688D1004C01022013P3 I Page 1 of 4 NOTICE TO LIENHOLDER I '�✓ '°wa f 7 02 1M a 150 ARM 000428 z 2002 i Thk GAFmft*f h1 prwH.t.vM--s tht mA hu been~nbd in tW$O for m.Ibg.TM6 form andlwemetbrwlmNl. .._ _. . .. .._.._ _.._. .._\O _. ___. C`��• 'rom Scott A.Dietterick,Esquire c/o Zucker,Goldberg&Ackerman, LLC } 200 Sheffield Street,Suite 101 f Mountainside, NJ 07092 J° XFP-158688/sde TEAM C i i TM0 UNKNOWN TENANT OR TENANTS Postmark Here I 411 Miller Avenue New Cumberland,PA 17070-1867 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i T- 09- TES 02 1M 000428 V1,:._J MAI 709 TlifirtI ofMo tprwMuwi @ mOwtma flhnbnnpnowda dtoUSPS•f wmNk,&Twkrr......,-...«�.............. b v� . erd gerrutbnal moll u Fns Scott A.Dietterick,Esquire ~ w c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-158688/sde TEAM C TO! COMMONWEALTH OF PENNSYLVANIA Postmark Hen 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 I i I i Page 2 of 4 NOTICE TO UENHOLDER �/� �! 02 1M irt!!#7 "Sa -. k. 0004282036 �• � MAILEp 0 70'82' ThkCaMfeaM of McQna palda a-kleaa that and ha been Paanpd M tWS*ferrwWkg.7W form mey be wad for domeetic IV �......... and bAarrretlonelmeN. .... �-.. Scott A. Dietterick, Esquire ti "�0 ' c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 gQ�' Mountainside,NJ 07092 Up-158688/sde TEAM C T00 CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Hem Cumberland County Courthouse One Courthouse Square Carlisle,PA 17013 i County of P.Q.:CUMBERLAND PS Form 3817,AprN 2007 PSN 7530-02-000-9065 . ..Mern.o�aene L ES. 02 11A ,4 01 a 15° 000428203fj JM,1�6 2013 MARMF"21006J,97082 TNeCWWW MofMWftPrahae-We rwe dotme!hubeenymarawdtoUSPS•forrmftTht .... ^r ''• f. Jf eed Werveg"W rm! J 0 7 U y t Scott A. Dietterick,Esquire 4P, c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 w ti Mountainside, NJ 07092 7r ' XFP-158688/2TEAM INTEGRITY HOME FUNDING,LLC Postmark Here P.O.Box 11701 Newark,NJ 07101-4701 County of P.Q.:CUMBERLAND PS Form 3817,AprN 2007 PSN 7530-02-000-9065 Page 3 of 4 NOTICE TO LIENHOLDER 00.4282030 'J N 15 2013 � d� pmmdl 07082 Vida.vdmM m9hwbrnpn nhMUWPfarrrmft7w%, w �3 Scott A.Dietterick,Esquire _ c/o Zucker,Goldberg&Ackerman,LLC 111-Y 200 Sheffield Street,Suite 101 j Mountainside, NJ 07092 5 XFP-158688/sde TEAM C To CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Postmark Here Domestic Relations Section 13 N.Hanover Street PO Box 320 Carlisle,PA 17013 County of P.Q.:CUMBERLAND PS Form 3817,Apr6 2007 P5N 7530-02-OOD-9065 r i Ide nHr� 0 0 282 01.X01 ��' AN 15 2013 MAIlEL) fiP�O 0 70 92 Thk0wdit *fMMKprcv" IhMnwNbawboon and InbrmWmW era. pw•nMd to LISPS•for m•INry.Thb ream m•y b•used fordamNtk Scott A.Dietterick, Esquire Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-158688/sde TEAM C 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 753042-000-9065 Page 4 of 4 NOTICE TO LIENHOLDER • _.. .. .. _ 02 1M i 0004282030 IIOIUtEp �' IMCefftw*01110 paldr.Me=thatm.uhr been ProwgbdtoL*KoforMAMr 'm � 7 82 wW bMtm*tbmd m■e J INN Scott A. Dietterick,Esquire c/o tucker,Goldberg&Ackerman,LLC ti 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 J� W-15MU/sde TEAM C T°' UNKNOWN SPOUSE ftonmwk Here 17 Circle Drive i Mechanicsburg,PA 17055-6140 j County of P.Q.:CUMBERLAND PS F"m 3817,A 11 2007 PSN 753"2-000.9065 i I i t r SHERIFF'S OFFICE OF CUMBERLAND COUNTY 6 Ronny R Anderson = Sheriff r -` f L• f'ri E E , A r•�, tgr�nf , Jody S Smith r L JUL 23 AM 10: 0 Chief Deputy Richard W Stewart "' CUMBERWID C0tJ1k1 rY Solicitor OFFICE OF THE SHERIFF P P44 S Y LVA M A Wells Fargo Bank, N.A. Case Number vs. Jeffrey L. Moore 2012-2353 SHERIFF'S RETURN OF SERVICE 01/02/2013 07:25 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jeffrey L. Moore at 17 Circle Drive, Upper Allen Township, Mechanicsburg, PA 17055, Cumberland County. 01/03/2013 11:18 AM - Deputy Dennis Fry, 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 411 Miller Avenue, New Cumberland, PA 17070, Cumberland County. 01/24/2013 As directed by Jaime R Ackerman,Attorney for the Plaintiff, Sheriffs Sale Continued to 5/1/2013 05/01/2013 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, Cumberland County, PA on May 1, 2013 at 10:00 a.m.. He sold the same for the sum of$1.00 to Attorney Jaime Ackerman, on behalf of Wells Fargo Bank, NA, being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,207.94 SO ANSWERS, July 02, 2013 RbNW R ANDERSON, SHERIFF �, mss'-�,1• �b- 01-7 (c)CountySuite Sheriff,Teleosoft:In--. • c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 12-2353-CIVIL VS. Execution No.: Jeffrey L. Moore; 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 411 Miller Avenue, New Cumberland, PA 17070-1867. 1. Name and Address of Owner(s) or Reputed Owner(s): JEFFREY L. MOORE,SINGLE, 17 Circle Drive Mechanicsburg, PA 17055-6140 2. Name and Address of Defendant(s) in the Judgment: JEFFREY L. MOORE 17 Circle Drive Mechanicsburg, PA 17055-6140 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: i 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 INTEGRITY HOME FUNDING, LLC - - P.O. Box 11701 - Newark, NJ 07101-4701 5. Name.and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BLIREAU 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 ofevery 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 411 Miller Avenue New Cumberland, PA 17070-1867 - UNKNOWN SPOUSE - 17 Circle Drive - Mechanicsburg, PA 17055-6140 _ PA DEPT. OF REVENUES INHERITANCE TAX DIVISION Dept. 280601 - Harrisburg, PA 17128-0601 lekcrnuin. L,L(. I 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 a thorities. ZUCKER GOLD G &ACKERM , LLC Dated: BY: Scott ie teri quire; PA I.D.#55650 Ki erly 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. #3110324/ 200 Sheffield Street,Suite 101 Mountainside, N1 07092 File No.: XFP-158688 (908) 233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com <fldhcrq,k Ackr.mian. H-C XI P-1�R6$8 Exhibit"A" LEGAL DESCRIPTION ALL that certain tract or parcel of land.-and premises,situate,lying and being in the Borough of New Cumberland,in the County of Cumberland,and Commonwealth of Pennsylvania, more particularly described as follows;- BEGfNNM at a point on the northern line of Miller Avenue,said point being one hundred -- thirty and ninety-five hundredths(130.95)feet in a westerly direction from the western line of -- Reno Street,thence along the northern line of Miller Avenue south forty-four(44)degrees thirty(30)minutes wrest,twenty-five(i5)feet to a point;thence through the center of a -- partition wall,separating the premises 41 I Miller Avenue and 413 Miller Avenue,and beyond,.north forty-five(45)degrees thirty(30)seconds west,fifty-four and forty hundredths - (54.40)feet to a stake on line of lands nnw or late of Jacob Zimmerman;thence north forty- four(44)degrees thirty(30)minutes east,twenty-five(25)feet to a stake on the line of lands I now or late of Stanley and Francis Dodson; thence south forty-five(45)degrees thirty(30) minutes east,fifty-four and forty hundredths(54.40)feet to a point on the northern line of Miller Avenue,the place of BEGINNING. BEING the easterly 5.95 feet of the southern portion of Lot No. 28 and the westerly 19.05 - feet of the.southem portion of Lot No.29,Block"M",Plan of ButtorfFs Addition,recorded in the Cumberland County Recorder's Office in Deed Book"N",Volume 5,Page 498. ^ HAVING thereon erected a dwelling house being known and numbered as 411 Miller Avenue;New Cumberland, PA, 17070-1867. BEING the same premises which Bernadette A. Kowalczyk, by Deed dated June 23, 2008 and recorded June 26, 2008 in and for Cumberland County, Pennsylvania, in Deed Book Volume 200821563r_Page, granted and conveyed unto Jeffrey L. tyloore,single individual. Tax Map No.: 25-24-0811-253. .. Zucker,Goldberg&AFkerman, LLC XFP-158688 r� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A.. CIVIL DIVISION Plaintiff, vs. NO.: 12-2353-CIVIL Jeffrey L. Moore; Defendant. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Jeffrey L. Moore 17 Circle Drive Mechanicsburg, PA 17055-6140 AND 411 M��illj�x nM-e' �Nenr•t timberland, PA 17070-1867 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 03/06/2013 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: 411 Miller Avenue, New Cumberland, PA, 17070-1867 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-2353-CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Jeffrey L. Moore 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 Zucker,Goldberg&Ackerman, LLC XFP-158688 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 maybe 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 liroperty 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. 2. After the- Sheriff's 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. Zucker,Goldberg&Ackerrhan,LLC XFP-158688 3 A petition or petitions raising the legal issues or rights mentioned in the preceding pa6graphs 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 &,AdKERMAN LLC Dated: BY: Scott ietterick, 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-158688 (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-158688 Exhibit"A" - LEGAL DESCRIPTION _ ALL that certain traet or parcel of land_and premises,situate;lyi4g acid being in the Borough of New Cumberland,in the County of Cumberland,and Commonwealth of Pennsylvania,more particularly described as follows;- BE+G)EI+t"G at a,point on the northerh line of Miller Avenue,said point being one hundred thirty and ninety-Bve hundredths(134.95)feet in a westerly direction from the western line of Reno Street;thence along the northern line of Miller Avenue south forty-four(44)degrees thirty(30)minutes west,twenty-five(25)feet to a point;thence through the center of a partition wall,separating the premises 411 Miller Avenue and 413 Miller Avenue,and beyond,north forty-five(45)degrees thirty(30)seconds west,fifty-four and forty hundredths (54.44)feet to a stake on line of lands n-ow or late of Jacob Zimmerman;thence north forty- F four(44)degrees thirty(30)minutes east,twenty-five(25)feet to a stake on the line of lands now or late of Stanley and Francis Dodson;thence.south forty-five(45)degrees thirty(30) minutes east,fifty-four and forty hundredths(54,44)feet to a point on the northern line of Miller Avenue,the place of BEGINNING. ,BEING the easterly 5.95°feet of southern portion of Lot No;2$and the westerly 19.05 - feet of the southern portion.of lot No.2-9,Block"M",Plan of Buttorff's Addition,recorded in the Cumberland County Recorder's office in Deed Book"N",Volume 5,Page 498. HAVING thereon erected,a dwelling house being known and numbered as 411 Miller Avenue,New Cumberland, PA, 17070-1867. e BEING the same premises which Bernadette A. Kowalczyk, by Deed dated June 23, 2008 and recorded June 26,2008 in and for Cumberland County,Pennsylvania, in Deed Book Volume 200821563,^Page, granted and conveyed unto Jeffrey L. Moore,single individual. Tax Map No.: 25-24-0811-253. Zucker,Goldberg&Ackerman, LLC XFP-158688 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-2353 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK,N.A., Plaintiff(s) From JEFFREY L. MOORE (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: $111,069.48 L.L.: $.50 Interest FROM 6/22/2012 TO DATE OF SALE-$4,707.44 Atty's Comm: Due Prothy:$2.25 Atty Paid: $194.25 Other Costs: Plaintiff Paid: Date: 11/29/12 uell,Prothono ry (Seal) By: 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 TRUE COPY FROP"I 'RECORD In TestitnonY`Nhereof,.I.here unto set my hand and the&eal oI said Gpurt at Carlisle,Pa.This� -'day of nn rothoriotary On December 3, 2012 the Sheriff levied upon the defendant's interest in the real property situated in New Cumberland Borough, Cumberland County, PA, Known and numbered as, 411 Miller Avenue, New Cumberland, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: December 3, 2012 By: Real Estate Coordinator CUMBERLAND LAW JOURNAL Writ No. 2012-2353 Civil BEING the same premises which Bernadette A. Kowalczyk, by Deed Wells Fargo Bank,N.A. dated June 23, 2008 and recorded VS. June 26, 2008 in and for Cumber- Jeffrey L. Moore land County, Pennsylvania,in Deed Book Volume 200821563 Page, Atty.:Jaime R.Ackerman granted and conveyed unto Jeffrey 1. ALL that certain tract or parcel Moore, single individual. of land and premises, situate, ly- Tax Map No.: 25-24-0811-253. ing and being in the Borough of New Cumberland, in the County of Cumberland, and Commonwealth of Pennsylvania, more particuiarly described as follows BEGINNING at a point on the. northern line of Miller Avenue, said point being one hundred thirty and ninety-five hundredths(130.95)feet in a westerly direction from the west- ern line of Reno Street;thence along the northern line of Miller Avenue south forty-four (44) degrees thirty (30) minutes west, twenty-five (25) feet to a point; thence through the center of a partition wall, separat- ing the premises 411 Miller Avenue and 413 Miller Avenue,and beyond, north forty-five (45) degrees thirty (30)seconds west,fifty-four and forty hundredths (54.40) feet to a stake on line of lands now or late of Jacob Zimmerman; thence north forty four(44) degrees thirty(30)minutes east, twenty-five (25) feet to a stake On the line of lands now or late of Stanley and Francis Dodson;thence south forty-five (45) degrees thirty (30)minutes east,fifty-four and forty hundredths(54.40)feet toa point on the northern line of Miller Avenue, the place of BEGINNING BEING the easterly 5.95 feet of ithe southern portion of Lot No. 28 and the westerly 19.05 feet of the southern portion of Lot No.29,Block "M", Plan of Buttorffs Addition, re- corded in the Cumberland County Recorder's office in Deed Book"N", Volume 5,Page 498. HAVING thereon erected a dwell- 'ing house being known and num- bered as 411 Miller Avenue,: New Cumberland,PA, 17070-1867. . 86 I i I 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: January 25, February 1, and February 8, 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. isa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this 8 da y of February, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBER i BD Q COUNTY My Commission Expires Ap The Patriot-News Co. 2020 Technology Pkwy a no X(W5 I Suite 306 Mechanicsburg, PA 11050 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 u Coun lnhin.in Miscellaneous Book"M",Volume 14, Page 317. 2012-2363 Ch All Wells Fargo Bank,N Vs This ad ran on the date(s)shown below: Jeffrey L.Moore Atty. Jaime R Ackerman 01/22/13 ALL that certain tract or parcel of land 01129/13 and premises, situate, lying and being -1 c 02/05/13 in the Borough of New Cumberland, ��j in the County of Cumberland, and A Commonwealth of Pennsylvania, more particularly described as follows . . . . . . . . . . . . . . . BEGINNING at a point on the.northern line of Miller Avenue,said point being one x, hundred thirty and ninety-five hundredths Sworn to and subscribed before me * 14 day of February, 2013 A.D. (130.95)feet in a westerly direction from the western line of Reno Street;thence, ;I along the northern line of miller Avenue AlACALU;T" I , south forty-four (44) degrees thirty (30) V minutes West, twenty-five (25) feet to a point; thence through the center of a partition wall,separating the premises 411 mifleT Avenue and 413 Miller Avenue, and beyond,north forty-five(45)degrees thirty (30) seconds west, fifty-four and COMMONWEALTH OF PENNSYLVANIA forty hundredths (54,40) feet to a stake Notarial Seal on line of lands now or late of Jacob Holly Lynn Watfel,Notary Public Zimmerman;thence north forty four(44) Washington Twp.,Dauphin County degrees thirty(30)minutes east,twenty- My Commission Expires Dec.12,2016 five(25)feet to a stake orm—e MEET lands MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES now or late of Stanley and Francis Dodson; thence south forty-five(45)degrees thirty COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 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 N Aq is the grantee the same having been sold to said grantee on the 1 st day of May A.D., 2013, under and by virtue of a writ Execution issued on the 29th day of November, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 2353, at the suit of Wells Fargo Bank N A against Jeffrey L Moore is duly recorded as Instrument Number 201324174. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 42�- day of 0,tj5,7, _, A.D. 3 4 Recorder of Deeds Recorder of De s,Cumberland County,Carlisle,PA My Commission Expires the First Monday of Jan.2614