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HomeMy WebLinkAbout12-2497 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., Plaintiff, vs. RICHARD E. ADAMS; Defendant. 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. CIVIL DIVISION NO.: TYPE OF PLEADING % ;; M "n a -or- 4 CIVIL ACTION - COMPLAINT.??? rr t :10 "F IN MORTGAGE FORECLOSU =C) 3 ._. FILED ON BEHALF OF: ? w ':.' r'ri Wells Fargo Bank, N.A. '-i w CO V 70 -C COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY 1HA1 THE ADDRESS OF THE PLAINTIFF IS: 3476 Stateview Blvd. MAC # X7801-013 Ft. Mill, SC 29715 AND THE DEFENDANT: 615 Woodland Avenue Mount Holly Springs PA 17065-1937 CERFIFICATE OF LOCAL ION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTE Y THIS LIEN I 615 Woodland Avenu ount Holly Sprig ATTORNEY 5W P AM FILE NO.: XFP 165026 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@zuckergoldberg.com File No.: XFP- 165026/hp 3, 75' (ki? 3%73 d, A 7V /6 ( Zucker, Goldberg & Ackerman, LLC XFP-165026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: RICHARD E. ADAMS; 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 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-165026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: RICHARD E. ADAMS; Defendant(s). AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demands establecida en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion 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 reclamacion o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGAR UNO, 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-165026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: j 4 -C-- / / / c? ?t RICHARD E. ADAMS; Defendant(s). CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff") through its servicing agent WELLS FARGO BANK, N.A. located at 3476 Stateview Blvd., MAC # X7801-013, Ft. Mill, SC 29715. 2. Defendant, RICHARD E. ADAMS, is an individual whose last known address is 615 Woodland Avenue, Mount Holly Springs, PA 17065-1937. 3. On or about July 31, 2008, RICHARD E. ADAMS executed a Note in favor of PNC Mortgage LLC in the original principal amount of $122,084.00. 4. On or about July 31, 2008, as security for payment of the aforesaid Note, RICHARD E. ADAMS, a single person made, executed and delivered to PNC Mortgage LLC a Mortgage in the original principal amount of $122,084.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on August 1, 2008, Instrument #200826207. 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 PNC Mortgage LLC to Wells Fargo Bank NA, plaintiff herein, pursuant to an assignment of mortgage dated July 31, 2008 and recorded on August 4, 2008 in the Office of the Recorder of Deeds for Cumberland County, Instrument #200826359. 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 October 2011 payment, and pursuant to the terms of the aforesaid Mortgage, after written Zucker, Goldberg & Ackerman; LLC XFP-165026 notice of said default to Defendant(s), the entire principal balance and accrued interest due thereunder has been accelerated. 7. RICHARD E. ADAMS, married man 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 $117,576.15 Interest through 04/06/12 $4,562.78 Escrow Advance $103.33 Suspense Balance ($561.26) Late Charges $862.68 Inspection Fees 450.00 Total $122,993.68 plus interest on the principal sum ($117,576.15) at the daily per diem amount of $20.94, 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-165026 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 $122,993.68, with interest thereon at the daily per diem amount of $20.94 plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GO C AN, LLC BY: Dated: Y I Scott . Dietterick, Esquire; PA I.D. #55650 l Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh Levy Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-165026/hp 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-165026 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-165026 g Prepared By: PNC MORTGAGE, LLC 2710 5TH AVENUE S„ MINNEAPOLIS, MH 554080000 Return To: WPM FINAL DOCS X9999-01M 1000 BLUE GENTIAN ROAD EAGAN, MN 55121 Parcel Number: Premises: 615 WOODLAND AVE MT HOLLY SPRINGS !Space A6(nr 7'61. Line Fur Recording Datal FIIA Cure No Commonwealth of Pennsylvania MORTGAGE THIS MORTGAGE ("Security Instrument') is given on JULY 31, 2008 The Mortgagor is RICHARD E ADAMS, A SINGLE PERSON ("B(trruwc:r"). This Security Instrument is given to PNC MORTGAGE, LLC PNC MORTGAGE, LLC which is orSani&%J and existing under the laws of THE STATE OF DELAWARE and whose address is P.O. BOX 11701, NEWARK, NJ 071014701 ("Lender"). Borrower owes Lender the principal sum of ONE HUNDRED TWENTY TWO THOUSAND EIGHTY FOUR AND 00/100 Dollars (U.S. $ ********122,084. 00 NMFL 4'0642 (PAFM) Rev 4/24/2006 F1 1A Pcan ytvanla Nk)rtgage - 4196 ® -4R(PA) ime) ,are 0. 6 VMS 1:(ortppe :wluty n t Nt: .. I I I '. ,1 /o This debt is evidenced by Bonowees note dated the same due as this Security Instrument ("Note"). which provides for monthly payments, with the full debt, if not Paid earlier, due and payable on AVOUST 01. 2030 This Security Instrumentsomms to bender: (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 otter soots, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the, performance of Borrower's covenants and agreements under this Security Inst:umentand the dote. For this purpose.`Botrower does hereby mortgage, grant and convey to the Leader the following described property located in CUMMU i ND County; Pennsylvania: w*SU ATTACKED which has the address of 615 WOODL.AMD AVE tsuml Wr UDLLY SPRXIM [City], Pennsylvania 17065 [zipcadel ('Property Addresa•); TOGETHER WITH :. all the improvements now or hereafter erected on the property, and all easements, appwtemmncces and fixtures: now or hereafter a part of the property. All replacernants-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 hereby conveyed sad has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and nonuniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. Borrower and bender covenant and area as follows: UNIFORM COVENANTS. 1. Payment of Prinrlppl. Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of Tax", Iarsuramce and Other Charges. Borrower shall include in each monthly payment. together with the principal and interest as set forth in the Note and any hate chargot, a sum for (s) taxes and special Lwessmom levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance requited under patagsapk 4. In any year in which the Leader must pay a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretat"), or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shell also. include either. (i) a sum for the 414RIPAt mm ?w. r w o atmual.mortgagc is sura ce premium to be paid by Leader to the Secretary, or (ii) a monthly charge instead Of a mortgage insurance premium if this Security lostrument is bald by the Secretary, in a reasonable amount to be dowmic ed by the Secretary . Except for the monthly charge by the Secretary, these items are called 'Escrow Items' and the sums paid to lender are called "Escrow Funds.' Lender may, at any time, collect sod hold amounts for Escrow Items is an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow acetnmt under the Real Estale Settlement Procedures Art of 1974, 12 U.S.C. Section 2601 et seq. and implementing ,regulations, 24 CFR Put 3500, as they may be amended from time to time ("RESPA'), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may rat be based on amounts due for the mortgage innuanm 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 requited by RBSPA. [f the amounts of ftmds held by Leader at any time in not sufficient to pay the Escrow (term when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by AMA. The Escrow Funds are pledged as additional security for all scams secured by this Security Instrument. If Borrower tanders to Lender the full payment of all such sums, Borrower's account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender hat not become obligated to pay to the Secretary, and Lender shall promptly refund any excel: {cads to Borrower. Immediately prior to a forsclosore ask of the Property or its acquisition by Leader. Borrower's secoumt shall be credited with any balance remaining for all installments for items (a), (b), and (c)- 3. Application of Psyrttents. All payments under paragraphs 1 and 2 shall be applied by Lender as follows: First. to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage lnnotanee premium; juga to say taxes, special assessments, kisehold payments or ground. tents, and fart, flood and other hazard insurance premiums, as required; Thiel, to intereat due under the Note; Pow, to amortization of die principal of the Note; and EI& to late charges due under the Note. 4. Fire, Fined and O tr Hssar'd Insurance. Borrower shall insure all improvements on the Property, whether now in exirts= or subsequently erected, against any hazards, casualties, and contingencies, including fare, for which Lender requires insurance. This insurance shall be maintained m the amounts and for the periods that Lender requires. Borrower shall 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 Leader. The insurance policies and any renewals shall be held by Leader and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. in the mat of loss, Borrower shall give Leader immediate notice by mail. Lender may rusks proof of loss if not made promptly by Borrower. Bach insurance company concerned is hereby authorized and directed to make payment for such loan directly to Lender, instead of to Borrower mid to Lender jointly. All or any put of the inaarance procceda may be applied by Lender, at its option, either (a) to the reduction of the indebtedness tinder the Mote and this Security Instrument. fru to any delinquent amounts applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. AM application of the proceeds to the preeipai abed 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 insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled therret/oo. hif.1 v-a ?-MPA) msosw r.s.a .a o In the event of foreclosure of this Security Instrument or other transfer of title to the Property that' extinguishes the indebtedness, all right, title aid interest ofBotrower in and to iawrams policies in 6ocee SW pass to the purchaser. S. O"aaq, Preservation, Maintenance and Protection of the Property, Sewer's Loan Application; Leaseholds. Borrower shall occupy, estabiiah,: std nee the preperty.as Borrower's principal tesideacc 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-lRocmwer's principal residence for at least one year after the date of occupancy, unless Lender determ res that requirement will cause undue hardship for Borrower, or unless extenuating circumstance exist which in beyond Borrower's control. Borrower shall notify Leader of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant of abandoned or the town is in default. Lender way take reasonable auction to prettact and preserve such vacant or abandoned Properly. Borrower shall also be in default if Borrower, during the Loan application process, gave materially false or itasccurate information or statements to leader (or failed to provide Lender with any nmterW information) in connection with the loan evidenced by the Note, including, but ant limited to, representati= concerning Borrower's occupancy of the Property as a principul.residence. If this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lace. If Borrower.acquires fee tide to the Property, the leasehold and fee tide shall not be merged unless Lender agrees to the merger in writing. 6. Cerdemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or tether taking of any part of the property, or for conveyance in place of condemnation, are hereby assigned and shag be Paid to Lender to the extent of the foil amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender " apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amoutus applied in the order provided in paragraph 3. and then to prepayment of principal. Any application of the proceeds to the principal shalt not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument" be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protecdott of Lender's Rights In the Property., Borrower shall pay all governmental or municipal charges, fires and impositions that are not Lttcluded in paragraph 2. Borrower shall pay these obligations on time directly to the entity wbich is owed the payment. If failure to pay would adversely effect Lender's interest in the Property, upon Leader'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 fails to perform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may aignifipatly affect Lender's rights in the Properly (start as a proceeding in bankruptcy, far coalenutatioa or to enfom laws ar regulations), alma Lender rosy da and pay whatever is neeesssry to protect the vales of the Property sad-3endtr'a rights in the Property, including payment of tszes, hamrd insurance and other items mdttioaed in paragtapb 2. Any amounts disbursed b7 Lender Hader this paragraph shall neonate an additional debt of Borrower and be natured by this Security Instrument. There amounts shall bear interest from the date of disbursement, at the Nola rate, sad et the option o€ Loader, shall be immediately due and payable. Borrower shall-promptly discharge any lion wbioh has priori ty over is Security Instrument unless Borrower:' (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender: (b) contests in good faith the lien by, or dekads against enforcement of the pion in, legal proceedings which in the Leader's opinion operate to prevent the enforcement of the lien; or (c) secures Ktww. ai? ek-4RiPRRosov P,r' 4 0 9 from the holder of the life an agreement satisfactory to Lender subordinating the lien tb this security Instrument. If Loader determines that any part of the property is subject to a lien which may amin priority over this Security Instrument, Leader may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8. Fen. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) DefaulL Lender [stay, except as limited by regulations issued by the secretary, in the can of payment defaults. require immediate payment in full of all sums secured by this Security Instrument if: (i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument prior to or on the due data of the next monthly payer, 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 barn-St. Germain Depository Institutions Act of 1982, 12 U.S.C. 1701j-3(d)) and with the prior approval of the Secretary, require immediate payment in !Lill of all sums secured by this Security Instrument if- (i) All or part of the Property, or a beneftcW interest in a trust owning all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approved in accordance with the requirements of the Secretary. (e) No Waiver. If circumstances occur that would permit Leader 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 MM Secretary. In many circumstances regulations issued by the Secretary will limit Lender's tights, in the case of payment defstilts, to require immediate payment in full sad foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender way, at its option, require immediate payment in fall of all sums secured by this Security Instrument. A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Leader's failure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if Leader Las required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump am all amounts required to bring Borrower's amount 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 required immediate payment in full. However, Lender is not required to permit reinstatement if. (i) Leader has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure - 7. dDdA(PA)m.w PM 5.19 proceediag,' (ii) reinstateoxvit will preclude foreclosure oil different grobods in the future, or (iii). rebatmemeat will adversely affect the priority of the lien crested by this Security Instrument. 1'1. Borrower Not Released; Forbearance By Lender Not s Waiver. Extension of the time of payment or modification of amortvation of the sums secured by this Security Iosnument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrow" or Borrower's successor in interest. Lender shall not be tegaired to commence p." W against any successor in interest or refuse to extend time for payment or otherwise modify amortization of die sums wound by this Security Instrument by reason of any demand made by the on iatl Borrower or Borrower's successors : in interest Any forbearance by Lender in exercising any tight or remedy shall not be a waiver. of or preclude the exercise of any right or remedy. 12. Successors and Assigns Bound; Joint awl Several Liability, Co-Signers. The coventats and agreements of this Security Instrument shall bind and benefit the successors and asaignt of Leader and Borrower, subject to the provisions of paragraph 9(b). Borrower's cow matt stud agreements shall be joint and several. Any Borrower who co-signs; this Security Instrument but does not, execute the Now. (s) is this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument: (b) is not pctsonaliy obl4pw to pry the sums secured by this security Instrument; and (e) agrees that Lender mad my other Borrower; may agues to extend, modify, forbear or m4e any as podaelons with regard to the terms of this Security Instrument or the Note without that Borrower's comm. 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by trailing it by first class mail unless applicable law inquires use of another method; The notice: shall be directed to the property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by fast class mail to Lender's a khm stated' herein or say address Lender designates by notice to Borrower. Any notice provided for in this Security Iatetnmeat shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law; Severability. This Securgy Instrument shall be governed by Federal law and the law of the jurisdiction in which the Property is located. In the event that may provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not:affeet other. provisions of this Security Ina u neat or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note we declared to be aevaable. 15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security instrument. 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hn udouet Substances on or in the Property: Borrower shelf not do, nor allow anyone else to do. anything affecting the Property: that is in violation of any Environmental Law. The preceding two semlettces shall not apply to the presence, use, or storage on the Property of small: quantities of anWous Substances that are generally recogmfzed to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice. of any investigation. shish, demand, lawsuit or other action by any govavz=W or regulatory agency or private party involving the Property and any Hazardous Substance or EnvironmeuW`Law of which Borrower bas actual knowledge. If Borrower learns. or is notified by say governmental or regulatory authority, that any removal or othernmediation of tarty Hurdous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial factions in accordance with Environmental Law. As used in this patagrapb 16, 'Hazardous Substances' arc those nhbstaws defined etc toxic or bazardous substances by Environmental Law and the following Substancss gasolirse, k mama, other flammable or toxic petroleum produces; toxic pesticides and herbicides, volatik solvents, materials containing asbestos" or foroaldehyde, and radioactive materials. As used in this paragraph 16, LiH?e: t14R1PAl mom Pays 0 or 9 'Environmental 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 Ladder Strther covenant andagree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to Leader all the rents and reventpa of the Property. Borrower authorizes Lender or Lender's agents :. to collect the rents and revenues and hereby diner each tenant of the Property to pay the rears to Lender or L.eodei s agents. Ilowever, prior to Leader's notice io Borrower of Borrower's breach of any coveeent or.agreement in the Security Inshment, Borrower shall collect and receive all rents and revennea of the Property as know for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assigm>mat'and not an assignment for additional security only. If Lender gives notice of breach to Borrower. (a) all rents received by Borrower shen be held by Borrower a6 trustee for benefit of Leader only, to be applied to the sums secured by the Security instrument;; (b) Leader shall be entitled to collect and receive all of the rents of the Property; and (c) each tensw of the property shall pay all vents due and unpaid to Lender or Lender's agent on Lender's written demand to the Wow. Borrower lass not executed any prior assignment of ibe_tents and has not and will not perform any act that would prevent Leader from exercising its rights under this paragraph 17. Lender shall not be required to enter upon, take control of or maintain the. Property before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time thin is a breach. Arty application of rents shell not cure or waive any default or invalidate any other right or remedy of Leader. Thins assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full, 18. Foreclosure Proce ore. If Lender regtdres immediate payment in flA under paragraph 9, header may foreclose this Security Instrument by Judi" proceeding. Lender shall be entloW to collect all expenses hucarred in pursuing the remedles prodded In this paragraph 18, including, but not limited to, attaencys' fees and cost of title evidence. If the Lmdees Interest In this Security Instrument is held by the Secretary and the Secretary requites Imased rte payment in U under Foagraph 9, the Secretary may invoke Use mWudicittl power of sale provided In the Single Family Mortgage Foreclosure Ara of 1994 ("Act") (12 U.S.C. 3751 et seq.) by requesting a foreclosure commissioner designated under the Act to commtatce foreclonte and to sell the Property as provided in the Act. Nothing in the preceding sentence SW deprive the Secretary of any rights otherwise available to a Leader under this Paragraph 18 or applicable law, 19. Release. Upon payment of all soma secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Leader shall discharge and satisfy this Seetttity histrumetu without charge to Borrower. Borrower stud pay any recordation costs. 20. Walvers. Borrower. to the extent pevmtrted by applicable law, waives and releases any error or defects to proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws, providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sage pursuant to this Security i wrumeat. 22. Pundose Money hortgage. If any of'the.debt secured by this Security Instrument is tent to Borrower to sequin title to the Property, this Security Instrument shall beta purchase t wary mortgage. 23. Interest Rate After Judgment. Borrower "a that the interest rate payable after a juopwnt is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. MARWA1mswi ow. or 24. Riders to this Security Ltstrumtnt. If one or more riders are executed by Borrower Said recorded together with this Security Instrument, the covenants of each such rider " be incorporated into and shell amend and rapplement the covenants and agteementa of this Security Instrument as if tie rider(s) were a pat of this Security Instrument. [ applicable box(es)]. Condominium Ricer Growing Equity Rider ? Other [specify]. Planned Unit Development Rider Graduated Payment Rider BY "SIONDiG BELOW Borrower accepts add agrees to Ike terms contained in this Security Instrument and in any rider(s) ommed by Borrower and recorded with it. witnessw RICHARD I ADAMS 8ocrower (se+d) Bo mwet -(Seat) (Seal) -eurwwer -Barowor (Seal) (Seal) -Bormwer -9ottowcr (Seal) (seal) Domower -Bocmwmr AAFI NA] meow P." a.r 0 COMMONWEALTH OF P&NSYLVANIA, C MA rm a4 courtly s: - on", 31sT day of JULY 2000 , beforo me, the Uadetsigoed offuxr, personailygVmed RICMD Z ADAM known tome (or adisfactocity protita). tb bgtll° person(s) wbmse mate isfue subscribed to the widdu inst tent and acknowledged tbitt hMS ey . . execow the same for the purposes hessin contained. IN Wi MSS WHMWF, I hemMto set my band and official seal. ?Q MY Commission F_tipi;ea: c pi0WALSM TR1SfiA A. LVESS. N0181Y Ptit k ` .sh of Caylale Cwb Coo '!-'" cex+nps M t? 2^ 2.' i me of Ottkar Cerdfkste of Residence I,. c , do hereby certify that the correct address of the within-( k P.O. BOX 11701, ARK, XT 071014701 witness my,hatod this 31sT day of JIIi,Y 2t10y? ` Agent of Leader 1,44w: AW A-MPA1050481 v9• W a s 915 Woodland Avenue, Mt. HOHY Springs, PA 17095 Part of Parcel No. 40-30.2949-044 ALL THAT CERTAIN tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, pounded and described as follows: ON the East by toodland Avenue; on the South by Lot No, 61 of the hereinafter mentioned Plan of Lots; on the West by Lot No. 88 of said Plan of Lots; and on the North by the northern half of Lot No. 59 of said Plan of Lots; having a frontage of 77.45 feet, more or less. on Woodland Avenue, a depth on the South of W feet, a width in the rear of 75 fast and a depth on the North of 119.35 feet, more or less; and being Lot No. 60 and the southern half of Lot No. 59 of the Plan of Lots known as Mt. View Addition Adjoining Mt. Hotly Springs Borough, recorded in the Office of the Recorder of Deeds for Cumberland County, in Pier Book 3, Page 86. 0 ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE' CARLISLE, PA 17013 717-240-6370 Instrument Number . 200826207 Recorded On 8/112008 At 10:35:13 AM "Instrument Type - MORTGAGE Invoke Number - 26269 Uses ID - MBL a Mortgagor - ADAMS, RICHARD E a Mortgagee - PNC MORTGAGE LLC ' Customer- BARKER * rug STATE` SPRIT TAX $0.50 STATE JCS/AGCRSS TO $10.00 JUSTICE RECORDING FEES - $23.50 RECORDER OF DEEDS AMRDABLE HOUSING $11.50 COUNTY ARCHIVES M $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $50.50 * Total Pages -11 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O D DS - Information dessted by an astwisk may ebange daring the verification process sad may not be re@Kkd on this page. mm 11111151111111 VERIFICATION Ismael Hernandez, hereby states tha he/ he is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter, tha he she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best o his er information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. File # 165026 Name: ADAMS Name: Ismael Hernandez "Title: Vice President Loan Documentation 032-PA-V3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: RICHARD E. ADAMS; Cl C -? Defendant(s). rnW ? - 2:r- 7 Vrfl 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 conference in an effort to resolve this matter with your lender. If you do not have 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 Mid Penn 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 attached 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. TIDS PROGRAM IS FREE. T ZUCKER, GOLDBE ACKERM , LLC BY: Dated: Scott A. i terick, Esquire; PA I.D. #55650 I Kimb y A. Bonner, Esquire; PA I.D. #89705 Joel . 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-165026/cper 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-165026 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: Yes ? No ? Yes ? No ? Listing date State: Zip: Price: $ Realtor Phone: State: Zip: Home: Office: Cell: Other: How long? Home: Cell: First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ? No ? If yes, provide names, location of court, case number & attorney: Date you closed your loan: How long? State Office: _ Other: Included Taxes & Insurance: Zip: 1 Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2: Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/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 Agency? Yes ? No ? If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: 2 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 known, 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 Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of Income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) V Listing agreement (if property is currently on the market) 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. RICHARD E. ADAMS; Defendant(s). REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. 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 Signature of Defendant Date Date IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, VS. RICHARD E. ADAMS; Defendant(s). CIVIL DIVISION NO.: 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 Cumberland County Courthouse, Carlisle, Pennsylvania. at the 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 discretion 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 Conference 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 lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; 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. Zucker, Goldberg & Ackerman, LLC XFP-165026 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-165026 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY I C' .. : 4ir? ' of 4:,<u ? E i CN0 T/SAC,'; 2? 11 MAY -3 ply 1: CUMSERLANL) CoUjgTy PENNSYLVANIA Wells Fargo Bank, N.A. vs. Richard E. Adams SHERIFF'S RETURN OF SERVICE Case Number 2012-2497 04/27/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Richard E. Adams, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Richard E. Adams. Request for service at 615 Woodland Avenue, Mount Holly Springs, Pennsylvania 17065 the Defendant was not found. The mailbox is full of the Defendant's mail, the electric utility is shut off to this residence and neighbors have not seen the Defendant in months. SHERIFF COST: $40.00 SO ANSWERS, April 27, 2012 RON R ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY - Ronny R Anderson Sheriff ... 2. Jody S Smith rrn Chief Deputy �� � -� -urn Richard W Stewart Solicitorra(. 3> C>-rj CD , .�. Wells Fargo Bank, N.A. vs. Case Number Richard E.Adams 2012-2497 SHERIFF'S RETURN OF SERVICE 04/2912013 03:25 PM-Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Richard E.Adams, pursuant to Order of Court by'Posting"the premises located at 615 Woodland Avenue, South Middleton Township, Mount Holly Spri s, PA 17065 with a true and correct copy according to law. zw/ 41ftCLIAW CLINE, DEPUTY SHERIFF COST: $41.91 SO ANSWERS, April 30, 2013 RbNW R ANDERSON, SHERIFF (c)CountySuile Sheriff,Teleosotf.lric. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 12-2497-CIVIL vs. • 2012-02497 E.ADAMS; s ; , • Defendant. r. PRAECIPE TO REINSTATE COMPLAINT --t p" TO THE PROTHONOTARY: Please mark the Complaint irk Mortgage Foreclosure filed at the above-captioned term and number reinstated. ZUCKER,GOLDBERG &A J:MAN, LLC t-- By: Dated: October Z,2013 Scott A. Diett- ick, Esquire; PA I.D.#55650 Kimberly A. -onner, 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. Attorneys for Plaintiff XFP-165026/cper 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908)233-1390 FAX Email: Office @zuckergoldberg.com uA fl -6 eL"5 /93 9, q ') Ci)CoS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., ISSUE NO.: 12-2497-CIVIL 2012-02497 Plaintiff, vs. TYPE OF PLEADING c- RICHARD E.ADAMS; AFFIDAVIT OF SERVICE OF == COMPLAINT PURSUANT TO rn Defendant. Pa.R.C.P.,430 SPECIAL ORDER- N 6' OF COURT -< -: c') - CODE: -4 1 FILED ON BEHALF OF: _r Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER,GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D.#55650 Kimberly A. Bonner, Esquire- PA I.D.#89705 Joel A.Ackerman, Esquire- PA I.D.#202729 Ashleigh Levy Marin, Esquire-PA I.D.#306799 Ralph M.Salvia, Esquire- PA I.D.#202946 Jaime R.Ackerman, Esquire- PA I.D.#311032 Jana Fridfinnsdottir, Esquire- PA I.D.#315944 Brian Nicholas, Esquire- PA I.D.#317240 /Denise Carlon, Esquire- PA I.D.#317226 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office @zuckergoldberg.com File No.:XFP- 165026/dlaw IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, ' vs. NO.: 12-2497-CIVIL 2012-02497 RICHARD E.ADAMS; Defendant. • AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT Il, d'ti l Se Car Vii, Esquire,attorney for Plaintiff,Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiffs Complaint in Mortgage Foreclosure on Defendant, RICHARD E.ADAMS, as follows: 1. On or about January 11, 2013, an Order of Court was entered granting Plaintiff's Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit"A", attached hereto and made a part hereof. 2. Pursuant to said Order,on or about April 24, 2013, Zucker, Goldberg&Ackerman, LLC, the counsel for Plaintiff served Defendant, RICHARD E.ADAMS with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure,via First Class U.S. Mail and Certified Mail, Return Receipt Requested to the defendant's last known address being 615 Woodland Avenue, Mount Holly Springs, PA 17065-1937. A true and correct copy of said returned receipt and certificate of mailing are marked Exhibit"B", attached hereto and made a part hereof. 3. Pursuant to said Order,on or about April 29, 2013,the Sheriff of Cumberland County posted the property subject to the Mortgage, being 615 Woodland Avenue, Mount Holly Springs, PA 17065-1937 with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure. A true and correct copy of the Service Form from the Cumberland County Sheriffs Office is marked Exhibit"C", attached hereto and made a part hereof. 4. Pursuant to said Order, on or about November 22, 2013, Plaintiff published Plaintiffs Complaint in Mortgage Foreclosure once in The Cumberland Law Journal,for Cumberland County, Pennsylvania. True and correct copy of the Proofs of Publication are marked Exhibit"D",attached hereto and made a part hereof. 5. Pursuant to said Order,on or about November 22, 2013, Plaintiff published Plaintiffs Complaint in Mortgage Foreclosure once in The Sentinel,for Borough of Carlisle,Cumberland County, Pennsylvania. True and correct copy of the Proofs of Publication are marked Exhibit"E", attached hereto and made a part hereof. ZU ER,GOLDBERG &ACKERMAN, LLC Dated: January 17 ,2014 B �! ,� OP, 4 JAL_ 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 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 --Denise Carlon, Esquire; PA I.D.#317226 Atty File No.:XFP-165026 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 Email: Office @zuckergoldberg.com (908) 233-8500; (908)233-1390 FAX Sworn to and subscribed before me this /7 day of January, 2014 (2 //`1761\4 - ---. Notary Public MY COMMISSION EXPIRES: Cheryl Debeneadto Notary Public My Comm.Expires Oct.16,2016 ID #2280276 State of New Jersey IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL-DIVISION Plaintiff, vs NO.:12-2497-CIVIL . .2012-02497 . RICHARD E.ADAMS; Defendant: ORDER OF COURT AND NOW,this day of ‘314""r ,208 upon consideration of Plaintiff's Motion for Special Service, it is hereby ORDERED,ADJUDGED AND DECREED that Plaintiff shall serve its. Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) RICHARD E. ADAMS, by instructing the Sheriff of Cumberland County to POST a copy of same on,the Mortgaged Premises, being 615 Woodland Avenue,Mount Holly Springs PA 17065-1937,and by m ilk ing a cop 'a t..lA Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid +i, said.soo , v in accordance with Pa.R.C.P.430. BY THE c o ' 'Pt:* r :--- z ' bay r� z c -n Q Zucker,Goldberg&Ackerman,LLC XFP-165026. UNITED STATES . .I , . • otasP06). POSTAL SERVICE® u. • • .:.: • .453.' n N.......„limey This Certificate of Ma ging provides evidence that mail has been presented to MPS.for mailin.This f f. ,,: k: %. 0 and International mall. ..1-- ,Z), ri. 0? IM $ 01'20° .t.,..:72;14. 2.„:,,, el 0 42820 3 6 F"'" Scott A. Dietterick,Esquire APR 2., 11.' MAILED c/o Zucker,Goldberg&Ackerman,LLC FROM ZIPCODE°7092 200 Sheffield Street,Suite 101 . SID N 0›, • n• m co Mountainside, Ni 07092 eel (f.o ,-) INif . XFP-165026/ns TEA B rosignilicH2ere4 2013 E.= To: RICHARD E.ADAMS 615 Woodland Avenue UsPS Mount Holly Springs, PA 17065-1937 County of P.Q.:CUMBERLAND PS Form 3817,Apri12007 PSN 7530-02-000-9065 Zucker,Gc dberg&Ackenna1,LLC 1111 1111 I 11111 PO Box 1219 Mountainside,NJ 07092-1219 7196 9006 9296 6798 9584 20130424-102 t^I.11111111'1191'hlml'luln°ru'll°Inu.IIPPdhvl RICHARD E.ADAMS 615 WOODLAND AVE MOUNT HOLLY SPRINGS,PA 17065-1937 ISMTG EXHIBIT C SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith l(a 56 a,0 4/4 Chief Deputy ;. -nom Richard W Stewart `' Solicitor orrlcE oc Tlit,sp,FlF� Wells Fargo Bank, N.A. Case Number vs. Richard E.Adams 2012-2497 SHERIFF'S RETURN OF SERVICE 04/29/2013 03:25 PM-Deputy William Cline,being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Richard E.Adams, pursuant to Order of Court by"Posting"the premises located at 615 Woodland Avenue, South Middleton Township, Mount Holly Spri s, PA 17065 with a true and correct copy according to law. "\-1-7 — e-V ttlA CLINE, DEPUTY SHERIFF COST: $41.91 SO ANSWERS, April 30, 2013 ROHR ANDERSON, SHERIFF • t,c)CountySuito Sherd',Tolcosofi hoc. 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 November 22,2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal,a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement,and that all allegations in the foregoing statements as to time,place and character of publication are true. sa Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 22 day of November,2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MENT MAY BE ENTERED AGAINST MORTGAGE FORECLOSURE YOU WITHOUT FURTHER NOTICE FOR RELIEF REQUESTED BY THE In the Court of Common Pleas of PLAINTIFF.YOU MAY LOSE MONEY Cumberland County,Pennsylvania OR PROPERTY OR OTHER RIGHTS Civil Action—Law IMPORTANT TO YOU. YOU SHOULD TAKE THIS NO- NO.: 12-2497-CIVIL TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER Wells Fargo Bank,N.A. OR CANNOT AFFORD ONE, GO Plaintiff TO OR TELEPHONE THE OFFICE vs. SET FORTH BELOW TO FIND OUT RICHARD E.ADAMS WHERE YOU CAN GET LEGAL HELP. Defendant(s) NOTICE TO DEFEND LAWYER REFERRAL TO:RICHARD E.ADAMS Cumberland County Bar Association PRESENTLY OR FORMERLY of 32 S.Bedford Street 615 Woodland Avenue,Mount Holly Carlisle,PA 17013 { Springs, PA 17065-1937. A lawsuit Phone(800)990-9108 has been filed against you in mort- (717)249-3166 gage foreclosure and against your Nov.22 real estate at 615 Woodland Avenue, Mount Holly Springs,PA 17065-1937 because you have failed to make the regular monthly payments on your mortgage loan and the loan is in default.The lawsuit is an attempt to • collect a debt from you owed to the plaintiff, Wells Fargo Bank, N.A. A detailed notice to you of your rights under the Fair Debt Collection Prac- tices Act (15 U.S.C. §1692 at seq.) is included in the Complaint filed in the lawsuit. The lawsuit is filed in the Cumberland County Court of Common Pleas, at the above term and number. A copy of the Complaint filed in the lawsuit will be sent to you upon request to the Attorney for the Plain- tiff,Scott A.Dietterick,Esquire,P.O. Box 1024,Mountainside,NJ 07092. Phone(908)233-8500. IF YOU WISH TO DEFEND,YOU MUST ENTER A WRITTEN AP- PEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE YOUR DEFENSES OR OBJECTIONS IN WRITING WITH THE COURT. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PRO- CEED WITHOUT YOU AND A JUDO- 9 s PROOF OF PUBLICATION State of Pennsylvania,County of Cumberland Jackie Cox,Director of Sales,of The Sentinel,of the County and State aforesaid,being duly sworn,deposes an d says that THE SENTINEL,a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13th, 1881,since which date THE SENTINEL has been regularly issued in said County,and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): November 22,2013 - COPY OF NOTICE OF PUBLICATION �,•,.•••••,,,-„,,,r r fi 1 tr if�C , ,f✓-b' i i2 • ,_,-,_-•-1,,t "dl �`, ;`���r�,;1,1,,(,�� t�,</ `,� "�-_ , f ; � � Affiant further de oses that he she is not• r r �A°l�� f,i ���z .• fs7 p ' •,t r�S �( r3el 4 7.,53 s�• , , i 7�, ��; r �Sr E F,, , , � ••••., {,�,„� interested in the subject matter of the•• � ' � j ` ���r '� t �� '. aforesaid notice or advertisement and that 4i 1`T 'a"' i„,' ✓�- _ ,�l �d Y Y. fir]� 4- 1- 4".�'•",•1 t 1 , y r all allegations in the foregoing statement as '� ���,3f a '� i • 1> 7 ,,',.•'',,,',< . to time,place and character of publication' ;:., ' It''''" ';;If,ii,''''' / i 60,5e2 i dl+ f 4 iur e ,' y7;�4 i• � tE 70 1 � t, S � s C ���J +�XS- are ■• 'S` f,, 'tr. 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( r , 1, i P f-._,,,,,-.;.).4, 4-Ifi �.t.{. 1,7�S� .. il� i 1fo�,����� �l'`j"��tT rJl�) 17����j�f'� C�S�i`��515 �Uflii.� 1 io �i 5�, YI'i�',FfX i,� rCitr„lLFyg rt',C7F tx�y K Sworn to and subscribed before me this 7 y., A' -,,,{t i ,,� 11 2 �A 4 3:°l`r S - ,k 9i4-4. ° �` r ���a�- � � i s - 'q f l �3©�"t.',...1 =41f fiRJY 51 .�ly q �� �p {� (�(f� � r 1!(m w1a Sod it �oY �"1� q1 e z t�'Y � t'II _ I,U.U� [ �O�1tl r OO1_ °��i Ii LL) )A��'-3�In U� fit l{o r z �t � f: �s hr`s y �”" , ,. , �X m ‘P.. -},� ter3roL13: ,`4r�"° .fnS �^°'4�"�Pi°�lYs�''tb°�,�1ge��lYR�. ��o �Fe ('zoe` n ,'' a , '., f, '1‘;',.\',.0 ��,�j--+' - `- 2,5,', s .h j� �y,i n{_�' }�Lt.. �.0 ,tiE i Public sy��rr' � A,F, ,, r ,, , �`r` `�� $( z'�� ' .x-4,''',•!. ,, h.:: f'I� } �� tt e' t ?..+: '44,r'1 �I I-- Yfi �y�3. �-t j , , 3 r''. I t J My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Bethany M.Holtry,Notary Public Carlisle Bole,Cumberland County My Commission Expires Sept 26,2015 ' .‘ 4•Wkl? MEMBER PENNSYLVANIAASSOCIATION OF NOTARIES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c" Wells Fargo Bank, N.A., CIVIL DIVISION T Plaintiff No.: 12-2497-CIVIL u r� �C} 2012-02497 i vs. ISSUE NUMBER: e� . RICHARD E.ADAMS; TYPE OF PLEADING: ` Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT Mortgaged Premises: (MORTGAGE FORECLOSURE) 615 Woodland Avenue, Mount Holly Springs, PA 17065-1937 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 Jana Fridfinnsdottir, Esquire- Pa I.D.#315944 Brian Nicholas, Esquire- Pa I.D.#317240 Denise Carlon, Esquire- Pa I.D. #317226 200 Sheffield Street, Suite 101 Mountainside, N1 07092 (908) 233-8500 Atty File No.: XFP-165026 al ,2 � 3cal � a� Praefcipe for Entry of Judgment Zucker,Goldberg&Ackerman, LLC XFP-165026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 12-2497-CIVIL 2012-02497 RICHARD E.ADAMS; Defendant. 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 set forth in Complaint: Amount as set forth in Complaint $122,993.68 plus interest on the judgment amount($122,993.68)from April 7, 2012, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 615 Woodland Avenue address is: Mount Holly Springs, PA 17065-1937 i ZUCKER,GOLBERG &ACKERMAN, LLC Dated: , I I BY: 0 A �iA H I'll - Joel A.Ackerman, Esquir • PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Jaime R.Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-165026 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908)233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com 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, vs. NO.: 12-2497-CIVIL 2012-02497 RICHARD E.ADAMS; Defendant. AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. ! L ! ZUCKER,GOLBERG &ACKERMAN, LLC Y Dated: i I O i ! `y BY: 0 A h4 fl' )� h, ` ❑� , Joel A.Ac erman, Esquire; PA I.D.#202729 U Ashleigh L. Marin, Esquire; PA I.D.#306799 F1 Jaime R.Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-165026 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com Sworn to and subscr' ed before me Thiso4?V'day of , 20/ Y Notary Public My Commission Expires: Cheryl Debeneadto Notary public MY Comm.Expires Oct. 16 2016 ID#2280276 State of New Jersey Zucker,Goldberg&Ackerman, LLC XFP-165026 Department of Defense Manpower Data Center Results as of:Jan-24-2014 08:26:28 AM SCRA 3.0 Status Report E Pursuant to Servicemembers Civil Relief Act Last Name: ADAMS First Name: RICHARD Middle Name: E Active Duty Status As Of: Jan-24-2014 On Active Duty On Active Status Pete -+ -Active D uty Start Data Active End Date' "' 8$` Servl '(sin t NA NA 'No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active-Du .Within 367 D of Active S�tus bate Active Duty Start Date Active D dyiEndl Date` • ' S[atus service component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date Th.Mernbarcrilill tllnRVffaaAotllledofaFutureCa11U'to '.drtAcMva•. Sfatusl tek, :a t+,r order Notificatlon Start Date Order Notification End Date Status' Service Com NA NA No NA This response reflects whether the individual or his/her unit has received earlynotificalion to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NCAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Ohl e orn ..+ Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and 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 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on 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 to 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.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active 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 active 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 in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve 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(NOAH 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 periods. 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 service. 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 have 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 SCRA 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 SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: T61 DW9DFG05BE40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 12-2497-CIVIL 2012-02497 RICHARD E.ADAMS; Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: RICHARD E.ADAMS 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 [ ] Plaintiff [-4] Defendant [ ] Additional Defendant You are hereby notified that an Ord r, Decree or Judgment was entered in the above captioned proceeding on [ ] A copy of the Order or Decree is enclosed, or [-4] The judgment is as follows: $122,993.68 plus costs. Prge ono Zucker,Goldberg&Ackerman, LLC XFP-165026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A., ISSUE NO.: 12-2497-CIVIL 2012-02497 Plaintiff, VS. TYPE OF PLEADING RICHARD E.ADAMS; AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO Defendant. Pa.R.C.P.,430 SPECIAL ORDER OF COURT CODE: FILED ON BEHALF OF: Wells Fargo Bank. N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER,GOLDBERG&ACKERMAN,LLC Scott A. Dietterick,Esquire PA I.D.#55650 Kimberly A. Bonner,Esquire-PA I.D.#89705 Joel A.Ackerman;Esquire-PA I.D.#202729 Ashleigh Levy Marin,Esquire-PA I.D.#306799 Ralph M.Salvia, Esquire-PA I.D.#202946 Jaime R.Ackerman,Esquire-PA I.D.#311032 Jana Fridfinnsdottir, Esquire- PA I.D.#315944 Brian Nicholas,Esquire- PA I.D.#317240 Denise Carlon, Esquire- PA I.D.#317226 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500 (908)233-1390 FAX officeC«7zuckereoldbere.com File No.:XFP-165026/thaw IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, VS. NO.:12-2497-CIVIL 2012-02497 RICHARD E.ADAMS; Defendant. AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT �KlSt CO-HO) Esquire,attorney for Plaintiff,Wells Fargo Bank,N.A.,being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff s Complaint in Mortgage Foreclosure on Defendant,RICHARD E.ADAMS, as follows: 1. On or about January 11,2013,an Order of Court was entered granting Plaintiffs Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit"A",attached hereto and made a part hereof. 2. Pursuant to said Order,on or about April 24,2013,Zucker,Goldberg&Ackerman, LLC, the counsel for Plaintiff served Defendant,RICHARD E.ADAMS with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure,via First Class U.S.Mail and Certified Mail,Return Receipt Requested to the defendant's last known address being 615 Woodland Avenue,Mount Holly Springs, PA 17065-1937. A true and correct copy of said returned receipt and certificate of mailing are marked Exhibit"B",attached hereto and made a part hereof. 3. Pursuant to said Order,on or about April 29,2013,the Sheriff of Cumberland County posted the property subject to the Mortgage,being 615 Woodland Avenue,Mount Holly Springs, PA 17065-1937 with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure. A true and correct copy of the Service Form from the Cumberland County Sheriff's Office is marked Exhibit"C", attached hereto and made a part hereof. 4. Pursuant to said Order,on or about November 22,2013,Plaintiff published Plaintiffs Complaint in Mortgage Foreclosure once in The Cumberland Law Journal,for Cumberland County, Pennsylvania. True and correct copy of the Proofs of Publication are marked Exhibit"D",attached hereto and made a part hereof. 5. Pursuant to said Order,on or about November 22,2013,Plaintiff published Plaintiffs Complaint in Mortgage Foreclosure once in The Sentinel,for Borough of Carlisle,Cumberland County, Pennsylvania. True and correct copy of the Proofs of Publication are marked Exhibit"E",attached hereto and made a part hereof. ZUCKER.GOLDBERG&ACKERMAN,LLC Dated: January ,2014 B •�D� � 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 Mann,Esquire; PA I.D.#306799 Ralph M.Salvia,Esquire; PA I.D.#202946 Jaime R.Ackerman,Esquire;PA I.D.#311032 Jana Fridfinnsdottir,Esquire;PA I.D.#315944 Brian Nicholas,Esquire; PA I.D.#317240 --Denise Carlon,Esquire;PA I.D.#317226 Atty File No.:XFP-165026 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 Email: Offlce@zuckergoldberg.com (908)233-8500; (908)233-1390 FAX Sworn to and subscribed before me this f 7 day of January,2014 Notary Public MY COMMISSION EXPIRES: Cheryl Debeneadto Notary Public My Comm.Expires Oct.16,2016 ID#2280276 State of New Jersey EXHIBIT A IN THE COURT OF'COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,..N.A. 'gwLTIVISION Plaintiff, vs; j�0:` 2-2487-C(1/lL ' .2012-02497. RICHARD E.ADAMS; Defendant: ORDER OF COURT. AND NOW,this'- day of ,20 upon consideration of Plaintiffs Motion for-Special Service,it Whereby ORDERED;ADJUDGED AND DECREED that Plaintiff shall serve its. Complaint in Mortgage Foreclosure and Notice of Sale, If- necessary, pry Defendant(s) RICHARD E. ADAMS, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises,being 615 Woodland Avenue,Mount Holly Springs PA 17Q65-1937,and by m 1la ing a cap a Certified Mail, no signature required and First Class U.S. Mail,Postage Prepaid v in accordantgwith Pa.R.C.P:430'. BYThIE T: • • CAR. j C- • �� �..- .-•tom Zucker,Goldberg&Ackerman,LLC XFP-16502.6: EXHIBIT B UNITED S- TAMS.- -P SUL 5ERVIC { Thb GrtNhte efNW*s podds wWwcethat rml his how proomted to Lffn-fwmn t.Thbf MKT end6uenutbmlmaa 0004282 036 Scott A.Dietterick,Esquire 01.200 23 E FRpM ZO�Cppg 07092 I c/o Zucker,Goldberg&Ackerman,LLC _ .. 200 Sheffield Street,Suite 101 o� - ? Mountainside,NJ 07092 xFP-165026/fs TEA s 2 4 2013 To' RICHARD E.ADAMS 615 Woodland Avenue Mount Holly Springs,PA 17065-1937 SP f County of P.Q.:CUMBERLAND j PS Form 3817,Aprd 2007 PSN 7530-02-000-9065 zucW.Goldbw9 a nd�m,U.0 PO B-1119 MourAnnddq NJ W092-1219 7396 9006 9296 6798 9584 2019D124192 61,11111,111.1 l•d41a•I lulurlrp lnn•IIPPdh•�I RICHARD E.ADAMS 815 WOODLAND AVE MOUNT HOLLY SPRINGS,PA 17065.1937 ISMTG EXHIBIT C SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith J 1 2'� �QOntiY of uarr,�y�b Chief Deputy' ! �o �>4-Kilt Richard W Stewart solic for OifICE Or TK SKWr Wells Fargo Bank,N.A. vs, Cass Number Richard E.Adams 2012-2497 SHERIFF'S RETURN OF SERVICE 04/29/2013 03:25 PM-Deputy William Cline,being duly swom according to law,served the requested Notice of Residential Mortgage Foreclosure•Diveralon Program and Complaint in Mortgage Foreclosure upon the within named Defendant,to wit:Richard E.Adams, pursuant to Order of Court by"Posting"the premises located at 615 Woodland Avenue,South Middleton Township,Mount H 17065 h a true and correct copy according to law. SHERIFF COST:$41.9 1 SO ANSWERS, April 30,2013 RON R ANDERSON,SHERIFF (a)CounLYS1410 Swat.T011160tl Ma. EXHIBIT D PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No.587,approved May 15,1929),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 November 22,2013 i 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. F sa Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 22 day of November.2013 Notary { NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commissioa Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MENT MAY BE 17 IT`t RED AGAINST MORTGAGE FORECLOSURE YOU WITHOUT FURTHER NOTICE �.. FOR RELIEF REQUESTED BY T;iE In the Court of Common Pleas of PL.AVnW7.YOU MAY DOSE MONEY Cumberland County,Pennsylvania OR PROPERTY OR OTHER RIGHTS Civil Action—Law IMPORTANT TO YOU. YOU SHOULD.TARE THIS MO- NO.:12-2497-CIVIL 710E TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER i Wells Fargo Bank,N.A. OR CANNOT AFFORD ONE, GO ! Plaintiff TO OR TELEPHONE THE OFFICE Va, SET FORTH BELOW TO FIND OUT i RICHARD E.ADAMS WHEREYOU CAN GET LEOALHEW Defendant(s) NOTICE TO DEFEND LAWYER REFERRAL TO.RICHARD E.ADAMS CumbadandCouclyBarAssodaon I PRESENTLY OR FORMERLY of 32 S.Bedford Street 615 Woodland Avenue,Mount Holly Carlisle,PA 17018 Springs,PA 17065-1937.A lawsuit Phone(800)990-9108 has been filed against you in mart (7171249-3166 gage foreclosure and against your Nov.22 real estate at 615 Woodland Avenue, MountHollySprings,PA 17065.1937 'because you have failed to make the regular monthly payments on your mortgage loan and the loan is in default.The lawsuit is an attempt to collect a debt from you owed to the plaintiff;Wells Fargo Bank, N.A.A detailed notice to you of your rights under the Fair Debt Collection Prac- tices Act(15 U.S.C. 91692 et seq.) is included in the Complaint Sled in the lawsuit.The lawsuit is filed i in the Cumberland County Court of Common Pleas, at the above term and number. A copy of the Complaint filed in the lawsuit will be sent to you upon request to the Attorney for the Plain- tiff,Scott A.Dietteriok,Esquire,P.O. Box 1024,Mountainside,NJ 07092. Phone(908)233-8500. IF YOU WISH TO DEFEND,YOU MUST ENTER A WRITTEN AP- PEARANCE PERSONALLY OR BY AN ATTORNEY AND FILE YOUR DEFENSES OR OBJECTIONS IN WRITING WITH THE COURT.YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PRO- CEED WITHOUTYOU AND AJUDO- 9 EXHIBIT E ,. . __�._._-�..__.._.___.._...:.:w;.eu.L••,:k::,.;:t.a,;;�,i:.:.'_. ..,_. -..+:_...,i..-b.._..-iv.+-�;+—�-..,_rte` ,. .._......_._.�.------_....-�_.._. ._.. ...u. ....�I PROOF OF PUBLICATION State of Pennsylvania,County of Cumberland laclde Cox,Director of Sales of The Sentinel,of the County and State aforesaid,being duly sworn,deposes and says that THE SENTINEL,a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13t�, 1881,since which date THE SENTINEL has been regularly issued in said County,and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): November 22.2013 COPY OF NOTICE OF PUBLICATION Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement,and that all allegations in the foregoing statement as to time,place and character of publication are Sworn to and subscribed before me this QL t h c rn1w r- i; I tary Public My commission expires: COMMONM EALM OF PENNSYLVANIA NomrWi Seal 1Y M.HdtrYr NoTY Public aniae eoro,amberlana County MY ox�ssro 1 ac 10 sept 26,2015 MM&E&PM9SYLVAM no110 F koru s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,N.A., ISSUE NO.: 12-2497-CIVIL 2012-02497 Plaintiff, VS. TYPE OF PLEADING RICHARD E.ADAMS; AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO Defendant. Pa.R.C.P.,430 SPECIAL ORDER OF COURT CODE: FILED ON BEHALF OF: Wells Fargo Bank,N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER,GOLDBERG&ACKERMAN,LLC Scott A. Dietterick, Esquire PA I.D.#55650 Kimberly A.Bonner, Esquire-PA I.D.#89705 Joel A.Ackerman,Esquire-PA I.D.#202729 Ashleigh Levy Marin, Esquire-PA I.D.#306799 Ralph M.Salvia, Esquire-PA I.D.#202946 Jaime R.Ackerman,Esquire-PA I.D.#311032 Jana Fridfinnsdottir,Esquire- PA I.D.#315944 Brian Nicholas, Esquire- PA I.D.#317240 Denise Carton,Esquire- PA I.D.#317226 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500 (908)233-1390 FAX office@zuckereoldberg.com File No.:XFP-165026/dlaw IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Home Mortgage, Inc.f/k/a Norwest CIVIL DIVISION Mortgage, Inc. Plaintiff, NO.: 12-2497-CIVIL 2012-02497 vs. RICHARD E.ADAMS Defendant. IMPORTANT NOTICE TO: RICHARD E.ADAMS 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 DATE OF NOTICE: 6/11/2013 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 Home Mortgage, Inc.f/k/a Norwest CIVIL DIVISION Mortgage, Inc. Plaintiff, NO.: 12-2497-CIVIL 2012-02497 vs. RICHARD E.ADAMS Defendant. AVISO IMPORTANTE TO: RICHARD E.ADAMS 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 FECHA DEL AVISO:6/11/2013 USTED ESTA EN REBELDLA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INNLEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. 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 ZUCKER,GOLDBERG &ACKERMAN BY: SOLI#A. Q IeftB1-Ick Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 165026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION File No. 12-2497-CIVIL Wells Fargo Bank, N.A., • 2012-02497 • Amount Due $122,993.68 Plaintiff, • vs. Interest from 04/07/2012 to date of sale @ $20.94/day $16,500.72 RICHARD E.ADAMS; • Costs Defendant. • • • • TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed 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 CS,) cad S d a� OUAA .00 egF , 103 .75 M 7) ,r. t1 . S `' 1 <c �.a .as Ck#,5"" Zucker Goldberg&Ackerman,LLC /217LdIGIO N1 /eS' 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 personalty 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 against real estate of the defendant(s)described in the attached exhibit. DATE: J I ( L Signature: YlC 111 Print Name: Sco t . Di tterick, Esquire Kimberly A. Bonner, Esquire Joel Ackerman, Esquire Ashleigh L. Marin, Esquire Ralph M. Salvia, Esquire Jaime R.Ackerman, Esquire Jana Fridfinnsdottir, Esquire Brian Nicholas, Esquire Denise Carlon, 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.: 55650 89705 202729 306799 202946 311032 315944 317240 317226 Zucker,Goldberg&Ackerman, LLC XFP-165026 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY WOODLAND AVENUE; ON THE SOUTH BY LOT NO. 61 OF THE HEREINAFTER MENTIONED PLAN OF LOTS; ON THE WEST BY LOT NO. 69 OF SAID PLAN OF LOTS; AND ON THE NORTH BY THE NORTHERN HALF OF LOT NO. 59 OF SAID PLAN OF LOTS; HAVING A FRONTAGE OF 77.45 FEET, MORE OR LESS, ON WOODLAND AVENUE, A DEPTH ON THE SOUTH OF 144 FEET, A WIDTH IN THE REAR OF 75 FEET AND A DEPTH ON THE NORTH OF 119.35 FEET, MORE OR LESS; AND BEING LOT NO. 60 AND THE SOUTHERN HALF OF LOT NO. 59 OF THE PLAN OF LOTS KNOWN AS MT. VIEW ADDITION ADJOINING MT. HOLLY SPRINGS BOROUGH, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY, IN PLAN BOOK 3, PAGE 86. SUBJECT, HOWEVER,TO THE BUILDING AND USE RESTRICTIONS AND CONDITIONS AS SET FORTH AND ATTACHED TO SAID PLAN OF LOTS, WITH WHICH THE GRANTEES, FOR THEMSELVES,THEIR HEIRS AND ASSIGNS,AGREE TO COMPLY BY THE ACCEPTANCE OF THIS DEED. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 615 WOODLAND AVENUE, MOUNT HOLLY SPRINGS, PA, 17065-1937. BEING THE SAME PREMISES WHICH LOIS A. BARNER, PAULA.ADAMS, ROBYN A. PORTER, PAMELA C. RUTTER, MARGIE A. SHENK, ALBERT E. ADAMS, III, AND RICHARD E. ADAMS, BY DEED DATED JUNE 16, 2008 AND RECORDED AUGUST 1, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, AS INSTRUMENT#200826206, GRANTED AND CONVEYED UNTO RICHARD E. ADAMS, MARRIED MAN. TAX MAP NO.: 40-30-2646-044. Zucker,Goldberg&Ackerman, LLC XFP-165026 • • WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-2497 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 RICHARD E.ADAMS (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: $122,993.68 L.L.: $.50 Interest FROM 4/7/202 TO DATE OF SALE @$20.94/DAY-$16,500.72 Atty's Comm: Due Prothy: $2.25 Atty Paid: $254.16 Other Costs: Plaintiff Paid: Date: 2/26/14 David D.Buell,Prothonotary t . (Seal) _ BY: � �� - _ ft.,/ Deputy REQUESTINGPARTY: Name:ASHLEIGH-L.MARIN,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.306799 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 12-2497-CIVIL t r' vs. 2012-02497 G, � ' RICHARD E.ADAMS; Execution No.: D .. . 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 615 Woodland Avenue, Mount Holly Springs, PA 17065-1937. 1. Name and Address of Owner(s)or Reputed Owner(s): RICHARD E.ADAMS, MARRIED MAN 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 2. Name and Address of Defendant(s) in the Judgment: RICHARD E.ADAMS 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 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 STATE FARM INSURANCE COMPANIES P.O. Box 2371 Bloomington, IL 61702 AND c/o Wix, Wenger&Weidner 4705 Duke Street Harrisburg, PA 17109-3041 Zucker,Goldberg&Ackerman,LLC X.FP-165026 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff PNC MORTGAGE, 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 SOUTH MIDDLETON TOWNSHIP MUNICIPAL AUTHORITY P.O. Box 8 Boiling Springs, PA 17007 AND cjo Keith 0. Brenneman, Esquire Snelbaker&Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055 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 Zucker,Goldberg&Ackerman,LLC XFP-165026 UNKNOWN TENANT OR TENANTS 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 UNKNOWN SPOUSE 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 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. ZUCKER,GOLDBERG &ACKERMAN, LLC Dated: 1 11K m W 1 II4 BY: a/ 7r Scott A. Dietterick Esquire; PA`F.D.#55650 q , 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 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D.#317226 Attorneys for Plaintiff XFP-165026/11 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908)233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC X.FP-1.65026 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY WOODLAND AVENUE; ON THE SOUTH BY LOT NO. 61 OF THE HEREINAFTER MENTIONED PLAN OF LOTS; ON THE WEST BY LOT NO. 69 OF SAID PLAN OF LOTS; AND ON THE NORTH BY THE NORTHERN HALF OF LOT NO. 59 OF SAID PLAN OF LOTS; HAVING A FRONTAGE OF 77.45 FEET, MORE OR LESS, ON WOODLAND AVENUE, A DEPTH ON THE SOUTH OF 144 FEET, A WIDTH IN THE REAR OF 75 FEET AND A DEPTH ON THE NORTH OF 119.35 FEET, MORE OR LESS;AND BEING LOT NO. 60 AND THE SOUTHERN HALF OF LOT NO. 59 OF THE PLAN OF LOTS KNOWN AS MT.VIEW ADDITION ADJOINING MT. HOLLY SPRINGS BOROUGH, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY, IN PLAN BOOK 3, PAGE 86. SUBJECT, HOWEVER,TO THE BUILDING AND USE RESTRICTIONS AND CONDITIONS AS SET FORTH AND ATTACHED TO SAID PLAN OF LOTS, WITH WHICH THE GRANTEES, FOR THEMSELVES,THEIR HEIRS AND ASSIGNS, AGREE TO COMPLY BY THE ACCEPTANCE OF THIS DEED. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 615 WOODLAND • AVENUE, MOUNT HOLLY SPRINGS, PA, 17065-1937. • BEING THE SAME PREMISES WHICH LOIS A. BARNER, PAULA. ADAMS, ROBYN A. PORTER, PAMELA C. RUTTER, MARGIE A. SHENK, ALBERT E.ADAMS, III, AND RICHARD E.ADAMS, BY DEED DATED JUNE 16, 2008 AND RECORDED AUGUST 1, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, AS INSTRUMENT#200826206, GRANTED AND CONVEYED UNTO RICHARD E. ADAMS, MARRIED MAN. TAX MAP NO.: 40-30-2646-044. Zucker,Goldberg&Ackerman, LLC XFP-165026 • • r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 12-2497-CIVIL vs. 2012-02497 RICHARD E. ADAMS; C3 — Defendant. --11 1 rYt 37C) C-pc NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 RICHARD E.ADAMS 615 Woodland Avenue Mount Holly Springs, PA 17065-1937. TAKE NOTICE: • That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/4/2014 at 10:00 a.m. 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: 615 Woodland Avenue, Mount Holly Springs, PA, 17065-1937 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-2497-CIVIL 2012-02497 Zucker, Goldberg&Ackerman, LLC XFP-165026 • w r J THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: RICHARD E.ADAMS, married man A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff(for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty(30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association . Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800)990-9108 (717)249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 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-165026 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 &ACKERMAN, LLC BY: 0 irw7 Dated: 1 �K i Scott A. ietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA 1.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 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA 1.D. #317226 Attorneys for Plaintiff XFP-165026/11 200 Sheffield Street,Suite 101 • Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX Email: Office @zuckergoldberg.com VIA ORDER OF COURT Zucker, Goldberg&Ackerman, LLC XFP-165026 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY WOODLAND AVENUE; ON THE SOUTH BY LOT NO. 61 OF THE HEREINAFTER MENTIONED PLAN OF LOTS; ON THE WEST BY LOT NO. 69 OF SAID PLAN OF LOTS; AND ON THE NORTH BY THE NORTHERN HALF OF LOT NO. 59 OF SAID PLAN OF LOTS; HAVING A FRONTAGE OF 77.45 FEET, MORE OR LESS, ON WOODLAND AVENUE, A DEPTH ON THE SOUTH OF 144 FEET, A WIDTH IN THE REAR OF 75 FEET AND A DEPTH ON THE NORTH OF 119.35 FEET, MORE OR LESS; AND BEING LOT NO. 60 AND THE SOUTHERN HALF OF LOT NO. 59 OF THE PLAN OF LOTS KNOWN AS MT. VIEW ADDITION ADJOINING MT. HOLLY SPRINGS BOROUGH, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY, IN PLAN BOOK 3, PAGE 86. SUBJECT, HOWEVER,TO THE BUILDING AND USE RESTRICTIONS AND CONDITIONS AS SET FORTH AND ATTACHED TO SAID PLAN OF LOTS, WITH WHICH THE GRANTEES, FOR THEMSELVES, THEIR HEIRS AND ASSIGNS, AGREE TO COMPLY BY THE ACCEPTANCE OF THIS DEED. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 615 WOODLAND AVENUE, MOUNT HOLLY SPRINGS, PA, 17065-1937. • BEING THE SAME PREMISES WHICH LOIS A. BARNER, PAULA. ADAMS, ROBYN A. PORTER, PAMELA C. RUTTER, MARGIE A. SHENK, ALBERT E. ADAMS, III,AND RICHARD E. ADAMS, BY DEED DATED JUNE-16, • 2008 AND RECORDED AUGUST1, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, AS .INSTRUMENT#200826206, GRANTED AND CONVEYED UNTO RICHARD E. ADAMS, MARRIED MAN. • TAX MAP NO.: 40-30-2646-044. Zucker, Goldberg&Ackerman, LLC XFP-165026 • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. C1VIL'DIVISION Plaintiff, NO.: 12-2497-CIVIL vs:. .2012-02497 RICHARD E.ADAMS; Defendant. • • ` ' ORDER OF COURT AND NOW,this t day of , 208 upon consideration of Plaintiff's Motion for Special Service, it is hereby ORDERED,ADJUDGED AND DECREED that Plaintiff shall serve its. Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) RICHARD E. ADAMS, by instructing the Sheriff of Cumberland County to POST a copy of same on.the Mortgaged Premises, being 615 Woodland Avenue, Mount Holly Springs PA 17065-1937,and by m iling.a cop a Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid mr az'e im v p , ��i 4‘43.44444ej in accordance with Pa.R.C.P.430. BY THE 6 , - • Y . .. _,.- --i jam. c"'' ��,.•'3 r C•r . 't7,g"} ,<1=1 ...p -n. _ .Z .; • p Zucker,Goldberg&Ackerman,LLC' XFP-165026. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION vs. Plaintiff, NO.: 12 -2497 -CIVIL 2012-02497 RICHARD E. ADAMS; Execution No.: Defendant(s). AMENDED 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 615 Woodland Avenue, Mount HoIIy Springs, PA 17065-1937. 1. Name and Address of Owner(s) or Reputed Owner(s): RICHARD E. ADAMS, MARRIED MAN 615 Woodland Avenue Mount HoIIy Springs, PA 17065-1937 2. Name and Address of Defendant(s) in the Judgment: RICHARD E. ADAMS 615 Woodland Avenue Mount HoIIy Springs, PA 17065-1937 cF� 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 STATE FARM INSURANCE COMPANIES P.O. Box 2371 Bloomington, IL 61702 AND c/o Wix, Wenger & Weidner 4705 Duke Street Harrisburg, PA 17109-3041 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff PNC MORTGAGE, 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 SOUTH MIDDLETON TOWNSHIP MUNICIPAL AUTHORITY P.O. Box 8 Boiling Springs, PA 17007 AND c/o Keith 0. Brenneman, Esquire Snelbaker & Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055 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 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 UNKNOWN SPOUSE 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 PERRY COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 2 W Main St., Rhinesmith Hotel Bldg, New Bloomfield, PA 17068-0159 LUZERNE COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section Bernard C. Brominski Bldg. 133 W North St. Wilkes-Barre PA 18711-1001 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: lac ZUCKER, GOLDBERG & ACKERMAN, BY: Scott A. Diette ick, 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 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XCP-165026/nfe 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY WOODLAND AVENUE; ON THE SOUTH BY LOT NO. 61 OF THE HEREINAFTER MENTIONED PLAN OF LOTS; ON THE WEST BY LOT NO. 69 OF SAID PLAN OF LOTS; AND ON THE NORTH BY THE NORTHERN HALF OF LOT NO. 59 OF SAID PLAN OF LOTS; HAVING A FRONTAGE OF 77.45 FEET, MORE OR LESS, ON WOODLAND AVENUE, A DEPTH ON THE SOUTH OF 144 FEET, A WIDTH IN THE REAR OF 75 FEET AND A DEPTH ON THE NORTH OF 119.35 FEET, MORE OR LESS; AND BEING LOT NO. 60 AND THE SOUTHERN HALF OF LOT NO. 59 OF THE PLAN OF LOTS KNOWN AS MT. VIEW ADDITION ADJOINING MT. HOLLY SPRINGS BOROUGH, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY, IN PLAN BOOK 3, PAGE 86. SUBJECT, HOWEVER, TO THE BUILDING AND USE RESTRICTIONS AND CONDITIONS AS SET FORTH AND ATTACHED TO SAID PLAN OF LOTS, WITH WHICH THE GRANTEES, FOR THEMSELVES, THEIR HEIRS AND ASSIGNS, AGREE TO COMPLY BY THE ACCEPTANCE OF THIS DEED. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 615 WOODLAND AVENUE, MOUNT HOLLY SPRINGS, PA, 17065-1937. BEING THE SAME PREMISES WHICH LOIS A. BARNER, PAUL A. ADAMS, ROBYN A. PORTER, PAMELA C. RUTTER, MARGIE A. SHENK, ALBERT E. ADAMS, III, AND RICHARD E. ADAMS, BY DEED DATED JUNE 16, 2008 AND RECORDED AUGUST 1, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, AS INSTRUMENT #200826206, GRANTED AND CONVEYED UNTO RICHARD E. ADAMS, MARRIED MAN. TAX MAP NO.: 40-30-2646-044. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff No.: 12 -2497 -CIVIL 2012-02497 vs. RICHARD E. ADAMS; TYPE OF PLEADING: Defendant Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST 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 Levy Marin, Esquire -Pa I.D. #306799 Ralph M. Salvia, Esquire- Pa I.D. #202946 Jaime R. Ackerman, Esquire- Pa I.D. #311032 Jana Fridfinnsdottir, Esquire- PA I.D. #315944 Brian Nicholas, Esquire- PA I.D. #317240 Denise Carlon, Esquire- PA I.D. #317226 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-165026 c-� CID Y CD cp f.. r� CO CD t (.11 N) r Zucker, Goldberg & Ackerman, LLC XFP-165026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. RICHARD E. ADAMS; Plaintiff, Defendant. CIVIL DIVISION NO.: 12 -2497 -CIVIL 2012-02497 Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Margaret Agyepong, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriff's Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant(s) Richard E. Adams, married man, is/are the record owners of the real property. 2. Pursuant to the Order of Court dated January 11, 2013, the Sheriff of Cumberland County posted Plaintiffs Notice of Sheriff's Sale, at the address of the mortgaged premises, being 615 Woodland Avenue, Mount Holly Springs, PA 17065-1937, on or about March 25, 2014. A true and correct copy of said Order of Court and Proof of Posting are marked Exhibit "A", attached hereto and made a part hereof. 3. Pursuant to the Order of Court dated January 11, 2013, Plaintiff's counsel served Defendant(s) Richard E. Adams, with Plaintiff's Notice of Sheriffs Sale, via Certified Mail no signature required, at the address of 615 Woodland Avenue, Mount Holly Springs, PA 17065-1937, on or about March 13, 2014. True and correct copies of said Notices and Proofs of Mailing are marked Exhibit "B", attached hereto and made a part hereof. 4. Pursuant to the Order of Court dated January 11, 2013, Plaintiff's counsel served Defendant(s) Richard E. Adams, with Plaintiff's Notice of Sheriffs Sale via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing, at the address of 615 Woodland Avenue, Mount Holly Springs, PA 17065-1937, on or about March 14, 2014. True and correct copies of said Certificate of Mailing is marked Exhibit "C", attached hereto and made a part hereof. Zucker, Goldberg & Ackerman, LLC XFP-165026 5. Pursuant to the Order of Court dated January 11, 2013, Plaintiff's counsel published Plaintiffs Notice of Sale for Defendant Richard E. Adams, once in The Sentinel, Newspaper general circulation in Cumberland County, Pennsylvania, on or about April 23, 2014, and The Cumberland Law Journal on or about April 11, 2014. True and correct copies of the Proofs of Publication are marked Exhibit "D", attached hereto and made a part hereof. 6. On or about May 5, 2014, Plaintiff's counsel served all other parties in interest with Plaintiff's Notice of Sheriff's Sale according to Plaintiff's Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "E", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendants/Owners and all other Parties of Interest were served with Plaintiff's Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P. 3129.2. Dated: May , 2014 Sworn to and subscribed before This day of 1 1 fk 1 , 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff MARGARET < YEPONG Paralegal/Legal Assistant Nota Public MY COMMISSION EXPIRES: PAUL C. NADRATOWSKI Notary Publico ew Jersey 0 My Commission Expires 4/27/2016 Zucker, Goldberg & Ackerman, LLC XFP-165026 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-165026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs'. RICHARD E. ADAMS; Plaintiff, Defendant. /44 AND NOW, this it day of CIVIL DIVISION NO.: 12 -2497 -CIVIL .2012-02497 ORDER OF COURT V Motion for Special Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its. Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) RICHARD E. ADAMS, by instructing the Sheriff of Cumberland County to POST a copy of same on. the Mortgaged Premises, being 615 Woodland Avenue, Mount Holly Springs PA 17065-1937, and by m it a cop 'a G�pv( Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid v in accordance with Pa.R.C.P. 430 , 208 upon consideration of Plaintiff's Zucker, Goldberg & Ackerman, LLC XFP-165026 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY of 4i!riri.ta Wells Fargo Bank, N.A. Case Number vs. Richard E. Adams 2012-2497 SHERIFF'S RETURN OF SERVICE 03/25/2014 07:16 PM - Deputy Dawn Kell, 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 615 Woodland Avenue, South Middleton - Township, Mount Holly Springs, PA 17065, Cumberland County. 03/25/2014 07:16 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Richard E. Adams, pursuant to Order of Court by "Posting" the premises located at 615 Woodland Avenue, South Middleton Township, Mount Holly Springs, PA 17065, Cumberland County with a true and correct copy according to law. SHERIFF COST: $1,438.79 SO ANSWERS, May 23, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-165026 Zucker, Goldberg & Ackerman, LLC PO Box 1219 Mountainside, NJ 07092-1219 i i i i i i ?196 9006 9297 2962 3593 20140313-102 PIiI1*IhiI"IIIIIIIIIIIIIIIIlII,IIIII11111I1I1'I1'1111,I„ RICHARD E. ADAMS 615 WOODLAND AVE MOUNT HOLLY SPRINGS, PA 17065-1937 PANOSS •er IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. RICHARD E. ADAMS; Plaintiff, Defendant. CIVIL DIVISION NO.: 12 -2497 -CIVIL 2012-02497 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 RICHARD E. ADAMS 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 6/4/2014 at 10:00 a.m. 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: 615 Woodland Avenue, Mount HoIIy Springs, PA, 17065-1937 The JUDGMENT under or pursuant to which your property is being sold Is docketed to: No. 12 -2497 -CIVIL 2012-02497 Zucker, Goldberg & Ackerman, LLC XFP-165026 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: RICHARD E. ADAMS, married man A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS,A.NOTICE. QF THETIME AND PLACE. OE.THE SALEOFYOUR PROPEITY.. 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 prevant your property from being taken. A lawyer can advise you more specifically of these right?. If you wish to exercise your rights; you must act promptly. YOU, $HOLILE) TAKE THIS PAPER TO YOUR. I,AWYEKAT ONCE.. GO: TO:OR TEL fir)NETHE 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 procechire used against you. 2. After the Sheriff's 5ale, you may file a petition with the Curt of Common Pteas of Cumberland County t': 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-165026 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 & ACKERMAN, LLC BY:. Scott A. }ie ...: k, Esqu rf 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 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-165026/II 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com VIA ORDER OF COURT Zucker, Goldberg & Ackerman, LLC XFP-165026 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS: ON THE EAST BY WOODLAND AVENUE; ON THE SOUTH BY LOT NO. 61 OF THE HEREINAFTER MENTIONED PLAN OF LOTS; ON THE WEST BY LOT NO. 69 OF SAID PLAN OF LOTS; AND ON THE NORTH BY THE NORTHERN HALF OF LOT NO. 59 OF SAID PLAN OF LOTS; HAVING A FRONTAGE OF 77.45 FEET, MORE OR LESS, ON WOODLAND AVENUE, A DEPTH ON THE SOUTH OF 144 FEET, A WIDTH IN THE REAR OF 75 FEET AND A DEPTH ON THE NORTH OF 119.35 FEET, MORE OR LESS; AND BEING LOT NO, 60 AND THE SOUTHERN HALF OF LOT NO. 59 OF THE PLAN OF LOTS KNOWN AS MT. VIEW ADDITION ADJOINING MT. HOLLY SPRINGS BOROUGH, RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS FOR CUMBERLAND COUNTY, IN PLAN BOOK 3, PAGE 86. SUBJECT, HOWEVER, TO THE BUILDING AND USE RESTRICTIONS AND CONDITIONS AS SET FORTH AND ATTACHED TO SAID PLAN OF LOTS, WITH WHICH THE GRANTEES, FOR THEMSELVES, THEIR HEIRS AND ASSIGNS, AGREE TO COMPLY BY THE ACCEPTANCE OF THIS DEED. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 615 WOODLAND AVENUE, MOUNT HOLLY SPRINGS, PA, 17065-1937. BEING THE SAME PREMISES WHICH LOIS A. BARNER, PAUL A. ADAMS, ROBYN A. PORTER, PAMELA C. RUTTER, MARGIE A. SHENK, ALBERT E. ADAMS, III, AND RICHARD E. ADAMS, BY DEED DATED JUNE 16, 2008 AND RECORDED AUGUST 1, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, AS INSTRUMENT #200826206, GRANTED AND CONVEYED UNTO RICHARD E. ADAMS, MARRIED MAN. TAX MAP NO.: 40-30-2646-044. Zucker, Goidberg & Ackerman, LLC XFP-165026 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo 6ank,,N,A. vs. RICHARD E. ADAMS; Plaintiff, Defendant.. CLVIL°DIVISION NO.:' 12 -2497 -CIVIL 2012-02497 ., ORDER OF COURT AND NOW, this / day of • . , 208 upon consideration of Plaintiff's Motion forSpecialService, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its, Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) RICHARD E. ADAMS, by instructing the Sheriff of Cumberland County to POST a copy of same on. the Mortgaged Premises, being 615 Woodland Avenue, Mount Holly Springs PA 3.7465-1937, mitt by rn i1>n a:ctsp Certified Mall, no signature required and First Class U.S. Mail, Postage Prepaid. mac p.r. a : ce with Pa R,C.P. 490. Ca tt 7 jun ratioter~= /Crrlz '"' - c C.• -70 .44 ENI U. Zucker, Goldberg & Ackerman, LLC XFP-165026, EXHIBIT C Zucker, Goldberg & Ackerman, LLC XFP-165026 S2_NOS CERT UNITED STATES POSTAL SERVICE® Certificate Of Mailing This Certificate of Mailing provides evidence that mail has been presented to USW for mailing. This form may be used for domeatio and International mall. From: Ashleigh Levy Marin, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 TO: RICHARD E. ADAMS 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 County of P.Q.; CUMBERLAND To pay fee, aftbattam hare. t -n, terpostage D XFP-165026/pn TEAM- PA - C PS Form 3817, April 2007 PSN 7530-02-000-9065 Postmark Here yYNYd�1a4Nl6 001 20° 2034 Page 1 of 1 EXHIBIT D Zucker, Goldberg & Ackerman, LLC XFP-165026 NTL Page 1 of 7 UNITED STATES Cita POSTAL SERVICE Certificate Of Mailing US. POSTAGE j»PnTNEY s This Certlficete of Mailing provides evidence that mall has been presented to MPS' for mulling. This form may be used for domestic and Intemetionel mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-165026/nfe TEAM- C CLIMB i I • INTY1'AX-CLAIM-BUR Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 ZIP•07092 ► 001.2f° 0001387430 MAY 05 2014 To pay fee, affix stamps or meter postage here, Postmark Here County of P.Q.: CUMBERLAND MAY o s 2314 PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE Certificate Of Mailing This Certificate of Melling provides evidence that malt has been presented to USPS' for mailing. This fonts may be used for domestic and International mall. #r°n" Scott A. Dietterick, Esquire d o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-165026/nfe TEAM- C Tot COMMONWEALTH OF PENNSYLVANIA 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 SO AVM 0£fL (.1000 MI Z 00Z Z6040 dig S3MO0 AaN azi «SE}VJ SOd'STi To pay fee, affix stamps or mater postage here, Postmark Here MAY 05 210/4 NTL Page 2 of 7 ir7):1'111 UNITED STATES -ff'dif POSTAL SERVICEe Certificate 0 Mailing "i U.S. POSTAGE » RIMY BOWES This Certificate of MeiNng provides evidence that mad has bean presented to OPP for mailing. This form may be used for domestic and International mall. FromScott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-165026/nfe TEAM- C cor.inar . ZIP 07092 $ 001200 02 1 ri . 0001367430 MAY 05 2014 To pay fee, affix stomps or meter postage here, c' UNKNOWN TENANT OR TENANTS 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICED Postmark Here Certificate Of Mailing This Certificate of Meiling provides evidence that mill has been presented to UPS* for mailing. This form may be used for domestic end international mall. Fr°'„ Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-16502§/nfe TEAM- C STATE FARM INSURANCE COMPANIES P.O. Box 2371 Bloomington, IL 61702 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 t. I OZ SO AVVI OEPLEIC 000 00r 100 $ L6OLO 0 ip 411 p S3M0/3 A3N1Ja 39V190d -s-n To pay fee, affix stamps or meter postage here. Postmark Here NTL Page 3 of 7 UNITED STATES grali POSTAL sERwcE6 Certificate 0 Mailing This Certificate of MallIng provides evidence that mall has been presented to UPS' for melting. This form may be used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-165026/nfe TEAM- C To: STATE FARM INSURANCE COMPANIES c/o Wix, Wenger & Weidner 4705 Duke Street Harrisburg, PA 17109-3041 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ZIP2 0711Y092 $ 001.200 0 0001307430MAY, 05 2014 To pay fee, Obi stamps or meter postage hen. UNITED STATES Certificate Of • - POSTAL SERVICES MailingTo YM,efPotatampsormeterpoatge Mn. This Certificate of Melling provides evidence that nibll has been pneented to USPS• for melting. This form may be used for domestic and Intereetlonai meg. From: Scott A. Dietterick, Esquire C/0 Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-165026/nfe TEAM- C Tee PERRY COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 2 W Main St., Rhinesmith Hotel Bldg, New Bloomfield, PA 17068-0159 County of P.Q.: CUMBERLAND PS Form 3817, AprIl 2007 PSN 7530-02-000-9065 PLOZ 50 AVW0C4L9EL000 0025100 $ MOLD dfZ AMMOldr .Ire Savice 3DVI.SOd s n Postmark Here NTL Page 4 of 7 UNITED STATES POSTAL SERVICED Certificate 0 Mailing Ll:S. NAGE»PITt This Certificate of Miffing provides evidence that mall has been presented to USPS" for mailing, This form may be used for domestic and International mall, From' Scott A. Dietterick, Esquire C/0 Zucker, Goldberg & Ackerman, LIC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-165026/nfe TEAM- C To: LUZERNE COUNTY DOMESTIC RELATIONS OFFICE DomesticlielationsSection Bernard C. Brominski Bldg. 133 W North St. Wilkes-Barre PA 18711-1001 ZIP 07092 $ 001""20° 02 1rf 00013'87430 MAY 05 2014 To pay M, elfin stamps or meter postage here. Postmark Here County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICED Certificate Of Mailing This Grtmate of Mailing provides evidence that mall has bean presented to U5P5" for milling. This form may be used for domestic end international mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-165026/nfe TEAM- C To: SOUTH MIDDLETON TOWNSHIP MUNICIPAL AUTHORITY c/o Keith O. Brenneman, Esquire Snelbaker & Brenneman, P.C. 44 West Main Street Mechanicsburg, PA 17055 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 VI 0Z SO M440071.0 E1000 p0Z 100 $ Z6© 0 clIZ .ez 110290 STMCKIA , <39VLSOci Sn To pry fee, pills stamps or meter postage hen. NTL Page 5of7 uNirEDsrnrEs lir POST/1L SERVICE Certificate 0 Mailing U.S. POSTAGE» PrrNEy eowEs This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International mag, From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, C 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP 165026ffa i EAM- To: SOUTH MIDDLETON TOWNSHIP MUNICIPAL AUTHORITY P.O. Box 8 Boiling Springs, PA 17007 County of P,Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ��� UNITEDSTI]TES IJ POST/1t SERVICE, Certificate Of Mailing This Cogitate of Melting provides evidence that mag has been presented to USPS• for m end international mall. From: Scott A. Dietterick, Esquire form maybe used for domestic c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-165026/nfe TEAM- C To: PNC MORTGAGE, LLC P.Q. Box 11701 Newark, NJ 07101-4701 ZIP 07092 $ 001.200 02 1i7 0001387430 MAY 05. 2014 To pay fee, effle stamps or meter postage here. County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 PIOZ 90 AVW0CPL it L000 pJai Z 0Zle00 - Z60LOdIZ Postmark Here MAY 05 2 To pay fee, efge stamps or meter postage here. Postmark Here NTL Page 6 of 7 11 UNITED STATES eall1 POSTAL SERVICE Certificate 0 Mailing Thu Certificate of Mailing provides evidence that mall has been presented to UPS. for mailing. This form may be used for domestic and International mall. Fre"' Scott A. Dietterick, Esquire 00 Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-165026 nfe TEAM- C To' CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 a -7M UNITED STATES P POSTAL SERVICE Certificate Of Mailing U.S. POSTAGEPPiTNEY WIVES eri47:14.=iir= ZIP 07092 $ 001 200 02 111 0001387430MAY 05 2014 To pay fee, if ix stamps or meter postage here. This Certificate of Mailing provides evidence that mail has been presented to USPS• for mailing. This form may be used for domestic and International mat. From' Scott A. Dietterick, Esquire do Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-165026/nfe TEAM- C To: PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 County of P.Q.: CUMBERLAND Postmark Here 0 5 2f1,14 To pay fee, affix stamps or meter postage here. PS Form 3817, AprIl 2007 PSN 7530-02-000-9065 P1O SO AVVi OEVL9C1000 ZO 00Z.100 $ Z6OLO dIZ a • 7irmer, •,t.'4 1 Do SWAM A3,411d <<3VV1SOd .S.n NTL Page 7 of 7 UNITED STATES ir-fatiii POSTAL SERVICED; Certificate 0 Mailing ' U.S. POSTAGE >>FiTNEyBowES ZIP 07092 $ 001.200 • 02 1Y1 0001387430MAY 05 2014 This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 ---,XFP71851326/OfeTEA1V14- To' UNKNOWN SPOUSE 615 Woodland Avenue Mount Holly Springs, PA 17065-1937 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 To pay fee, affix stamps or meter postage here. Postmark Here MAY 0 5 ?TA EXHIBIT E Zucker, Goldberg & Ackerman, LLC XFP-165026 PROOF OF PUBLICATION Stale of Pennsylvania, County of Cumberland Patrick Doane, Production Director, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): April 23, 2014. COPY OF NOTICE OF PUBLICATION CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone 800.990-9108 717-249-3188 IN THE COURT OF COMMON PLP.AS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL AC TION • LAW NO.: 12.2497 -CIVIL 2012-02487 NOTICE OF SHERIFF SALE OF REAL ESTATE PURSUANT TO Pa.R.C.P. 3129 Wells Fargo Bank, NA., Plaintiff vs. RICHARD E. ADAMS;, Defendant(s) TO: RICHARD El ADAMS That the Sheriff's Bale of Real Property (Real Estate) will be held at the Cumberland County Courthduse, 1 Courthouse Square, Carlisle, PA 17013 on 814!2014 at 10:00am prevailing local time. THE PROPERT'tt TO BE SOLD ie 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. . The LOCATION of your property to be sold Is: 815Woodland Avenue, Mount Hotly Springs, PA, 17085-1937 The JUDGMENT under or pursuant to wh)ch your properly Is being sold Is docketed to: No.: 12 -2497 -CIVIL 2012-02497 Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and subscribed before me this 11551 V) frau c A complete copy of the Notice of Sheriff Sale will be sent to you upon request to the Attorney for the Plaintiff, Scott A. Dletterick, Esquire. Zucker, Goldberg & Ackerman, LLC, 200 Sheffield Street, Mountainside, NJ 07092, 908-233.8600 THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE ISA 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 away. 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 TOYOURLAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE TOUCAN GET FREE LEGAL ADVICE: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone 800-990-9108 717.249-3188 Notary Public My commission expires: COMMONWEALTH OF PENNSYl-VANiA Notarial Seal Bethany M. Holtry, Notary Public Carlisle ru,o, Cvmteriand County h;y C,x;tino:,:,.:p.,r',.';4 Fcpl', 2G, 1015 ^. t'l1(U''OTA1'JLS PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz April 11, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. sa Marie Coyne, I ditor SWORN TO AND SUBSCRIBED before me this 11 day of April, 2014 Notary CARLISLE BOROUGH, CLIMB .�..,., COLLINS CUMBERLAND COUNTY, My Commission Expires Apr 28, 2054 NOTARIAL SEAL DEBORAH A COL Notary Public CUMBERLAND LAW JOURNAL NOTICE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action—Law NO.: 12 -2497 -CIVIL 2012-02497 Wells Fargo Bank, N.A., Plaintiff vs. RICHARD E. ADAMS, Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO Pa. R.C.P. 3129 TO: RICHARD E. ADAMS 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 June 4, 2014 at 10:00 a.m. prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal descrip- tion consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major im- provements erected on the land. The LOCATION of your property to be sold is: 615 Woodland Avenue, Mount Holly Springs, PA 17065- 1937. The JUDGMENT under or pursu- ant to which your property is being sold is docketed to: No. 12 -2497 -CIVIL, 2012-02497. A complete copy of the Notice of Sheriff's Sale will be sent to you upon request to the Attorney for the Plaintiff, Scott A. Dietterick, Esquire, Zucker, Goldberg & Ackerman, LLC, 200 Sheffield Street, Mountainside, NJ 07092, (908) 233-8500. THIS PAPER ISA 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 pre- vent your property from being taken away. 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: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 13 Apr. 11 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED -OFFICE Sheriff , � ' THE PROTHCNOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor OF T E $.nRErr 204 OCT 21 PH 2: So CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Richard E. Adams Case Number 2012-2497 SHERIFF'S RETURN OF SERVICE 03/25/2014 07:16 PM - Deputy Dawn Kell, 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 615 Woodland Avenue, South Middleton - Township, Mount Holly Springs, PA 17065, Cumberland County. 03/25/2014 07:16 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Richard E. Adams, pursuant to Order of Court by "Posting" the premises located at 615 Woodland Avenue, South Middleton Township, Mount Holly Springs, PA 17065, Cumberland County with a true and correct copy according to law. 06/04/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse 1 Courthouse Square Carlisle Pa, 17013 at 1000 am on June 4, 2014. He sold the same for the sum of $1.00 to Attorney Jaime Ackerman, on behalf of, Wells Fargo Bank, N.A., being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,097.31 SO ANSWERS, September 17, 2014 RONNY R ANDERSON, SHERIFF W•o) pd. Or4 ae £9 9f 3/53, (c) t::ounfyu:ie Sheriff, '� elecsof?. inc On February 28, 2014 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as 615 Woodland Avenue, Mount Holly Springs, as Exhibit "A" filed .with this writ and by this Reference incorporated herein. Date: February 28, 2014 By: Real Estate Coordinator LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14 Writ No. 2012-2497 Civil Term Wells Fargo Bank, N.A. vs. Richard E. Adams Atty.: Jaime R. Ackerman ALL THAT CERTAIN tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: ON THE EAST by Woodland Av- enue; on the south by Lot No. 61 of the hereinafter mentioned Plan of Lots; on the west by Lot No. 69 of said Plan of Lots; and on the north bythe northern half of Lot No. S9 of said Plan of Lots; having a frontage of 77.45 feet, more or less, on Woodland Avenue, a depth on the south of 144 feet, a width in the rear of 75 feet and a depth on the north of 119.35 feet, more or less; and being Lot No. 60 and the southern half of Lot No. 59 of the Plan of Lots known as Mt. View Addition adjoining Mt. Holly Springs Borough, recorded in the Office of the Recorder of Deeds for Cumberland County, in Plan Book 3, Page 86. SUBJECT, however, to the build- ing and use restrictions and condi- tions as set forth and adached to said Plan of Lots, with which the grantees, for themselves, their heirs and assigns, agree to comply by the acceptance of this deed. HAVING THEREON ERECTED a dwelling house being known and numbered as 615 Woodland Avenue, Mount Holly Springs, PA, 17065- 1937. BEING THE SAME PREMISES which Lois A. Barner, Paul A. Adams, Robyn A. Porter, Pamela C. Ruder, Margie A. Shenk, Albert E. Adams, III, and Richard E. Adams, by deed dated June 16, 2008 and recorded August 1,2008 in and for Cumber- land County, Pennsylvania, as In- strument #200826206, granted and conveyed unto Richard E. Adams, Married Man. TAX MAP NO.: 40-30-2646-044. 20 1 a PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 18, April 25 and May 2, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this 2 day of May, 2014 Notary 1 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO., CUMBERLAND CNTY My Commission Expires Apr 28, 2018 Tha Patriot -News Co. 2620 Technology Pkwy • Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriotNews Now you know 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 the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, . respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2012.2497 Civil Term :ay Wells Fargo Bank, N.A. r Vs Richard E. Adams 1 Atty: Jaime R Ackerman 1 ALL THAT CERTAIN TRACT OF LAND SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, I PE SYLVANIA, BOUNDED AN DESCRIBED AS FOLLOWS: ON HE EAST BY WOODLAND <' AVE ; ON THE SOUTH BY LOT NO. 61 OF THE HEREINAFTER MENTIONED 9, PLAN OF LOTS; ON THE WEST BY LOT NO. 69 OF SAID PLAN OF LOTS; AND ON THE NORTH BY THE NORTHERN HALF OF LOT NO. S9 OF SAID PLAN OF LOTS; HAVING A FRONTAGE OF 77.45 FEET MORE OR LESS. ON UU(\CW i AMIN AVr/kil TC A T1rydru This ad ran on the date(s) shown below: 04/13/14 04120/14 04/27/14 <G - Sworn to`a d subscribed before this 02 day of May, 2014 A.D. tary ublic COMMONWEALTH OF PENNSYLVANIA Notarlas Seas Hely Lynn Warfel,oopar Public b is t:r ahtngtcn Twp., VI Camm"ros Pec.12 2016 MEMBER, PENNVI AN A ASS!1CIA'ION of NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Wells Fargo Bank N A is the grantee the same having been sold to said grantee on the 4th day of June A.D., 2014, under and by virtue of a writ Execution issued on the 26th day of February, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 2497, at the suit of Wells Fargo Bank N a against Richard E Adams is duly recorded as Instrument Number 201424026. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this a' fA��%r-I'll , A.D. 02 k4:1 day of • )p01 R ' of Deeds, Cumberland County, Carlisle, PA *Commission Expires the First Monday of Jan. 2018 Recorder of Deeds