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HomeMy WebLinkAbout12-2563 !° 1LF[ -rz?J}?` U? i T. 1RC f HOL! s + 0 TA, . Jf1 7 -! ki c6 t1 ?I° 3 "FI ! SYLVANIA PHELAN HALLINAN & SCHMIEG, LLP Matthew Brushwood, Esq., Id. No.310592 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 278473 WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5 7105 CORPORATE DRIVE PLANO, TX 75024 v. Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. ?a:-a$c?3 ?tV?l CUMBERLAND COUNTY SARA N. EPPLEY A/K/A SARA N. GELBAUGH, Individually and in her capacity as Heir of GERALDINE J. WISNER, Deceased 1137 SHANNON LN CARLISLE, PA 17013-1784 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GERALDINE J. WISNER, DECEASED 114 WOODLAWN LANE CARLISLE, PA 17015-4351 Defendants File #: 278473 CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE 103.75 °? CkungasaH `' ??a?va?lo NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 278473 1. Plaintiff is WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: SARA N. EPPLEY A/K/A SARA N. GELBAUGH, Individually and in her capacity as Heir of GERALDINE J. WISNER, Deceased 1137 SHANNON LN CARLISLE, PA 17013-1784 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GERALDINE J. WISNER, DECEASED 114 WOODLAWN LANE CARLISLE, PA 17015-4351 who is/are the real owner(s) of the property hereinafter described. 3. On 04/14/2006 GERALDINE J. WISNER made, executed and delivered a mortgage upon the premises hereinafter described to BANK OF AMERICA, N.A. which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1947, Page 0287. By Assignment of Mortgage recorded 11/08/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201131079.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File 4: 278473 5 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. The following amounts are due on the mortgage as of 04/03/2012: Principal Balance $140,154.17 Interest $16,299.90 07/01/2010 through 04/03/2012 Late Charges $142.14 Property Inspections $105.00 Escrow Deficit $4,366.00 TOTAL $161,067.21 7. 8 9 10 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. The mortgage premises are vacant and abandoned. Mortgagor GERALDINE J. WISNER died on 07/29/2010 and, upon information and belief, her surviving heir(s) are SARA N. EPPLEY and RANDY V. SABETT. Plaintiffs representative contacted the Register of Wills of CUMBERLAND COUNTY and was informed that no estate has been raised on behalf of the decedent mortgagor. File #: 278473 11. By executed waiver(s), RANDY V. SABETT waived his right to be named as a defendant in the foreclosure action. Said waiver(s) is/are attached as Exhibit"A ". 12. Plaintiff hereby releases GERALDINE J. WISNER, from liability for the debt secured by the mortgage. 13. Plaintiff does not hold the named Defendant(s), SARA N. EPPLEY A/K/A SARA N. GELBAUGH, personally liable on this cause of action. This action is being brought to foreclose the interest of the said Defendant(s) in the aforesaid real estate only, and the Defendant(s) has/have been named in accordance with the requirements of Pa R.C.P. 1144(a)(2) and 20 Pa.C.S.A. § 301(b). WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $161,067.21, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN UALLINAN & SCHMIEG, LLP By: shwood, Esquire Plaintiff File #: 278473 Exhibit "A" Nov 04 11 02;21 p Sabett family fax 301-963-1105 p.1 WAIVER OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION 1. Randv V. Sabett, Heir of Geraldine J. Wisner, Deceased hereby acknowledge that I may have an ownership interest in the property located at 114 Woodlawn Lane, Carlisle, PA 17015 in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa. C.S.A. § 301(b)]. I do hereby waive my right to be narned as a defendant in a foreclosure action as provided by Pa. R.C.P. 1141 et seq., which maybe instituted by WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5involving said property, which property was owned by the decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of said action, including but not limited to the Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. I do retain anv and all rights I may have under Pennsylvania law to reinstate or otherwise payoff the underlying debt or to make any claim for excess proceeds generated by the Shcrifl's sale of the mortgage premises. Date: l-l I 1 !?-s " Rand I I e i r of Geraldine ? . 'GX'is er, Deceased c w? LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described, as follows, together with the improvements erected thereon: BEGINNING at a point on the Northern side of Woodlawn Lane, on the dividing line between Lots Nos. 2 and 3 on the hereinafter mentioned Plan of Lots; thence by the Northern side of Woodlawn Lane on a curve to the right having a radius of 425 feet, an arc distance of 94.68 feet to a concrete monument; thence continuing by the Northern side of Woodlawn Lane, South 85 degrees 19 minutes West 18.5 feet to a point; thence by the dividing line between Lots Nos. 3 and 4 on said Plan of Lots, North 4 degrees 41 minutes West 150 feet to a point; thence North 71 degrees 17 minutes 10 seconds East 78.83 feet to a point; thence by the dividing line between Lots Nos. 2 and 3 aforesaid South 17 degrees 26 minutes 50 seconds East 162.63 feet to the Place of BEGINNING. BEING Lot No. 3 of Section T, of the Plan of Lots known as Forge Road Acres as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 20, page 3. PROPERTY ADDRESS: 114 WOODLAWN LANE, CARLISLE, PA 17015-4351 PARCEL # 40-24-0758-069 File #: 278473 VERIFICATION ,,la m(25 M. pog4dein of (/'e , hereby states that/she is A /S *nr Vile Pr'ILof BANK OF AMERICA, N.A., servicing agent for Plaintiff in this matter, that/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 of Qk/her 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. DATE: q- 0 7- )_01a, File#: 278473 Name: EPPLEY " or, - N e: Ta lve j M. Title: AfJ'ttt?t - vii q- rres;del, BANK OF AMERICA, N.A. File #: 278473 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson _i l.- . L jr ILL Sheri qtr o t ?:,,,, t;ej,r'?O -Ur r) ? ?? ?., ?? ? i p^, .. • . Jody S Smith Chief Deputy 2012 MAY -1f Phi 3: 2 I Richard W Stewart CUMBERLAND COUNT', Solicitor PENNSYLVANIA Wells Fargo Bank, N.A. vs Case Number . Sara N. Eppley (et al.) 2012-2563 SHERIFF'S RETURN OF SERVICE 04/27/2012 04:50 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 27, 2012 at 1650 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Unknown Heirs, Successors, Assigns and All Persons, Firms or Associations Claiming Right, Title or Interest from or Under Geraldine J. Wisner, Deceased, by making known unto Stephanie Winisko, current resident of 114 Woodlawn Lane, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her personally the said true and correct copy of the same. STEPHEN BENDER, DEPUTY 04/27/2012 08:30 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 27, 2012 at 2030 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Sara N. Eppley a/k/a Sara N. Gelbaugh, by making known unto Mitch Gelbaugh, Husband of Defendant at 1137 Shannon Lane, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. 292 STEPHEN BENDER, DEPUTY 05/02/2012 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: Sara N. Eppley, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Sara N. Eppley. Request for service at 114 Woodlawn Lane, Carlisle, Pennsylvania 17015 the Defendant was not found. Deputies were advised Sara N. Eppley currently resides at 1137 Shannon Lane, Carlisle, Pennsylvania 17013. SHERIFF COST: $77.00 May 02, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF ;.c) GourrvSkAC- Shen`t. TelpoesutT. In;;. a Fu-Ui FICc t' (€ F 'R T[t0u0 TAr, ,,, 2012 AUUG 23 AM 10:39 PE ,BE CGUNTY cA Phelan HOlinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5 VS. SARA N.'EPPLEY A/K/A SARA N. GELBAUGH, Individually and in her capacity as Heir of GERALDINE J. WISNER, Deceased ET AL. Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO. 12-2563-CIVIL CUMBERLAND COUNTY MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE- HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5, respectfully requests that this Honorable Court enter an ORDER granting Plaintiffs Motion for Service Pursuant to Special Order of Court in the above captioned matter and in support thereof avers the following: 1. The property located at 114 WOODLAWN LANE, CARLISLE, PA 17015-4351 is owned by SARA N. EPPLEY and GERALDINE J. WISNER, as tenants in common by virtue 278473 of a deed dated 12/21/2009 and recorded 01/06/2010, Instrument # 201000474 of the CUMBERLAND County Recorder of Deeds Office. 2. On April 14, 2006, GERALDINE J. WISNER made, executed, and delivered a mortgage upon the premises at 114 WOODLAWN LANE, CARLISLE, PA 17015-4351. 3. The loan is in default as payments due August 1, 2010 and each month thereafter are due and unpaid. 4. Real Owner GERALDINE J. WISNER died on July 29, 2010. 5. Plaintiffs representative contacted the Register of Wills of CUMBERLAND County and was informed that no estate has been raised on behalf of the decedent mortgagor. 6. Plaintiff performed a Good Faith Investigation in an attempt to identify and locate the heirs of GERALDINE J. WISNER. Plaintiffs investigation did not confirm any new heirs. Attached hereto, marked as Exhibit "A" is a true and correct copy of Plaintiffs Affidavit of Good Faith Investigation. 7. Plaintiff obtained a copy of the obituary published in the Niagara Gazette on August 1, 2010. The obituary advised she was survived by her daughter, Sara N. Gelbaugh and her son Randy V. Sabett. Attached hereto, marked as Exhibit "B" 8. By letters dated 10/3/2011 Plaintiff attempted to contact any possible heirs of GERALDINE J. WISNER to inform them of the foreclosure and to request heir information. Attached hereto, marked as Exhibit "C" are true and correct copies of said letters. 9. Upon information and belief, the surviving heirs at law and next-of-kin of GERALDINE J. WISNER are SARA N. EPPLEY and RANDY V. SABETT. 10. By letter dated 10/20/2011 Plaintiff contacted SARA N. EPPLEY and RANDY V. SABEIT to inform them of the foreclosure action. Plaintiff attached with its letter a Waiver 278473 by Heir of Right to be Named as a Defendant. Plaintiff also requested information regarding the heirs of GERALDINE J. WISNER. Attached hereto, marked as Exhibit "D" is a true and correct copy of Plaintiffs letter. 11. By executed waiver(s), RANDY V. SABETT waived his right to be named as a defendant in the foreclosure action. Said waiver(s) is attached as Exhibit "E". 12. On April 26, 2012, Plaintiff filed an Action in Mortgage Foreclosure. Attached hereto, marked as Exhibit "F" is a true and correct copy of the Complaint in Mortgage Foreclosure. 13. Plaintiff named as a defendant, the unknown heirs, successors, assigns, and all persons, firms or associations claiming right, title or interest from or under the decedent record owner in order to ensure that all possible parties with an interest in said property are notified of these proceedings and in order to ensure that good and marketable title to said property is conveyed by any future sheriff s auction. See Exhibit "F." 14. Because there may be parties with an interest in the mortgaged premises that are unknown, Plaintiff must effectuate service through Special Order of Court. 15. In compliance with Cumberland County Local Rule 208.3(a)(2), Plaintiff avers that no Judge has previously entered a ruling in this case. 16. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to the Defendants on August 7, 2012 and requested the Defendants' concurrence. Plaintiff did not receive any response from the Defendant. A true and correct copy of Plaintiff's letter pursuant to Local Rule 208.3(9) and postmarked certificate of mailing is attached hereto, made part hereof, and marked as Exhibit "G" 278473 WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint, and all future pleadings, by regular mail, by posting of the mortgaged premises, and by publication. Respectfully submitted, PHELAN HALLINAN & S r r r n Date: Allison . lls, Esq., Id. No.309519 Attorney for Plaintiff 278473 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5 vs. SARA N. BPPLEY A/K/A SARA N. GELBAUGH, Individually and in her capacity as Heir of GERALDINE J. WISNER, Deceased ET AL. CUMBERLAND COUNTY MEMORANDUM OF LAW According to Pa.R.Civ.P. 430(a), a plaintiff may petition the court to provide an alternative to personal service if the plaintiff cannot serve a party personally. The rule requires the affidavit presented in support of the motion for alternative service to state "the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why personal service cannot be made." Pa.R.Civ.P. 430 (a). The purpose of this procedure is to provide proof that a good faith effort has been made to effect service under normal methods. Only after such proof has been offered is the Court authorized to direct another method of substitute Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO. 12-2563-CIVIL 278473 service. Deer Park Lumber, Inc. v. Maio r, 384 Pa.Super. 625,559 A.2d 941, 944 (1988), appeal denied, 525 Pa. 582, 575 A.2d 113 (1990). Plaintiff has attached a report to its Motion, which sets forth the nature and extent of the investigation that has been made to determine the whereabouts of the heirs and assigns and the reason that such service cannot be made. Attached hereto, marked as Exhibit "A" is a copy of the Affidavit of Good Faith Investigation. A deceased mortgagor need not be named as a party in a foreclosure action. Federal Land Bank of Baltimore v. King, 294 Pa.86, 143 A. 500 (1928). The personal representative, heir or devisee of a deceased mortgagor, if known, (unless released from liability) must be named as a defendant in a mortgage foreclosure action. Moyer v. Diehl, 130 Pa.Super. 115, 196 A. 575 (1938). In the instant action, Plaintiff has appropriately named the unknown heirs, successors, assigns and all persons, firms, and associations claiming right title or interest from or under the decedent mortgagor as a defendant in order to convey clear and marketable title after a foreclosure sheriff's sale. Title companies customarily require foreclosing mortgagees to name the !unknown parties in order to assure that any potential party with an interest in the mortgaged premises has an opportunity to defend the foreclosure. Finally, Plaintiff is seeking only to enforce an in rem judgment through the foreclosure of the mortgaged premises and is not pursuing a deficiency judgment in this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant the requested relief. PHELAN , LLP Date: _ U---- Allison F. We s, q., Id. No.309519 Attorney for Plaintiff 278473 EXh?bit „A„ AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 278473 Attorney Firm: Phelan, Hallinan & Schmleg, LLP Subject: Geraldine J. Wisner Property Address: 114 Woodlawn Lane, Carlisle, PA 17015 Possible Mailing Address: 9440 Newbridge Drive, Apartment 207, Potomac, MD 20854 1. CREDIT INFORMATION A. SOCIAL SECURITY NUMBED. Our search verified the following information to be true and correct Geraldine J. Wisner - xxx-xx-3360 B. EMPLOYMENT SEARCH Geraldine J. Wisner - A. review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Geraldine J. Wisner reside(s) at: 114 Woodlawn Lane, Carlisle, PA 17015. 11. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases, which had no listing for Geraldine J. Wisner. B. On 10-05-7.1 our office searched directory assistance databases, which had no phone number for Geraldine J. Wisner. Our office was unable to locate, any heir for Geraldine J, Wisner. 111 OBITUARY SEARCH A. Attempted to find obituary via http://oa.newsbank.com/ B. Found obituary published August 1, 2010 in the Niagara Gazette (NY). See attached. IV. INQUIRY OF HEIRS AND NEIGHBORS On 10-05-11 our office was unable to locate any information for Ernest Richard Wisner, relative of Geraldine J. Wisner. On 10-05-11 our office attempted to contact Randy V. Sabett, relative of Geraldine J. Wisner at: 9400 Hurth aster Road, Gaithersburg, MD 20882, but was unable to get any phone number for him. On 1.0-05-11 our office attempted to contact Steven C. Carter, potential relative of Geraldine) Wisner at: 51.7 Greenwood Road, Linthicum Heights, MD 21090, but was unable to get any phone number for him. On 10-05-11 our office made several phone calls in an attempt to contact Sarah Natalie Eppley, relative of Geraldine J. Wisner at (717) 243-4174,670 West Louther Street, Carlisle, PA 17013: no answer. On 10-05-11 our office.made several phone calls in an attempt to contact Vito S. Sabett, potential relative of Geraldine J. Wisner at (716) 648-2548, 74 Rovner Place, Hamburg, NY 14075: answering machine. On 10-05-11 our office made several phone calls in an attempt to contact Mitchell S. Gelbaugh, potential relative of Geraldine J. Wisner at (717) 249-6865,1137 Shannon Lane, Carlisle, PA 17013: answering marhinv On 10-05-11 our office made several phone calls in an attempt to contact Susan N. Nepi, potential relative of Geraldine J. Wisner at (410) 859-4922, 517 Greenwood Road, Linthicum Heights, MD 21090: answering machnne. On 10-05-11 our office made a phone call in an attempt to contact Marina M. Sabett, potential relative of Geraldine J. Wisner at (410) 244-7794, 750 East Pratt Street, Baltimore, MD 21202: spoke with an unidentified male who could not confirm any heir information for Geraldine J. Wisner. A On 10-05-11 our office made several phone calls in an attempt to contact Thomas C. Dame, potential relative of Geraldine J. Wisner at (410) 664-7893,1809 Dixon Road, Baltimore, MD 21209: answering machine. On 10-05-11 our office made several phone calls in an attempt to contact Jimmy Carroll Lolley, potential relative of Geraldine J. Wisner at (410) 665-3630,2106 Cider Mill Road, Parkville, MD 21234: answering machine. On 10-05-11 our office made several phone calls in an attempt to contact Bonita K. Matthews, neighbor of the subject at (717) 243-3793,113 Woodlawn Lane, Carlisle, PA 17015: answering machine. On 10-05-11 our office made a phone call in an attempt to contact Alyce F. Heller, neighbor of the subject at (717) 243-1424,110 Woodlawn Lane, Carlisle, PA 17015: disconnected. On 10-05-11 our office made a phone call in an attempt to contact holly Lebo, neighbor of the subject at (717) 243-8366,109 Woodlawn Lane, Carlisle, PA 17015: disconnected. Using our white pages database our office was unable to locate any neighbors for 9440 Newbridge Drive, Apartment 207, Potomac, MD 20854. Our office was unable to locate any heir for Geraldine J. Wisner. V. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 10-05-11 we reviewed the National Address database and found the following information: Geraldine J. Wisner - 9440 Newbridge Drive, Apartment 207, Potomac, MD 20854. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: 9440 Newbridge Drive, Apartment 207, Potomac, MD 20854. VI. OTHER INQUIRIES A. DEATH RECORDS As of 10-05-11 Vital Records and all public databases have a death record on file for Geraldine J. Wisner, VII, ADDITIONAL INFORMATION OF SUBJECT A. YEAR OF BIRTH Geraldine J. Wisner -1939 B. DATE OF DEATH Geraldine J. Wisner - 07-29-2010 C. A.K.A. Geraldine J. Sabett Our accessible databases have been checked and cross-referenced for the above named individual(s). " Please be advised our database information indicates the subject resides at the current address. I hereby verify that the statements made herein are true and correct to the best of my knowledge, n and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S. Sec. tin , to unswPrfTa si tiotn to authorities. he a n r information is obtained from available public records ffA, si we are only liable for the cost of the affidavit. \D _ -I( E)Chibit v ObitsArchive.com: Document Display ObitsArchivexom Niagara Gazette (NY) - August 1, 2010 Deceased Name: Geraldine J. "Gerri" Wisner Date of death: 07/29/2010 Geraldine J. "Gerri" Wisner Niagara Gazette Page 1 of 1 .2?`9 W13 POTOMAC, MD - Geraldine J. Wisner, "Gerri", of Potomac, MD, passed away on July 29, 2010. Born in Niagara Falls, NY, she was the daughter of the late Felix and Helen Wisner. She graduated from Niagara Falls High School in 1957 (member of Theta Xi Upsilon) and enjoyed working on many of her high school reunions. Gerri received her nursing certificate from the University of Rochester in 1961 and Bachelor of Science in Nursing from Niagara University in 1987. She worked for many years'', as a pediatric nurse for Doctors Schiff and Crea in Niagara Falls, and was a Certified Diabetes Educator (CDE). She enjoyed spending time with her family, friends and pets. She is survived by her brother, Ernest Richard Wisner of Clermont, FL; her son, Randy V. Sabett of Laytonsville, MD; her daughter, Sara N. Gelbaugh of Carlisle, PA; five grandchildren; and several nieces and nephews. A mass will be held at the Niagara University Chapel at 10:00 AM on Tuesday, August 3, 2010. Entombment will be at the Gate of Heaven Mausoleum. In lieu of flowers, please send donations to Niagara University, the American Association of Diabetes Educators, or the Niagara County SPCA. Arrangements were made by the Zajac Funeral Home, Inc. Visit www.niagara-gazette.com/obituaries for online guest register. Niagara Gazette (NY) Date: August 1 2010 Record Number: FCxK7eNfHljFCxK7eNfESSAAAAAAAAAQ http://oa.newsbank.com/oa-search/we/Archives?p_action=print&p_docid= 1315926EDFFF... 10/3/2011 14 Elchibit it C„ PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 215-320-0007, ext. 1200 Fax: 215-563-8656 Eddie.Baker@fedphe.com Eddie Baker Legal Assistant, Decedent Department October 3, 2011 Occupants & Possible Heirs of Geraldine J. Wisner, Deceased 114 Wood lawn Lane Carlisle, PA 17015 RE: GERALDINE J. WISNER 114 WOODLAWN LANE, CARLISLE, PA 17015 BANK OF AMERICA, N.A. PHS# 278473 Dear Sir/Madam, Representing Lenders in Pennsylvania and New Jersey Kindly be advised that the Law Offices of Phelan Hallinan & Schmieg represent WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5, the holder of the mortgage against the above-referenced mortgaged premises. Our office has been retained to bring a foreclosure action. Our office has been informed that Geraldine J. Wisner, an owner of the mortgaged premises, has unfortunately passed away. We are attempting to identify and contact Geraldine J. Wisner's next-of-kin because they may have been automatically vested with an ownership interest in the mortgaged premises upon Geraldine J. Wisner's death under 20 Pa. C.S.A. §301(b). If you are, an heir of Geraldine J. Wisner or have any information regarding the heirs of Geraldine J. Wisner, please contact the undersigned at (215) 563-7000, ex. 1200 within seven 7 days of the date of this correspondence. Sincerely, 'i!!!!Z Eddie Paer_- Legal Assistant * This firm has been di a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt urged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 215-320-0007, ext. 1200 Fax: 215-563-8656 Eddie.Baker@fedphe.com Eddie Bajker Legal Assistant, Decedent Department October 3 2011 Sara N. Eppley A/K/A Sara N. Gelbaugh 1137 Shannon Lane Carlisle, PA 17013 RE. GiERALDINE J. WISNER 114 WOODLAWN LANE, CARLISLE, PA 17015 BANK OF AMERICA, N.A. PHS# 278473 Dear Sir/Madam, Representing Lenders in Pennsylvania and New Jersey Kindly be advised that the Law Offices of Phelan Hallinan & Schmieg represent WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5, the holder of the mortgage against the above-referenced mortgaged premises. Our office has been retained to bring a foreclosure action. Our office has been informed that Geraldine J. Wisner, an owner of the mortgaged premises, has unfortunately passed away. We are attempting to identify and contact Geraldine J. Wisner's next-of-kin because they may have been automatically vested with an ownership interest in the mortgaged premises upon Geraldine J. Wisner's death under 20 Pa. C.S.A. §301(b). If you are, an heir of Geraldine J. Wisner or have any information regarding the heirs of Geraldine J. Wisner, Nease contact the undersigned at (215) 563-7000, ex. 1200 within seven 7 days of the date of this correspondence. Sincerely, ,ddie Ba eta Legal Assistant * This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 215-320-0007, ext. 1200 Fax: 215-563-8656 Eddie.Baker@fedphe.com Eddie Baker Legal Assistant, Decedent Department October 3, 2011 Randy V, Sabett 9400 Huntmaster Road Gaithersburg, MD 20882 RE: GERALDINE J. WISNER 114 WOODLAWN LANE, CARLISLE, PA 17015 BANK OF AMERICA, N.A. PHS# 278473 Dear Sir/Madam, Representing Lenders in Pennsylvania and New Jersey Kindly be advised that the Law Offices of Phelan Hallinan & Schmieg represent WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5, the holder of the mortgage against the above-referenced mortgaged premises. Our office has been retained to bring a foreclosure action. Our office has been informed that Geraldine J. Wisner, an owner of the mortgaged premises, has unfortunately passed away. We are attempting to identify and contact Geraldine J. Wisner's next-of-kin because they may have been automatically vested with an ownership interest in the mortgaged premises upon Geraldine J. Wisner's death under 20 Pa. C.S.A. §301(b). If you are an heir of Geraldine J. Wisner or have any information regarding the heirs of Geraldine J. Wisner, please contact the undersigned at (215) 563-7000, ex. 1200 within seven 7 days of the date of this correspondence. Sincerely Eddie Baker Legal Assistant * This firm has been di a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt iarged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. Exhibit fit D" PHELAN HALLINAN & SCHMIEG, LLP Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-320-0007 ext.1228 Fax: 215-563-3352 Eddie.Baker@fedphe.com Eddie Baker Legal Assistant, Decedent Department October 20, 2011 SARA N. EPPLEY A/K/A SARA N. GELBAUGH, INDIVIDUALLY AND AS HEIR OF GERALDINE J. WISNER, DECEASED 1137 SHANNON LANE CARLISLE, PA 17013 RANDY V. SABETT, HEIR OF GER.AI DINE J. WISNER, DECEASED 9400 HUNTMASTER ROAD GAITHERSBURG, MD 20882 RE: GERALDINE J. WISNER 114 WOODLAWN LANE, CARLISLE, PA 17015 BANK OF AMERICA, N.A. PHS# 278473 Dear Sir/Madam: Representing Lenders in Pennsylvania and New Jersey Kindly be advised that the Law Offices of Phelan Hallinan & Schmieg, LLP represent WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2006-5, the holder of the mortgage against the above- referenced mortgaged premises. Our office has been retained to bring a foreclosure action. Our office has been informed of Geraldine J. Wisner's unfortunate death. We are sorry for your loss. As a possible heir of Geraldine J. Wisner, you may have a vested ownership interest in the mortgaged premises upon her death under 20 Pa. C.S.A. § 301(b). As such, Pennsylvania law requires that you be included as a defendant solely in your capacity as heir in order to complete the foreclosure. Please be advised that you are not personally liable for the debt, as you did not execute the mortgage or note. * This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. This letter serves to afford you an opportunity to waive your right to be named as a defendant in the foreclosure action. Please find attached a Waiver which I would appreciate your executing and returning to the undersigned within fourteen (14) days of the date of this correspondence. If the Waiver is timely returned it will not be necessary to name you as a defendant in the foreclosure action. However, if the Waiver is not timely returned and it is believed that you are an heir of the decedent, then our office may have no choice but to name you as a defendant in the action in order to divest any ownership interest you may have in the property. Our Office also requests that you please provide us with any additional heir information for Geraldine J. Wisner. Thank you for your cooperation in this regard. Please note that this waiver does not preclude you from attempting to sell the subject premises' and recovering any possible equity in the mortgaged premises prior to the completion of the foreclosure action. We would encourage you to contact your own attorney in regard to this matter. If you would like to request a payoff or reinstatement figure, please call (215) 563- 7000, and ask for the Foreclosure Resolution Department. If you have any other questions regarding this letter, please contact the undersigned at (215) 563-7000, ex. 1200. Sincerely. Eddie I.Itt ter Legal Assistant * This firm is a debt collector. Any information we receive will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the real estate secured by the mortgage. WAIVER OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION 1, Randy V. Sabett, Heir of Geraldine J. Wisner, Deceased hereby acknowledge that I may have an ownership interest in the property located at 114 Woodlawn Lane, Carlisle, PA 17015 in', accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa. C.S.A. § 301(b)]. I do hereby waive my right to be named as a defendant in a foreclosure action as provided by Pa. R.C.P. 1141 et seq., which may be instituted by WELLS FARGO !,BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5involving said property, which property was owned by the decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of said action, including; but not limited to the Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. I do retain any and all rights I may have under Pennsylvania law to reinstate or otherwise payoff the underlying debtor to make any claim for excess proceeds generated by the Sheriff's sate of the mortgage premises. Date: Randy V. Sabett, Jr., Heir of Geraldine J. Wisner, Deceased Exhibit It E" Nov 04-1102:21 p Sabett family fax 301-963-1105 p.1 WAIVER OF RIGHT TO BE NANIED AS A DEFENDANT IN FORECLOSURE ACTION I, Randy V. Sabot, Heir of Geraldine J. Wisner, Deceased hereby acknowledge that I may have an ownership interest in the property located at 114 Woodlawn Lane, Carlisle, PA 17015 in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 lea. C.S.A. § 301(b)]. I do hereby waive my right to be named as a defendant in a foreclosure action as provided by Pa. R.C.P. 1141 et seq., which may be instituted by WELLS FARGO FLANK, N.A., AS TRLSTEE FOR TI- CERTIFICATE HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5inyolving said property, which property was owned by the decedent. at the time of her death. I hereby consent to the foreclosure action, without any further notice of said action, including but not limited to the SheritT's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. I do retain any and all rights I may have under Pennsylvania law to reinstate or otherwise payoff the underlying debt or to make any claim for excess proceeds generated by the Sherifl's sale of the'mortgage premises. Date: 1t_S Rand , Heir of Geraldinc . Luis er, Deceased C?/ F G^y 0 O{ (gyp, - o? - J ?J Exhibit It F" r tF' '"?C ue '; . 7n?? enh ?r s: • Ui (, ['s.: NNS YL VANIA PHELAN HALLINAN & SCHMIEG, LLP Matthew Brushwood, Esq., Id. No.310592 1617 7FK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-5163-7000 278473 WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERJES 2006-5 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff V. SARA N. EPPLEY A/K/A SARA N. GELBAUGH, Individually and in her capacity as Heir of GERALDINE J. WISNER, Deceased 113' SHANNON LN CARLISLE, PA 17013-1784 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL, PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GERALDINE J. WISNER, DECEASED 114'WOODLAWN LANE CARLISLE, PA 17015-4351 Defendants Fite A: 27$473 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 1 a? ?Sta 3 ?iUt( CUMBERLAND COUNTY CIVIL ACTION - LsAW COMPLAINT IN MORTGAGE FORECLOSURE l.:D Q sID17s,Pl al? ck17:}asa4 1A 7i A 7 (p NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS' OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File 4: 279473 1. Plaintiff is WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: SARA N. EPPLEY A/K/A SARA N. GELBAUGH, Individually and in her capacity as Heir of GERALDINE J. WISNER, Deceased 1137 SHANNON LN CARLISLE, PA 17013-1784 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GERALDINE J. WISNER, DECEASED 114 WOODLAWN LANE CARLISLE, PA 17015-4351 who is/are the real owner(s) of the property hereinafter described. 3. On 04/14/2006 GERALDINE J. WISNER made, executed and delivered a mortgage upon the premises hereinafter described to BANK OF AMERICA, N.A. which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1947, Page 0287. By Assignment of Mortgage recorded 11/08/2011 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201131079.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File #: 278473 The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01 /2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 04/03/2012: Principal Balance $140,154.17 Interest $16,299.90 07/01/2010 through 04/03/2012 Late Charges $142.14 Property Inspections $105.00 Escrow Deficit $4,366.00 TOTAL $161,067.21 7 9 10 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. The mortgage premises are vacant and abandoned. Mortgagor GERALDINE J. WISNER died on 07/29/2010 and, upon information and belief her surviving heir(s) are SARA N. EPPLEY and RANDY V. SABETT. Plaintiffs representative contacted the Register of Wills of CUMBERLAND COUNTY and was informed that no estate has been raised on behalf of the decedent mortgagor. File h: 278473 11. By executed waiver(s), RANDY V. SABETT waived his right to be named as a defendant in the foreclosure action. Said waiver(s) is/are attached as Exhibit"A It, 12. Plaintiff hereby releases GERALDINE J. WISNER, from liability for the debt secured by the mortgage. 13. Plaintiff does not hold the named Defendant(s), SARA N. EPPLEY A/K/A SARA N. GELBAUGH, personally liable on this cause of action. This action is being brought to foreclose the interest of the said Defendant(s) in the aforesaid real estate only, and the Defendant(s) has/have been named in accordance with the requirements of Pa R.C.P. 1144(a)(2) and 20 Pa.C.S.A. § 301(b). WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $161,067.21, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELANIJALLINAN & SCHMIEG, LLP By: shwood, Esquire Plaintiff He M; 278473 Exhibit "A" Nov 0411 0221 p Sabett family fax 301-963-1105 p.1 NVAIVER OF RIGHT TO BE NANIED AS A DEFENDANT IN FORECLOSURE ACTION 1. Rand;. V. Sabot, Hair of Geraldine J. Wisner, Deceased lteruby acknowledge that I may have an o-vvnership interest in the property located at 114 tiWoodlawn Lanz, Carlisle, PA 17015 in accordance 171.11 Section 301(6) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa. C.S.A. § 301(b)T. I do hereby waive my right to be named as a defendant in a for Nlasure action as provided by Pa. R.C.P. 1141 et seq., which may be instituted by WELLS FARGO BANK, N.A., AS TRUSTEE FOR TI-1;E CERTIFICATE-HOLDERS OF BANC OF :1.MERICA ALTERNATIVE LOAN, TRUST 2006-5, MORTGAGE PASS-THROUGH C RTIFICATES, SERIES 2006-5involving said property, which property was ovmed by the decedent at -he time of her death. I hereby consent to the foreclosure action, without any further notice of said action, inciudin- bt;' not limited to the SheritTs sale, and understand that any interest I may have in the mortgaged prcni scs ,,will be divested upon completion of the foreclosure actioar. I do retain anv and all rights I may have under Pennsylvania law to reinstate or otherwise payoff the underlying debt or to make any claim for excess proceeds generated by the Shcrifl's sale of the mortgage premises. J ?'?'l?1Lf Datc : _ _ Rand , Heir of Geraldine .. *Wis er, Deceased ?i?? caul LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described, as follows, together with the improvements erected thereon: BEGINNING at a point on the Northern side of Woodlawn Lane, on the dividing line between Lots Nos. 2 and 3 on the hereinafter mentioned Plan of Lots; thence by the Northern side of Woodlawn Lane on a curve to the right having a radius of 425 feet, an arc distance of 94.68 feet to a concrete monument; thence continuing by the Northern side of Woodlawn Lane, South 85 degrees 19 minutes West 18.5 feet to a point; thence by the dividing line between Lots Nos. 3 and 4 on said Plan of Lots, North 4 degrees 41 minutes West 150 feet to a point; thence North 71 degrees 17 minutes 10 seconds East 78.83 feet to a point; thence by the dividing line between Lots Nos. 2 and 3 aforesaid South 17 degrees 26 minutes 50 seconds East 162.63 feet to the Place of BEGINNING. BEING Lot No. 3 of Section T, of the Plan of Lots known as Forge Road Acres as recorded in the Office of the Recorder of Deeds for Cumberland County in Plan Book 20, page 3. PROPERTY ADDRESS: 114 WOODLAWN LANE, CARLISLE, PA 17015-4351 PARCEL # 40-24-0758-069 Fite #: 278473 VERIFICATION , a me5 h, Cr?aM of rfe , hereby states that /she is ASS1)*nr Vke PY6;deA? of BANK OF AMERICA, N. A., servicing agent for Plaintiff in this matter, that /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 of Q01er 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. Br.??1Jcr?arre_ N e: -foi ej M. DATE: q ' 17- )-o 1,a, Title: Afs,'AAA - v, *c( Tres;de0- BANK OF AMERICA, N.A. File#: 278473 Name: EPPLEY File N: 279473 Exhibit 414, G" i 3CJG diZ W412ld a=lltHW 0440 ZO $ vv: z {M15N A3N Ild Z 6 ti ? b?&Dd S3,y-0y5 w N z 45 xN? U o c n 00 ? W,?d aWx ? N a??a z 30 a ae o a0a z v??-U y .O r U ? L y ? a Cd "O A O Q ?zU ?oHw V?u cn In W?W? .? CUjOawWr`r'i O ??C7wAr?l ow?AO? a???d dUO - U iF iF iF N o ? y? ?o aW N V U ~1 N W n. 0 ?b z> w ? w T O ? 00 F 0. Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE, CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5 VS. SARA N. EPPLEY A/K/A SARA N. GELBAUGH, Individually and in her capacity as Heir of GERALDINE J. WISNER, Deceased ET AL. Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION NO. 12-2563-CIVIL CUMBERLAND COUNTY CERTIFICATION OF SERVICE I hereby certify a true and correct copy of the foregoing Plaintiff's Motion for Special Service was served by regular mail on Defendant(s) on the date listed below: SARA N. EPPLEY A/K/A SARA N. GELBAUGH 1137 SHANNON LN CARLISLE, PA 17013-1784 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GERALDINE J. WISNER, DECEASED 114 WOODLAWN LANE CARLISLE, PA 17015-4351 PHELAN LLP Dated: Big --- -? Allison ells, Esq., Id. No.309519 Attorney for Plaintiff 278473 ' _ ~o~~~"~~~~~~. UF' FNE P~~37 ~,~d~ HAY ~~~za~c~s aM~~~ 5~ CUM~E~#.A1~~ Ct~ttNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., AS TRUSTEE COURT OF COMMON PLEAS FOR THE CERTIFICATE-HOLDERS OF BANC CIVIL DIVISION OF AMERICA ALTERNATIVE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH NO. 12-2563-CIVIL CERTIFICATES, SERIES 2006-5 CUMBERLAND COUNTY vs. . SARA N. EPPLEY A/K/A SARAN. GELBAUGH, Individually and in her capacity as Heir of GERALDINE J. WISNER, Deceased ET AL. ORDER AND NOW, this o?fl~ day of ~G~~ , 2012, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of the Complaint, and all future pleadings, on the Defendant, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GERALDINE J. WISNER, DECEASED, by publication of the Complaint in accordance with Pa.R.C.P. 430(b)(1); by mailing a true and correct copy of the Complaint by PHS# 278473/MJG Phelan Flallinan &Schmieg, LLP Allison F. Wells, Esq., Id. No.309519 1617 J1=K Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19]03 2]~-563-7000 __ WLLI.'~ FAlZGO BANK, N.A., AS TRUSTEE FOR THE CER~I-II=[CATE-HOLDERS OF BANG OF AMERICA AL"fERNA'fIVE, LOAN TRUST 2006-5, MOR"I~GAGf: PASS-THROUGH CERTIFICATES, SIRIL:S 2006-5 Plaintiff vs. SARA N. EPPLEY A/K/A SARA N. GELBAUGH, [NDIVIDUALLY ANU IN HER CAPACITY AS HEiR OF GI:RAI,DINI~ J. WISNER, DECEASED UNKNOWN HLIRS, SUCCESSORS, ASSIGNS, AND ALL, PI~;RSONS, 1=IRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GERALDINF, J. WISNER, DECEASED Defendant(s) COURT OF COMMON PLI~,AS CItilIL DIVISION CUMBERLAND COUN~I'1` No. 12-25Ei3-CIVIL AFFIDAVIT OF SERVICE BY PUBLICATION IN ACCORDANCE WffH COURT ORDER 1 hereb~~ certify that service of the Civil Action Complaint in Mortgage Foreclosure was made in a~;.cordance with the Court Order dated August 20, 2012 as indicated below: By publication as provided by Pa. R.C.P. Rule 430(b)(1) in The Sentinel on October 4., 2012 and Cumberland Law Journal on October 12, 2012. Proofs of the said publications are attached h~.~retc. I~he undersigned understands that this statement is made subject to the penalties of 18 I'a. C .S. Section 4904 relating to unsworn falsification to authorities. DA"1 };: October 26 2012 - - _ _~ -- --> `_ _.. Phelan H~i~~ chmieg, LI.P' ---..._ - _ _~'. _ - -- -- _ - Phelan Hallinan &Schmieg, LI_I' Allison F. Wells, Esq., Id. No.>G9> 1 ~) Attorney for Plaintiff 1617 J1~'K Boulevar~~3, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ATTORNEYS FOR ~~~C:~~FL~~~r--~Ct_ i~12Ql.i ~7 ~il'~ lu~ Q~i CUMBERLAriG C,Ot1~dTY PENNSYl..~raNIA PIIS tl 278473 MYH PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland s an rssues of THE SENTINEL on the following day(s): October 4, 2012 Jackie Cox Sales Director, of The Sentinel, of the County and State aforesaid, bein sworn, deposes and says that THE SENTINEL, a newspaper of general circulation Borough of Carlisle, County and State aforesaid, was established December 13th, 1. since which date THE SENTINEL has been regularly issued in said County, and tl printed notice or publication attached hereto is exactly the same as was printed an published in the regular edition d COPY OF NOTICE OF PUBLICATION NOTICE OF ACTION IN MORTGAGE FORECLOSURE IN THE COURT OF COMMON PLEAS OF CUMt3fRLANO GOUNtY, PENNSYLVANIA CIVIL ACTION -LAND WELLS FARQO BANK,•N.A., AS TRUSTEE FOR THE CERTIFICATE-HALDEFFS OF BANC OF AMERiGA ALTEF#NATIVE tOAN TRUST 200&-5, MORTGAGE PASS-THROUQH CERtIFICATES, SERIES 2006-5 Plaintiff vs. SARA N. E EY A/IVA SARA N. GELBAUGH, ~Alf~i HER CAPAGiTY AS i HEiF1M~ O~fAiLLEt~AI,'FdJ. WtSNER, DECEA$~D UNKNOWN 1~1~, BUGCESSORS, ASSK~NS, AND ALL PER ;FIRMS, OR ASSOCIATIONS GtA1MING RIGHT; Tl'€LE OR INTEREST FROM OR UNDER CiERRLDNVE J. WISN$R;taECEA$ED COURT QF COMMON PLEAS CIWL DIVISION CUMBERLAND COUNTY No. 12-2563-CIVIL Affiant further deposes that he/she is r interested in the subject matter of the aforesaid notice ox advertisement, and all allegations in the foregoing statemer to time, place and character of publicat are true. y~ ~ ~ sf 1~ >/' Sworn to and subscribed before me thi: ~~ ~ V~~ Notary Public Deterldants »o~e~ T RIGHT, 717E t>#I INTEES PRaH FOR SUNDER GERALD MERJ. W tSNER DE1~ SED end HA INpY V SAaETT You aro h nttrlet on Apr~Zd 281g,1t~iMitf, WELLSFAFtGfl BANK, N.A.; AS TRUSTEE FQR THE CEflT?F~ 1f(}LB~F!'$QF 6b1t~ (?F AMEAiCA ALT6RHAT41/E LOAN TRUST 2008.5; i~iTf3AGE ; PkS,4»~~7ItfFT~1~lLlIES2868+8: tffyia a{ F closure Complaint endorsed wifh~a Netlc~M Q1-teald, ~!~tlN~t+~lmvn Pl~as~~ C~~q~~~iD Cauhly~PmrfaydY~gf,~dpel€e~d to No: 1 b tdiaactrsae ort Me mortgaEe secured on yow propeAy located at 114 W EtA't 1S-A351 wh6r®rspan-Your property would be sold try the 8tteritt of Ydu eM IterrOp ~p1C the above relersnced Comptarnt on of patore 20:days from the date of this pubtioatkm ar a Judgtnbnt wNt be enterAd against you. NOTICE ff youwish to defend, you m tastnnter a wrltean appearance personally or by attorney and till your defenses or objections M Writing vofff~ the court. You aYe waited tttet if you fates to bo so the case tray proceed abitttput you end's judgm~r+t may ya aryer~d agginst.you wit hxtl'ter note tot the rebel requested by the plaintiff. You mey lose money D1~ pprop9rry or oerev iigMts Nnptirtant to you: YOU SHOULD TAKE THIS NQTtC£ TO YOUA LAWYER ATONC$~ <f YQU DO tJD7 HAVE A LAWYER,Oat3'Tp`OA TELlrPHONE THE OFFICE 3ETfORTH BELOW. THIS OFHC~ CAti PROVIDE YOU WITH INFORMAT~N ABOUT HIA WG A LAWYER. 1F YOU CANNOT AFFORD TO HN# L/lWYER,,TttlS OFFICE MAY t3E ABLE TO PROVIDE YOU WITH Nd€pRk~a'~ `~1~13~~' p,{,$~#iC1i9~~MA~}`tVBA'/t~~fFEiR L£`SYIC SEP9VlrvES TO ELf(it9LE PERSON8 AT A REDUCED FEE OR NO FEE. ' CUMBERLAND COUNTY ATTORNEY REFERRAL :C CU$ERLAI"1t5j Ct7UNTRY ©URTHOttS~N 2 L18EFlTY AVENUE .CARLISLE, t?A 17013 ~17c248-31$6 800-990-9168 My commission expires: ~~J .f lifiic~f~; ,..'ifC f1ARLlSLE Fs0ii0UGF3, ... _-, r 4~;y,, ,, _ ,, i~!y Conrn~s~i.;rt I" ~j, PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established. January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz October 12, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to~ time, place and character of publication are true. e Coyne, E~tor SW(9'RN TO AND SUBSCRIBED before me this 12 day of October, 2012 /' / Notar Y ,; NG ~.ar~lAi_ sEA~ uEBG~AN A COLLlNS PJotary Public CARLlS~LE 00RGUGH, CtJ~iB~ni At~D t':~L1NTY My Gemmissinn Fxpises ;air 2F, ~C114 CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law No. 12-2563-C:NIL WELLS FARGO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE- HOLDERS OF BANC OF AMERICA ALTERNATNE LOAN TRUST 2006- 5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5 Plaintiff vs. SARA N. EPPLEY a/k/a SARA N. GELBAUGH, INDNIDUALLY AND IN HER CAPACITY AS HEIR OF GERALDINE J. WISNER, DECEASED, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GERALDINE J. WISNER, DECEASED Defendants NOTICE To UNKNOWN HEIRS, SUCCES- SORS, ASSIGNS, AND ALL PER- SONS, FIRMS, OR ASSOCIA- TIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER GERALDINE J. WISNER, DE- CEASED and RAND' V. SABETT: You are hereby notified that on Apri126, 2012, Plaintiff, WELLS FAR- GO BANK, N.A., AS TRUSTEE FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ALTERNATNE LOAN TRUST 2006-5, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-5, filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of CUMBERLAND County; Pennsylva- nia, docketed to No. 12-2563-CNIL. Wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 114 WOODLAWN LANE, CARLISLE, PA 17015-4351 whereupon your property would be sold by the Sheriff of CUMBERLAND County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of this publication or a Judgment will be entered against you. NOTICE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses or objections in writing with the court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMA- TION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A RE- DUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL Cumberland County Bar Association Cumberland County Courthouse 32 S. Bedford St. Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 Oct. 12 AFFIllAVIT OF' SER~JICE - (CUMBERLAND MYII PLAINTIFF COUNTY: CUMI3I~RLAND WELLS FARGG B~,NK, N.A., AS TRUSTEE FOR THE {:EIZ'I'1F1CA"I'F,-kIOLI:~ERS OF BANC OF AMI3RICA ~ COURT ~O. I2-2563-CIVIL AL1'ERNA'["1VL i,i1A~~V TRUS"h 2006-5, MOR"['GAGE k ~GII ~'>/R~rIrICATES, s~,Rlr;s aoo6-s ASS-THROI' -_ -___ _ _____ _____- I _ - ___ _ _- llEFENllANT ~~ UNKN0~1'N HEIKS, SUCCESSORS, ASSIGNS, AND ~ TYPE OF ACTION ALL PERSONS, FII~4S, OR ASSOCIATIONS XX Mortgage Foreclosure. ~; CLAIMING RIGh17', TITLE OR INTEREST FROM OR ( Eviction U?~iDER GIRALDINF, 3. WISNER, llECEASED ~ XX Civil Action ~, Complaint on Promissor~~ Note SERVE AT: 114 W(~Ul)I,AVJN Lf1NI;, CARLISLE, PA 17015-435! ***PLEASL POST THE PROPERTY*** ***IN ACCORDANCE WITH THE***** *** 'T'1'ACHFll ('OURT ORDER****** _.. ..... __- ....___-_.. ., ~_ _.r_ _..._.._._. -_._..... __ ..._- .. Served P~:~sted rind n,adc mown UNKNOWN IIEll2S, SUCCESSORS, ASSIGNS, AND ALL PERSONS, F'iRMS, OR :~S5UC1 ^ h :l IONS C"LAI!~~(NG u1 d< )~ '~' e R1GIIf. Tlll,t: OR !NTERIS'1' PROM OK LJNDFR GERALDINI: 7. WISHER, llECEASF,D, Defendant on t ,L ^ _ - at [~_~i.0 _ o'clo~i:. _~._ 'V1., at i 14 WOOllLAWN LANE, CARLISi,E, PA 1701-4351, in the manner descrc cc e uw Defendant personally served. Adult famih~ member with whom Defendant(s) reside(s). _ Kelauonship is __ _" _ Adult ~t~ r.hurge of Defendant's residence who refused to give nameirelationship. M,inagerlClea"4,. of place of lodging in which Defendant(s) reside(s). =,ent ur pcrsen in charge of Defendant's office ar usual place of business. A~ _ of said defendant company. an office _ / / O:'t~cr _ ~ ;i S~'~-~ ~(~f~ ~~ P Ell? ~! Description: Age __ I~eight Weight _ Race`^ Sex_ _ _ Other__ `" i , sx competent adult, being duly sworn according to law, depose and state that 1 personally post ed a true and con~ect r< ~ , ;~ the Cu;npl;~int in \~Tw•t~r+}Ie Foreclosure issued in the captioned case on the date and the address indicated rbcvd. Iun ~ derstand that this ation to authorit~cs. .~ t nf:r,t ; , ~~c,Ir va.c~jcct tct ti,e penalties of 1 R Pa. C.S. Scc. 4904 r ,., nsworn falsii :... F'~.[N"hEll T1AME: _ _ - NOT SERVEll C7 ~ , 20_, at ___ o'clock _. M., Defendant NOT FOUND because. ~ iay of [,n the ^~ ~r ~' _ -_ Vac,:~~ri Does Not Exist Moved __ Does Not Reside (Not Vacant) ~tfi7 © -.~ -, ; r- Sen~,cc P:clic;cd -<~" C,"1 ~ ~ ~ ""' ~- -f G <G ~-n (_)ihcr, ~ ~ ~ ~'T~ ~ ~, :~ -- p,C tJ ~ - _.;, .~ -•t A - _ ~_ AFFIDAVIT QF SERVICE --CUMBERLAND MYII ~ PLAINTIFF ~ ~~ ~~~ COUNTY: CUMBERLAND ~ WELLS FARGO I3ANK, N.A., AS TRUSTEF's FOR THE CERTIFICATE-HOLDERS OF BANC OF AMERICA ~ COURT NO. 12-2563-CIVIL !. ALTERNATIVE LOAN TRUST 200b-5, MORTGAGE ~ PASS-"THROI;GI ~ CERTIFICATES, SERIES 2006-5 llEFENDAN"l UNKNOV6'N HEIF:S, SUCCESSORS, ASSIGNS, AND ALL PERSONS, .FIRMS, OR ASSOCIATIONS CLAIMING R1G1 fT, TITLE OK INTEREST FROM OR UNDER GL;Rt~LL'~INE J. WISNER, DECEASED SERVE A I 1 14 Vb'OOI)LA1'ti'?~I LANE. CARLISLE, PA 1'015-4351 ***PLEASE PO;~T THE PROPERTY*** ***IN ACCORDA-NCE WITH THE***** ***ATTACHEll COURT ORDER****** TYPE OF ACTION :KX Mortgage Foreclosure Eviction YX Civil Action _ Complaint on Promisson~ NoTe Served Posted and made known UNKNOWN HEIRS, SUCCESSORS, ASSIGNS; AND ALL PERSONS, FIRMS, OR AS50CIA~!~IONS CLAIMING R1GI f I', "f' I I L OR ~[~ITEREST FROM OR UNDF,R GEItALDINE 7. WISNER, DECEASED, Defendant on tht• (~ ~ dav° of _...._ _ ~cta_llki2_....___~2n I;1- ____._ at __.---1-~-1~_ o'cloc6:, h. M., at 114 WOODLAWN 1_.ANE, CARLISLE, PA 17015-4351, in the manner described bclow~ Defendant personally served. Adult family member with whom Defendant(s) resides}. Rclationshil:, is __ Adult ir: charge of I_)efendant's residence who refused [o give namelrelationship. __ Manatrer!Clerk of place of lodging in which Defendant(s) reside(s). .Agent ur peror. in charge of Defendant's office or usual place of business, ~ an oI'fice'of said defendant company. Description: .4ge Height Weight Race`_ Sex___ Other I• __=_-__, a competent adult, being duly sworn according to law, depose and state that I personally posted a true and con~ect cnpy oi`thc t'umptairat in t4lort~~ge Foreclosure issued in the captioned n the date and the address indicated abovo I ~,n;iierstand that this st.:tetncnt is n~;td~ sarhjc~~t iu the penalties of 18 Pa. C.S. Sec. 4904 rel m;~; to un orn falsific n o • uthoritics. } PRINTED NAME: =~`'Ii:!'~,s -' f~~i~ 1'I`['LE, x"• -;fir ~~- NOT SERVED e a Or, the Clay of ___ , 20 , at o'clock . M., Defendant NOT FOUND because: ~'~ "`~ ~ V ac::r! _ i Does Not Exist _ Moved _ Does Not Reside (1\ot Vacant} Zr''' ~, © -mo ~ Z-r T-.. No .a~:c,ver ot: ast ----- - --.. ~t_~ _ - _ -_ V3~ ..~r. t tV ~~~ -~~:, yen ice Rcfirscrl ("' a=- ~ ~ ` C? ~ ()thcr: ZL j ~ r ~' D ~ © ~ `''' ---t q PtIS~2~sa~_3 ~ .,V-