HomeMy WebLinkAbout12-2778. r
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVV IA,,-
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WELLS FARGO BANK, N.A., CIVIL DIVISION a
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TYPE OF PLEADING t-"J
Brian G. Fagan; r
CIVIL ACTION - COMPLAINT
Defendant. IN MORTGAGE FORECLOSURE
TO: DEFENDANT
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED
AGAINST YOU.
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
COUNSEL OF RECORD FOR THIS PARTY:
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS
3476 Stateview Blvd.. MAC # X7801-013. Ft.1 Mill. SC 29715
AND THE DEFENDANT:
705 West Keller Street
Mechanicsburg-. PA 17055-3738
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
ATTORNEY
ATTY FILYNO.: XFP 164687
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire
Pa. I.D. #55650
Kimberly A. Bonner, Esquire
Pa. I.D. #89705
Joel A. Ackerman, Esquire
Pa I.D. #202729
Ashleigh Levy Marin, Esquire
Pa I.D. #306799
Ralph M. Salvia, Esquire
Pa I.D. #202946
Jaime R. Ackerman, Esquire
Pa I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
office(@zuckereoldbere.com
File No.: XFP- 164687/trk
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IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBIT 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 LID. 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 DIFF RENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US 0 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 O THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY
(20) DAYS, YOU MAY OBTAIN A EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE
MADE TO THE COURT FOR A JUD MENT 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 CRE ITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR
RECEIPT OF THIS COMPLAINT, T E LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION
OR OTHERWISE) TO COLLECT TH DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU
SHOULD CONSULT AN ATTORNE FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS
SUIT.
IF YOU HAVE FILED BANKRUPTCYIAND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A
DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
VS.
CIVIL DIVISION
NO.: I a - D') )8
Brian G. Fagan;
Defendant(k).
NOTICE TO DEFEND
You have been sued in court. If, ou wish to defend against the claim set forth in the following pages,
you must take action within twe ty (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 judg ent 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 FOR H BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
NOTIC? TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-908
(717) 249-3, 66
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
Phone (800) 990-9108
(717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
VS. NO..
Brian G. Fagan;
Defendant(.
AVISO
LISTED HA SIDO DEMANDADO/A N CORTE. Si usted desea defenderse de la demanda establecida en las
siguientes paginas, debe tomar a ci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n
de esta Demanda y Aviso respon iendo personalmente o por medio de un abogado una comparecencia
esc rita y radicando en la Corte p r escrito sus defensas y objeciones a las demandas establecidas en su
contra. Se le advierte de que si sted falla en tomar accion como se describe anteriormente, el caso
puede proceder sin usted sin p vio aviso y un fallo por cualquier suma de dinero reclamada en la
demanda 0 cua Iquier otra recla aci6n o remedio solicitado por el demandante, puede ser dictado en
contra suva por la Corte. Usted p ede perder dinero o propiedades u otros derechos importantes para
usted.
LISTED DEBE LLEVAR ESTE DOCU ENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN
ABOGADO 0 NO PUEDE PAGAR LI NO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE
PUEDE ENCONTRAR ASISTENCIA L EGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar ssociation Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990-9108 Phone (800) 990-9108
(717) 249-3166 (717) 249-3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
vs. NO..
Brian G. Fagan;
Defendant(s).
CIVIL ACTIONI- COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC,
and files this Complaint in Mortg*e Foreclosure as follows:
1. The Plaintiff is V ells Fargo Bank, N.A., (hereinafter "plaintiff") having its principal
place of business at 3476 Statevie`w Blvd., MAC # X7801-013, Ft. Mill, SC 29715.
2. Defendant, Brian! G. Fagan, is an individual whose last known address is 705 West
Keller Street, Mechanicsburg, PA 117055-3738.
3. On or about Dec?mber 31, 2008, Brian G. Fagan executed a Note in favor of Wells
Fargo Bank, NA in the original principal amount of $149,190.00.
4. On or about December 31, 2008, as security for payment of the aforesaid Note, Brian
G. Fagan, a single man made, exe?uted and delivered to Wells Fargo Bank, NA a Mortgage in the
original principal amount of $149190.00 on the premises hereinafter described, with said Mortgage
being recorded in the Office of thO Recorder of Deeds of Cumberland County on January 6, 2009,
Instrument #200900355. A true and correct copy of said Mortgage containing a description of the
premises subject to said Mortgag? is marked Exhibit "A", attached hereto and made a part hereof.
5. The aforesaid 4ortgage was amended and increased in principal amount of
$149,703.88 pursuant to a certain Modification Agreement by and between Wells Fargo Bank, NA
and Defendant, Brian G. Fagan, v?hich is unrecorded at this time. The terms of said modification set
forth the interest rate at 4.625° with a new monthly payment and interest amount of $ 769.69
commencing September 1, 2011 land continuing thereon with the due date of obligation August 1,
2041. A true and correct copy of aid Modification Agreement is marked Exhibit "B", attached hereto
and made a part hereof.
Zucker, Goldberg & Ackerman, LLC
XFP-164687
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 November 2011 payment, and pursuant to the terms of the aforesaid Mortgage, after written
notice of said default to Defendant(s), the entire principal balance and accrued interest due
thereunder has been accelerated]
7. Brian G. Fagan is he record and real owner of the aforesaid mortgaged premises.
8. On December 16? 2011, Defendant(s) were mailed a Notice of Intention to Foreclose
Mortgage, in compliance with Ac? 6 of 1974,41 P.S. §101, et seq.
9. The amount due ?nd owing Plaintiff by Defendant(s) is as follows:
Principal $149,297.22
Interest through 04/11/2012 $3,641.70
Escrow Advance $867.69
Late Charges $177.88
Inspection Fees $30.00
Total $154,014.49
plus interest on the principal sub ($149,297.22) at the daily per diem amount of $18.92 , and all
other additional amounts authdrized under the Mortgage, actually and reasonably incurred by
Plaintiff, including but not limiteO 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 suml to the above amount due and owning when incurred.
10. 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 Noted in a bankruptcy proceeding, this action is in no way an attempt to
re-establish such liability.
Zucker, Goldberg & Ackerman, LLC
XFP-164687
WHEREFORE, Plaintiff delmands judgment in mortgage foreclosure for the amount due of
$154,014.49, with interest thereon at the daily per diem amount of $18.92 plus additional late
charges, and costs (including additional escrow advances), additional attorneys' fees and costs and
for foreclosure and sale of the mortgaged premises.
Dated:
ZUCKER, GOLD, AC
BY: L.
Scott A. Di terick, Esquire; PA 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
Attorneys for Plaintiff
XFP-164687/mme
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
THIS 1S AN ATTEMPT ? COLLECT A DEBT, AND ANY INFORMATION OBTAINED
ILL BE USED FOR THAT PURPOSE.
Zucker, Goldberg & Ackerman, LLC
XFP-164687
T
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
XFP-164687
eXW 13I T A
ROBERT P. Z EGLER
RECORDER O DEEDS
CUMBERLAND COUNTY
ICOURTHOUS SQUARE
CARLISLE, P 17013
717-240-6370
Instrument Number - 20090035
Recorded On 1/6/2009 At 2:41:1 PM
* Instrument Type - MORTGAGE
Invoice Number - 34869 User ID - MBL
* Mortgagor - FAGAN, BRIAN G
* Mortgagee - WELLS FARGO B N A
* Customer - KEYSTONE LAND
* FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $10.00
JUSTICE
RECORDING FEES - $23.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
AFFORDABLE HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $60.50
*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 /,)'7FWS
r
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
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Prepared By:
WELLS FARGO BANK, N.A.
111 CONTINENTAL DR, SUITE 114,
NEWARK, AE 1.97130000
Return To:
WFHM FINAL DOGS X99991-01M
1000 BLUE GENTIAN ROXD
EAGAN, MN 55121
Parcel N umber: a 6 ?a (? ?7 rj - Q d?
Premises:
705 W KELLER ST
MECHANICSBURG
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Commonwealth of )Pennsylvania MORTGAGE _
THIS MORTGAGE ("St::urity Instrument") is given on DECEMBER 31, 2008
The Mortgagor is BRIAN G ! PAGAN, A SINGLE PERSON
("Borrower"). ThLs Security instrument is given to WELLS FARGO BANK, N. A.
WELLS FARGO BANK, N.A.
which is organized and existin under the laws of THE UNITED STATES and
whose address is P.O. BOXI 11701, NEWARK, NJ 071014701
("[ender"). [Borrower owes Lender the principal suns of
ONE HUNDRED FORTY NIZE THOUSAND ONE HUNDRED NINETY AND 00/100
j.
Dullars (U.S, $ ********149,190.00
NMFL #0642 WAFM) Rev 4124/2006
=,-4R FHA Pennsylvania Mo age - 4196
(PA) w5osi
VMP mortgage somic-,
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IN
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This debt is evidenced by, Borrower's note dated the same date as this Security Instrument
("Note"), which provides for thonthly payments, with the hull debt, if trot paid earlier, due and payahle on
JANUARY 01, 2039 This Security Instrument secures to Lender: (it) the rq)aymeut
of the debt evidenced by the Note, with interest, and all renewals, extensions and utodificaticns of the
Note; (b) the payment of all m her sums, with interest, advanced under paragraph 7 to protect the security
of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this
Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to
the Lender the following descr bed property located in CUMBERLAND
County, Pennsylvania:
**SEE ATTACHED
which has the address of 7051 W KELLER ST IStra•etl
MECHANICSBURG ICrtyl, Pennsylvania 17055 l/it. G'Al
("Property Address");
TOGETHER WITH all the improvements flow or hereafter erected on the property, and sill
easements, appurtenances and fixtures now or hereafter a part of the property. All replacements and
additions shall also he covered by this Security Instrument. All of the foregoing is referred to in this
Security Instrument as the "Pro perty."
BORROWER COVENA TS that Borrower is lawfully seized of the estate hereby conveyed and has
the right to mortgage, grant d convey the Property and that the Property is unencumbered, except tiff
encumbrances of record. Borrower warrants and will defend generally the title to the Property against all
claims and demands, subject t any encumbrances of record.
T14IS SECURITY INSTRUMENT combines uniform covenants for national use and non-unitiorm
covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real
property.
Borrower and Lender co errant and agree as follows:
UNIFORM COVENANt1s.
1. Payment of Principa , 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 Nolte.
2. Monthly Payment o Taxes, Insurance and Other Charges. Borrower shall include in each
nun+thly payment, together with the principal surd interest as set forth in the Note and any late charges, a
sum for (a) taxes and speci• t assessments levied or to he levied against the Property, (h) leasehold
payments or ground rents on tile Property, and (c) premiums for insurance required under paragraph 4, In
any year in which the Lender must pay a mortgage insurance prerniusn to the Secretary of Housing and
Urban Development ("Secretary"), or in any year in which such premium would have heen required if
Lender still held the Security Instrument, each monthly payment shall also include either: (j?rr' nl for the
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annual mortgage insurance pre rriurrt to he paid by Lender to the Secretary, or (ii) a monthly cliargQ instead
of a mortgage Lrsurance pret ium if this Security Instrument is held by the Secretary, in a reasoaahle
amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are
called "Escrow Items" and the wrrs paid to Lender are called "Escrow Funds."
Lender may, at any time collect and hold amounts for Escrow bents ur an aggregate amount not to
exceed the maximum amount lint may be required for Borrower's escrow account under the Real Estate
Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 et .secy. and implementing regulations, 24 CFR
Part 3500, as they may be at vended from time to time ("RESPA"), except that the cushion or reserve
permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments arc
available in the account may not be based on amounts due for the mortgage insurance premium.
Ville amounts held by L rider for Escrow Items exceed the amounts permitted to he held by RESPA,
Lender shall account to BOTH er for the excess funds as required by RESPA. if the amounts of funds held
by Lender at any time are not sufficient to pity the Escrow Items when due, Lender may no ity the
Borrower and require Borrowe to make up the shortage as permitted by RESPA.
The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument.
If Borrower tenders to Lender he full payment of all such sums, Borrower's account shall be credited with
the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium
installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund
any excess funds to Borrower. Immediately prior to it foreclosure sale of the Property or its acquisition by
Lender, Borrower's account sl all be credited with any balance retnair)ing for all installments for Items (a),
(b), and (c).
3. Application of Paymonts. All payments under paragraphs 1 acid 2 shall be applied by Lender as
follows:
First, to the mortgage insurance premium to be paid by Leader to the Secretary or to the aconthiy
charge by the Secretary instead; of (lie monthly mortgage insurance premiurtt;
Second, to any taxes, spt?cial assessments, leasehold payments or ground rents, and fire, 11<x,d and
otiter hazard insurance preiniums, as required;
Third, to interest due under the Note;
Fou t , to amortization o tare principal of the Note; and
Fifth, to late charges due under the Note.
4, Fire, Flood and Other Hazard Insurance. Burrower shall insure all improvements ore die
Property, whether now in existence or subsequently erected, against any hazards, casualties, and
contingencies, including fire, or which Lender requires hrsurauue. This insurance shall be maintained in
the amounts and for the perio s that lender requires. Borrower shall also insure all improvement's on the
Property, whether now in exiS once or subsequently erected, against loss by floods to the extent required
by the Secretary. All insuran e shall be carried with companies approved by Lender. The nisurat ie
policies and any renewals shail be held by Lender and shall hwiude loss payable clauses in favor (if. and in
a form acceptable to, Lender.
In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of
loss if trot made promptly by Borrower. Each insuraricc company concerned is hereby authoria,ed and
directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly.
All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the
reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent arnouuts
applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair
of the damaged Property, Any pplictition of the proceeds to the principal shall not extend or postpone the
due date of the rrunnthly payt entti which are referred to in paragraph 2, or change the amount of such
payments. Any excess insurai •e proceeds over an amount required to pay all outstanding indehtedne."
under the Notc and this Securit Instrument shall he paid to the entity legally entitled thereto.
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In the event of foreclosure of this Security Instrument or other transfer of tide to the Property that
extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in farce
shall pass to the purchaser.
S, Occupancy, Preserv tion, Maintenance and Protection of the Property; Borrower's Loan
Application; Leaseholds. Bo rower shall occupy, eStablish, and use the Property as Borrower's principal
residence within sixty days offer the execution of this Security instrument (or within sixty days of it later
sale or transfer of the Prorty) and shall continue to occupy the Property as Borrower's prinLipal
residence for at least one year after the date of occupancy. unless Lender determines that requirement will
cause undue hardship for orrower, or unless extenuating circumstances exist which are beyond
Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall nut
commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate,
reasonable wear and tear exec ted. Lender may inspect the Property if the Property is vacant or abandoned
or the loan is in default. Under may take reasonable action to protect and preserve such vacant or
abandoned Property. Borrower shall also be in default if Borrower, during the loan application process,
gave materially false or inaccurate information or statements to I,ender (or failed to provide Lender with
any material information) in a nnection with the loan evidenced by (lie Note, including, but not limited to,
representations concerning Bo rower's occupancy of the Property as a principal residence. If this Security
Instrument is on a leasehold, orrower shall comply with the provisions of the lease. If Borrower accloires
fee title to the Property, the le sehoid and fee title shall not he merged unless Lender agrees to the merger
in writing.
6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in
coauection with any condenur tion or other taking of any part of the Property, or for corrveyanLe in place
of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the
indebtedness that remains un aid under the Note and this Security itlStrUrnL'Itt. Lender shall apply .such
proceeds to the reduction of he indebtedness under the Note and this Security Instrument, first to any
delinquent atmounts applied inn the order provided in paragraph 3, and then to prepayineut of principal. Any
application of the proceeds t the principal shall not extend or postpone the due date of the monthly
payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess
proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security
Instrument shall be paid to the entity legally entitled thereto.
7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay alt
governmental or municipal chtrges, fines and impositions that are not included ill paragraph 2. Burrower
shall pay these obligations on ime directly to the entity which is owed the payment. If failure to pay would
adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish
to Lender receipts evidencing these payments.
If Borrower fails to make these payments or the payments required by paragraph 2, or fails to
perform ally other covenants and agreements contained in this Security Instrument, or there is a legal
proceeding that may significantly affect Lender's rights in the Property (such as a proceeding it,
bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is
necessary to protect the value of the Property and Lender's rights in the Property, including payrnernt of
taxes, hazard insurance and of er items mentioned in paragraph 2.
Any amounts disbursed y fender under this paragraph shall become as additional debt of Borrower
au.d be secured by this Se urity Instrument. These amounts shall bear interest from the date of
disbursement, at tine Note rate and at the option of Lender, shall be immediately due and payable,
Borrower shall promptly discharge any lien which has priority over this Security Instrwncnt unless
Borrower (a) agrees in writin to the payment of tine obligation secured by the lien in a manner acceptable
to Lender; (b) contests in gc 'rd faith the lieu by, or defends against enforcement of the lien in, legal
proceedings which in the Len per's opinion operate to prevent the enfuccemert of the lien; or fcj secure
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from the holder of' the lien n agreement satisfactory to Lender suhordinating the lien to this Security
Itstrument. If Lender determi es that any part of the Property is subject to a lien which may attain priority
over this Security Instrument Lender may give Borrower a notice identifying the lien. Borrower shall
satisfy the lien or take one or norc of tine actions set forth above within 10 days of the giving of notice
8. Fees. Lender may collect fees and charges authorized by the Secretary.
9. Grounds for Acceler tion of Debt.
(a) Default. Lender y, except as limited by regulations issued by the Secretary, in the case of
payment defaults, require immediate payment in full of all sums secured by this Security
Instrument if:
(i) Borrower defa lts by failing to pay in full any mouthly payment required by this Security
Instrument prior t) Or on the due date Of the next Monthly payment., or
(ii) Borrower def ults by failing, for a period of thirty days, to perfimn any other obligations
contained in this Security Instrument.
(b) Sale Without Credit Approval, bender shall, if permitted by applicable law (including
Section 341(d) of to Garn-St. Germain Depositary Institutions Act of 1982, 12 U S.C.
Mlj-31d)) and with the prior approval of the Secret uy, require IMMudiate payment in full of all
sums secured by this ecurity Instrument if:
(i) All or part o the Property, or a beneficial interest in a trust Owning all or part of this
Property, is sold rr otherwise transferred (other than by devise or descent), and
(ii) The Property is, not occupied by the purchaser or grantee as leis or her principal residence,
or the purchaser or grantee does so occupy the Property but his or her credit has not been
approved in acco ante with the requirements of the Secretary.
(c) No Waiver. If circumstances occur that would permit Lender to require immediate payment in
full, but Lender does not require such payments, Lender does not waive its rights with respect to
subsequent events.
(d) Regulations of HUD Secretary, In many circumstances regulations issued by the Secretary
will limit Lender's r ghts, it) the case Of payment defaults, to require immediate payment in full
and foreclose if not aid. This Security Instrument does not authorize acceleration or foreclosure
if not permitted by regulations of the Secretary.
(e) Mortgage Not Insured. Borrower agrees [liar if this Security instrument and the Note are not
determined to be elf ible for insurance under the National Housing Act within 60 days from the
elate hereof, Lender May, at its option, require immediate payment in full of all scuts 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 deem conclusive proof of such ineligibility, Notwithstanding the fofegoitag, this
option may not be xercised by Lender when (lie unavailability of insurance is solely due to
Lender's failure to reknit a mortgage insurance premium to the Secretary.
10. Reinstatentent. Bor ower has a right to be reinstated if Lender has required immediate payment
in toll because of Borrower's failure to pay an amount due under the Note or this Security htsnurnew. This
right applies even after for closure proceedings are instituted. To reinstate the Security ltrstrunteut,
Borrower shall tender in a lump sum all amounts required to bring horrowar', account cum.-iii including,
to the extent they are oblig tions of Borrower under this Security instrument, foreclosure cosr.x mud
raasortable and customary attorneys' fees and expenses properly associated with tite foreclosure proceeding.
Upon reinstatement by Borrower, this Security instrument and the obligations that it secures shall retrain
in effect as if Lender had not required immediate payment in full. However, Lender is not required to
permit reinstatement if: (i) ender has accepted reinstatement after the commencement of foreclosure
proceedings within two years itrunediately preceding the cotrunemutnent of a curre rt foreclosure
4o-4RIPAf toeoe: a.u. a o+s
proceeding, (ii) reinstatement will preclude foreclosure on different grounds in cite future, or (iii)
reinstatement wil; adversely of uct the priority of the lien created by this Security instrument,
11. Borrower Not Released; Forbearance By Lender Not a Waiver, Extension of the time of
payment or modification of amortization of the sums secured by this Security instrument granted by tender
to any successor iii interest of orrower shall not operate to release the liability of the original Borrower or
Borrower's successor in interest. Lender shall not be required to commence proceedings against tiny
successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums
secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's
successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver
of or preclude the exercise of any right or remedy,
12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. 'I he covenants and
agreements of this Security It strutnent shall bind and benefit the successors and assigns of Lender and
Borrower, subject to the provi ions of paragraph 9(b). Borrower's covenants and agreements shall be joint
and several. Any Borrower w xi co-signs this Security Instrument but does not execute the Note: (a) is
co-signing Ellis Security Inst ment only to mortgage, grant and convey that Borrower's interest sir the
Property under the terms of his Security Instrument; (b) is not personally obligated to pay the sums
secured by this Security Instr ment; and (c) agrees that Lender and any other Borrower tnay agree to
extend, modify, forbear or ma a any accommodations with regard to the terms of this Security Instrument
or the Note without that Borro er's consent.
13. Notices. Any notice to Borrower provided for in this Security instrument shall be given by
delivering it or by mailing it ly first class mail unless applicable law requires use of another method. The
notice shall be directed to flit Property Address or any other address Borrower designates by notice to
Lender. Any notice to Lender shall he given by first class mail to Lender's address stated herein or ally
address Lender designates by i otice to Borrower. Any notice provided tot in this Security Inatrutncnt shall
be deemed to have been given o Borrower or Lender when given as provided in this paragraph.
14, Governing Law; Se erability. This Security Instrument shall be governed by Federal law and
the law of the jurisdiction in ich the Property is located. In the event drat any provision or clause of this
Security Instrument or the Nut conflicts with applicable law, such conflict shall not affect other provisions
of this Security Instrument or t ie Note which can be given effect without the conflicting provision. To this
end the provisions of this Seen ity Ittstniment and the Note are declared to he severable.
15. Borrower's Copy. B rrrower shall be given one conformed copy of the Note and of thiti Security
1 ustrument.
16. Hazardous Substan es. Borrower shall not cause or permit the presence, use, disposal, storage,
or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone
else to do, anything affecting he Property that is in violation of any Environmental Law, The preccdiug
two sentences shall not apply to flit: presence, use, or storage on flit Property of small quantities of
Hazardous Substances that are generally recognized to he appropriate to nornuil residential uses and to
maintenance of the Property.
Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or
other action by any goverrun ttal or regulatory agency or private party involving the Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge. ft Borrower learns,
or is notified by any governm ntal or regulatory authority, that any removal or other renaediation of any
Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary
remedial actions in accordance with Environmental Law.
As used in this phmgra h 16, "Hazardous Substances" are those substances defiled as toxic or
hazardous substances by Div ronmental Law and the fallowing substances: gasoline, kerosene, other
flammable or toxic petroleum products, toxic pesticides acid herbicides, volatile solvents, materials
cuntxiriing ashestos or form ldehyde, and radioactive materials. As used in this paragraph 16,
-4R(PA) iosos; a,oe e
"Luviromnental Law" means ?O'nmental deral laws and laws of the jurisdiction where the Property is locoed that
relate to health, safety or envi protection.
NON-UNIFORM COVENANTS. Borrower and Lender tirrtlwr covenant and agree as follows:
17. Assignment of Ren . Borrower unconditionally assigns and transters to Lender all the rents and
revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues
and hereby directs each tenan of the Property to pay the rents to Lender or Lender's agents. However,
prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security
Instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the
henetit of Lender aria Borro er. This assignment of rents constitutes an absolute assigruneut and not an
assignment for additional security only.
If Lender gives notice of breach to Borrower: (a) all rents received by Burrower shall be held by
Borrower as trustee fur hen tit of Leader only, to be applied to the sums secured by the Security
Instrument; (b) Lender shall entitled to collect and receive all of the rents of the Property; and (c) each
tenant of the Property shall pry all rents due and unpaid to Lender or tender's agent on Lender's written
demand to the tenant.
Borrower has not execut d any prior assigtunent of the rents and has not and will not perform any act
that would prevent Lender from exercising its rights under this paragraph 17.
Lender shall not be required to enter upon, take control of or maintain the Property hefore or after
giving notice of breach to Borrower. However, Lender or a judicially appointed receiver shay do so at any
tirne there is a breach. Any a plication of rents s11311 not cure or waive any default or invalidate any other
right or remedy of Lender. TI is assignment of rents of the Property shall terminate when flip debt secured
by the Security Instrument is aid in full.
18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9,
Lender may foreclose this ecurity Instrument by judicial proceeding. Lender shall be entitled to
collect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, hilt
not limited to, attorneys' fee; and costs of title evidence.
If the Lender's interes in this Security Instrument is held by the Secretary and the Secretary
requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial
power of sale provided in tie Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C.
3751 et seq.) by requesting a foreclosure commissioner designated under the Act to commence
foreclosure and to sell the Property as provided in the Act. Nothing in the preceding sentence shall
deprive the Secretary of ally rights otherwise available to a Lender under this Paragraph 18 or
applicable law.
i
19. Release. Upon payment of all sums secured by this Security hhstrurrteat, this Security histrumeut
and the estate conveyed shall terminate and hecomc void. After such uccurreuce, Lender shall discharge
and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any rccordauou costs.
20. Waivers. Borrower, to the extent permuted by applicable law, waives and releases any error or
defects in proceedings to enforce. this Security Instrument, and hereby waives the henefit of any present or
future laws providing for sur of execution, extension of rime, exemption from attachment, levy and sale.
and homestead exemption.
21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to oue
hour prior to the cuTrlnretlce ent of bidding at a sheriff's sale or other sale pursuant to this Security
Instrument.
22, Purchase Money Mortgage. It any of the debt secured by this Security lustrumcnt i. Icnt to
Borrower to acquire title to th Property, this Security Instrument shall he a purchase money mortgage
23. Interest Rate After Judgment. Borrower agrees that the interest rite payable after a judgment is
entered on the Note or in all action of mortgage foreclosure shall he the rate payable from time to time
under the Note.
Init ne
MAMPAI Ioscw PAQe 7 9
24, Riders to this Security Instrument. If one or more riders are, executed by Borrower and
recorded together with this Security Instrument, the covenants of each such rider shall be iocorporated into
and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s)
were a part of this Security In, trurneut. JCheck app) icabte box(es)].
iJ Condominium Rider U Growing Equity Rider L- Other (spec.ityk
U Planned Unit Developrrnt Rider ? Graduated Payment Rider
BY SIGNING BELOW1 Borrower accepts and agrees to the teens contained in this Security
Instrument and in any rider(s) executed by Borrower and recorded with it.
Witnesses:
--- ?' - --- ---- ._ (Beak)
G FA Borrower
(.Seal?
<}?+rruwcr
riurreswer
_ ._ (seal)
-Burrower
-(Seal)
Borrawcr
- (Seal)
Hormucl
(Seal)
Rorrowcr
-, (Seal)
bbl r( I WC F
APMA) M09; Pepe 8 0l S
COMMONWEALTH OF P NSYLVANIA,
On [his, 31ST di of DECEMBER
personally appeared BRIAN FAGAN
0 et r ` County SS:
2008 before me, the utidcrsigaed officer,
known to me (or satisfactorily proven) io he the
person(s) whose name is/arel subscribed to the within instrument and acknowledged that helsheAltey
executed (lie saute for the pu ses herein contained.
IN WITNESS WHEREOF, 1 hereunto Set my hand and official seal.
My Commission Expires: ? ---
COMMONWF-'ALTHOFA INNSYLYANIA
140TARIAL 5 AL 1` C t%?-== --
VICKIE R. WELKERR. N 12ry Public Tlte pi Offit"r
Camp Hill Born., Cum d 4c ull
Certificate of Residence
t do hereby certity that the correct addre,?s of
the within-named lender is V-0- BOX 11701, NEWARK, NJ 071014701
Witness my hand this 31ST day of DEC ER 2008
Agcm +?r lender
® -4R(PA) iosoei Pace 9 of s
c9
First American Title Insurance Company
Commitment Number'
SCHEDULE C
PROPERTY DESCRIPTION
Lhe land referred to in this Commitment 's described as follows:
ALL THOSE CERTAIN two Lots of Ground situate on the south side of West Keller Street, in the Borough of
Mechanicsburg, in the County of Cumberland and State of Pennsylvania, bounded and described as follows, to
wit:
LOT NO. 1:
BEGINNING at a point on the south rn line of West Keller Street and at corner of Lot No. 27 on the hereinafter
mentioned Plan of Lots; thence in a southerly direction along the line of said Lot No. 27, 200 feet to a point on
the northern line of a 12 feet wide a ley; thence in a westerly direction along the northern line of said alley, 50
feet to a point at corner of Lot No. 2 on the hereinafter mentioned Plan of Lots; thence in a northerly direction
along the line of said Lot No. 29, 20 feet to a point on the southern line of said West Keller Street aforesaid;
thence in an easterly direction alon the said line of West Keller Street, 50 feet to a point, at the place of
BEGINNING.
BEING Lot No. 28 on a Plan of Loto known as GREEN ACRES, which Plan is recorded in the Recorder's Office
in and for said Cumberland Countyin Plan Book No. a, Page 4.
LOT NO. 2;
BEGINNING at a point on the southern line of West Keller Street and at the corner of Lot No. 28 on the
hereinafter mentioned Plan of Lots; thence in a southerly direction along the line of said Lot No. 28, 200 feet to a
point on the northern line of a 12 feet wide alley; thence in a westerly direction along the northern line of said
alley, 50 feet to a point at a corner of Lot No. 30 on the hereinafter mentioned Plan of Lots; thence in a northerly
direction along the line of said Lot No. 30, 200 feet to a point on the southern line of West Keller Street
aforesaid; thence in an easterly dir ction along the said line of West Keller Street, 50 feet to a point, at the place
of BEGINNING.
BEING Lot No. 29 on a Plan of Lot known as GREEN ACRES, which Plan is recorded in the Recorder's Office
in and for said Cumberland County in Plan Book 4, Page 4.
BEING the same as Tax Parcel Number 20-24-0785-007.
BEING the same premises which J hn W. Shanabrook and Mildred C. Shanabrook by deed dated January 25,
2003 and recorded March 4, 2003 in the Office of the Recorder of Deeds in and for Cumberland County,
Pennsylvania, in Deed Book 255, age 4818, granted and conveyed unto The John W. Shanabrook and Mildred
M. Shanabrook Revocable Living ,rust.
ALTA Commitment
Schedule C (08520108520/16)
EXHIBIT B
Zucker, Goldberg & Ackerman, LLC
XFP-164687
acr??S?r
Wells Fargo Flome Mortgage
MAC X9999 01N
2101 Wells I'argo Way
Minneapoks, MiN 55467
LOANiMODIFICATION AGREEMENT
LOAN?NUMBER
PROP RTY ADD .S 705 W Keller St
Mechanicsburg PA 17055
THIS LOAN MODIFICATION'AGREEMENT ("Agreement"), made on
June 13, 2011, by and ?etween Brian G Fagan and
and (the "Borrower (s) r') and
Wells Fargo Bank, N A (the "Lender",
together with the Borrower(s), the "Parties").
WITNESSETH
WHEREAS, Borrower has requested and bender has agreed, subject to the
following terms and co ditions, to a loan modification as follows:
NOW THEREFORE, in consideration of the covenants hereinafter set forth
and for other good and valuable consideration, the receipt and
sufficiency of which are hereby acknowledged by tho Parties, it is agreed
as follows (notwithstanding anything to the contrary in the Note and
Security Instrument dated 12/31/2008.)
1. BALANCE. As of Jun 13, 2011, the amount payable under the Note
and Security Instrument (the "Unpaid Principal Balance") is U.S.
$ 144,758.31.
2. EXTENSION. This Agreement hereby modifies the following Lerms of Lhe
Note and Security Instrument described herein above as follows:
A. The current contractual. due date has been extended from 04-01-11
to 09/01/2011. The first modified contractual due date is on
09/01/2011.
B. The maturity date has been extended from 01-39 (month/year) to
08/01/2041.
C. The amount of interest to be included (capitalized) will be U.S.
$ 3,39; .75.
't'he amount of the Escrcfw Advance to be capitalized will be U.S. $1,649.48.
The amount of Recoverable Expenses* to be capitalized will. be
U.S. $0.00.
The modified Unpaid Principal Balance is U.S. $ 149,703.88-
* Recoverable Expense may include, but are not :Limited to: Title,
Attorney fees/costs, PO/Appraisal, and/or Property PreservaLion/
Property Inspections
D. The Borrower(s) promises to pay the Unpaid Principal Balance plus
irttere.;t, to the order of the Lender-- Interest will be charged on the
unpaid Principal Balance of U_S. $ 149,703.88. The Borrower(s) promisen
to make monthly payments of principal and interest of U.S. $ 769.69,
at a yearly rate of 4.,625%, not including any escrow deposit, if
applicable. If on the maturity date the Borrower(s) still owes an amount
under the Note and Se unity instrument, as amended by this Agreement,
Borrower(s) will pay his amount in full on the maturity date.
LM521/KSD/1
Together we'll go far
Wells Frnuo I tome Mortgage is a cl -sioo of Wells Fargo 8{nk. N.A. _
.a +wr r ^?
?,?:,.
,?
,.t;
Wells Faryo Home Mortgage
MAC X9999-01N
2701 Wells -'aryo Way
T'dinncepuGs, 1viN 5S4B7
E. Borrower agrees that certain amounts owed will not be capitalized,
waived, or addressed a part of this Agreement, and will remain owed
until paid. These amou is owed are referenced in the Cover Trettc-r to
this Agreement, which 's incorporated herein, and are to be paid with
the return of this executed Agreement. If these amounts owed are not
paid with the return or this executed Agreement, then Lender may deem
this Agreement void.
3. NOTE AND SECURITY INSTRUMENT- Nothing in this Agreement. shall he
understood or construe to be a satisfaction or release, in whole or in
part of the Borrower's' obligations under the Note or Security Instrument.
Further, except as otherwise specifically provided in this Agreement, the
Note and Security Instrument will remain unchanged, and Borrower and
Lender will be bound by, and shall comply with, all of the terms and
provisions thereof, as amended by this Agreement.
4. The undersigned Bo rower(s) acknowledge receipt and acceptance of the
Loan Modification Settlement Statement. Borrower(s) agree with the
information disclosed in and understand that I/we am/are responsible for
payment of any outstanding balances outlined in the Loan Modification
Settlement.
5. The undersigned B rrower(s) acknowledge receipt and acceptance of Lhe
Borrower Acknowledgements, Agreements, and Disclosures Document. (HAAF))
6- If included, the undersigned Borrower(s) acknowledge receipt and
acceptance of the Truth in Lending statement.
7. Tf included, the undersigned Borrower(s) acknowledge receipt and
acceptance of the Spe ial Flood Hazard Area (SFHA).
8. That (he/she/they) (is/are) the Borrower(s) on the above-referenced
Mortgage Loan serviced by wells Fargo Bank, N A.
That (he/she/they) ha?e experienced a financial `iardship or change iii
financial. ciscumstanc s since the origination of (hi.s/he.r-/t.heir)
Mortgage Loan.
That (he/she/they) did not intentionally or purposefully default on the
Mortgage Loan in orde? to obtain a loan modification.
LM521/KSD/2
Together we'll go far
Wells Faryo Hcme Mortgage Is a division of Wclls Fargo Bbnk, N.A.
A t
0 '
,
Wells Fargo Home Mortgage
MAC X999Sa OlN
2701 Wells =ergs Way
CORRECTION AGREEMENT. he undersigned borrower(s), for and in
consideration of the-a proval., closing and funding of this
Modification, hereby grants Wells Fargo Bank, N A, as
lender, limited power f attorney to correct and/or initial all
typographical or cleri al errors discovered in the Modification
Agreement required to ?e signed. In the event this limited power of
attorney is exercised,Ithe undersigned will be notified and receive
a copy of the document' executed or initialed on t=heir behalf. This
provision may not be used to modify the interest rate, modify the
term, modify the outstanding principal balance or modify the
undersigned's monthly principal and interest payments as modified by
this Agreement. Any of these specified changes must be executed
directly by the undersigned. This limited power of attorney shall
automatically terminate in 120 from the closing date of the
undersigned's Modification. - (Borrower(s) initial)
IN WITNESS WHEREOF, tYIe Parties hereto have executed this Agreement as
the date first above v?ritten.
By signing this Agree*nt I hereby consent to being contacted concerning
this loan at any cell lar or mobile telephone number I may have. This
includes text message and telephone calls including the use of
automated dialing systems to contact my cellular or mobile telephone.
You will not. be billet by your cellular or mobile carrier for any text
messages you may receive from Wells Fargo, however, any calls we place
to your cellular or m bile phone will incur normal airtime charges
assessed by your mobi e carrier.
Dated as of this % day of j&Ioe_ 2O_ZL.
Brian ?ag?a?n
signature Signature
Wel ls` 'V`argo Bank, N Al N - U&
Halimo dem WMa. UCWU
Name : entlim entation ow % am
ptle 16,!01!
Tts: _
LM527/KSD/3
ff ??\l t (L V
Together we'll go far
q ,
Wells Fau o Home Mort a e is a division of Wells Fargo B IN A.
41; 1 /
VERIFICATION
Brent Alban, hereby':,states tha he/ he is Vice President Loan Documentation of
WELLS FARGO BANK, 14 A., plaintiff or mortgage servicing agent for plaintiff in this
matter, that&he is authori, zed to make this Verification, and verify that the statements
made in the foregoing CivillAction in Mortgage Foreclosure are true and correct to the
best o is her information 4nd 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.
f Name: Brent Alban
DATE: `f 12 2?1
Title: Vice President Loan Documentation
032-Pit-V3 File #: X P-161687
T
WELLS FARGO BANK, N.A.,
Plaintiff(s)
vs.
..a
IN THE COURT OF COMMON PLEAS a
CUMBERLAND COUNTY, PENNSYLVKN-
Brian G. Fagan;
Deferndant(s) V Civil
v. ?
-l
:y
N --
NOTICE OF RESID)ENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with aforeclosure complaint that could cause you to lose your home.
If you own and live in the res dential property which is the subject of this foreclosure action, you may
be able to participate in a court-supe ised 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 MidPenn Legal
Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a
legal representative at no charge toy you. Once you have been appointed a legal representative, you must
promptly meet with that legal represe tative within twenty (20) days of the appointment date. During that
meeting, you must provide the legal r presentative with all requested financial information so that a loan
resolution proposal can be prepared o your behalf. If you and your legal representative complete a financial
worksheet in the format attached he o, 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 o and a conciliation conference is scheduled, you will have an
opportunity to meet with a represents ive 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
eligible for a conciliation conferenc
appointment of a legal representative,
information so that a loan resolution I
a financial worksheet in the format at
Conference with the Court, which mr
the foreclosure complaint. If you do
opportunity to meet with a representa
with your lender before the mortgage
IF YOU WISH TO SAVE
STEPS REQUIRED BY THIS N(
v
a
FORM I
twyer, you and your lawyer must take the following steps to be
It is not necessary for you to contact MidPenn Legal Service for the
However, you must provide your lawyer with all requested financial
oposal can be prepared on your behalf. If you and your lawyer complete
,shed hereto, your lawyer will prepare and file a Request for Conciliation
t be filed with the Court within sixty (60) days of the service upon you of
) and a conciliation conference is scheduled, you will have an
ve of your lender in an attempt to work out reasonable arrangements
oreclosure suit proceeds forward.
HOME, YOU MUST ACT QUICKLY AND TAKE THE
THIS PROGRAM IS FREE.
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST F R HARDSHIP ASSISTANCE
To complete-your request fo hardship assistance, your lender must consider your
circumstances to determine ossible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes E] No E] Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ? No ?
Mailing Address (if different: _
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Email :
# of people in household:
First Mortgage Lender: _
Type of Loan:
Loan Number:
Second Mortgage Lender:
Type of Loan: _
Loan Number:
Total Mortgage Payments
Date of Last Payment: _
Primarv Reason for Default:
How long?
Home:
Cell:
State:
Zip:
How long?
Date You Closed Your Loan:
count: $ Included Taxes & Insurance:
Office:
Other:
Is the loan in Bankruptcy? Yies ? No ?
If yes, provide names, location of court, case number & attorney:
Assets- Elmo 'nt Owed: Value:
Home: $- _- $
Other Real Estate. $ $
Retirement Funds: $ _ $ _
Investments: $ $ _
Checking: $ _
- $
Savings: $
- $ _
Other: $
? $_ _
Automobile #1: Mod el: Year:
Amount owed: _ Value:
Automobile #2: Mod el: Year:
Amount owed: Value:
Other transportation autom biles boats motorcy cles): Model:
Year: Amount *d: Value
Monthly Income
Name of Employers:
1.
?
2.
3.
Additional Income Descripti
1. -monthly,
2. -monthly
Borrower Pay Days:l?
Monthly Expenses: (Please
(not wages):
Dunt:
Co-Borrower Pay Days:
include expenses you are currently paying)
EXPENSE AM T EXPENSE AMOUNT
Mortgage Food
21° Mortgage Utilities
Car Pa ment s Condo/Nei . Fees
Auto Insurance Med. not covered
Auto fuel/repairs Other prop. payment
..-
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Money
Day/Child Care/Tuit. Other Expenses
Amount Available for Mon
Have you been working i
YesE] No ?
If yes, please provide the
Counseling Agency:
Counselor:
Phone (Office):
Mortgage Payments Based on Income & Expenses:
a Housing Counseling Agency?
owing information:
Fax:
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ? No ?
If yes, please indicate the sta?tus of the application:
Have you had any prior negdtiations with your lender or lender's loan servicing company
to resolve your delinquency`s
Yes ? No ?
If yes, please indicate the sta?us of those negotiations:_
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact:
Phone:
I/We, , authorize the above
named to use/refer this information to my lender/servicer for the sole
purpose of evaluating my financial situation for possible mortgage options. I/We
understand that Uwe am/are der no obligation to use the services provided by the above
named
Borrower Signature
Co-Borrower Signature
Please forward this do(
lender's counsel:
Proof of income
Date
Date
along with the following information to lender and
Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation
(hardship letter)
Listing agreement (if property is currently on the market)
FORM 3
WELLS FARGO BANK,; N.A.,
Plaintiff(s)
VS.
Brian G. Fagan;
Defendant(s)
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL
FOR CONCILIATION CONFERENCE
Pursuant to the Admostrative Order dated .2012 governing the Cumberland
County Residential Mortgag Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
I . Defendant is a owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant liv?s in the subject real property, which is defendant's primary
residence;
3. Defendant h been served with a "Notice of Residential Mortgage Foreclosure
Diversion Pro am" and has taken all of the steps required in that Notice to be
eligible to p icipate in a court-supervised conciliation conference.
The undersigned verities 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
unsworn falsification to authorities.
Signature of Defendant's C unsel/Appointed Date
Legal Representative
Signature of Defendant
Signature of Defendant
Date
Date
FORM 4
WELLS FARGO BANK, N.A.,?
Plaintiff(s)
VS.
Brian G. Fagan;
Defendant(s)
AND NOW, this
the above-captioned residential r
Conciliation Conference verifyir
Administrative Rule requiremen
ORDERED AND DECREED th
1. The parties and their
conciliation Conferer
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
NO.
day of , 20 , the defendant/borrower in
?rtgage foreclosure action having filed a Request for
that the defendant/borrower has complied with the
for the scheduling of a Conciliation Conference, it is hereby
ansel are directed to participate in a court-supervised
on at M. in
the Cumberland County Courthouse, Carlisle, Pennsylvania,
2. At least twenty-one (41) 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 Co?rt. the case shall be removed from the Conciliation Conference
schedule and the ten
3. The defendant/borro
Conference in perso:
either attend the Cor
during the course of
plaintiff/lender who
actual authority to re
plaintiff/lender must
iry stay of proceedings shall be terminated.
and counsel for the parties must attend the Conciliation
and an authorized representative of the plaintiff/lender must
iliation Conference in person or be available by telephone
ie Conciliation Conference. The representative of the
irticipates in the Conciliation Conference must possess the
oh a mutually acceptable resolution, and counsel for the
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
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore ail 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; 4d the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
I
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FILED-OFFICE
Sheriff _ur THE PROTHONOTAR)'
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
0614" of um bell"*#
OFPCE OF --E E-fFrrF
2012 MAY 22 AM 9: 09
CUMBERLAND COUNTY
PENNSYLVANIA
Wells Fargo Bank, NA
VS. Case Number
Brian G. Fagan 2012-2778
SHERIFF'S RETURN OF SERVICE
05111/2012 04:44 PM - Ryan Burgett, Deputy Sheriff, who being duly swum according to law, stag that on May 11,
2012 at 1644 hours, he sewed a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Brian G. Fagan, by making known unto himself personally, at 705 W.
Keller Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time
handing to him personally the said true and correct copy of the same.
M
RYAN BURGETT, DE
SHERIFF COST: $38.00
May 17, 2012
SO ANSWERS,
(jZ'
RON R ANDERSON, SHERIFF
(c) County&dte Sheriff, Telemft, Inc.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Cl)
e
G
Wells Fargo Bank, N.A., CIVIL DIVISION ?;v
x
'r r"
„
Plaintiff No.: 12-2778-CIVIL
Co ca
3;0 C?
Vs. ISSUE NUMBER: ?Q?
3> Z
Brian G. Fagan; TYPE OF PLEADING: o
Defendant(s).
Mortgaged Premises:
705 West Keller Street, Mechanicsburg, PA 17055-
3738
PRAECIPE FOR ENTRY OF JU PIT BY
(MORTGAGE FORECLOSURE)
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
Plaintiff
COUNSEL OF RECORD FOR THIS PARTY:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire- Pa I.D.# 55650
Kimberly A. Bonner, Esquire- Pa I.D. #89705
Joel A. Ackerman, Esquire- Pa I.D. #202729
Ashleigh L. Marin, Esquire-Pa I.D. #306799
Ralph M. Salvia, Esquire- Pa I.D. #202946
Jaime R. Ackerman, Esquire- Pa I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
Atty File No.: XFP-164687
ILT
OLM4 islu. opa Ofi
??, ? 3 yap
r-) L,. a $sas
Praecipe for Entry of Judgn
Zucker, Goldberg & Ackerman,
X? ?6A
oe
*&j
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAMIIA?
Wells Fargo Bank, N.A.
VS.
Brian G. Fagan;
CIVIL DIVISION
Plaintiff, NO.: 12-2778-CIVIL
Defendant(s).
PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE)
TO: PROTHONOTARY
Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of
Plaintiff and against Defendant(s), for failure to file a response to Plaintiffs Complaint within the
appropriate time limits from service thereof, and assess Plaintiff's damages as follows:
Amount as set forth in Complaint $154,014.49
Interest from Complaint date through 07/10/2012 $1,683.88
Late Charges $61.58
TOTAL $155,759.95
plus interest on the judgment amount ($155,759.95) from July 11, 2012, at the statutory rate and for
foreclosure and sale of the mortgaged premises.
I hereby certify that the defendant's last known 705 West Keller Street
address is: Mechanicsburg, PA 17055-
3738
Dated: ,i1) iii
ZLICWR,GOLBE & AC KERMAN, LLC
J an, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP-164687
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 23L-8500; (908) 233-1390 FAX
Email: @z o .com
DAMAGES ARE HEREBY ASSESSED AS INDICATED
Date
BY:
[f
Prothonotary
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
VS.
Brian G. Fagan;
CIVIL DIVISION
Plaintiff, NO.: 12-2778-CIVIL
Defendant(s).
AFFIDAVIT OF NON-MILITARY SERVI1CE AID CERTWICATE OF MAHJNG OF
NOTICE' OF INTENT TO TAKE DEFAULT JUDGMENT
STATE OF NEW JERSEY
COUNTY OF UNION
SS:
I, the undersigned attorney for the plaintiff in the above action, being duly sworn according
law, do hereby depose and say that the statements made herein are true in and correct to the best
my knowledge, information, and that:
1) The Defendant is not in the military service of the United States of America to the
of my knowledge, information and belief as evidenced by the attached copies;
2) The Notice of intent to take Default Judgment was mailed in accordance with Pa. R.C.I
237.1 and that the time limits provided for that notice have expired.
Z . KER, GOLBERG & ACKERMAN, LLC
Dated: BY:
FH/ Joel A. Acker an, ; A I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP-164687
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
Sworn to and subscribed before me
T ' (L day of 20 ( Z
N ry Public
My Co ssion Expires:
EDWARD J. SCHWAHL II
Commission # 2383239
Notary Public, State of New Jersey
My Commission Expires
March 09, 2014 Zucker, Goldberg & Ackerman,
XFP-164
Department of Defense Manpower Data Center Results as or: .10-10-201 :D11:36:21
S RA 2.2.1
ft" 40 PWNNM Replalrt
to ervicrattF.11111.?t Qvff Relief Ad
Last Name: FAGAN First Name: BRIAN G
Active Duty Status As Of: Jul-10-2012
Aesr. cwy>perl crte AeM C?cytiw4 Me titer ?olnlK
13a AY?tra?agr Gn Arfw tl??MiWetfrM.
NA NA No NA
This remp, reAaea IM k0ft" acM d" sake based on do AaM Duty status Derv
h>wri'tilair?wraln »rl??Ilrrra arw
NeywtfelkrirtElw ,weti?w euptend eve awn. eerwelr Wnwaara
NA NA No NA
Tldt response re8eca where tiro kMlvidual MR active duty status w*M 387 deya preoedng tie Active Duty Status Date
7hs AMcapr errtiUNer lint lyat titolMed d a FusAS CrWp le Aotisa flub en Aatiw Dub agttus Ocga
Drdsr No-0, -, hart Dale ordw "coo"" En/ bete eUhe 8enow Gbnipsrrent
NA NA No NA
This response rolleea whether tie indkid al or NOW unti hat received ery noNmUn b report far active duty
Upon searchirV the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the
the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Healt
Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty.
7
and
of
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
4600 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
Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems.
The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 at seq, as amended) (SCRA) (formerly kno 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 fa ily
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 ti i 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
"defensslink.mir URL: http:/A~.deferooft.mWfaglpWM09SLDR.html. If you have evidence the person was on active duty for the active duty s
date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521( ).
This response reflects the following Infometion: (1) The individuars Active Duty status on the Active Duty Status Date (2) Whether the individual left
Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or histher unit received early notification to report for a
duty on the Active Duty Status Date.
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the acute 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 meat be assigned against an authorized mobiNmtlon position the
unit they support. This Includes Navy Training and Administration of the Reserves (TAR*), Marine Corps Active Reserve (ARs) and Coast Guard Re e
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 HeaHh Service or the National Oceanic and Atmospheric Administration (NOM 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 acute duty for purposes of the SCRA who would be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services per .
Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(dj(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 vice.
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 hs not
actually begun active dirty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the CRI
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
are protected
WARNING: This oertiAcato was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous
information will cause an erroneous certificate to be provided.
Report ID: 7DMBRTV7JK
IN THE COURT OF COMMON PLEAS OF CUMKRLAND COt TY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff, NO.: 12-2778-CIVIL
VS.
Brian G. Fagan;
Defendant(s).
NOTICE OF ORDEiii, DECREE OR JUDGMENT
TO: Brian G. Fagan
705 West (teller Street
Mechanicsburg, PA 17055-3738
[ ] Plaintiff
[y] Defendant
[ ] Additional Defendant
You are hereby notified that an Order, Decree or Judgment was entered in the above captioned
proceeding on s? XS 41 , -,,% V ;?-
[ ] A copy of the Order or Decree is enclosed,
or
[d] The judgment is as follows: $155,759.95 plus c
Prothonotary
Zucker, Goldberg & Ackerman,
XFP-164
31 ! 'S DICE OF CU lt.l?iQ COUNTY
RAndomm FILED-OFFICE
C;r THE PROTHONOTARY
.sr s spa
c Dw*
moMnl w s
Mcibr
o?+ce oss?
2012 MAY 22 AM 9: 09
CU PMi?RJ,IdIQ,AQtM?TY
rrma1?v ?A
V%ft FWV* bw r, NA
V& cow
M Mr eA., a. fir, 2042.2"8
05MIG M2 - ?.?+ o ? sn ? w!a r.wera Nw, atNw??ita?t M?qr 11,
X112 rt 1114 mss, hrs?walatla ar+c'a Fem.
w+r+r+ a.aar rr, a «?r te a. by ri+wms mom oft +ww..?r ?, ac W.
MarMr?r?rt ?a aaa>ws ?a ow" *no
b tin o..?y w. sMd Via. snd aarrat a?a???N• sra..
SHOW COST. $WOO
Msy 17, 2012
90 ANSVAM,
40? ?• 4
(WCougiWb SNWWI Townt Mo.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
VS.
Orion G. Fagan
TO: Brun G. Fagan
M WAnt KeRw 8ltrost
MsalMM*burg, PA 17065-3738
DATE OF NOTICE: 6/26/2012
NO.: 12-2778-CIVIL
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
Cram Cwt Bar Association Cumborkwul County Bar Association
32 ib. da*vrd Street 32 & 0 din I Blrset
C.srH** PA 17013 C , PA 17013
Phone to" "04106 Phone WO) 9i!fl-8108
(717) 249.3166 (717) 249-3166
Defendant.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Woft Fargo Bank, N.A.
Plaintiff,
CIVIL DIVISION
VS.
Brian G. Fagan
TO: Brian G. Fagan
705 Murat KeNer Street
Mod niesrburg, PA 170554738
Defendant.
NO.: 12-2778-CIVIL
AVISO IMPORTANTE
FECHA DEL AVISO:6/26l2012
LISTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION
REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE
LOS PROMMOS DMZ (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'PROPMDAD Y OTROS DERECHOS IWORTANTES. USTED DEBE
LLEVAR ESTE DOCUNiENTO 5WEDIATAIENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR LINO, VAYA O LLAME LA OFIC I A
ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA
LEGAL.
NOTICE TO DEFEND & LAWY'ERREFERRAL SERVICE
Cumbergnd County Bar Association Cumberland County Bar Association
32 S. Bedford Sheet 32 S. Bedfwd Steet
Ca Moo-, PA 17013 Carlisle, PA 1T013
Phone (848) 4l114108 Phone (90) 490-8108
(717) 24"166 (717) 244-3166
ZUCKER, GOLDBERG &ACKERMAN
BY: fto A.
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 164687
f
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. : CIVIL DIVISION
Plaintiff, ..))
NO.: 12-2778-CIVIL
vs.
Brian G. Fagan; • - �
Defendant. %-"
•-n
C") 3�.y
PRAECIPE TO WITHDRAW DEFAULT JUDGMENT -t -
Please mark the Default Judgment filed at the above-captioned term and number WITHDRAWN,
without prejudice.
Respectfully Submitted:
ZUCKER, GOLDBERG &ACKERMAN, LLC
BY: ZAA .�I
Scott A. D -t erfck, squire; PA I.D. #55650
Kimberl 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,
Attorneys for Plaintiff
XFP-164687/11
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
G04 4g* 611-11.
SSO66,
a9`7 3 41
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff, •
vs. NO.: 12-2778-CIVIL
Brian G. Fagan; •
Defendant.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing Praecipe to
Withdraw Default Judgment was served on the following this of , 2013,via
First Class U.S. Mail, Postage Pre-Paid:
Brian G. Fagan
705 West Keller Street
Mechanicsburg, PA 17055-3738
Respectfully Submitted:
ZUCKER, GOLDBERG & KERMAN, LLC
BY:
Scott A. 4 ietterick, Esquire; PA I.D.#55650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A.Ackerman, Esquire; PA I.D.#202729
Ashleigh L. Marin, Esquire; PA I.D.#306799
Ralph M. Salvia, Esquire; PA I.D.#202946
Jaime R.Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
X F P-164687/11
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A., CIVIL DIVISION
Plaintiff No.: 12-2778-CIVIL ern ,y
C-- r.0 L.
vs. ISSUE NUMBER:
Brian G. Fagan; TYPE OF PLEADING: --
Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY 66AUT
(MORTGAGE FORECLOSURE)
Mortgaged Premises:
705 West Keller Street, Mechanicsburg, PA 17055- FILED ON BEHALF OF:
3738
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, NJ 07092
(908)233-8500
Atty File No.: XFP-164687
la
a� r
3win
Praecipe for Entry of Judgment
Zucker,Goldberg&Ackerman,LLC
po� X1 4687
, FP-Lt 11 �
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
vs. NO.: 12-2778-CIVIL
Brian G. Fagan;
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 $154,014.49
plus interest on the judgment amount ($154,014.49)from April 12, 2012, at the statutory rate and for
foreclosure and sale of the mortgaged premises.
I hereby certify that the defendant's last known 705 West Keller Street
address is: Mechanicsburg, PA 17055-
3738
f�� l�
ZUC ER, GOLBERG &ACKERMAN, LLC
Dated: BY;
Joel A.A erman, squire; PA I.D.#202729
Ashleigh L. Marin, Esquire; PA I.D.#306799
Jaime R.Ackerman, Esquire; PA I.D.#311032
Attorneys for Plaintiff
XFP-164687
200 Sheffield Street,Suite 101
Mountainside, N1 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.: 12-2778-CIVIL
Brian G. Fagan;
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.
ZUCKER,GOLBERG &ACK6RMAN, LLC
Dated: l�a a.�I� BY:
Joel X Ackerman, Esquire; PA I.D.#202729
Q' Ashleigh L. Marin, Esquire; PA I.D.#306799
Jaime R.Ackerman, Esquire; PA I.D.#311032
Attorneys for Plaintiff
XFP-164687
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908)233-8500; (908) 233-1390 FAX
Email: Office @zuckergoIdberg.com
Sworn to and subscribed before me
This &72—day of ' 20 /
Notary Public
My Commission Expires:
Cheryl Debeneadto Notary Public
My Comm. Expires Oct. 16,2014
ID#2280276
State of New Jersey
Zucker,Goldberg&Ackerman, LLC
XFP-164687
Department of Defense Manpower Data Results as of:Jan-14-201406:36:52
Center
SCRA 3.0
State I-MI
Pursuant to Servicemembers Civil Relief Act
Last Name: FAGAN
First Name: BRIAN
Middle Name: G
Active Duty Status As Of: Jan-14-2014
Status Date
. Active Duty Start Date• Active DU 'IE` D to-"� Statue SetNiDm'
NA NA No NA
This response reflects the individuals'active duty status based on the Active Duty Status Date
-Left Active 367 Da of Activa:Du ' bIs Data
Active Duty Start Date Active Duty End Da T r
ta;`� ' Statue ServicdComponent
NA I NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Merrlber'or*As u' ti V` 'otll Mdkik tt l= 're d"'to to Active Du on Active, tus Date.,
Order Notification Start Date. Order Notifloat oq End Dam' Status Service°Con ponent
NA NA No NA
This response reflects whether the Individual or his/her unit has recelved early notiftcation 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,NOAA,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.
At ,r+
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 maybe 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(NOAA Commissioned Corps).
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be
reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services 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: N617022DO087960
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
VS. '
NO.: 12-2778-CIVIL
Brian G. Fagan;
Defendant.
NOTICE OF ORDER, DECREE OR JUDGMENT
TO: Brian G. Fagan
705 West Keller Street
Mechanicsburg, PA 17055-3738
[ ] Plaintiff
[V] Defendant
[ ] Additional Defendant
You are hereby notified that an rder, Decree or Judgment was entered in the above captioned
proceeding on
[ ] A copy of the Order or Decree is enclosed,
or ,
[V] The judgment is as follows:$154,014.49 plus co ts.
Prothonotary
Zucker,Goldberg&Ackerman, LLC
XFP-164687
SHERIFF'S OFFICE OF CUMBERLAND COUNW
Ronny R Anderson FILED-G t F I C :
SherftP` r THE PROTHO?�OTruRY
Joey s smith L4tl,,r of taebxr �b
Chiefoeptry ; 2012 MAY 22 AM 9: 09
Richard W Start CUMBERLAND COUNTY
Solic#or �usecccx e+ � PENNSYLVANIA
Wails Fargo Bank,NA
VS. Case Number
Brian G. Fagan 2012.2778
SHERIFF'S RETURN OF SERVICE
05!1112012 04:44 PM-Ryan Burgett,Deputy Sheriff,who being duly swam according to law,suss that on May 11,
2412 at 1641 hours,he served a true copy of to within Complaint in Mortgage Foreclosure, upon the
within warned do*KWM,to wit:Orion G.Fagan,by making known unto himself personally,at 705 W.
Ksiler Street,Mechanicsburg,Cuniberland County,Pennsylvania 17055 ib contents and at the same tune
handing to him personally the said true and correct copy of the same.
RYAN BURGETT,DE
SHERIFF COST:$38.00 SO ANSWERS,
May 17,2012
RONNY R ANDERSON,SHERIFF
(c)0"IyStFN POW,NNW.ire.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
vs. NO.: 12-2778-CIVIL
Brian G. Fagan
Defendant.
IMPORTANT NOTICE
TO: Brian G. Fagan
705 West Keller Street
Mechanicsburg, PA 17055-3738
DATE OF NOTICE: 6/19/2013
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 Bank, N.A. CIVIL DIVISION
Plaintiff,
vs. NO.: 12-2778-CIVIL
Brian G.Fagan
Defendant.
AVISO IMPORTANTE
TO: Brian G.Fagan
705 West Keller Street
Mechanicsburg, PA 17055-3738
FECHA DEL AVISO:6/19/2013
USTED ESTA EN REBELDL4 PORQUE HA FALLADO DE TOMAR LA ACCION
REQUEREDA 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 SUVA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE
PERDER SU PROPIEDAD Y OTROS DERECHOS Hv2ORTANTES. USTED DEBE
LLEVAR ESTE DOCUNIENTO R,11+IEDIATAh ENTE A SU ABOGADO. SI USTED NO
TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O 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: $cclt A. D letterldc
Scott A. Dietteri ck,Esquire
Attorneys for Plaintiff
PA I.D. # 55650
200 Sheffield Street, Suite 301
P.O. Box 1024
Mountainside,NJ 07092-0024
(717) 5 33-356 0
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Public nquiries/dews/CAXPY Views/pY5510D
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
•
File No. 12-2778-CIVIL
Wells Fargo Bank, N.A., Amount Due $154,014.49
Plaintiff, • Interest from 04/12/2012 to date of sale $19,835.70
vs. •
Costs `-y
Brian G. Fagan; • ;
-.
Defendant. •
• G' ---k 'v;
•
•
c) tnlm
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
PRAECIPE FOR ATTACHMENT EXECUTION
Issue Writ of Attachment to the Sheriff of Cumberland County,for debt, interest and costs, as above,
directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six
copies of the description; supply four copies of lengthy personality list):
and all other property of the defendant(s) in the possession,custody or control of the said garnishee(s).
&.)
per- 3S 6p e'6 '"
e_t•
S Ck-\‘'6
st)1 CL it `�ci t) 9 Zucker,Goldberg&Ackerman,LLC
XI-P-164687
38Ie( $� P sce1
(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: k I Signature: ie a
Print Name: Scot . terick, Esquire
Kimberly A. Bonner, Esquire
Joel A.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-164687
r v
Exhibit "A"
LEGAL DESCRIPTION
ALL THOSE CERTAIN TWO LOTS OF GROUND SITUATE ON THE SOUTH SIDE OF WEST KELLER STREET, IN
THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA,
BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
LOT NO. 1 - BEGINNING AT A POINT ON THE SOUTHERN LINE OF WEST KELLER STREET AND AT CORNER
OF LOT NO. 27 ON THE HEREINAFTER MENTIONED PLAN OF LOTS;THENCE IN A SOUTHERLY DIRECTION
ALONG THE LINE OF SAID LOT NO. 27, 200 FEET TO A POINT ON THE NORTHERN LINE OF A 12 FEET WIDE
ALLEY;THENCE IN A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF SAID ALLEY 50 FEET TO A
POINT AT CORNER OF LOT NO. 29 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE IN A
NORTHERLY DIRECTION ALONG THE LINE OF SAID LOT NO. 29, 200 FEET TO A POINT ON THE SOUTHERN
LINE OF SAID WEST KELLER STREET AFORESAID; THENCE IN AN EASTERLY DIRECTION ALONG THE SAID
LINE OF WEST KELLER STREET 50 FEET TO A POINT,AT THE PLACE OF BEGINNING.
BEING LOT NO. 28 ON A PLAN OF LOTS KNOWN AS GREEN ACRES,WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY, IN PLAN BOOK NO. 4, PAGE 4.
LOT NO. 2 - BEGINNING AT A POINT ON THE SOUTHERN LINE OF WEST KELLER STREET AND AT THE
CORNER OF LOT NO. 28 ON THE HEREINAFTER MENTIONED PLAN OF LOTS,THENCE IN A SOUTHERLY
DIRECTION ALONG THE LINE OF SAID LOT NO. 28, 200 FEET TO A POINT ON THE NORTHERN LINE OF A
12 FEET WIDE ALLEY; THENCE IN A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF SAID ALLEY 50
FEET TO A POINT AT A CORNER OF LOT NO. 30 ON THE HEREINAFTER MENTIONED PLAN OF LOTS;
THENCE IN A NORTHERLY DIRECTION ALONG THE LINE OF SAID LOT NO. 30, 200 FEET TO A POINT ON
THE SOUTHERN LINE OF WEST KELLER STREET AFORESAID;THENCE IN AN EASTERLY DIRECTION ALONG
THE SAID LINE OF WEST KELLER STREET 50 FEET TO A POINT,AT THE PLACE OF BEGINNING.
BEING LOT NO. 29 ON A PLAN OF LOTS KNOWN AS GREEN ACRES, WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY, IN PLAN BOOK NO. 4, PAGE 4.
EXCEPTING AND RESERVING THE ADVERSE CONVEYANCE IN THE CUMBERLAND COUNTY RECORDER OF
DEEDS IN DEED BOOK 2I-U, PAGE 52 AS FOLLOWS:
ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT AN IRON PIN AT CORNER OF LOT NO. 30 AND LOT NO. 29;THENCE IN AN
EASTERLY DIRECTION A DISTANCE OF ONE HUNDRED(100) FEET THROUGH LOTS
NOS. 29 AND 28 TO AN IRON PIN AND CORNER OF PART OF LOT NO. 27;THENCE IN A
SOUTHERLY DIRECTION A DISTANCE OF SEVENTY-FIVE (75) FEET ALONG THE WESTERLY
LINE OF PART OF LOT NO. 27 TO A POINT AND CORNER OF 12 FOOT ALLEY;THENCE IN A
WESTERLY DIRECTION ALONG THE NORTHERLY SIDE OF SAID 12 FOOT ALLEY A DISTANCE
OF ONE HUNDRED (100) FEET TO AN IRON PIN AT CORNER OF LOT NO. 30;THENCE IN A
NORTHERLY DIRECTION ALONG THE LINE OF SAID LOT NO. 30 A DISTANCE OF SEVENTY-FIVE
(75) FEET TO AN IRON PIN AND CORNER OF LOTS NOS. 29 AND 30 AND PLACE OF BEING
Zucker,Goldberg&Ackerman,LLC
XFP-164687
IT BEING ALL THE SOUTHERN SEVENTY-FIVE (75) FEET OF LOTS NOS. 28 AND 29 AS
SHOWN ON PLAN OF LOTS KNOWN AS GREEN ACRES WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY IN PLAN BOOK NO.4,
PAGE 4.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 705 WEST KELLER
STREET, MECHANICSBURG, PA, 17055-3738.
BEING THE SAME PREMISES WHICH DONNA J. MCCREARY, CO-TRUSTEE AND ALAN V. SHANABROOK,CO-
TRUSTEE OF THE JOHN W.SHANABROOK AND MILDRED M. SHANABROOK REVOCABLE LIVING TRUST
AGREEMENT DATED JANUARY 25, 2003, BY DEED DATED DECEMBER 30, 2008 AND RECORDED JANUARY
6, 2009 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT
NUMBER 200900354, PAGE , GRANTED AND CONVEYED UNTO BRIAN G. FAGAN.
TAX MAP NO.: 20-24-0785-007.
Zucker,Goldberg&Ackerman,LLC
XFP-164687
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-2778 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 BRIAN G.FAGAN
(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: $154,014.49 L.L.: $.50
Interest FROM 4/12/2012 TO DATE OF SALE-$19,835.70
Atty's Comm: Due Prothy: $2.25
Atty Paid: $212.75 Other Costs:
Plaintiff Paid:
Date: 2/24/14
I
. . • David D.Buell,Prothonotary
(Seal)
Deputy
REQUE STING TARTY:
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.: 12-2778-CIVIL
vs.
0--"
Execution No.: rz rn
Brian G. Fagan; : _.`
•
Defendant(s). • r"o
P-
C% Cr
•
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 705 West
Keller Street, Mechanicsburg, PA 17055-3738.
1. Name and Address of Owner(s)or Reputed Owner(s):
BRIAN G. FAGAN
705 West Keller Street
Mechanicsburg, PA 17055-3738
2. Name and Address of Defendant(s) in the Judgment:
BRIAN G. FAGAN
705 West Keller Street
Mechanicsburg, PA 17055-3738
3. Name and Address of every judgment creditor whose judgment is a record lien on the
real property to be sold:
WELLS FARGO BANK, N.A.
Plaintiff
4. Name and Address of the last record holder of every mortgage of record:
WELLS FARGO BANK, N.A.
Plaintiff
Zucker,Goldberg&Ackerman,LLC
X.FP-1.64687
DOMESTIC BANK
815 Reservoir Avenue
Cranston, RI 02910
5. Name and Address of every other person who has any record lien on the property:
CUMBERLAND COUNTY TAX CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
6. Name and Address of every other person who has any record interest in the property
and whose interest may be affected by the sale:
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
7. Name and Address of every other person of whom the Plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE.
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
UNKNOWN TENANT OR TENANTS
705 West Keller Street
Mechanicsburg, PA 17055-3738
UNKNOWN SPOUSE
705 West Keller Street
Mechanicsburg, PA 17055-3738
Zucker,Goldberg&Ackerman,LLC
XFP-164687
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
n, LA fro
Dated: BY: a1 t(
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
Attorneys for Plaintiff
XFP-164687/II
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office @zuckergoldberg.com
Zucker,Goldberg&Ackerman;LLC
XFP-164687
Exhibit"A"
LEGAL DESCRIPTION
ALL THOSE CERTAIN TWO LOTS OF GROUND SITUATE ON THE SOUTH SIDE OF WEST KELLER STREET, IN
THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA,
BOUNDED AND DESCRIBED AS FOLLOWS,TO WIT:
LOT NO. 1 -BEGINNING AT A POINT ON THE SOUTHERN LINE OF WEST KELLER STREET AND AT CORNER
OF LOT NO. 27 ON THE HEREINAFTER MENTIONED PLAN OF LOTS;THENCE IN A SOUTHERLY DIRECTION
ALONG THE LINE OF SAID LOT NO. 27, 200 FEET TO A.POINT ON THE NORTHERN LINE OF A 12 FEET WIDE
ALLEY;THENCE IN A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF SAID ALLEY 50 FEET TO A
POINT AT CORNER OF LOT NO. 29 ON THE HEREINAFTER MENTIONED PLAN OF LOTS;THENCE IN A
NORTHERLY DIRECTION ALONG THE LINE OF SAID LOT NO. 29, 200 FEET TO A POINT ON THE SOUTHERN
LINE OF SAID WEST KELLER STREET AFORESAID;THENCE IN AN EASTERLY DIRECTION ALONG THE SAID
LINE OF WEST KELLER STREET 50 FEET TO A POINT,AT THE PLACE OF BEGINNING.
BEING LOT NO. 28 ON A PLAN OF LOTS KNOWN AS GREEN ACRES,WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY, IN PLAN BOOK NO. 4, PAGE 4.
LOT NO. 2- BEGINNING AT A POINT ON THE SOUTHERN LINE OF WEST KELLER STREET AND AT THE
CORNER OF LOT NO. 28 ON THE HEREINAFTER MENTIONED PLAN OF LOTS,THENCE IN A SOUTHERLY
DIRECTION ALONG THE LINE OF SAID LOT NO. 28, 200 FEET TO A POINT ON THE NORTHERN LINE OF A
12 FEET WIDE ALLEY;THENCE IN A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF SAID ALLEY 50
FEET TO A POINT AT A CORNER OF LOT NO. 30 ON THE HEREINAFTER MENTIONED PLAN OF LOTS;
THENCE IN A NORTHERLY DIRECTION ALONG THE LINE OF SAID LOT NO. 30, 200 FEET TO A POINT ON
THE SOUTHERN LINE OF WEST KELLER STREET AFORESAID;THENCE IN AN EASTERLY DIRECTION ALONG
THE SAID LINE OF WEST KELLER STREET 50 FEET TO A POINT,AT THE PLACE OF BEGINNING.
BEING LOT NO. 29 ON A PLAN OF LOTS KNOWN AS GREEN ACRES,WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY, IN PLAN BOOK NO.4, PAGE 4.
EXCEPTING AND RESERVING THE ADVERSE CONVEYANCE IN THE CUMBERLAND COUNTY RECORDER OF
DEEDS IN DEED BOOK 2I-U, PAGE 52 AS FOLLOWS:
ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS,TO WIT:
BEGINNING AT AN IRON PIN AT CORNER OF LOT NO. 30 AND LOT NO. 29;THENCE IN AN
EASTERLY DIRECTION A DISTANCE OF ONE HUNDRED(100) FEET THROUGH LOTS
NOS. 29 AND 28 TO AN IRON PIN AND CORNER OF PART OF LOT NO. 27;THENCE IN A
SOUTHERLY DIRECTION A DISTANCE OF SEVENTY-FIVE (75) FEET ALONG THE WESTERLY
LINE OF PART OF LOT NO. 27 TO A POINT AND CORNER OF 12 FOOT ALLEY;THENCE IN A
WESTERLY DIRECTION ALONG THE NORTHERLY SIDE OF SAID 12 FOOT ALLEY A DISTANCE
OF ONE HUNDRED (100) FEET TO AN IRON PIN AT CORNER OF LOT NO. 30;THENCE IN A
NORTHERLY DIRECTION ALONG THE LINE OF SAID LOT NO. 30 A DISTANCE OF SEVENTY-FIVE
(75) FEET TO AN IRON PIN AND CORNER OF LOTS NOS. 29 AND 30 AND PLACE OF BEING
Zucker,Goldberg&Ackerman, LLC
XFP-164687
IT BEING ALL THE SOUTHERN SEVENTY-FIVE (75) FEET OF LOTS NOS. 28 AND 29 AS
SHOWN ON PLAN OF LOTS KNOWN AS GREEN ACRES WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY IN PLAN BOOK NO.4,
PAGE 4.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 705 WEST KELLER
STREET, MECHANICSBURG, PA, 17055-3738.
BEING THE SAME PREMISES WHICH DONNA J. MCCREARY, CO-TRUSTEE AND ALAN V.SHANABROOK,CO-
TRUSTEE OF THE JOHN W.SHANABROOK AND MILDRED M.SHANABROOK REVOCABLE LIVING TRUST
AGREEMENT DATED JANUARY 25, 2003, BY DEED DATED DECEMBER 30, 2008 AND RECORDED JANUARY
6, 2009 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT
NUMBER 200900354, PAGE, GRANTED AND CONVEYED UNTO BRIAN G. FAGAN.
TAX MAP NO.: 20-24-0785-007.
Zucker,Goldberg&Ackerman, LLC
XFP-164687
7
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
•
vs. NO.: 12-2778-CIVIL c a
Brian G. Fagan; •
•
Defendant. r' c�
•
7:
•
C> �
-4 C .,..
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Brian G. Fagan
705 West Keller Street
Mechanicsburg, PA 17055-3738
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 06/04/2014 at 10:00am
prevailing local time.
THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a
statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A").
The LOCATION of your property to be sold is:
705 West Keller Street, Mechanicsburg, PA, 17055-3738
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 12-2778-CIVIL
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE:
Brian G. Fagan
Zucker, Goldberg&Ackerman, LLC
XFP-164687
•
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-164687
v
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
Dated: 101, 1'' BY: • I Ai�
Scott A. D e erick, Esquire; • 1.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 1.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Attorneys for Plaintiff
XFP-164687/ll
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office @zuckergoldberg.com
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND
VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO.
Zucker, Goldberg&Ackerman, LLC
XFP-164687
i
1
Exhibit"A"
LEGAL DESCRIPTION
ALL THOSE CERTAIN TWO LOTS OF GROUND SITUATE ON THE SOUTH SIDE OF WEST KELLER STREET, IN
THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA,
BOUNDED AND DESCRIBED AS FOLLOWS,TO WIT:
LOT NO. 1 - BEGINNING AT A POINT ON THE SOUTHERN LINE OF WEST KELLER STREET AND AT CORNER
OF LOT NO. 27 ON THE HEREINAFTER MENTIONED PLAN OF LOTS;THENCE IN A SOUTHERLY DIRECTION
ALONG THE LINE OF SAID LOT NO. 27, 200 FEET TO A POINT ON THE NORTHERN LINE OF A 12 FEET WIDE
ALLEY; THENCE IN A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF SAID ALLEY 50 FEET TO A
POINT AT CORNER OF LOT NO. 29 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE IN A
NORTHERLY DIRECTION ALONG THE LINE OF SAID LOT NO. 29, 200 FEET TO A POINT ON THE SOUTHERN
LINE OF SAID WEST KELLER STREET AFORESAID; THENCE IN AN EASTERLY DIRECTION ALONG THE SAID
LINE OF WEST KELLER STREET 50 FEET TO A POINT, AT THE PLACE OF BEGINNING.
BEING LOT NO. 28 ON A PLAN OF LOTS KNOWN AS GREEN ACRES, WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY, IN PLAN BOOK NO.4, PAGE 4.
LOT NO. 2 - BEGINNING AT A POINT ON THE SOUTHERN LINE OF WEST KELLER STREET AND AT THE
CORNER OF LOT NO. 28 ON THE HEREINAFTER MENTIONED PLAN OF LOTS,THENCE IN A SOUTHERLY
DIRECTION ALONG THE LINE OF SAID LOT NO. 28, 200 FEET TO A POINT ON THE NORTHERN LINE OF A
12 FEET WIDE ALLEY; THENCE IN A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF SAID ALLEY 50
FEET TO A POINT AT A CORNER OF LOT NO. 30 ON THE HEREINAFTER MENTIONED PLAN OF LOTS;
THENCE IN A NORTHERLY DIRECTION ALONG THE LINE OF SAID LOT NO. 30, 200 FEET TO A POINT ON
THE SOUTHERN LINE OF WEST KELLER STREET AFORESAID;THENCE IN AN EASTERLY DIRECTION ALONG
THE SAID LINE OF WEST KELLER STREET 50 FEET TO A POINT, AT THE PLACE OF BEGINNING.
BEING LOT NO. 29 ON A PLAN OF LOTS KNOWN AS GREEN ACRES, WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY, IN PLAN BOOK NO. 4, PAGE 4.
EXCEPTING AND RESERVING THE ADVERSE CONVEYANCE IN THE CUMBERLAND COUNTY RECORDER OF
DEEDS IN DEED BOOK 2I-U, PAGE 52 AS FOLLOWS:
ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS,TO WIT:
BEGINNING AT AN IRON PIN AT CORNER OF LOT NO. 30 AND LOT NO. 29;THENCE IN AN
EASTERLY DIRECTION A DISTANCE OF ONE HUNDRED (100) FEET THROUGH LOTS
NOS. 29 AND 28 TO AN IRON PIN AND CORNER OF PART OF LOT NO. 27; THENCE IN A
SOUTHERLY DIRECTION A DISTANCE OF SEVENTY-FIVE (75) FEET ALONG THE WESTERLY
LINE OF PART OF LOT NO. 27 TO A POINT AND CORNER OF 12 FOOT ALLEY;THENCE IN A
WESTERLY DIRECTION ALONG THE NORTHERLY SIDE OF SAID 12 FOOT ALLEY A DISTANCE
OF ONE HUNDRED (100) FEET TO AN IRON PIN AT CORNER OF LOT NO. 30;THENCE IN A
NORTHERLY DIRECTION ALONG THE LINE OF SAID LOT NO. 30 A DISTANCE OF SEVENTY-FIVE
(75) FEET TO AN IRON PIN AND CORNER OF LOTS NOS. 29 AND 30 AND PLACE OF BEING
Zucker,Goldberg&Ackerman, LLC
XFP-164687
IT BEING ALL THE SOUTHERN SEVENTY-FIVE (75) FEET OF LOTS NOS. 28 AND 29 AS
SHOWN ON PLAN OF LOTS KNOWN AS GREEN ACRES WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY IN PLAN BOOK NO.4,
PAGE 4.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 705 WEST KELLER
STREET, MECHANICSBURG, PA, 17055-3738.
BEING THE SAME PREMISES WHICH DONNA J. MCCREARY, CO-TRUSTEE AND ALAN V. SHANABROOK, CO-
TRUSTEE OF THE JOHN W. SHANABROOK AND MILDRED M. SHANABROOK REVOCABLE LIVING TRUST
AGREEMENT DATED JANUARY 25, 2003, BY DEED DATED DECEMBER 30, 2008 AND RECORDED JANUARY
6, 2009 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT
NUMBER 200900354, PAGE , GRANTED AND CONVEYED UNTO BRIAN G. FAGAN.
TAX MAP NO.: 20-24-0785-007.
Zucker,Goldberg&Ackerman, LLC
XFP-164687
low
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. ,
vs.
Brian G. Fagan;
Plaintiff,
Defendant(s).
CIVIL DIVISION
NO.: 12 -2778 -CIVIL
: Execution No.:
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 705 West Keller Street,
Mechanicsburg, PA 17055-3738.
1. Name and Address of Owner(s) or Reputed Owner(s):
BRIAN G. FAGAN
705 West Keller Street
Mechanicsburg, PA 17055-3738
2. Name and Address of Defendant(s) in the Judgment:
BRIAN G. FAGAN
705 West Keller Street
Mechanicsburg, PA 17055-3738
3. Name and Address of every judgment creditor whose judgment is a record lien on the real
property to be sold:
WELLS FARGO BANK, N.A.
Plaintiff
4. Name and Address of the last record holder of every mortgage of record:
WELLS FARGO BANK, N.A.
Plaintiff
DOMESTIC BANK
815 Reservoir Avenue
Cranston, RI 02910
ADMIRALS BANK FKA DOMESTIC BANK, A FEDERAL SAVINGS BANK
815 Reservoir Avenue
Cranston, RI 02910
5. Name and Address of every other person who has any record lien on the property:
CUMBERLAND COUNTY TAX CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
6. Name and Address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
COMMONWEALTH OF PENNSYLVANIA
DEPARTMENT OF WELFARE
P.O. Box 2675
Harrisburg, PA 17105
7. Name and Address of every other person of whom the Plaintiff has knowledge who has any
interest in the property which may be affected by the sale:
CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE
Domestic Relations Section
13 N. Hanover Street
PO Box 320
Carlisle, PA 17013
UNKNOWN TENANT OR TENANTS
705 West Keller Street
Mechanicsburg, PA 17055-3738
UNKNOWN SPOUSE
705 West Keller Street
Mechanicsburg, PA 17055-3738
PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION
Dept. 280601
Harrisburg, PA 17128-0601
I verify that the statements made in this Amended 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:
BY:
ZUCKER, GOLDBERG &' CKERMAN, 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
Attorneys for Plaintiff
XCP-164687/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 THOSE CERTAIN TWO LOTS OF GROUND SITUATE ON THE SOUTH SIDE OF WEST KELLER STREET, IN THE
BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BOUNDED
AND DESCRIBED AS FOLLOWS, TO WIT:
LOT NO. 1- BEGINNING AT A POINT ON THE SOUTHERN LINE OF WEST KELLER STREET AND AT CORNER OF LOT
NO. 27 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE IN A SOUTHERLY DIRECTION ALONG THE
LINE OF SAID LOT NO. 27, 200 FEET TO A POINT ON THE NORTHERN LINE OF A 12 FEET WIDE ALLEY; THENCE IN
A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF SAID ALLEY 50 FEET TO A POINT AT CORNER OF LOT
NO. 29 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE IN A NORTHERLY DIRECTION ALONG THE
LINE OF SAID LOT NO. 29, 200 FEET TO A POINT ON THE SOUTHERN LINE OF SAID WEST KELLER STREET
AFORESAID; THENCE IN AN EASTERLY DIRECTION ALONG THE SAID LINE OF WEST KELLER STREET 50 FEET TO A
POINT, AT THE PLACE OF BEGINNING.
BEING LOT NO. 28 ON A PLAN OF LOTS KNOWN AS GREEN ACRES, WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY, IN PLAN BOOK NO. 4, PAGE 4.
LOT NO. 2 - BEGINNING AT A POINT ON THE SOUTHERN LINE OF WEST KELLER STREET AND AT THE CORNER OF
LOT NO. 28 ON THE HEREINAFTER MENTIONED PLAN OF LOTS, THENCE IN A SOUTHERLY DIRECTION ALONG
THE LINE OF SAID LOT NO. 28, 200 FEET TO A POINT ON THE NORTHERN LINE OF A 12 FEET WIDE ALLEY;
THENCE IN A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF SAID ALLEY 50 FEET TO A POINT AT A
CORNER OF LOT NO. 30 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE IN A NORTHERLY
DIRECTION ALONG THE LINE OF SAID LOT NO. 30, 200 FEET TO A POINT ON THE SOUTHERN LINE OF WEST
KELLER STREET AFORESAID; THENCE IN AN EASTERLY DIRECTION ALONG THE SAID LINE OF WEST KELLER
STREET 50 FEET TO A POINT, AT THE PLACE OF BEGINNING.
BEING LOT NO. 29 ON A PLAN OF LOTS KNOWN AS GREEN ACRES, WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY, IN PLAN BOOK NO. 4, PAGE 4.
EXCEPTING AND RESERVING THE ADVERSE CONVEYANCE IN THE CUMBERLAND COUNTY RECORDER OF
DEEDS IN DEED BOOK 2I -U, PAGE 52 AS FOLLOWS:
ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE BOROUGH OF MECHANICSBURG, CUMBERLAND
COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT AN IRON PIN AT CORNER OF LOT NO. 30 AND LOT NO. 29; THENCE IN AN EASTERLY
DIRECTION A DISTANCE OF ONE HUNDRED (100) FEET THROUGH LOTS
NOS. 29 AND 28 TO AN IRON PIN AND CORNER OF PART OF LOT NO. 27; THENCE IN A
SOUTHERLY DIRECTION A DISTANCE OF SEVENTY-FIVE (75) FEET ALONG THE WESTERLY
LINE OF PART OF LOT NO. 27 TO A POINT AND CORNER OF 12 FOOT ALLEY; THENCE IN A
WESTERLY DIRECTION ALONG THE NORTHERLY SIDE OF SAID 12 FOOT ALLEY A DISTANCE
OF ONE HUNDRED (100) FEET TO AN IRON PIN AT CORNER OF LOT NO. 30; THENCE IN A NORTHERLY
DIRECTION ALONG THE LINE OF SAID LOT NO. 30 A DISTANCE OF SEVENTY-FIVE
(75) FEET TO AN IRON PIN AND CORNER OF LOTS NOS. 29 AND 30 AND PLACE OF BEING
IT BEING ALL THE SOUTHERN SEVENTY-FIVE (75) FEET OF LOTS NOS. 28 AND 29 AS
SHOWN ON PLAN OF LOTS KNOWN AS GREEN ACRES WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY IN PLAN BOOK NO.4,
PAGE4.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 705 WEST KELLER
STREET, MECHANICSBURG, PA, 17055-3738.
BEING THE SAME PREMISES WHICH DONNA J. MCCREARY, CO -TRUSTEE AND ALAN V. SHANABROOK, CO -
TRUSTEE OF THE JOHN W. SHANABROOK AND MILDRED M. SHANABROOK REVOCABLE LIVING TRUST
AGREEMENT DATED JANUARY 25, 2003, BY DEED DATED DECEMBER 30, 2008 AND RECORDED JANUARY 6,
2009 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT NUMBER
200900354, PAGE , GRANTED AND CONVEYED UNTO BRIAN G. FAGAN.
TAX MAP NO.: 20-24-0785-007.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A., t
CIVIL DIVISION `�'
c<1. crk rµ `moi
Plaintiff, NO.: 12 -2778 -CIVIL, %P
VS. cl �� ' 4� �-
en
Brian G. Fagan; TYPE OF PLEADING %�G:
--
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.
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- 164687/mag
Zucker, Goldberg & Ackerman, LLC
XFP-164687
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Brian G. Fagan;
Plaintiff,
Defendant.
CIVIL DIVISION
NO.: 12 -2778 -CIVIL
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 Plaintiffs Notice of Sheriff's Sale of Real Property in this matter on
Defendant/Owner and Other Parties of Interest as follows:
1. Defendant, Brian G. Fagan, is the record owner of the real property.
2. On or about March 17, 2014, defendant Brian G. Fagan was served with Plaintiffs Notice
of Sheriff's Sale of Real Property Pursuant to Pa. R.C.P. 3129, via certified mail, return receipt requested
at the address of the mortgaged premises, being 705 West Keller Street, Mechanicsburg PA 17055-
3738. A true and correct copy of said Notice and Return of Service are marked Exhibit "A", attached
hereto and made a part hereof.
3. On or about May 5, 2014, Plaintiff's counsel served all other parties in interest with
Plaintiffs Notice of Sheriff's Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class
U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing. True and correct copies of said Certificates of
Mailing are marked Exhibit "B", attached hereto and made a part hereof.
Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of
Zucker, Goldberg & Ackerman, LLC
XFP-164687
Interest were served with Plaintiff's Notice of Sheriffs Sale of Real Property in accordance with Pa.R.C.P.
3129.2.
Dated: May cZ3 , 2014
Sworn to and subscribed before
me this 2..b
day of May, 2014
Notary ublic
MY COMMISSION EXPIRES:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Attorneys for Plaintiff
MARGAR £ GYEPONG
Paralegal/Legal Assistant
PAUL C. NADRAT0WSK1
Notary Public
of New Jersey
850
My Commission Expires 4/27/2016
/27
Zucker, Goldberg & Ackerman, LLC
XFP-164687
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
XFP-164687
Zucker, Goldberg & Ackerman, LLC
PO Box 1219
Mountainside, NJ 07092-1219
11
i
i
i
i
i
i
i
11
i
7196 9006 9297 2962 3586
20140313-102
iI.11141J„1111k111111111Iuiu "111JhIIII11II'II'I'I11IIIIIH
Brian G. Fagan
705 W KELLER ST
MECHANICSBURG, PA 17055-3738
PANOSS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Brian G. Fagan;
Plaintiff,
Defendant,
CIVIL DIVISION
NO.: 12 -2778 -CIVIL
NOTICE OF SHERIFF'S SALE
OF REAL PROPERTY PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
Brian G. Fagan
705 West Keller Street
Mechanicsburg, PA 17055-3738
TAKE NOTICE:
That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland
County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 06/04/2014 at 10:OOam
prevailing local time.
THE PROPERTY TO BE SOLD is delineated In detail in a legal description consisting of a
statement of the measured boundaries of the property, together with a brief mention of the
buildings and any other major improvements erected on the land.
(SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")..
The LOCATION of your property to be sold is:
705 West Keller Street, Mechanicsburg, PA, 17055-3738
The JUDGMENT under or pursuant to which your property is being sold is docketed to:
No. 12 -2778 -CIVIL
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE:
Brian G. Fagan
Zucker, Goldberg & Ackerman, LLC
XFP-164687
rili
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 TIIS..P,APER 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-164687
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:. 19 I
ZUCKER, GOLDBERG & ACKERMAN, LLC
.
BY:
Scott A..eater ck,Equ
Esquire; P I.D. #55650
Kimberly A. Bonner, Esquire; PAID, #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-164687/1I
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND
VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO.
Zucker, Goldberg & Ackerman, LLC
XFP-164687
Exhibit "A"
LEGAL DESCRIPTION
ALL THOSE CERTAIN TWO LOTS OF GROUND SITUATE ON THE SOUTH SIDE OF WEST KELLER STREET, IN
THE BOROUGH OF MECHANICSBURG, IN THE COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA,
BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
LOT; NO. 1 - BEGINNING AT A POINT ON THE SOUTHERN LINE OF WEST KELLER STREET AND AT CORNER
OF LOT NO. 27 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE IN A SOUTHERLY DIRECTION
ALONG THE LINE OF SAID LOT NO. 27, 200 FEET TO A:POINT ON THE NORTHERN LINE OF A 12 FEET WIDE
ALLEY; THENCE IN A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF SAID ALLEY 50 FEET TO A
POINT AT CORNER OF LOT NO. 29 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE IN A
NORTHERLY DIRECTION ALONGTHE LINE OF SAID LOT NO. 29, 200 FEET TO A POINT ON THE SOUTHERN
UNE OF SAID WEST KELLER STREET AFORESAID; THENCE IN AN EASTERLY DIRECTION ALONG THE SAID
LINE OF WEST KELLER STREET 50 FEET TO A POINT, AT THE PLACE OF BEGINNING.
BEING LOT NO. 28 ON A PLAN OF LOTS KNOWN AS GREEN ACRES, WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY, IN PLAN BOOK NO. 4, PAGE 4.
LOT NO. .2.- BEGINNING AT A PAINT ON THE SOUTHERN LINE OF WEST KELLER STREET AND AT THE
CORNER OF LOT'NO. 28 ON THE HEREINAFTER MENTIONED PLAN OF LOTS, THENCE IN A SOUTHERLY
DIRECTION ALONG THE LINE OF SAID LOT NO. 28, 200 FEET TO A POINT ON THE NORTHERN LINE OF A
12 FEET WIDE ALLEY; THENCE IN A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF SAID ALLEY 50
FEET TO A POINT AT A CORNER OF LOT NO. 30 ON THE HEREINAFTER MENTIONED PLAN OF LOTS;
THENCE IN A NORTHERLY DIRECTION ALONG THE UNE OF SAID LOT NO. 30, 200 FEET TO A POINT ON
THE SOUTHERN LINE OF WEST KELLER STREET AFORESAID; THENCE IN AN EASTERLY DIRECTION ALONG
THE SAID LINE OF WEST KELLER STREET 50 FEET TO A POINT, AT THE PLACE OF BEGINNING.
BEING LOT NO. 29 ON A PLAN OF LOTS KNOWN AS GREEN ACRES, WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY, IN PLAN BOOK NO. 4, PAGE 4.
EXCEPTING AND RESERVING THE ADVERSE CONVEYANCE IN THE CUMBERLAND COUNTY RECORDER OF
DEEDS IN DEED BOOK 21-U, PAGE 52 AS FOLLOWS:
ALL THAT CERTAIN LOT OF GROUND SITUATE IN THE BOROUGH OF MECHANICSBURG,
CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AND DESCRIBED AS FOLLOWS, TO WIT:
BEGINNING AT AN IRON PIN AT CORNER OF LOT NO. 30 AND LOT NO. 29; THENCE IN AN
EASTERLY DIRECTION A DISTANCE OF ONE HUNDRED (100) FEET THROUGH LOTS
NOS. 29 AND 28 TO AN IRON PIN AND CORNER OF PART OF LOT NO. 27; THENCE IN A
SOUTHERLY DIRECTION A DISTANCE OF SEVENTY-FIVE (75) FEET ALONG THE WESTERLY
LINE OF PART OF LOT NO. 27 TO A POINT AND CORNER OF 12 FOOT ALLEY; THENCE IN A
WESTERLY DIRECTION ALONG THE NORTHERLY SIDE OF SAID 12 FOOT ALLEY A DISTANCE
OF ONE HUNDRED (100) FEET TO AN IRON PIN AT CORNER OF LOT NO. 30; THENCE IN A
NORTHERLY DIRECTION ALONG THE LINE OF SAID LOT NO. 30 A DISTANCE OF SEVENTY-FIVE
(75) FEET TO AN IRON PIN AND CORNER OF LOTS NOS. 29 AND 30 AND PLACE OF BEING
Zucker, Goldberg & Ackerman, LLC
XFP-164687
IT BEING ALL THE SOUTHERN SEVENTY-FIVE (75) FEET OF LOTS NOS. 28 AND 29 AS
SHOWN ON PLAN OF LOTS KNOWN AS GREEN ACRES WHICH PLAN IS RECORDED IN THE
RECORDER'S OFFICE IN AND FOR SAID CUMBERLAND COUNTY IN PLAN BOOK NO.4,
PAGE 4.
HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 705 WEST KELLER
STREET, MECHANICSBURG, PA, 17055-3738.
BEING THE SAME PREMISES WHICH DONNA J. MCCREARY, CO -TRUSTEE AND ALAN V. SHANABROOK, CO -
TRUSTEE OF THE JOHN W. SHANABROOK AND MILDRED M. SHANABROOK REVOCABLE LIVING TRUST
AGREEMENT DATED JANUARY 25, 2003, BY DEED DATED DECEMBER 30, 2008 AND RECORDED JANUARY
6, 2009 1N AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME INSTRUMENT
NUMBER 200900354, PAGE , GRANTED AND CONVEYED UNTO BRIAN G. FAGAN.
TAX MAP NO.: 20-24-0785-007.
Zucker, Goldberg & Ackerman, LLC
XFP-164687
r.
2. Article Number
11
1
1
1
1
11
1
1
1
1
1
i
11
11
1
1
1
7196 9006 9297 2%2 3586
F:j1
Zo 3. Service ee Type CERTIFIED MAIL
N 4. Restricted Delivery? (Extra Fee)
3
N
O.
u)
•O
fYes
1.
Article Addressed to:
COMPLETE THIS SECTION ON DELIVERY
A. Rec ived by (Please Print Clearly)
8. Date of Delivery
./
C. Signature
Agent
Addressee
D. Is delivery ad,greadif event from item 1?
If YES, enter delivery address below:
Yes
I No
-Brian G. Fagan
705 W KELLER ST
MECHANICSBURG, PA 17055-3738
PS�Fo m 3811, January 2005
Reference Information
164687
PANOSS
Domestic etum eceipt
3/13/2014
7196 9006 9297 2462 3586-102
UNITED STATES POSTAL SERVICE
First -Class Mail
Postage & Fees Paid
USPS
Permit No. G-10
Zucker, Goldberg & Ackerman, LLC
PO Box 9076
Temecula, CA 92589-9076
EXHIBIT B
Zucker, Goldberg & Ackerman, LLC
XFP-164687
NTL Page 1 of 4
mr---""1111 UNITED STATES
EU POSTAL SERVICE®
Certificate 0
Mailing
This Certificate of Mailing provides evidence that melt has been presented to USPS, for milling. 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, Ni 07092
To' CUMBERLAND COUNTY TAX CLAIM BUREAU
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
XFP-164687/nfe TEAM- C
U.S. POSTAGE* PITNEY BOVIE3
4 e„, lialzamp
inr
ZIP 07092 $ 001.200
000201187430 MAY. 05 2014
To ply fee, MK stamps or meter postage
hem
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES
POSTAL SERVICEe
Certificate Of
Mailing
This Certificate of Mailing provided evidence INA mill Ms been presented to USPS. for melting. This form may be toed for d erne stk
end internetional man.
Fri'm' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-164687/n e TEAM C
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
410Z SO 'AVM 0E012E1000
00Z. 100 $ Z 6 OLO dIZ
LO
411/1/1/IMINNIMMIft
:04.111111Cir.
MIOB A3,tk << 39VISOci "s'n
To pay fee, affbt stumps or meter postage
hue.
Postmark Here
NTL Page 2 of 4
UNITED STATES
POSTAL SERVICE
Certificate 0
Mailing
This Certificate of Mailing provides evidence that mall has been presented to MPS* for mailing. This form may be used for domestic
and intematianel mail.
P'°m: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-164687/nfe TEAM- C
UNKNOWN TENANT OR TENANTS
U.S. POSTAGE *PITNEY Bowes
ZIP 0.7092 $ 001.20°
02 111
0001387430MAY 05 2014
To pry fee, affil Namur or niter portage
hare.
Postmark Here
705 West Keller Street
Mechanicsburg, PA 17055-3738
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
�UNITED STATES
POSTdL SERVICEE11
Certificate Of
Mailing
This C.rHicataofMr [Nag provides evidence that moil hes been presented toUSPS. for mailing This form may Ism wad for domeatk
and international mall.
`'°m' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-164687/nfe TEAM- C
Toi DOMESTIC BANK
815 Reservoir Avenue
Cranston, RI 02910
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
t+102 SO AVWOc'L'8E1000
Mt ZO
09Z.1•00 4604 0 t1
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NTL Page 3 of 4
UNITED STATES
Mill POSTAL SERV!CE®
Certificate
Mailing
This Certificate of Mulling provides evidence that mall Ns been presented to USPS• for mulling. This form may be owed for domestic
and International mall.
rrom: Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, Ni 07092
XFP-164687/nfe TEAM- C
U.S. POSTAGE )) prrr Y aowES
�...az/0==z.
ZIP 009 7 0
02 1,1, $ 001.20
00013874.30 MAY 05 2014
To payfa, of b, stamps or m.tar postage
hen.
T°' ADMIRALS BANK EKA.DflMEST.C.BAAI
IC -A F�1=RAS-SAVINGS-BtINIF--eosm,ar.u°
815 Reservoir Avenue
Cranston, RI 02910
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES
POST/JL SERVICE
Certificate Of
Mailing
This Certificate of Maglns provides evidence that mall has been presented to USPS, formarl- This
end International mall.
Ffam' Scott A. Dietterick, Esquire
rm may be used for domestic
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-164687/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
PIOZ SO AWYO£pL9£1000
00Z100 $ Z6OLO dIZ
S3N108 mud «30V1SOd's71
To pay fee, aft rumps or meter postage
hen.
NTL Page 4 of 4
UNITED STATES
POSTAL SERVICE®
"M.
Certificate 0
Mailing
U.S. POSTAGE>> PITNEY BOWES
411111111e
This Certificate of Melling provides evidence that mill has been presented to U5P56 for maPine. This form may be used for domestic
and Intemationel mall.
Frm' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
XFP-164687/nfe TEAM- C
To' PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION
Dept. 280601
Harrisburg, PA 17128-0601
County of P.Q.: CUMBERLAND
PS Form 3817, April 2007 PSN 7530-02-000-9065
UNITED STATES
POSTAL SERVICE®
Certificate Of
Mailing
This certIfIcatir of milling provides evidence that mall his been presented to USW for malilna. This form may be word for domestic
and International min,
Fr"' Scott A. Dietterick, Esquire
c/o Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Suite 101
Mountainside, Ni 07092
XFP-1646 7/nfe TEAM- C
To: UNKNOWN SPOUSE
705 West Keller Street
Mechanicsburg, PA 17055-3738
County of P.Q.: CUMBERLAND
P5 Form 3817, April 2007 PSN 7530-02-000-9065
PIN,' 90 AVVIOCP/13£1 0 0
Z6 0./. 0 dIZ
MI at
OZ. 1000 $
ASnameal.
reamerarigrougmee
ZIP 0709200120°
02 1Y1
00013874 30 MAY 05. 20 14
To pay fee, One stamps or meter pestle,
here,
Postma
ere
To pay fel, ate stamps or meter ports",
here.
Postmark tiere, •••
, •
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
OFF;',:''
Ft:
OF THE PROs HONu
20111 JUL 25 PM 2:
CUMBERLAND COUNTY
PENNSYLVANIA
�o�ov of ,Cifir,br��4:,ryd
OFFICE OF NE SHERIFF
Wells Fargo Bank, NA
vs. Case Number
Brian G. Fagan 2012-2778
SHERIFF'S RETURN OF SERVICE
03/24/2014 04:13 PM - Deputy Ryan Burgett, 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 705 West Keller Street, Mechanicsburg - Borough,
Mechanicsburg, PA 17055, Cumberland County.
03/24/2014 04:13 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit:
Brian G. Fagan at 705 W. Keller Street, Mechanicsburg Borough, Mechanicsburg, PA 17055,
Cumberland County.
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 Sqaure, Carlisle, PA 17013 on June 04, 2014 at 10:00
a.m. He sold the same for the sum of $108,000.00 to Barclay W. Fitzpatrick, 125 N. 30th Street, Camp
Hill, PA 17011, being the buyer in this execution, paid to the Sheriff the sum of $
07/16/2014 Distribution of Schedule as Proposed
SHERIFF COST: $4,794.58 SO ANSWERS,
July 16, 2014 RONR ANDERSON, SHERIFF
1.cl CaunlySude Sheriff, Teleosatt, Inc.
4/g° 06 pd - ac4.
amp -0.
S? c- ,0d.
4-4 97272
369.0S1
On February 27, 2014 the Sheriff levied upon the
defendant's interest in the real property situated in
Mechanicsburg Borough, Cumberland County, PA,
Known and numbered as 705 West Keller Street,
Mechanicsburg, as Exhibit "A" filed with this writ
n.
N
.•=•
6-; and by this Reference incorporated herein.
Q
Date: February 27, 2014
(,Li5:(
EJ
L ( r L..
1,.., C7, ..?
(; .r" O
ti
(S
By:
Real Estate Coordinator
LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14
Writ No. 2012-2778 Civil Term
Wells Fargo Bank, N.A.
vs.
Brian G. Fagan
Atty.: Jaime R. Ackerman
ALL THOSE CERTAIN two lots of
ground situate on the south side of
West Keller Street, in the Borough
of Mechanicsburg, in the County of
Cumberland and State of Pennsyl-
vania, bounded and described as
follows, to wit:
LOT NO. 1- BEGINNING at a point
on the southern line of West Keller
Street and at corner of Lot No. 27 on
the hereinafter mentioned Plan of
Lots; thence in a southerly direction
along the line of said Lot No. 27, 2do
feet to a point on the northern line
of a 12 feet wide alley; thence in a
westerly direction along the northern
line of said alley so feet to a point at
corner of Lot No. 29 on the hereinaf-
ter mentioned Plan of Lots; thence in
a northerly direction alongthe line of
said Lot No. 29, 200 feet to a point on
the southern line of said West Keller
Street aforesaid; thence in an easterly
direction along the said line of West
Keller Street 50 feet to a point, at the
place of BEGINNING.
BEING Lot No. 28 on a Plan of Lots
known as Green Acres, which plan is
recorded in the Recorder's Office in
and for said Cumberland .County, in
Plan Book No.4, Page 4.
LOT N0.2 - BEGINNING at a point
on the southern line of West Keller
Street and at the corner of Lot No. 28
on the hereinafter mentioned Plan of
Lots, thence in a southerly direction
along the line of said Lot No. 28, 200
feet to a point on the northern line
of a 12 feet wide alley; thence in a
westerly direction along the northern
line of said alley 50 feet to a point at
a corner of Lot No. 30 on the herein-
after mentioned Plan of Lots; thence
in a northerly direction along the line
51
of said Lot No. 30, 200 feet to a point
on the southern line of West Keller
Street aforesaid; thence in an easterly
direction along the said line of West
Keller Street 50 feetto a point, at the
place of BEGINNING.
BEING Lot No. 29 on a plan of lots
known as Green Acres, which plan is
recorded in the Recorder's Office in
and for said Cumberland County, in
Plan Book No.4, Page 4.
EXCEPTING AND RESERVING
the adverse conveyance in the Cum-
berland County Recorder of Deeds in
Deed Book 21-U, Page 52 as follows:
ALL THAT CERTAIN lot of ground
situate in the Borough of Mechanics-
burg, Cumberland County, Penn-
sylvania, bounded and described as
follows, to wit:
BEGINNING at an iron pin at
corner of Lot No. 30 and Lot No. 29;
thence in an easterly direction a
distance of one hundred (100) feet
through Lots Nos. 29 and 28 to an
iron pin and corner of part of Lot No.
27; thence in a southerly direction a
distance of seventy-five (75) feet along
the westerly line of part of Lot No. 27
to a point and corner of 12 foot alley;
thence in a westerly direction along
the northerly side of said 12 foot alley
a distance of one hundred (100) feet
to an iron pin at corner of lot no. 30;
thence in a northerly direction along
the line of said Lot No. 30 a distance
of seventy-five it being all the south-
ern seventy-five (75) feet of Lots Nos.
28 and 29 as shown on Plan of Lots
known as Green Acres which plan
is recorded in the Recorder's Office
in and for said Cumberland County
in Plan Book No.4, Page 4. Having
thereon erected a dwelling house
being known and numbered as 70s
West Keller Street, Mechanicsburg,
PA, 17055-3738.
BEING THE SAME PREMISES
which Donna J. McCreary, Co -
Trustee and Alan V. Shanabrook, Co -
Trustee of the John W. Shanabrook
LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14
and Mildred M. Shanabrook Revo-
cable Living Trust Agreement dated
January 25, 2003, by deed dated
December 30, 2008 and recorded
January 6,2009 in and for Cumber-
land County, Pennsylvania, in Deed
Book Volume Instrument Number
200900354, Page, granted and con-
veyed unto Brian G. Fagan.
TAX MAP NO.: 20-24-0785-007.
52
.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.
isa Marie Coyne, ditor
SWORN TO AND SUBSCRIBED before me this
2 day of May, 2014
Notary
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO.. CUMBERLAND CNTY
My Commission Expires Apr 28, 2018
The Patriot -News Co.
2020 Tetrhnology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
be 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
C_ o_ m_ pany_is_interested..th_p.subject matter of said printed notice or advertising, and that all of the allegations of this statement as
•2012-2778 Civil Term :er of publication are true; and
Wells Fargo Bank, NA 11 knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
Vs ). aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
Brian G. Fagan ?ctors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
Atty: Jaime R Ackerman Dhin in Miscellaneous Book "M", Volume 14, Page 317.
ALL THOSE CERTAIN TWO LOT:
OF GROUND SITUATE ON THI
SOUTH SIDE OF WEST KELLEF
STREET, IN THE BOROUGF
OF MECHANICSBURG, IN THI
COUNTY. OF CUMBERLANI
AND STATE OF PENNSYLVANIA
BOUNDED AND DESCRIBED Al
FOLLOWS, TO WIT:
LOT NO. 1- BEGINNING AT 1
POINT ON THE SOUTHER!
LINE OF WEST KELLER STREE
AND AT CORNER OF LOT NC
27 ON THE HEREINAFTE
MENTIONED PLAN OF LOT
THENCE IN A SOUTHERL
DIRECTION ALONG TH
UNE OF SAID LOT NO. 27, 2D,
FEET TO A POINT ON TH
NORTHERN LINE OFA 12 FEE
WIDE ALLEY; THENCE IN
WESTERLY DIRECTION ALON
THE NORTHERN LINE OF SAI
ALLEY SO FEET TO A POINT A
CORNER OF LOT NO. 29 ON TH
HEREINAFTER MENTIONE
PLAN OF LOTS; THENCE 1
A NORTHE LY DIRECTIO
ALONG TIT OF SAID LC
_wTn_ 1R. ,
This ad ran on the date(s) shown below:
04/13/14
04/20/14
04/27/14
Sworn to • n• subscribed before me
s,A2,day of May, 2
14 A.D.
ublic
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Holly Lynn Warfel, Notary Public
Washington ngton TWP , Dauphin Coun
ty
My Commission Expires Dec. 12, 2016
MEMBER. PENNSYLVANIA ASSOCIATION 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 Barclay Fitzpatrick & Mary Jane Casavant 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 24th day of February, A.D., 2014, out of the Court of Common Pleas of said County as of Civil
Term, 2012 Number 2778, at the suit of Wells Fargo Bank, NA against Brian G. Fagan is duly recorded
as Instrument Number 201416261.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this
as
day of
L J .t477, De
Recorder of eeds
Recorder of Deeds, Cumberland County, Cad sie, P*
My Commission. Expires the First Monday of Jan.2018