The URL can be used to link to this page

Home My WebLink About12-2943I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., Plaintiff, VS. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; Defendants. TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. CIVIL DIVISION 1 a? ?I3 VO NO . TYPE OF PLEADING CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE `" -- t " FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3476 Stateview Blvd., MAC # X7801-013, Ft. Mill, SC 29715 AND THE DEFENDANT: 33 Heidi Terrace Camp Hill, PA 17011-1141 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 33 Heidi Terrace, Camp Hill PA 17011-1141 Munici alit : East Pennsboro ATTORNE R LAN F ATTY FILE NO.: XFP 165557 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 OzuckerRold berg.com File No.: XFP-165557/pl ar?? ??°`??s? aNLI `3SS7S q%9-7soa? Zucker, Goldberg & Ackerman, LLC XFP-165557 w IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Zucker, Goldberg & Ackerman, LLC XFP-165557 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; Defendant(s). NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-165557 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; Defendant(s). AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demands 0 cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Listed puede perder dinero o propiedades u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR LINO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-165557 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; Defendant(s). CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff") having its principal place of business at 3476 Stateview Blvd., MAC # X7801-013, Ft. Mill, SC 29715. 2. Defendant, Tammy M. Geraci, deceased, died on October 31, 2011, and had a last known address of 33 Heidi Terrace, Camp Hill, PA 17011-1141. 3. Defendant, Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci, is an individual whose last known address is 1204 Capital Street, Harrisburg, PA 17102-2050. 4. On or about October 3, 2008, Tammy M. Geraci executed a Note in favor of American Mortgage Network, Inc., dba Amnet Mortgage in the original principal amount of $113,501.00. 5. On or about October 3, 2008, as security for payment of the aforesaid Note, Tammy M. Geraci made, executed and delivered to Mortgage Electronic Registration Systems, Inc., as nominee for American Mortgage Network, Inc., dba Amnet Mortgage a Mortgage in the original principal amount of $113,501.00 on the premises hereinafter described, with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on October 15, 2008, Instrument #200833988. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof. 6. The Mortgage was assigned by Mortgage Electronic Registration Systems, Inc., as nominee for American Mortgage Network, incorporated, doing business as Amnet Mortgage to Wells Fargo Bank, NA, pursuant to an assignment of mortgage dated February 14, 2012 and recorded on February 22, 2012 in the Office of the Recorder of Deeds for Cumberland County, Instrument #201205194. Zucker, Goldberg & Ackerman, LLC XFP-165557 7. - 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. 8. Defendant, Tammy M. Geraci ( a single woman), the record owner of the aforesaid mortgaged premises died on October 31, 2011, with defendant Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci, succeeding to her interest as believed heir and Administrator of her Estate. 9. Defendant, Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci, is hereby released from any and all personal liability under the Note pursuant to Pa. R.C.P. 1144(b). 10. On December 16, 2011, Defendant(s) were mailed a Notice of Intention to Foreclose Mortgage, in compliance with Act 6 of 1974, 41 P.S. §101, et seq. 11. The amount due and owing Plaintiff by Defendant(s) is as follows: Principal $109,190.78 interest through 04/23/2012 $3,670.58 Escrow Advance $496.01 Late Charges $210.54 Inspection Fees $45.00 Total $113,612.91 plus interest on the principal sum ($109,190.78) at the daily per diem amount of $17.95 , and all other additional amounts authorized under the Mortgage, actually and reasonably incurred by Plaintiff, including but not limited to, late charges, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums to the above amount due and owning when incurred. 12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability under the aforesaid Note in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. Zucker, Goldberg & Ackerman, LLC XFP-165557 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $113,612.91, with interest thereon at daily per diem amount of $17.95 plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GOLDBERG1& ACKERMAN, LLC BY: Dated: Scott A. ?Di-e+t-t?eir' ick, X l' l? I? 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. #31.1032 Attorneys for Plaintiff XFP-165557/pl 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, ARID ANY INFORMATION 08TAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP-165557 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-165557 mill Prepared By: RHONDA COPE Return To: WACHOVIA MORTGAGE CORPORATION NC-4723 ATTN: POST CLOSING 1100 CORPORATE CENTER DRIVE RALEIGH, NC 27607 Parcel Number: 09-17-1042-166 Premises: [Space Above This Line For Recording Data} Commonwealth of Pennsylvania MORTGAGE MIN THIS M RTGAGE ("Security Instrument") is given on OCTOBER 03, 2006 The mortgagor s TAMMY M ("Borrower"). This Security Instrument is given to Mortgage Electronic Registration Systems, Inc. ("MERS"), (solely as nominee for Lender, as hereinafter defined, and Lender's successors and assigns), as mortgagee. MERS is organized and existing under the laws of Delaware, and has an address and telephone number of P.O. Box 2026, Flint, MI 48501-2026, tel. (888) 679-MERS. AMERICAN MORTGAGE NETWORK, INC., DBA AMNET MORTGAGE ("Lender") is organized and existing under the laws of THE STATE OF DELAWARE > and has an address of P. O. BOX 85463, SAN DIEGO, CA 92186 FHA Pennsylvania Mortgage with MERS - 4/96 Wolters Kluwer Financial Services II„1, ???I VMP ®•4NIPA} t0708?.01 Amended 6102 Pepe I of 10 V1YI6 512PA Borrower owes Lender the principal sum of ONE HUNDRED THIRTEEN THOUSAND FIVE HUNDRED ONE AND 00/100 Dollars (U.S. S 113,501.00 ). This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on NOVEMBER 01, 2038 . This Security Instrument secures to bender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to MERS (solely as nominee for Lender and Lender's successors and assigns) and to the successors and assigns of MERS, the following described property located in CUMBERLAND County, Pennsylvania: SEE ATTACHED LEGAL DESCRIPTION "EXHIBIT A" PARCEL ID NUMBER: 09-17-1042-166 which has the address of 33 HEIDI TER [mil CAMP HILL [city], Pennsylvania 17011 [Zip Code] ("Property Address"); TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security Instrument as the "Property." Borrower understands and agrees that MERS holds only legal title to the interests granted by Borrower in this Security Instrument; but, if necessary to comply with law or custom, MERS, (as nominee for Lender and Lender's successors and assigns), has the right: to exercise any or all of those interests, including, but not limited to, the right to foreclose and sell the Property; and to take any action required of Lender including, but not limited to, releasing or canceling this Security Instrument. BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is .unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by jurisdiction to constitute a uniform security instrument covering real property. OMC VMP 0-4NIPA) lwoe).oi P." 2 ?( 10 Borrower and Lender covenant and agree as follows: UNIFORM COVENANTS. 1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and ::pecial assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year in which the Lender must pay a mortgage insurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year in which such premium would have been required if Lender still held the Security Instrument, each monthly payment shall also include either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds." Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 et seq. and implementing regulations, 24 CFR Part 3500, as they may be amended from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA, Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by Lender at any time are not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by RESPA. The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments. All payments under paragraphs 1 and 2 shall be applied by Lender as follows: First, to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; Second to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Third. to interest due under the Note; Fourth. to amortization of the principal of the Note; and EjftjL to late charges due under the Note. 4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements on the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in t9M & VMP 8AN(PA) r0708).01 Pp" 3 or 10 the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower shall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such loss directly to Lender, instead of to Borrower and to Lender jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. In the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. 5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security instrument (or within sixty days of a later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instmment, first to any delinquent amounts applied in the order provided in paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. 0+"G VMP ®-4NIPAl (0708(.01 Pp 4 of 10 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. U Borrower fails to make these payments or the payments required by paragraph 2, or fails to perform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condenination or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property and Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in paragraph 2. Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear interest from the date of disbursement, at the Note rate, and at the option of Lender, shall be immediately due and payable. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender, (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8. Fees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations issued by the Secretary, in the case of payment defaults, require immediate payment in full of all sums secured by this Security Instrument if (i) Borrower defaults by failing to pay in full any monthly payment required by this Security instrument prior to or on the due date of the next monthly payment, or (ii) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shall, if permitted by applicable law (including Section 341(d) of the Garn-St. Germain Depository Institutions Act of 1982, 12 U.S.C. 1701 1j-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all sums secured by this Security Instrument if- (i) All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grantee does so occupy the Property but his or her credit has not been approved in accordance with the requirements of the Secretary. (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. L9M G VMP ®-4N(PA) tmoel.o1 pa" 5 of 10 (d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary will limit Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including, to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall remain in effect as if Lender had not required immediate payment in full. However, Lender is not required to permit reinstatement if: (i) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding, (ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priority of the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right 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. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who co-signs this Security Instrument but does not execute the Note: (a) is co-signing this Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent. VMP 0 •4NtPA) (0708).01 Pape 5 of 10 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Any notice to Lender shall be given by first class mail to Lender's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law; Severability. This Security Instrument shall be governed by Federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affm ing the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16, "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or Lender's agents to collect the rents and revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each o bv- VMP 0 -4N(PA) (0708).01 P.Q.7 of 10 tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights under this paragraph 17. Lender shall not be required to enter upon, take control of or maintain the Property before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid in full. 18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9, Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, but not limited to, attorneys' fees and costs of title evidence. If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale provided in the 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 any rights otherwise available to a Lender under this Paragraph 18 or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 22. Purchase Money Mortgage. If any of the debt secured by this Security instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 23, interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)]. H Condominium Rider ? Growing Equity Rider ? Other [specify] Planned Unit Development Rider [] Graduated Payment Rider 6mG VMP ®-4NIPA) (0708(.01 Pace 0 of 10 This is a contract under seal and may be enforced under 42 PA. C.S. Section 5529(b)_ BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security Instrument and in any rider(s) executed by Borrower and recorded with it. Witnesses: _ (Seal) -Borrower _ (Seal) -Borrower _ (Seal) -Borrower (Seal) TAMMY M GERACI -Borrower (Seal) (Seal) -Borrower (Seal) -Borrower (Seal) grower VMP ®-M(PA) (0709).01 Page 9 or 10 COMMONWEAL T4 OF PENN YLVANIA, eUM4f"4'" County ss: On this, 3 day of C4V& r ZQQ , before me, the undersigned officer, personally appeared i?my m. G known to me (or satisfactorily proven) to be the person(s) whose name(s) is/are subscribed to the within instrument and acknowledged that he/she/they executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. My Commission Expires: c_MMONW AI.M! O PENNSYLVwrw Nwwb C. myen, No" pwft Title of tb rpo b oh 2.2M I tAen,eer. or Nftfts Certificate of Residence 1, , do hereby certify that the correct address of the within-named Mortgagee is P.O. Box 2026, Flint, MI 48501-2026. Witness my hand this . day of Agat of Mortgagee J9m C VMP®•4N(PA) 107oe1.01 P.O.10.f 10 ALL THAT CERTAIN tract or parcel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and described in accordance with a survey by Michael C. Angelo, Registered Surveyor, dated December 28, 1979, as follows, to wit: BEGINNING at a point, along the southerly curve of Heidi Terrace which point is 306.99 feet in an easterly direction from the intersection of Heidi Terrace and David Drive; thence along the southerly line of Heidi Terrace along a curve to the left having a radius of 50.0 feet, an arc distance of 38.76 feet to a pin at the dividing line between the herein described lot and Lot on the hereinafter mentioned Plan of Lots; thence along said dividing line South 15 degrees 30 minutes 42 seconds East through the center of a partition wall and beyond a distance of 105.88 feet to a pin at lands now or formerly of Edan Place Wesr, thence along said lands North degrees 57 minutes, 00 seconds West, a distance of 111.30 feet to a pin at the dividing line between herein described lot and Lot 4X on the hereinafter mentioned Plan of Lots, thence along said dividing line of North 30 degrees 3 minutes 00 seconds East, a distance of 59.14 feet to a pin along the southerly line of Heidi Terrace, the Place of BEGINNING. BEING Lot Number 5, Plan Number 17 at Ridley Park recorded in Plan Book 17, Page 64. HAVING THEREON ERECTED a two-story brick and aluminum house known as 33 Heidi Terrace. PARCEL 09-17-1042-166 (20080831. pfd/20080831. PF D119) ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY I COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200833988 Recorded On 10/15/2008 At 8:55:44 AM *Total Pages - 12 * Instrument Type - MORTGAGE Invoice Number - 30565 User ID - RAK * Mortgagor - GERACI, TAMMY M * Mortgagee - MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC * Customer - LAKESIDE ABSTRACT & SETTLEMENTS * FEES STATE WRIT TAX STATE JCS/ACCESS TO JUSTICE RECORDING FEES RECORDER OF DEEDS PARCEL CERTIFICATION FEES AFFORDABLE HOUSING COUNTY ARCHIVES FEE ROD ARCHIVES FEE TOTAL PAID $0.50 $10.00 $25.50 $10.00 $11.50 $2.00 $3.00 $62.50 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA RECORDER O D EDS * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 00 1 40Y IIIIIIINNNIWN 21'0 4Cl r_ r_ VERiFICATtON Ismael Hernandez, hereby states tha hey the is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff or mortgage servicing agent for plaintiff in this matter, tha he he is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relali?lg to unsworn falsification to authorities. DATE Name: Ismael Hernandez Title: Vice President Loan Documentation File #165557 Name: GERACI 032-P,/\-V3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, VS. CIVIL DIVISION L43 bVil NO.. I ) Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; Defendant(s). NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM ...7 You have been served with a foreclosure complaint that could cause you to lose your home. I ?r If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TIDS PROGRAM IS FREE. ZUCKER, GOLDBERG & ACKERMAN, LLC Dated: May 9, 2012 BY: 011M, 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 Attorneys for Plaintiff XFP-165557/ns 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-165557 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete. your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: State: Zip: Yes E] No ? Listing date: Price: $ Realtor Phone: Yes ? No ? Home: Cell: State Office: _ Other: Zip: How long? State: Zip: Home: Office: _ Cell: Other: How long? First Mortgage Lender: Type of Loan: Loan Number: Date you closed your loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes E] No ? If yes, provide names, location of court, case number & attorney: 1 Assets Home: Other Real Estate: Retirement Funds: Investments: Checking: Savings: Other: Automobile #1: Amount owed: Automobile #2: Amount owed: Value: Year: Value: Year: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2nd Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ? No ? If yes, please provide the following information: Counseling Agency: Amount Owed: Model: Model: Counselor: Phone (Office): Email: Fax: 2 Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: 1/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of Income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) V Listing agreement (if property is currently on the market) 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, VS. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; CIVIL DIVISION NO.. Defendant(s). REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, vs. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; Defendant(s). CIVIL DIVISION NO.. CASE MANAGEMENT ORDER AND NOW, this day of ,20 the defendant/borrower in the above- captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at M. in Cumberland County Courthouse, Carlisle, Pennsylvania. at the 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance! agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker, Goldberg & Ackerman, LLC XFP-165557 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?plt? o t ? rrrparr/ ?g ?h OFFICE ? Tl,G S•-ERIFF y HE PR0TPii0N,1 tt` ; Jody S Smith Chief Deputy Richard W Stewart Solicitor 2012 MAY 24 PM 1: CUMBERLAND COUNI'Y Wells Fargo Bank, N.A. vs. Case Number . Jerry A. Mattern, Jr. 2012-2943 SHERIFF'S RETURN OF SERVICE 05/22/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Jerry A. Mattern, Jr., but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Jerry A. Mattern, Jr. Request for service at 33 Heidi Terrace, Camp Hill, Pennsylvania 17011 the Defendant was not found. Deputies were advised, Jerry A. Mattern, Jr. has not been seen at this address in months. To date The Camp Hill Postmaster has been unable to provide a good forwarding address for the Defendant. SHERIFF COST: $48.00 May 22, 2012 (C) CountySuite Shenff. Teleosoft. Inc. SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION VS. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; Defendant(s). TO THE PROTHONOTARY: NO.: 12-2943-CIVIL PRAECIPE TO REINSTATE COMPLAINT t?IsL "I'M couil S Y L V.1"kA I A Please mark the Complaint in Mortgage Foreclosure filed at the above-captioned term and number reinstated. / i ZUCKER, pOLOBEIR(A & pCI(EWAN, LLC By: Dated: June C. '2012 Scott A. Di t erick, Esquire, P I.D. #55650 KimberlyA. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. arin, 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-165557/jab 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com 0?_saM}.s II. TS pd C I? ? 37 n14a-7 6 q?a SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff THE PROTHONOT,ts: Jody S Smith 12 JUL 12 AM $. 04 Chief Deputy Richard W Stewart Solicitor ? •?_ ??r?? ";?1M8EIZLANk? COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Case Number Jerry A. Mattern, Jr. 2012-2943 SHERIFF'S RETURN OF SERVICE 06/20/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent sear h and inquiry for the within named defendant, to wit: Jerry A. Mattern, Jr., but was unable to locate him i his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 07/02/2012 05:48 PM - Dauphin County Return: And now July 2, 2012 at 1748 hours I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jerry A. Mattern, Jr. by making known unto himself personally, at 1204 Capital Street, Harrisburg, Pennsylvania 17102 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 SO ANSWERS, July 09, 2012 RON R ANDERSON, SHERIFF fo) Coun+ySum Shen-,t l'eleCSntt. Irn;:. ( ptfirg of th e J&herr-r-t Shelley Ruhl Real Esta a Deputy William T. Tully Solicitor • Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin J Michael Assistant WELLS FARGO BANK, N.A. VS JERRY A. MATTERN, JR Sheriff s Return No. 2012-T-1816 OTHER COUNTY NO. 2012-2943 And now: JULY 2, 2012 at 5:48:00 PM served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon JERRY A. MATTERN, JR by personally handing to JER MATTERN, JR 1 true attested copy of the original REINSTATED COMPLAINT IN MORTG FORECLOSURE and making known to him/her the contents thereof at 1204 CAPITAL STREF HARRISBURG PA 17102 Sworn and subscribed to before me this 5TH day of July, 2012 -)P*Z COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission Expires August 17, 2014 So Answers, ye?41c- Sheriff of auphin Coun , a. By Depu eriff Deputy: BRIAN T HUNTER Sheriffs Costs: $41.25 6/25/2012 A. E IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff vs. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; Defendant(s). Mortgaged Premises: 33 Heidi Terrace, Camp Hill, PA 17011-1141 - ..; - CIVIL DIVISION No.:12-2943-CIVIL ~ - - .._ . ~ ,_ ,. ~~-~ -.~- -; ___ ;. ISSUE NUMBER: ,_ , _ c TYPE OF PLEADING; ~ - PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (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 LD.# 55650 Kimberly A. Bonner, Esquire- Pa I.D. #89705 Joel A. Ackerman, Esquire- Pa 1.D. #202729 Ashleigh L. Marin, Esquire-Pa LD. #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-165557 ~ a C~~ `~ . ~~a~a35 Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, LLC XFP-165557. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CNIL DNISION Plaintiff, N0.:12-2943-CNII. "~ vs. _, Jerry A. Mattern, Jr., Administrator of the Estate of -, ; _. . Tammy M. Geraci; ~ ~'~ -- r~.~ • : ,~. .: - ~, Defendant(s). ~- c.:~ - c ; _... _ ~._~ PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOS~1tE~, .= 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 Plaintiffls damages as set forth on complaint: Amount as set forth in Complaint $113,612.91 plus interest on the judgment amount ($113,612.91) from Apri124, 2012, at the statutory rate and for foreclosure and sale of the mortgaged premises. l hereby certify that the defendant's last known 1204 Capital Street address is: Harrisburg, PA 17102-2050 l Dated: ,~~C' ~,~ ' ~ ~. ZUCKER, GOL R r ; CKE AN, L,LC i ,,- ~~~,-=/ BY: ~ Joel A. Ackerman, Esquire; PA LD. #202729 ~ Ashleigh L. Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA LD. #31 1032 Attorneys far Plaintiff XFP-165557 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com DAMAGES ARE HEREBY ASSESSED AS INDICATED Date _ r ~j Prothonota IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DNISION Plaintiff, N0.:12-2943-CIVIL vs. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; Defendant(s). 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: l) 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, GOL G & ACKE AN, LC.C r ~~ Dated: ~< ~ / -~' I ~ l j~ I /I~ BY: /" f~ _ ! ~ Joel A Ackerman, Esquire; A I.D. #202729 ~ Ashl gh L. Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA LD. #31 1032 Attorneys for Plaintiff XFP-165557 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Sworn to and ubscribed efore me This 15 d y of f7 G ~ , 20 12~ ``--- -e Notary Public MY ron SHEREZA DEONARiNE Notary Public of New Jersey 1D# 2407261 ilAy Commission Expires 4/12/2016 Zucker, Goldberg & Ackerman, LLC XFP-165557 Results as of :Oct-11-2012 05:55.:45 Department of Defense Manpower Data Center SCRA I?.3 Status Ricpeart Pursuant #a S~rv~cemembers Civil Ri~1~f Act Last Name: MATTERN First Name: JERRY Middle Name: A Active Duty Status As Of: Oct-11-2012 on ncliva Duty or, Aare Duty statue Date Active Duty StarE Date AtlMe poly End Date .Status Service Gomponant.. NA NA No NA This response reflects the Individuals' active duly status based on the Ackve Duty Status Date Left A.ctlve Duty WNhkt 367 Gays d AcUVe Duty Statue Date Actlve Duty Start Date Aclhre Duly Ernl Date Statue - Service Component NA 'NA No NA ' This response reflects where the IndMdual left active duty status wktrin 387 days preceding theActiveDuty Status Dale The Member w HldHer Unk Was Wodfled of a Future CaI~Up to Acthre bury on Acute Duty Status Dets OrdarNoWicatlon Start.Date Order Notlflcat(on End Date Status Service Component NA NA No NA ~~ This response reflects whether the 4divldual or hlslher unit has received early nokficatlon 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 hislher unit receiving notification of future orders to report for Active Duty. ... Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Sttite 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: http:(/www.defenselink.millfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See `id 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)f 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: D09KEAAK00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, ' N0.:12-2943-CN'IL vs. • Jerry A. Mattern, Jr., Administrator c-f the Estate of Tammy M. Geraci; Defendant(s). NOTICE OF ORDER, DECREE OR JUDGMENT TO: Jerry .A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci 1204 Capital Street Harrisburg, PA 17102-2050 [ Plaintiff ] [~] Defendant [ Additional Defendant ] You are hereby notified that an Order. Decree r Judgment was entered in the above captioned proceeding on _ (~ ~~ [ A copy of the Order or Decree is enclosed, or [~] 'The judgment is as follows: $113,612.91 p cost othonotary Zucker, Goldberg & Ackerman, LLC XFP-165557 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor pautr of +Cuinbcr~a ~ ,. s 70 ~, - .,~ ~(_ ~.„~ ` '' ~~~~~'°` QFF ~cE aF 'H~ SwERIFF ~ ;~„~~-i)'r•~I%L ' I'HE pROTNOKOT/'~"~~. 2a12 .fill. 1 Z AM 8' ~~ i rUMBERLAND CpUtdTY p E ~lVS Y L.VA N 1 A Wells Fargo Bank, N.A. vs. Jerry A. Mattern, Jr. I I Case Numbe 2012-2943 SHERIFF'S RETURN OF SERVICE 0612 012 0 1 2 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent sear and inquiry for the within named defendant, to wit: Jerry A. Mattern, Jr., but was unable to locate him ii his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 07/02/2012 05:48 PM -Dauphin County Return: And now July 2, 2012 at 1748 hours 1, Jack 4otwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return that 1 served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jerry A. Mattern, Jr. by making known unto himself personally, at 1204 Capital Street, Harrisburg, Pennsylvania 17102 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $31.00 July 09, 2012 SO ANSWERS, N~ trr K ANDERSON, SHERIFF P;) CounrySuite Snonfl l'aiensor un:.. ~~.~.~>~:~ la# t~ ~> i~px~,f.~ Shelle~ Ruhl t R l E D t Nf~` • ea s e a epu y • , ~ William. T. Tully Solicitor Dauphin County 101 Market Street Harrisburg, Pennsylvania 17101-2079 ph: (717) 780-6590 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin J Michael Assistant WELLS FARGO BANK, N.A. VS JERRY A. MATTERN, JR Sheriffs Return No. 2012-T-1816 OTHER COUNTY NO. 2012-2943 And now: JULY 2, 2012 at 5:48:00 PM served the within REINSTATED COMPLAINT IN MORTGAGE FORECLOSURE upon JERRY A. MATTERN, JR by personally handing to JERI MATTERN, JR 1 true attested copy of the original REINSTATED COMPLAINT IN MORTG, FORECLOSURE and making known to him/her the contents thereof at 1204 CAPITAI. STREE HARRISBURG PA 17102 Sworn and subscribed to before me this 5TH day of July, 2012 ~~~ COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Karen M. Hoffman, Notary Public City of Harrisburg, Dauphin County M Commission ices Au 17 2014 So Anppswers,~ l~~ j~~~~ Sheriff a> as„ =may Depuiy`~'Iieriff ~ ~ Deputy: BRIAN T HUNTER Sheriff s Costs: $41.25 6/25/2012 i' A. 1N TIIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci Defendant. NO.: 12-2943-CIVIL IMPORTANT NOTICE TO: Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci 1204 Capital Street Harrisburg, PA 17102-2050 DATE OF NO"TILE: 9/5/2012 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 IN TLIE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci Defendant. NO.: 12-2943-CIVIL AVISiD IIVIPORTANTE TO: Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci 1204 Capital Street Harrisburg, PA 17102-2050 FECHA DEL AVIS0:9/5/2012 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXII~IIOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLE~TARSE A CABO UNA ~TISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IIvIPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INNIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARR QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TD DEFEND c~ 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, GC7LDBERG c4t.ACKERMAN BY: Soatt A. D ietterick Scott A. Dietterick, Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.Q. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 F[RST CLASS U.S. MAIL, PgSTAGE PREPAID 165557 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA ` CIVIL DIVISION File No. 12-2943-CIVIL Wells Fargo Bank,N.A., Amount Due $113,612.91 Plaintiff, Interest from 04/23/2012 to date of sale $013.0 Jerry A. Mattern,Jr., Administrator of the Estate of Costs Tammy M. Geraci; -,r.:t- co �x ..7 Defendant. > _, TO THE PROTHONOTARY OF THE SAID COURT: {' The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract of account based on a confession of judgment,but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County,for debt, interest and costs upon the following described property of the defendant(s): See Exhibit"A"attached 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 gamishee(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 gamishee(s). (Indicate)Index this writ against the gamishee(s)as a lis pendens agains state of t defendant(s) described in the att ache exhibit. ,DATE: � Signature: Print Name: Scott A e eri k, squi Kimb ly A. Bonner,Esquire pd Q Joel ckerman,Esquire T V Ash eigh Levy Marin, Esquire MF Ralph M. Salvia, Esquire 00' Jaime R.Ackerman,Esquire d� ire it Address: Zucker, Goldberg&Ackerman, LLC /t <. 200 Sheffield Street, Suite 101 Mountainside,NJ 07092 Attorney for: Plaintiff r Telephone: 908-233-8500 Supreme Court ID No.: 55650 (" 89705 ^�„�S . /!� 202729 G� 306799 SDLL 202946 311032 ef( AI Exhibit"Ai' LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIED IN ACCORDANCE WITH A SURVEYBY MICHAEL C. ANGELO,REGISTERED SURVEYOR, DATED DECEMBER 28, 1979, AS FOLLOWS TO WIT: BEGINNING AT A POINT, ALONG THE SOUTHERLY CURVE OF HEIDI TERRACE WHICH POINT IS 306.99 FEET IN AN EASTERLY DIRECTION FROM THE INTERSECTION OF THE HEIDI TERRACE AND DAVID DRIVE; THENCE ALONG THE SOUTHERLY LINE OF HEIDI TERRACE ALONG A CURVE TO THE LEFT HAVING A RADIUS OF 50.0 FEET, AN ARCH DISTANCE OF 38.76 FEET TO A PIN AT THE DIVIDING LINE BETWEEN THE HEARING DESCRIBED LOT AND LOT ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING LINE SOUTH 15 DEGREES 30 MINUTES 42 SECONDS EAST THROUGH THE CENTER OF A PARTITION WALL AND BEYOND A DISTANCE OF 105.88 FEET TO A PIN AT LANDS NOW OR FORMERLY OF EDAN PLACE WEST; THENCE ALONG SAID LANDS NORTH DEGREES 57 MINUTES, 00 SECONDS WEST, A DISTANCE OF 111.30 FEET TO A PIN AT THE DIVIDING LINE BETWEEN HEREIN DESCRIBED LOT AND LOT 4X ON THE HEREINAFTER MENTIONED PLAN OF LOTS,THENCE ALONG SAID DIVIDING LINE OF NORTH 30 DEGREES 3 MINUTES 00 SECONDS EAST, A DISTANCE OF 59.14 FEET TO A PIN ALONG THE SOUTHERLY LINE OF THE HEIDI TERRACE, THE PLACE OF BEGINNING. BEING LOT NUMBER 5, PLAN NUMBER 17 AT RIDLEY PARK RECORDED IN PLAN BOOK 17, PAGE 64. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 33 HEIDI TERRACE, CAMP HILL, PA, 17011-1141. BEING THE SAME PREMISES WHICH JERRY A. MATTERN AND SANDRA L. MATTERN (HUSBAND AND WIFE),BY DEED DATED JULY 12,2007 AND RECORDED JULY 27, 2007 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 281, PAGE 813, GRANTED AND CONVEYED UNTO TAMMY M. GERACI,AS SINGLE WOMAN. TAX MAP NO.: 09-17-1042-166. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A., CIVIL DIVISION ' Plaintiff, NO.: 12-2943-CIVIL VS. -•C co E3 Execution No.: Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank,N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 33 Heidi Terrace, Camp Hill, PA 17011-1141. 1. Name and Address of Owner(s) or Reputed Owner(s): JERRY A. MATTERN, JR., ADMINISTRATOR OF THE ESTATE OF TAMMY M. GERACI 1204 Capital Street Harrisburg, PA 17102-2050 2. Name and Address of Defendant(s) in the Judgment: JERRY A. MATTERN, JR., ADMINISTRATOR OF THE ESTATE OF TAMMY M. GERACI 1204 Capital Street Harrisburg, PA 17102-2050 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 MERS, INC., AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, INC., DBA AMNET MORTGAGE ITS PO Box 2026 Flint, MI 48501-2026 AND 1901 E. Voorhees St, Ste C Danville, IL 61834 AND 3300 SW 34th Ave, Ste 101 Ocala, FL 34474-4438 AND P.O. Box 85463 San Diego, CA 92186 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: JERRY MATTERN, SR. 245 Glenn Road Camp Hill, PA 17011 SANDRA MATTERN 245 Glenn Road Camp Hill, PA 17011 JOSEPH GERACI 312 Briar Ridge Circle Enola, PA 17025 Zucker,Goldberg 2k nckcrnnan.H XPP-16515' NICOLAS GERACI 312 Briar Ridge Circle Enola, PA 17025 TAMI SAUSSER MULL 4525 Indian Court Gainesville, GA 30506 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 33 Heidi Terrace Camp Hill, PA 17011-1141 UNKNOWN SPOUSE 1204 Capital Street Harrisburg, PA 17102-2050 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 & ACKERMA , LLC Dated: �j BY: �3 Scott A. Die ' ,Es ire; PA I.D. #55650 Kimberly Bonner, Esquire; PA.I.D. #89705 Joel A. Ac erman, 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 r/ 200 Sheffield Street, Suite 101 Mountainside,NJ 07092 File No.: XFP-165557 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Lucker.6oldhere& ;Ackerman. 1.15.E '011-1 65i57 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIED IN ACCORDANCE WITH A SURVEYBY MICHAEL C. ANGELO, REGISTERED SURVEYOR, DATED DECEMBER 28, 1979, AS FOLLOWS TO WIT: BEGINNING AT A POINT,ALONG THE SOUTHERLY CURVE OF HEIDI TERRACE WHICH POINT IS 306.99 FEET IN AN EASTERLY DIRECTION FROM THE INTERSECTION OF THE HEIDI TERRACE AND DAVID DRIVE; THENCE ALONG THE SOUTHERLY LINE OF HEIDI TERRACE ALONG A CURVE TO THE LEFT HAVING A RADIUS OF 50.0 FEET, AN ARCH DISTANCE OF 38.76 FEET TO A PIN AT THE DIVIDING LINE BETWEEN THE HEARING DESCRIBED LOT AND LOT ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING LINE SOUTH 15 DEGREES 30 MINUTES 42 SECONDS EAST THROUGH THE CENTER OF A PARTITION WALL AND BEYOND A DISTANCE OF 105.88 FEET TO A PIN AT LANDS NOW OR FORMERLY OF EDAN PLACE WEST; THENCE ALONG SAID LANDS NORTH DEGREES 57 MINUTES, 00 SECONDS WEST, A DISTANCE OF 111.30 FEET TO A PIN AT THE DIVIDING LINE BETWEEN HEREIN DESCRIBED LOT AND LOT 4X ON THE HEREINAFTER MENTIONED PLAN OF LOTS, THENCE ALONG SAID DIVIDING LINE OF NORTH 30 DEGREES 3 MINUTES 00 SECONDS EAST, A DISTANCE OF 59.14 FEET TO A PIN ALONG THE SOUTHERLY LINE OF THE HEIDI TERRACE, THE PLACE OF BEGINNING. BEING LOT NUMBER 5, PLAN NUMBER 17 AT RIDLEY PARK RECORDED IN PLAN BOOK 17, PAGE 64. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 33 HEIDI TERRACE, CAMP HILL, PA, 17011-1141. BEING THE SAME PREMISES WHICH JERRY A. MATTERN AND SANDRA L. MATTERN(HUSBAND AND WIFE), BY DEED DATED JULY 12, 2007 AND RECORDED JULY 27, 2007 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 281, PAGE 813, GRANTED AND CONVEYED UNTO TAMMY M. GERACI, AS SINGLE WOMAN. TAX MAP NO.: 09-17-1042-166. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION =' ~' Plaintiff, VS. NO.: 12-2943-CIVIL cr r r -< Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci; f - .,C- Defendants. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci 1204 Capital Street Harrisburg, PA 17102-2050 AND 33 Heidi Terrace Camp Hill, PA, 17011-1141 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 914!2013 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 33 Heidi Terrace, Camp Hill,PA, 17011-1141 Zucker,Goldberg&Ackerman, LLC XFP-165557 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-2943-CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff(for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle,PA 17013 Phone (800)990-9108 (717)249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. Zucker,Goldberg&Ackerman, LLC XFP-165557 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 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 GOLDBER ACKERYAN, LLC Dated: BY: �3 Scott A. Ltiey 4-n":c;k-, squire; PA I.D. #55650 Kimberly X 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 File No.: XFP-165557 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL,RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker,Goldberg&Ackerman, LLC XFP-165557 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP,CUMBERLAND COUNTY,PENNSYLVANIA,MORE PARTICULARLY BOUNDED AND DESCRIED IN ACCORDANCE WITH A SURVEYBY MICHAEL C. ANGELO,REGISTERED SURVEYOR,DATED DECEMBER 28, 1979,AS FOLLOWS TO WIT: BEGINNING AT A POINT,ALONG THE SOUTHERLY CURVE OF HEIDI TERRACE WHICH POINT IS 306.99 FEET IN AN EASTERLY DIRECTION FROM THE INTERSECTION OF THE HEIDI TERRACE AND DAVID DRIVE;THENCE ALONG THE SOUTHERLY LINE OF HEIDI TERRACE ALONG A CURVE TO THE LEFT HAVING A RADIUS OF 50.0 FEET, AN ARCH DISTANCE OF 38.76 FEET TO A PIN AT THE DIVIDING LINE BETWEEN THE HEARING DESCRIBED LOT AND LOT ON THE HEREINAFTER MENTIONED PLAN OF LOTS;THENCE ALONG SAID DIVIDING LINE SOUTH 15 DEGREES 30 MINUTES 42 SECONDS EAST THROUGH THE CENTER OF A PARTITION WALL AND BEYOND A DISTANCE OF 105.88 FEET TO A PIN AT LANDS NOW OR FORMERLY OF EDAN PLACE WEST; THENCE ALONG SAID LANDS NORTH DEGREES 57 MINUTES,00 SECONDS WEST,A DISTANCE OF 111.30 FEET TO A PIN AT THE DIVIDING LINE BETWEEN HEREIN DESCRIBED LOT AND LOT 4X ON THE HEREINAFTER MENTIONED PLAN OF LOTS,THENCE ALONG SAID DIVIDING LINE OF NORTH 30 DEGREES 3 MINUTES 00 SECONDS EAST,A DISTANCE OF 59.14 FEET TO A PIN ALONG THE SOUTHERLY LINE OF THE HEIDI TERRACE,THE PLACE OF BEGINNING. BEING LOT NUMBER 5,PLAN NUMBER 17 AT RIDLEY PARK RECORDED IN PLAN BOOK 17, PAGE 64. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 33 HEIDI TERRACE, CAMP HILL,PA, 17011-1141. BEING THE SAME PREMISES WHICH JERRY A. MATTERN AND SANDRA L. MATTERN(HUSBAND AND WIFE),BY DEED DATED JULY 12,2007 AND RECORDED JULY 27,2007 IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA, IN DEED BOOK VOLUME 281, PAGE 813, GRANTED AND CONVEYED UNTO TAMMY M. GERACI, AS SINGLE WOMAN. TAX MAP NO.: 09-17-1042-166. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-2943 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 JERRY A. MATTERN,JR.,ADMINISTRATOR OF THE ESTATE OF TAMMY M. GERACI (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 garnishees)that: (a)an attachment has been issued;(b)the gamishee(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: $113,612.91 L.L.: $.50 Interest FROM 4/23/2012 TO DATE OF SALE-$9,313.19 Arty's Comm: Due Prothy: $2.25 Arty Paid: $245.50 Other Costs: Plaintiff Paid: Date: 3/38/13 David D.Buell,Prothonot (Seal) By: C)twoucj.4 Deputy REQUESTING PARTY: Name: JAIME R.ACKERMAN,ESQUIRE Address: ZUCKER,GOLDBERG&ACKERMAN,LLC 200 SHEFFIELD STREET,SUITE 101 MOUNTAINSIDE,NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No.311032 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 12-2943-CIVIL } c 17�,`'Y, TYPE OF PLEADING F... Jerry A. Mattern,Jr., Administrator of the Estate C-_ of Tammy M.Geraci; Pa. R.C.P. RULE 3129.2(C)AFFIDAVIT OF 5-ERVFCt OF DEFENDANT/OWNER AND Defendants. OTHER PARTIES OF INTEREST FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D.#55650 Kimberly A. Bonner, Esquire- PA I.D.#89705 Joel A.Ackerman, Esquire- PA I.D.#202729 Ashleigh L. Marin, Esquire- PA I.D.#306799 Ralph M.Salvia, Esquire- PA I.D.#202946 Jaime R.Ackerman, Esquire- PA I.D.#311032 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office @zuckergoldberg.com File No.:XFP- 165557/dsc Zucker, Goldberg&Ackerman, LLC XFP-165557 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 12-2943-CIVIL vs. Jerry A. Mattern,Jr., Administrator of the Estate of Tammy M. Geraci; Defendants. Pa.R.C.P. RULE 3129(c)AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Daniel Schlesinger, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriff's Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Tammy M. Geraci (deceased), is single woman, are the record owners of the real property. 2. On or about July 29, 2013, Defendant Tammy M. Geraci was served with Plaintiff's Notice of Sheriff's Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland County, at her place of business, being Crump Insurance, 4135 N. Front Street, Harrisburg, PA 17110. A true and correct copy of said Proof of Service is marked Exhibit "A", attached hereto and made a part hereof. 3. On or about July 26, 2013, Plaintiff's counsel served all other parties in interest with Plaintiff's 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 Notices and Certificates of Mailing are marked Exhibit"B", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendants/Owners and all other Parties of Zucker, Goldberg&Ackerman, LLC XFP-165557 Interest were served with Plaintiff's Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER, GOLDBERG &ACKERMAN, LLC Attorneys for Plaintiff Dated: August t� , 2013 DANI SINGER Paralegal/Legal Assistant Sworn to and subscribed before me this /Z day of August, 2013 C Notar Public MY COMMISSION EXPIRES: PAUL C.NADRATOWSKI Notary Public of New Jersey ID#2407850 My Commission Expires 4/27/2ole Zucker, Goldberg&Ackerman, LLC XFP-165557 EXHIBIT A Zucker, Goldberg&Ackerman, LLC XFP-165557 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith4��at+'cti«nbtr��ra Chief Deputy , Richard W Stewart Solicitor OFFICE OF THE SPERIFF i Wells Fargo Bank, N.A. vs. Case Number Jerry A. Mattern,Jr. 2012-2943 SHERIFF'S RETUI NI OF SERVICE 06/13/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant,to wit:Jerry A. Mattern, Jr.,but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action,according to law. 07/01/2013 08:28 PM-Deputy Shawn Harrison,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 33 Heidi Terrace, East Pennsboro-Township,Camp Hill, PA 17011, Cumberland County. 07/29/2013 The requested Real Estate Writ, Notice and Description, in the above titled action,served by the Sheriff of Dauphin County upon Lauren Kubilas, Receptionist,who accepted for Jerry A. Mattern, Jr., at POB: Crump Insurance,4135 N. Front Street, Harrisburg, PA 17110. So Answers:W. Conway, Deputy Sheriff. SHERIFF COST: $920.70. SO ANSWERS, July 29,2013 RONNY R ANDERSON, SHERIFF i: t; i i. { i ......,.(l;1.CA1J.Y.tu.Sl ln.Al.n✓,M;;:i-,-.--.. ........... .. .. ....._.... .. ... ... ........ .. EXHIBIT B Zucker, Goldberg&Ackerman, LLC XFP-165557 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, VS. NO.: 12-2943-CIVIL Jerry A.Mattern,Jr., Administrator of the Estate of Tammy M.Geraci; Defendants. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P.3129(b) TO: UNKNOWN TENANT OR TENANTS UNKNOWN SPOUSE 33 Heidi Terrace 1204 Capital Street Camp Hill, PA 17011-1141 Harrisburg, PA 17102-2050 COMMONWEALTH OF PENNSYLVANIA PA DEPT.OF REVENUE-INHERITANCE TAX DEPARTMENT OF WELFARE DIVISION P.O. Box 2675 Dept.280601 Harrisburg, PA 17105 Harrisburg, PA 17128-0601 CUMBERLAND COUNTY TAX CLAIM BUREAU CUMBERLAND COUNTY DOMESTIC RELATIONS Cumberland County Courthouse OFFICE One Courthouse Square Domestic Relations Section Carlisle, PA 17013 13 N. Hanover Street PO Box 320 MFRS, INC.,AS NOMINEE FOR AMERICAN Carlisle,PA 17013 MORTGAGE NETWORK,INC., DBA AMNET MORTGAGE ITS JERRY MATTERN,SR. PO Box 2026 245 Glenn Road Flint, MI 48501-2026 Camp Hill,PA 17011 MERS, INC.,AS NOMINEE FOR AMERICAN SANDRA MATTERN MORTGAGE NETWORK, INC., DBA AMNET 245 Glenn Road MORTGAGE ITS Camp Hill, PA 17011 1901 E.Voorhees St,Ste C Danville, IL 61834 JOSEPH GERACI 312 Briar Ridge Circle MERS, INC.,AS NOMINEE FOR AMERICAN Enola,PA 17025 MORTGAGE NETWORK,INC.,DBA AMNET MORTGAGE ITS NICOLAS GERACI 3300 SW 34th Ave,Ste 101 312 Briar Ridge Circle Ocala, FL 34474-4438 Enola,PA 17025 Zucker,Goldberg&Ackerman,LLC «Field2»-sField1» ((Fieldl))D1004CO2/12/2008P1 MFRS, INC.,AS NOMINEE FOR AMERICAN TAMI SAUSSER MULL MORTGAGE NETWORK, INC., DBA AMNET 4525 Indian Court MORTGAGE ITS Gainesville,GA 30506 P.O.Box 85453 San Diego,CA 92185 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common i Pleas of Cumberland County, Pennsylvania,and to the Sheriff of Cumberland County,directed,there will be exposed to Public Sale in: the Cumberland County Courthouse,1 Courthouse Square,Carlisle, PA 17013 On 9/4/2013 at 10:00am,the following described real estate which Tammy M.Geraci,as single woman are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of: 33 Heidi Terrace, Camp Hill, PA 17011-1141 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). Zucker,Goldberg&Ackerman,LLC uField2»-uFieldlu «Fieldl»D 1004CO2/12/2008P2 The said Writ of Execution has been issued on a judgment in the action of Wells Fargo Bank,N.A. Plaintiff VS. Jerry A.Mattern,Jr., Administrator of the Estate of Tammy M.Geraci,et al Defendant(s) at EX. NO. 12-2943-CIVIL in the amount of$113612.91 plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty(30)days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten(10)days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriff's Sale or this Notice,you should contact your attorney as soon as possible. ZUCKER,GOLDBERG&ACKERMAN, LLC Dated: ��a� I� BY: 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; PA I.D.#202946 Jaime R.Ackerman,Esquire; PA I.D.#311032 200 Sheffield Street,Suite 301 Mountainside, N1 07092 File No.:XFP-165557 (908)233-8500; (908)233-1390 FAX E-mail: Office @zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC «Field2»-«Fieldl» KFieId1 uD 1004CO2/12/2008P3 Exhibit"A„ LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP,CUMBERLAND COUNTY,PENNSYLVANIA,MORE PARTICULARLY BOUNDED AND DESCRIED IN ACCORDANCE WITH A SURVEYBY MICHAEL C.ANGELO,REGISTERED SURVEYOR,DATED DECEMBER 28,1979,AS FOLLOWS TO WIT: BEGINNING AT A POINT,ALONG THE SOUTHERLY CURVE OF HEIDI TERRACE WHICH POINT IS 306.99 FEET IN AN EASTERLY DIRECTION FROM THE INTERSECTION OF THE HEIDI TERRACE AND DAVID DRIVE; THENCE ALONG THE SOUTHERLY LINE OF HEIDI TERRACE ALONG A CURVE TO THE LEFT HAVING A RADIUS OF 50.0 FEET,AN ARCH DISTANCE OF 38.76 FEET TO A PIN AT THE DIVIDING LINE BETWEEN THE HEARING DESCRIBED LOT AND LOT ON THE HEREINAFTER MENTIONED PLAN OF LOTS;THENCE ALONG SAID DIVIDING LINE SOUTH 15 DEGREES 30 MINUTES 42 SECONDS EAST THROUGH THE CENTER OF A PARTITION WALL AND BEYOND A DISTANCE OF 105.88 FEETTO A PIN AT LANDS NOW OR FORMERLY OF EDAM PLACE WEST;THENCE ALONG SAID LANDS NORTH DEGREES 57 MINUTES,00 SECONDS WEST,A DISTANCE OF 111.30 FEET TO A PIN AT THE DIVIDING LINE BETWEEN HEREIN DESCRIBED LOT AND LOT 4X ON THE HEREINAFTER MENTIONED PLAN OF LOTS,THENCE ALONG SAID DIVIDING LINE OF NORTH 30 DEGREES 3 MINUTES 00 SECONDS EAST,A DISTANCE OF 59.14 FEETTO A PIN ALONG THE SOUTHERLY LINE OFTHE HEIDI TERRACE,THE PLACE OF BEGINNING. BEING LOT NUMBER 5,PLAN NUMBER 17 AT RIDLEY PARK RECORDED IN PLAN BOOK 17, PAGE 64. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 33 HEIDI t TERRACE,CAMP HILL, PA,17011-1141. BEING THE SAME PREMISES WHICH JERRY A.MATTERN AND SANDRA L. MATTERN (HUSBAND AND WIFE),BY DEED DATED JULY 12,2007 AND RECORDED JULY 27,2007 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 281, PAGE 813,GRANTED AND CONVEYED UNTO TAMMY M.GERACI,AS SINGLE WOMAN. TAX MAP NO.:09-17-1042-166. I Zucker,Goldberg&Ackerman,LLC vField2n-((Field h ((Field]»D100402/12/2008P4 Page 1 of 8 NOTICE TO LIENHOLDERS 1 TTFS 9 < 1 �♦�`�F��_�'R.�._�_-_.,_-:_ a Pt1tJEYBOM7E5 QS`Tll :Sf :V1> 02 ,M $ 01-200 a 0004282036 JUL 26 2013 This Certificate of Mailing provides evidence that mail has been presented to usPsa ;P%l MAILED FROM ZIPCODE 07092 and International mail. \ v From Scott A. Dietterick, Esquire c/o Zucker, Goldberg&Ackerman, LC IJUZ %° 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 .S TEAM C To: UNKNOWN TENANT OR TENANTS Postmark Here 33 Heidi Terrace Camp Hill, PA 17011-1141 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 L�¢��i r, unclrrsr�srFS V 1.200 82036 This Certificate of Mailing provides evidence that mall has been presented to USP formlq JUL 26 2013 and interratlonal mail. FROM ZIP CODE 0 70.9 2 7 Promo Scott A.Dietterick, Esquire ';9-6 ,? m. c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 XFP-165557/sde TEAM C To' COMMONWEALTH OF PENNSYLVANIA Postmark Here DEPARTMENT OF WELFARE P.O.Box 2675 Harrisburg, PA 17105 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 1 of 8 Page 2 of 8 NOTICE TO LIENHOLDERS �Pesp% T //�'� �//��TT o� F i �J' TiGl[_ 5_ �- - - - a Bowes a AQST�I .:S RVI E i 02 11A 07.200 This CertWateofMallmg provides evidence that mail has been presentedtoUSPS afar ailing. t nma� 0004282036 JUL 26 2013 and international mail 4 �J �� DFROM ZIPCODE 07092 "'°m" Scott A. Dietterick, Esquire 13 c/o Zucker,Goldberg&Ackerman,LLC i 200 Sheffield Street,Suite 101 S Mountainside, NJ 07092 XFP-165557/sde TEAM C TO: CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Here Cumberland County Courthouse One Courthouse Square Carlisle,PA 17013 I County of P.Q.:CUMBERLAND a PS Form 3817,April 2007 PSN 7530-02-000-9065 CINITE>a-;S.T `' � F a:P..O-S--'T-13-L,S-'E'i? 'VICE(s This Certificate of Melling provides evidence that mail has been presented toUSPSafor .Thisforn �+a. 02 1M (� 1 r2�� . and International mail. V ven: • 0004282036 JUL 26 2013 ri Scott A. Dietterick, Esquire J D FROM ZIPCODE 0 7092 c/o Zucker,Goldberg&Ackerman, LLC E ZOIa 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 SPg XFP-165557/sde T C "o: MERS, INC.,AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, Postmark Here INC., DBA AMNET MORTGAGE ITS PO Box 2026 Flint, M148501-2026 i i County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i I Page 2 of 8 t Page 3 of 8 NOTICE TO LIENHOLDERS 'ta�11►1TEQ�T�TES_ FQ57�t: ERIE . 0't 200 This Certilirate of Milling provides evidence that mall has been presented to USPSe for malllng.ThR ion and international mai4 02 I M a From: Scott A.Dietterick,Esquire o'b� 0004282036 JUL 26 201 3 MAILED FROM ZIP CODE 0 7092 c/o Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 P-165557/s T MERS, INC.,AS NOMINEE FOR AMERICAN MORTGAGE NETWO Postmark Here INC., DBA AM NET MORTGAGE ITS 1901 E.Voorhees St,Ste C Danville, IL 61834 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 .T/J7'ES .. P �l.NTE S Q:ST/1L Sfl2! fCF j ThlsCertHlcatoof Mailing provides evidence that mall has been presented toUSPS e for mal6rq.This f 02 1M $ 01. 3 and intemationai mall. ��SE 0004282036 JUL 26 Scott A.Dietterick, Esquire MAILED FRO M ZIPCODE 0 7092 c/o Zucker,Goldberg&Ackerman, LLCM_ 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 k�-165557 T j- TO' MERS, INC.,AS NOMINEE FOR AMERICAN MORTGAGE NETWO Postmark Here s INC., DBA AMNET MORTGAGE ITS 3300 SW 34th Ave,Ste 101 Ocala, FL 34474-4438 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 3 of 8 Page 4 of 8 NOTICE TO LIENHOL©ERS AMA S VXZ� This Certificate of Mailing provides evidence that mafl has been presented to USPSO for fling.This 0 2 j�yj gO $ and lntemetiorWmeL �� 0004282036 09'200 From: Scott QERO JUL 26 2013 Scott A. Dietterick, Esquire '� zI CODF 0 7092 c/o Zucker,Goldberg&Ackerman, LLC \ 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-165557/sde TEAM C Te: MERS, INC.,AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, Postmark Here INC., DBA AMNET MORTGAGE ITS P.O. Box 85463 San Diego,CA 92186 County of P.Q.:CUMBERLAND t PS Form 3817,April 2007 PSN 7530.02-000-9065 S�P� � , UNI TEpTSTES` s .. y�� • 7 FrGVEV SAII , AOST/!L S R1l,C 00042 $ 01-200 . 82036 JUL26 2013 This Certificate of Mailing provides evidence that mall has been presented to USP59 for malling.Th form may 1 FitiOR/i ZIP CODE 0 70 32 and International mail Frem: Scott A.Dietterick, Esquire �oJ3 `;• c/o Zucker,Goldberg&Ackerman,LLC GS 200 Sheffield Street,Suite 101 i Mountainside, NJ 07092 XFP-165557/sde TEAM C To' TAMI SAUSSER MULL Postmark Here 4525 Indian Court Gainesville,GA 30506 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 I Page 4 of 8 Page 5 of 8 NOTICE TO LIENHOLDERS MTED — _ -_ a aanvcy e,owES Miala:yr > 02 M $ 01-200 4282036 JUL 26 2013 i This Certificate of Mailing provides evidence that mail has been presented to LISPS.for .This fc MAlLED FROM } and International mail. S� O„a ZIPCODE 07092 From: Scott A. Dietterick, Esquire , }- c/o Zucker,Goldberg&Ackerman, LLC 6 28 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 VS XFP-165557/Sde TEAM C TO: NICOLAS GERACI Postmark Here 312 Briar Ridge Circle !. Enola, PA 17025 i County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 UNITEC?ST/1TF5 ,� This Certificate of Mailing provides evidence that mall has been presented to LISPS•for mailing.This fort � 01 ,200 and international mall. $ 0 02 AM From: !� 00042$2036 JUL 2 Scott A. Dietterick, Esquire �pFtto�ZIPCODe 1p92 c/o Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 F!`165557/sde TEA TO: JOSEPH GERACI Pos 0 Here 312 Briar Ridge Circle Enola, PA 17025 i. County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 I. i. Page 5 of 8 i I Page 6 of 8 NOTICE TO LIENHOLDERS post ; VfiEt?; T�l1T S' L - � ..�..�__. Htt'lE C?ML-SFRVM .L • �� 01620° IhIsCertif xateofMail?ngprovidesevidence that mail has been p rawntedtoUSW for m alt formrl i 0004282038 07092 and International mall. O FROM ZIP GOQ� "omt Scott A. Dietterick, Esquire fill c/o Zucker,Goldberg&Ackerman,LLC 2 6 2413 "` 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-165557/sde TEAM C To: SANDRA MATTERN Postmark Here 245 Glenn Road Camp Hill, PA 17011 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 v--q Uw i ST/�L:SFnVICf� • Z o This Certificate of Mailing provides evidence that mail has been presented to USPS•for mating.7 �,Z'..29 3 ? and International mall. 02 4282p36 JUL 07092 Scott A. Dietterick, Esquire �5� 000 ROM ZIP Go c/o Zucker,Goldberg&Ackerman, LLC n I 200 Sheffield Street,Suite 101 JUL'2 6 2013 Mountainside, NJ 07092 XF�-165557/s /COC i. To` JERRY MATTERN,SR. PostmarkHere 245 Glenn Road Camp Hill,PA 17011 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 6 of 8 I Page 7 of 8 NOTICE TO LIENHOLDERS s t1N,1'TED ST TES C _ . � ` This Certficate of Mailing provides evidence that mail has been presented to LISPS•for maaing.This fc 02 IM $ 01-200 and International mall. 0004282036 JUL 26 2013 From: Scott A. Dietterick, Esquire �lr� MAILED FROM ZIP CODE 0 7092 D� c/o Zucker,Goldberg&Ackerman,LLC f 200 Sheffield Street,Suite 101 6 Mountainside, NJ 07092 NXQ-Mj57/Sd To: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Postmark Here Domestic Relations Section 13 N.Hanover Street r PO Box 320 Carlisle, PA 17013 !: County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-DOD-9065 1JNITE>D rT/lTFS: . s riag¢�vAssovs a-POS-TALSE(.[Y./. @ F1 2 1M $ 0 .20 0004282036 JUL 26 2013 This Certificate ofMailling providles evidence that mail has been presented to LISPSI for maill rm CODE 07092 and international mall. aw FROM ZIP t Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC L i 2 �� 200 Sheffield Street,Suite 101 f Mountainside, NJ 07092 VSPS f, XFP-165557/sde TEAM C To` PA DEPT.OF REVENUE-INHERITANCE TAX DIVISION Postmark Here Dept.280601 Harrisburg, PA 17128-0601 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i, Page 7 of 8 Page 8 of 8 NOTICE TO LIENHOLDERS UN ED:: 11T S` A P° 1?�3T/1t5�RVICE`a Z � This Certilicate of Mailing provides evidence that mall has been presented to LISPS•for mallh&this fei '+ 02 1M 0 and International ma0. 0004282036 JUL 26 2013 Ff01n' Scott A. Dietterick,Esquire �t '� MAILED FROMZIF'CpDE 07092 c/o Zucker,Goldberg&Ackerman,LLC 0 200 Sheffield Street,Suite 101 `�� Mountainside, NJ 07092 2013 Cft XFP-165557/sde 7 To: UNKNOWN SPOUSE �/S g ostmark Here 1204 Capital Street Harrisburg, PA 17102-2050 F County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000.9065 i i i t s f Page 8 of 8 3 i i i SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff °qtr of ttunbet Jody S Smith '�'�+ Chief Deputy --6. '„, ,. Richard W Stewart u EE LF, _r, Solicitor OFFICE OF THE St#ERIFF PENNSYLVANIA a � 17.2U:, o I Wells Fargo Bank, N.A. vs. Case Number Jerry A. Mattern, Jr. 2012-2943 SHERIFF'S RETURN OF SERVICE 06/13/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Jerry A. Mattern, Jr., but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of Dauphin County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 07/01/2013 08:28 PM- Deputy Shawn Harrison, 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 33 Heidi Terrace, East Pennsboro-Township, Camp Hill, PA 17011, Cumberland County. 07/29/2013 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of Dauphin County upon Lauren Kubilas, Receptionist,who accepted for Jerry A. Mattern, Jr., at POB: Crump Insurance, 4135 N. Front Street, Harrisburg, PA 17110. So Answers: W. Conway, Deputy Sheriff. 09/05/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on September 04, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Jaime R.Ackerman, on behalf of Wells Fargo Bank, N.A., being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $1,099.95 SO ANSWERS, November 21, 2013 RONNK ANDERSON, SHERIFF W.00 pd•L4 a aspd . ('e 397g- 3q / (r.)Coun ySuite Sheriff Telecsoft,In . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA • • Wells Fargo Bank,N.A., . CIVIL DIVISION • Plaintiff, . NO.: 12-2943-CIVIL vs. Execution No.: Jerry A. Mattern, Jr., Administrator of the Estate : of Tammy M. Geraci; • • Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank,N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 33 Heidi Terrace, Camp Hill, PA 17011-1141. 1. Name and Address of Owner(s)or Reputed Owner(s): JERRY A. MATTERN, JR., ADMINISTRATOR OF THE ESTATE OF TAMMY M. GERACI 1204 Capital Street Harrisburg, PA 17102-2050 2. Name and Address of Defendant(s) in the Judgment: JERRY A. MATTERN, JR., ADMINISTRATOR OF THE ESTATE OF TAMMY M. GERACI 1204 Capital Street Harrisburg, PA 17102-2050 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 MERS, INC.,AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, INC.,DBA AMNET MORTGAGE ITS PO Box 2026 Flint,MI 48501-2026 AND 1901 E. Voorhees St, Ste C Danville, IL 61834 AND 3300 SW 34th Ave, Ste 101 Ocala, FL 34474-4438 AND P.O. Box 85463 San Diego, CA 92186 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: JERRY MATTERN, SR. 245 Glenn Road Camp Hill, PA 17011 SANDRA MATTERN 245 Glenn Road Camp Hill, PA 17011 JOSEPH GERACI 312 Briar Ridge Circle Enola, PA 17025 Zucker,Goldberg&Ackerman.LI:C XFP-165557 NICOLAS GERACI 312 Briar Ridge Circle Enola,PA 17025 TAMI SAUSSER MULL 4525 Indian Court Gainesville, GA 30506 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 33 Heidi Terrace Camp Hill, PA 17011-1141 UNKNOWN SPOUSE 1204 Capital Street Harrisburg,PA 17102-2050 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 GOLDBER &ACKERMA/, LLC Dated: BY: A / `, 3 Scott A. Die - ;Es Srire; PA I.D. #55650 Kimberly • Bonner, Esquire; PA.I.D. #89705 Joel A. Ac erman, 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 t� 200 Sheffield Street, Suite 101 Mountainside,NJ 07092 File No.: XFP-165557 (908)233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com Zucker.Goldberg&Ackerman.I C XFP-165557 • Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA,MORE PARTICULARLY BOUNDED AND DESCRIED IN ACCORDANCE WITH A SURVEYBY MICHAEL C. ANGELO, REGISTERED SURVEYOR,DATED DECEMBER 28, 1979, AS FOLLOWS TO WIT: BEGINNING AT A POINT,ALONG THE SOUTHERLY CURVE OF HEIDI TERRACE WHICH POINT IS 306.99 FEET IN AN EASTERLY DIRECTION FROM THE INTERSECTION OF THE HEIDI TERRACE AND DAVID DRIVE;THENCE ALONG THE SOUTHERLY LINE OF HEIDI TERRACE ALONG A CURVE TO THE LEFT HAVING A RADIUS OF 50.0 FEET,AN ARCH DISTANCE OF 38.76 FEET TO A PIN AT THE DIVIDING LINE BETWEEN THE HEARING DESCRIBED LOT AND LOT ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING LINE SOUTH 15 DEGREES 30 MINUTES 42 SECONDS EAST THROUGH THE CENTER OF A PARTITION WALL AND BEYOND A DISTANCE OF 105.88 FEET TO A PIN AT LANDS NOW OR FORMERLY OF EDAN PLACE WEST; THENCE ALONG SAID LANDS NORTH DEGREES 57 MINUTES, 00 SECONDS WEST,A DISTANCE OF 111.30 FEET TO A PIN AT THE DIVIDING LINE BETWEEN HEREIN DESCRIBED LOT AND LOT 4X ON THE HEREINAFTER MENTIONED PLAN OF LOTS,THENCE ALONG SAID DIVIDING LINE OF NORTH 30 DEGREES 3 MINUTES 00 SECONDS EAST,A DISTANCE OF 59.14 FEET TO A PIN ALONG THE SOUTHERLY LINE OF THE HEIDI TERRACE,THE PLACE OF BEGINNING. BEING LOT NUMBER 5,PLAN NUMBER 17 AT RIDLEY PARK RECORDED IN PLAN BOOK 17, PAGE 64. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 33 HEIDI TERRACE, CAMP HILL, PA, 17011-1141. BEING THE SAME PREMISES WHICH JERRY A. MA'I I ERN AND SANDRA L. MATTERN (HUSBAND AND WIFE), BY DEED DATED JULY 12, 2007 AND RECORDED JULY 27, 2007 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 281, PAGE 813, GRANTED AND CONVEYED UNTO TAMMY M. GERACI, AS SINGLE WOMAN. TAX MAP NO.: 09-17-1042-166. • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, • • vs. NO.: 12-2943-CIVIL Jerry A. Mattern, Jr., Administrator of the • Estate of Tammy M. Geraci; • • • Defendants. • • NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci 1204 Capital Street Harrisburg, PA 17102-2050 AND 33 Heidi Terrace Camp Hill, PA, 17011-1141 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 9/4/2013 at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 33 Heidi Terrace, Camp Hill,PA, 17011-1141 Zucker,Goldberg&Ackerman, LLC XFP-165557 • The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-2943-CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Jerry A. Mattern, Jr., Administrator of the Estate of Tammy M. Geraci A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten(10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle,PA 17013 Phone (800)990-9108 (717)249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. Zucker,Goldberg&Ackerman,LLC XFP-165557 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 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 GOLDBERe : ACKE',%AN, LLC i /' Dated: BY: i �� a l3 Scott A. Ole' rick, squire; PA I.D. #55650 Kimberly : .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 File No.: XFP-165557 (908) 233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com VIA CERTIFIED MAIL,RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker,Goldberg&Ackerman,LLC XFP-165557 • Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND SITUATE IN EAST PENNSBORO TOWNSHIP,CUMBERLAND COUNTY,PENNSYLVANIA,MORE PARTICULARLY BOUNDED AND DESCRIED IN ACCORDANCE WITH A SURVEYBY MICHAEL C. ANGELO,REGISTERED SURVEYOR,DATED DECEMBER 28, 1979, AS FOLLOWS TO WIT: BEGINNING AT A POINT, ALONG THE SOUTHERLY CURVE OF HEIDI TERRACE WHICH POINT IS 306.99 FEET IN AN EASTERLY DIRECTION FROM THE INTERSECTION OF THE HEIDI TERRACE AND DAVID DRIVE;THENCE ALONG THE SOUTHERLY LINE OF HEIDI TERRACE ALONG A CURVE TO THE LEFT HAVING A RADIUS OF 50.0 FEET,AN ARCH DISTANCE OF 38.76 FEET TO A PIN AT THE DIVIDING LINE BETWEEN THE HEARING DESCRIBED LOT AND LOT ON THE HEREINAFTER MENTIONED PLAN OF LOTS;THENCE ALONG SAID DIVIDING LINE SOUTH 15 DEGREES 30 MINUTES 42 SECONDS EAST THROUGH THE CENTER OF A PARTITION WALL AND BEYOND A DISTANCE OF 105.88 FEET TO A PIN AT LANDS NOW OR FORMERLY OF EDAN PLACE WEST;THENCE ALONG SAID LANDS NORTH DEGREES 57 MINUTES, 00 SECONDS WEST, A DISTANCE OF 111.30 FEET TO A PIN AT THE DIVIDING LINE BETWEEN HEREIN DESCRIBED LOT AND LOT 4X ON THE HEREINAFTER MENTIONED PLAN OF LOTS,THENCE ALONG SAID DIVIDING LINE OF NORTH 30 DEGREES 3 MINUTES 00 SECONDS EAST,A DISTANCE OF 59.14 FEET TO A PIN ALONG THE SOUTHERLY LINE OF THE HEIDI TERRACE,THE PLACE OF BEGINNING. BEING LOT NUMBER 5,PLAN NUMBER 17 AT RIDLEY PARK RECORDED IN PLAN BOOK 17, PAGE 64. HAVING THEREON ERECTED A DWELLING HOUSE BEING KNOWN AND NUMBERED AS 33 HEIDI TERRACE, CAMP HILL, PA, 17011-1141. BEING THE SAME PREMISES WHICH JERRY A. MATTERN AND SANDRA L. MATTERN(HUSBAND AND WIFE), BY DEED DATED JULY 12, 2007 AND RECORDED JULY 27,2007 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, IN DEED BOOK VOLUME 281, PAGE 813, GRANTED AND CONVEYED UNTO TAMMY M. GERACI,AS SINGLE WOMAN. TAX MAP NO.: 09-17-1042-166. WRIT OF EXECUTION and/or ATTACHMENT • COMMONWEALTH OF PENNSYLVANIA) NO. 12-2943 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 JERRY A. MATTERN,JR.,ADMINISTRATOR OF THE ESTATE OF TAMMY M. GERACI (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: $113,612.91 L.L.: $.50 Interest FROM 4/23/2012 TO DATE OF SALE-$9,313.19 Atty's Comm: Due Prothy:$2.25 Atty Paid: $245.50 Other Costs: Plaintiff Paid: Date: 3/28/13 David D. Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name:JAIME R.ACKERMAN,ESQUIRE Address: ZUCKER,GOLDBERG&ACKERMAN,LLC 200 SHEFFIELD STREET,SUITE 101 MOUNTAINSIDE,NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No.311032 TF U COPY FROM RECOR© In Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle,Pa. This day of MQrcM20 /2 L&b �PrZnota • LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2012-2943 Civil Term by deed dated July 12, 2007 and recorded July 27, 2007 in and for WELLS FARGO BANK,N.A. Cumberland County, Pennsylvania, in Deed Book Volume 281,Page 813, vs. granted and conveyed unto Tammy JERRY A. MATTERN,JR. M. Geraci,as single woman. Atty.:Jaime R.Ackerman TAX MAP NO.: 09-17-1042-166. ALL THAT CERTAIN tract or par- cel of land situate in East Pennsboro Township, Cumberland County, Pennsylvania, more particularly bounded and descried in accordance with a survey by Michael C.Angelo, Registered Surveyor,dated December 28, 1979,as follows to wit: BEGINNING at a point, along the southerly curve of Heidi Terrace which point is 306.99 feet in an easterly direction from the intersec- tion of the Heidi Terrace and David Drive; thence along the southerly line of Heidi Terrace along a curve to the left having a radius of 50.0 feet, an arch distance of 38.76 feet to a pin at the dividing line between the hearing described lot and lot on the hereinafter mentioned Plan of Lots; thence along said dividing line South 15 degrees 30 minutes 42 seconds East through the center of apartition wall and beyond a distance of 105.88 feet to a pin at lands now or formerly of Edan Place West;thence along said lands North degrees 57 minutes, 00 seconds West, a distance of 111.30 feet to a pin at the dividing line be- tween herein described Lot and Lot 4x on the hereinafter mentioned Plan of Lots, thence along said dividing line of North 30 degrees 3 minutes 00 seconds East,a distance of 59.14 feet to a pin along the southerly line of the Heidi Terrace, the place of BEGINNING. BEING Lot Number 5,Plan Num- ber 17 at Ridley Park recorded in Plan Book 17,Page 64. HAVING THEREON ERECTED a dwelling house being known and numbered as 33 Heidi Terrace,Camp Hill,PA, 17011-1141. BEING the same premises which Jerry A. Mattern and San- dra L.Mattern (husband and wife), 75 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: July 26, August 2 and August 9, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. , k v isa Marie Coyn , Editor SWORN TO AND SU SCRIBED before me this 9 da of Au.ust 2013 A _/.act/.:L I" Notary NOTARIAL.SEAL DEBORAH A COLLINS Notary Fut lic CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 a The Patriot-News Co. 1900 Patriot Drive e patriotNtws • Mechanicsburg, PA 17050 Inquiries - 717-255-8213 Now you know CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Michael J. Morrow, being duly sworn according to law, deposes and says: That he is the 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 1900 Patriot Drive, 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 he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. 2012-2943 Clvll Tenn FARGO BANK, This ad ran on the date(s)shown below: RRY A.MATTERN,J ' 07/28/13 Jaime R Ackenna ALL THAT CERTAIN 'TRACT OR 08/04/13 PARCEL OF LAND SITUATE IN 08/11/13 EAST PENNSBORO TOWNSHIP, - CUMBERIAND COUNTY, i . PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIED IN ACCORDANCE WITH A SURVEY BY MICHAEL C.ANGELO, REGISTERED SURVEYOR, DATED Sworn 2 an. • .scribed be are me thi 3 d.y of August, 2013 A.D. DECEMBER 28,1979,AS FOLLOWS TO lir BEGINNING AT A-PO \ I THE SOUTHERLY CURVE HEIDI �� -� A .4' TERRACE WHICH POINT IS 306.99 otas( ' b_ — -i 11.E1' IN AN EASTERLY DIRECTION- FROM THE INTERSECTION OF THE HEIDI TERRACE AND DAVID DRIVE; THENCE ALONG THE SOUTHERLY LINE OF HEIDI TERRACE ALONG COMMONWEALTH OF PENNSYLVANIA A CURVE TO THE LEFT: `tirING Notarial:ealA RADIUS OF 50.0 FEET AN ARCH Holly Lynn Warfel,Notary Public DISTANCE OF 38.76 FEET TO A PIN AT Washington Twp.,Dauphin County THE DIVIDING LINE BETWEEN THE i My Commission Expirs Dec. 12,2016 HEARIN DESCRIBED LOT AND-LOT MEMBEER PENN YI.VANIA A±qC'1A11OiI OF NOTARIES ON THE HEREINAFTER MENTIONED PLAN .OE... nuyreu SAID DIVIDING 5 15 1. ' DEGREES 30 MINUTES 42 SECONDS (NV e COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Wells Fargo Bank,NA is the grantee the same having been sold to said grantee on the 4th day of Setpember A.D., 2013, under and by virtue of a writ Execution issued on the 28th day of March, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 2943, at the suit of Wells Fargo Bank,NA against Jerry A. Mattern Jr., Administrator of the Estate of Tammy M. Geraci is duly recorded as Instrument Number 201400300. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of "yiug,,,____, A.D. 020/f 0 . ! , 'ecorder of Deeds Recorder of 1 eds,Cumberland County,Carlisle,PA My Commission Expires the First Monday of Jan.2018