HomeMy WebLinkAbout12-3423IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.,
Plaintiff,
VS.
CIVIL DIVISION -? r."` i i - ':
aSYL'rP?NIA
TYPE OF PLEADING
Zidane M. Lamchaouri;
Defendant.
TO: DEFENDANT
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE (HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED
AGAINST YOU.
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
3476 Stateview Blvd- MAC # X7801-013, Ft. Mill, 29715
AND THE DEFENDANT:
302 April Drive
Camp Hill, PA 17011-5008
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
5008
ATTORNEY40W PLAI
ATTY FKE NO.: XFP 163895
CIVIL ACTION - COMPLAINT
IN MORTGAGE FORECLOSURE
FILED ON BEHALF OF:
Wells Fargo Bank, N.A.
COUNSEL OF RECORD FOR THIS PARTY:
ZUCKER, GOLDBERG & ACKERMAN, LLC
Scott A. Dietterick, Esquire
Pa. I.D. #55650
Kimberly A. Bonner, Esquire
Pa. I.D. #89705
Joel A. Ackerman, Esquire
Pa I.D. #202729
Ashleigh Levy Marin, Esquire
Pa I.D. #306799
Ralph M. Salvia, Esquire
Pa I.D. #202946
Jaime R. Ackerman, Esquire
Pa I.D. #311032
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500
(908) 233-1390 FAX
office(@zuckereoldberg.com
File No.: XFP-163895/mme
NY-? a - 7
s? a?.
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'IHIS 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.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
CIVIL DIVISION
Plaintiff,
NO..
VS.
Zidane M. Lamchaouri;
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
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
CIVIL DIVISION
Plaintiff,
NO..
VS.
Zidane M. Lamchaouri;
Defendant(s).
AVISO
USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las
siguientes ppginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n
de esta Denjanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia
esc rita y radiicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su
contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso
puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la
demanda O'',cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en
contra Suva'por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para
usted.
LISTED DEBIT LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN
ABOGADO b 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
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
NO..
VS.
Zidane M. Lamchaouri;
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, Zidane M. Lamchaouri, is an individual whose last known address is 302
April Drive, Camp Hill, PA 17011-5008.
3. On or about October 26, 2009, Zidane M. Lamchaouri executed a Note in favor of
Wells Fargo Bank, NA in the original principal amount of $137,464.00.
4. On or about October 26, 2009, as security for payment of the aforesaid Note, Zidane
M. Lamchaouri, a married person made, executed and delivered to Wells Fargo Bank, NA a Mortgage
in the original principal amount of $137,464.00 on the premises hereinafter described, with said
Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on November
6, 2009, Instrument #200937697. A true and correct copy of said Mortgage containing a description
of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part
hereof.
5. Defendant is in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest being contractually due for
the October 2011 payment, and pursuant to the terms of the aforesaid Mortgage, after written
notice of said default to Defendant(s), the entire principal balance and accrued interest due
thereunder has been accelerated.
6. Zidane M. Lamchaouri, married man is the record and real owner of the aforesaid
mortgaged premises.
7. On April 26, 2012, Defendant(s) were mailed a Notice of Intention to Foreclose
Mortgage, in compliance with Act 6 of 1974, 41 P.S. §101, et seq.
8. The amount due and owing Plaintiff by Defendant(s) is as follows:
Principal $133,989.45
Interest through 05/10/2012 $5,094.67
Escrow Advance $403.46
Suspense Balance ($827.19)
Late Charges $181.92
Inspection Fees $160.00
Total $139,002.31
plus interest on the principal sum ($133,989.45) at the daily per diem amount of $20.19, 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.
9. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is
not seeking' a judgment of personal liability against the Defendant(s), but reserves its right to do so in
a separate legal action if such right exists. If Defendant(s) have received a discharge of personal
liability under the aforesaid Note in a bankruptcy proceeding, this action is in no way an attempt to
re-establish such liability.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of
$139,002.31, with interest thereon at daily per diem amount of $20.19 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, GOLDBE & ACKERMAN, LLC
Dated: -1) V By:
/ Scot Dietterick, Esquire; PA I.D. #55650
Ki erly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP-163895/mme
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
'*IS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
EXHIBIT A
? y
Prepared By:
WELLS FARGO BANK, N.A.
6155 ROCKSIDE ROAD, SUITE 115,
INDEPENDENCE, OR 441312207
Return To:
WFHM FINAL DOCS X2599-024
405 SW 5TH STREET
DES MOINES, IA 50309-4600
Parcel Number:
Premises:
302 APRIL DR
CAMP HILL
Nllllllld ?°
00,MF,
[Space Above This Line For Recording Data)
w -'- Nn
Commonwealth of Pennsylvania MORTGAGE
THIS MORTGAGE ("Security Instrument") is given on OCTOBER 26, 2009
The Mortgagor is ZIDANE M LAMCHAOURI, A MARRIED PERSON
("Borrower"). This Security Instrument is given to WELLS FARGO BANK, N.A.
WELLS FARGO BANK, N.A.
which is organized and existing under the laws of THE UNITED STATES , and
whose address is P.O. BOX 11701, NEWARK, NJ 071014701
("Lender"). Borrower owes Lender the principal sum of
ONE HUNDRED THIRTY SEVEN THOUSAND FOUR HUNDRED SIXTY FOUR AND 00/100
Dollars (U.S. S ********137,464. 00 NMFL i#0642 (PAFM) Rev 412412006
FHA Pennsylvania Mortgage • 4/96
at : -4ROA) (osoa)
vMP Mortgage Soluaona, Inc.
Pays 1 of 9 Initlals:_ L`
,-
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
NOVM40R 01, 2039 . This Security Instrument secures to Lender: (a) the repayment
of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the
Note; (b)'', the payment of all other sums, with interest, advanced under paragraph 7 to protect the security
of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this
Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to
the Lender the following described property located in CUMERLAND
County, Pennsylvania:
**SEE ATTACHED
which has the address of 302 APRIL DR fstueer]
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 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.
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 special 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 Peivelopment ("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
Initials:`
7
(k'4RlPAl P5W) Pape 2 of 9
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 fly the Secretary instead of the monthly mortgage insurance premium;
S n to any taxes, special assessments, leasehold payments or ground rents, and fire, llood'and
other hazard insurance premiums, as required;
Third. to interest due under the Note;
Fo h to amortization of the principal of the Note; and
Fi 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
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.
"itlals:Z-+ L
4R.01(PA) (owe) Paps 3 of 9
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. Qccupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan
Application; Leaseholds. Borrower shall occupy, establish, and use the Propetty 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
Borrowee'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. Lcnder 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 Instnunent, 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.
7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all
governrrtental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower
shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would
adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly furnish
to Lender receipts evidencing these payments.
If Borrower fails to make these payments or the payments required by paragraph 2, or 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 to
bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is
necessary to protect the value of the Property and Lender's rights in the Property, including 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
Initials.
IR-4R(PA) (Owei Page 4 of 9
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 Gam-St. Germain Depository Institutions Act of 1982, 12 U.S.C.
1701j-3(d)) and with the prior approval of the Secretary, require immediate payment in 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.
(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 sepured 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 iE (i) Lender has accepted reinstatement after the commencement of foreclosure
proceedings within two years immediately preceding the commencement of a current foreclosure
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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 for 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 pre elude 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-
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.
14.1 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 affecting 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, keroseng, 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,
Initials:
1t-4R(PA) (0506) Page 6 of 9
"Environimental 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. 11pwever,
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 Fender 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
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.
Leader 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 II expenses incurred in pursuing the remedies provided in this paragraph 18, including, but
not limi eid to, attorneys' fees and costs of title evidence.
If (he Lender's interest in this Security Instrument is held by the Secretary and the Secretary
require$ 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 etseq.) 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.
19.1 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 lalws providing for stay of execution, extension of time, exemption from attachment, levy and sale,
and homestead exemption.
2L 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.
Initials: 7-4M
tk-4RlP'A) (05w) Page 7&9
24. Riders to this Security Instrument. If one or more riders are executed by Borrower and
recorded together with this Security Instrument, the covenants of each such rider shall be incorporated into
and shallamend and supplement the covenants and agreements of this Security Instrument as if the rider(s)
were a port of this Security Instrument. [Check applicable box(es)].
? Condominium Rider ? Growing Equity Rider ? Other [specify]
? Planned Unit Development Rider ? Graduated Payment Rider
BY SIGNING BELOW, Borrower accepts and agrees to the terms contained in this Security
Instrument and in any rider(s) a `bq?$orrower and recorded with it.
Witness ^
(Seal)
MAKE M LAMCHAOURI -Borrower
-(Seal)
-Borrower
(Seal)
-Borrower
-(Seal)
-Borrower
-(Seal) (Seal)
-Borrower -Borrower
_ (Seal) (Seal)
-Borrower -Borrower
4R.4R(PA) (ows) Page 8 of 9
' ` , 4 .
COMMONWEALTH OF PENNSYLVANIA,?`? County ss:
On this, 26TH day of OCTOBER 2009 , before me, the undersigned officer,
personally appeared ZIDANE M LAMCHAOURI
known to me (or satisfactorily proves) to be the
person(s) whose name is/are subscribed to the within instrument and acknowledged that he/she/they
executed the same for the purposes herein contain
IN WITNESS WHEREOF, I hereunto set m hand official 1.
My Commission Expires:
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
CAROL L. TROXELL, Notary Public Title of Officer
New Cumberland 9oro. Cumberland Co.
My Commission Expires Dec. 27, 2009
Cer ' of Residence
I, S ,, do hereby certify that the correct address of
the within-named Lender is P.0. BOX 11701, NEWARK, NJ 071014701
Witness my hand this 26TH day of OCTOBER
Agent of Lender
Initials: ?`-'
-4R?PA} (pspg) Pape 9 of 9
LEGAL DESCRIPTION
ALL-THAT CERTAIN piece or parcel of land, situate in the Borough of Camp Hill, (formerly Hampden Township),
County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit:
BEGINNING at a point on the Southern side of April Drive, which point is at the division line of Lots Nos. 113 and
114 on the hereinafter mentioned plan of lots; thence South 84 degrees 42 minutes -East along the
aforementioned' April Drive a distance of 65 feet to a point at the division line of Lot Nos. 112 and 113; thence
South 5 degrees 18 minutes West along the said division line a distance of 100.09 feet to a point on the northerly
right of way line of Route 767; thence North 84 degrees 42 minutes West along the aforementioned right of way,
Route 767 a diance of 65 feet to a point at the division line of Lots Nos. 113 and 114; thence North 5 degrees 18
minutes East along said division line a distance of 100.09 feet to a point, the PLACE OF BEGINNING.
IT BEING Lot No. 113, Block "E" on plan of Lots of Trindle Village, Section 3, which plan is recorded in and for the
County of Cumberland in Plan Book 10, Pages 54, 55 and 56.
HAVING THEREON ERECTED a dwelling house known and numbered as 302 April Drive.
UNDER AND SUBJECT NEVERTHELESS to easements, restrictions, reservation, conditions and rights of way of
record.
BEING THE SAME PREMISES which Luther James Miller and Edna Ruth Miller, his wife by their Deed dated
May 1, 1987 and recorded May 1. 1987 in the Office of the Recorder of Deeds in and for the County of
Cumberland, Pennsylvania, in Deed Book 032, Page 196, granted and conveyed unto Elton E. Manske and
Aibina E. Manske, his wife, Grantors herein.
ALSO BEINGjthe same premises which Wanda G. Phillips, Attorney-in-Fact for Albina E. Manske,
Grantors, agreed to sell by Installment Sales Contract dated September 2, 2008 and recorded September
10, 2008 in Instrument Number 200830746, in the office of the Recorder of Deeds in and for the County of
Cumberland, Pennsylvania, to Zidane M. Lamchaourl and Modem M. Oumzll, husband and wife, Grantee.
BEING the sa a premises which Elton E. Manske and Albina E. Manske, his wife by their Dead dated
2009 and about to be recorded In the Office of the Recorder of Deeds in and for the
County of Cumberland, Pennsylvania, granted and conveyed unto Zidane M. Lanchaourl ,Mortgagor herein.
ALTA Commitment
Schedule A (continued)
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 200937697
Recorded on 11/6/2009 At 2:13:03 PM
* Instrument Type - MORTGAGE
Invoice Number - 55654 User ID - AF
* Mortgagor - LAMCHAOURI, ZIDANE M
* Mortgagee - WELLS FARGO BK N A
* Customer - CEDAR CLIFF
* FEES
STATE WRIT TAX $0.50
STATE JCSjACCESS TO $10.00
JUSTICE
RECORDING FEES - $23.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00
FEES
AFFORDA$LZ HOUSING $11.50
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $60.50
* Total Pages -11
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
f ev e
,o
o
RECORDERIO /1)7E S
t?eo
• - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
uimauaiiiVuiu
, . ,
VTR IFI(':1"I O
Ismael Iicrnandez, hereh? States thao lie is Vice Presidenl Luau
L)tlcunlentatic)n ufWFUS TAR(;O BANK. N.A.. plaintiff ur murt,,,i .e srrv iciml ?l;rent
161- iIlaintitf in this mv.ltter, that lJhe is autWzed tt? make this \-'eriticatit>n_ Lind ?erif?
that the -tateme?lls made ill the it,rc,-roil ( i1 ll \c'tikm Cl MOrtL'a?-.k: It)Icclt»urc '!I."' trUC
anti C(wrect to the hest cat pis ier inftirnlitioll and helicf'. H IL., unilcrsi?,.?neci ulldcr,tunds
that this statement is made subject to the henaltics r,f 18 Pa. ('.S. Scc. 4904 rcLltinr' to)
ll:i5?1'(?rll talslficatiml to "luthurili,_'s.
On, Nanic?: isnlac-l I lc:rnarulc/
L)_VL.l
l itir: Vice President I t),m
I )()c Lill lentatit,n
How 1618
Nanle: i.A'\U'NAO URI
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff, NO..
vs. o? Ott 1 ?}
Zidane M. Laimchaouri; "
Defendant(s).
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you
may be able to participate in a court-supervised conciliation conference in an effort to resolve this
matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact 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 0 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
XFP-163895
ZUCKER, GOLDBERG & AC MAN, LLC
Dated: May ?Y , 2012 BY:
Scott A. 15 ri k, Esquire; PA .D. #55650
Kimber 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-163895/jab
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
Email: Office@zuckergoldberg.com
Zucker, Goldberg & Ackerman, LLC
XFP-163895
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date:
Cumberland' County Court of Common Pleas Docket #
BORROWEk REQUEST FOR HARDSHIP ASSISTANCE
To complete. your request for hardship assistance, your lender must consider your circumstances to
determine possible options while working with your
Please provide the following information to the best of your knowledge:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different):
City:
Phone Numbers:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
Yes ? No ? Listing date
State: Zip:
Price: $
Realtor Phone:
Yes ? No ?
Home:
Cell:
State
Office: _
Other:
How long?
State: Zip:
Home: Office:
Cell: Other:
How long?
First Mortgajgje Lender:
Type of Loam:
Loan Number:
Second Mortgage Lender:
Type of Loam:
Loan Number:
Total Mortgage Payments Amount
Date of Last Payment:
Primary Regspn for Default:
Is the loan in Bankruptcy? Yes ? No ?
If yes, provide names, location of court, case number & attorney:
Included Taxes & Insurance:
Zip:
Zucker, Goldberg & Ackerman, LLC
XFP-163895
uate you ciosea your loan:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1:
Amount owed:
Automobile #2:
Amount owed:
Model:
Model:
Value:
Year:
Year:
Monthly Incprne
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/rejpairs Other prop. payment
Install. LoanjPayment 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:
Counselor:
Phone (Office):
Email:
Fax:
Value:
Zucker, Goldberg & Ackerman, LLC
XFP-163895
r .
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):
Servicing Company (Name):
Contact:
Phone:
Phone:
[/We, , authorize the above named to use/refer this
information to my lender/servicer for the sole purpose of evaluating my financial situation for possible
mortgage options. I/We understand that I/we am/are under no obligation to use the services provided
by the above named
Borrower Signature
Co-Borrower Signature
Date
Please forward this document along with the following information to lender and lender's counsel:
Proof of Income
Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of current utility bill
Letter explaining reason for delinquency and any supporting documentation (hardship letter)
Listing agreement (if property is currently on the market)
Date
Zucker, Goldberg & Ackerman, LLC
XFP-163895
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
NO..
VS.
Zidane M. Lamchaouri;
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;
1. Defendant lives in the subject real property, which is defendant's primary residence;
2. 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 o Defendant's Counsel/Appointed Date
Legal Representative
Signature of!Defendant
Signature oflDefendant
Date
Date
Zucker, Goldberg & Ackerman, LLC
XFP-163895
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
CIVIL DIVISION
Plaintiff,
NO..
VS.
Zidane M. Lamchaouri;
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
1. 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.
2. 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
Defendant(s).
CASE MANAGEMENT ORDER
Zucker, Goldberg & Ackerman, LLC
XFP-163895
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.
3. 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.
4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation
conference.
BY THE COURT,
J.
Zucker, Goldberg & Ackerman, LLC
XFP-163895
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart e h--1s' BEiiL + `f L.iJt
Solicitor QFrICE OF T- F VIERIFF P E N'' N S Y 1.-VA 111 A
Wells Fargo Bank, N.A. Case Number
vs. 2012-3423
Zidane M. Lamchaouri
SHERIFF'S RETURN OF SERVICE
05/30/2012 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: Zidane M. Lamchaouri, but was unable to locate him in
his bailiwick. He therefore deputized the Sheriff of Dauphin County, Pennsylvania to serve the within
Complaint In Mortgage Foreclosure according to law.
05/31/2012 05:10 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on May
31, 2012 at 1710 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Merieum Oumzil, adult in charge at 302 April Drive, Camp Hill,
Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the
said true and correct copy of the same.
41Z-
STEFSHEWBENbER, DEPUTY
06/04/2012 11:03 AM - Dauphin County Return: And now June 4, 2012 at 1103 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: Zidane M. Lamchaouri by
making known unto Abdelouahab Latafa, adult in charge at 322 N. Second Street, Steelton, Pennsylvania
17113 its contents and at the same time handing to her personally the said true and correct copy of the
same.
SHERIFF COST: $68.00
June 06, 2012
SO ANSWERS,
." 4ate- ?
RON R ANDERSON, SHERIFF
Lc? GounfySuite Sheriff, Telecsoft_ Inc.
?
tfice of tEte 1`?exif?
William T. Tully
Solicitor
Commonwealth of Pennsylvania
County of Dauphin
Jack Lotwick
Sheriff
Jack Duignan
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
WELLS FARGO BANK, N.A.
VS
ZIDANE M. LAMCHAOURI
Sheriff s Return
No. 2012-T-1601
OTHER COUNTY NO. 2012-3423
And now: JUNE 4, 2012 at 11:03:00 AM served the within COMPLAINT IN MORTGAGE
FORECLOSURE upon ZIDANE M. LAMCHAOURI by personally handing to ABDELOUAHAB
LATAFA 1 true attested copy of the original COMPLAINT IN MORTGAGE FORECLOSURE and
making known to him/her the contents thereof at 322 N. SECOND STREET STEELTON PA 17113
ROOMMATE OF DEFENDANT AND PERSON IN CHARGE AT TIME OF SERVICE
Sworn and subscribed to So Answers,
before me this 5TH day of June, 2012 p 1,
-)P*2
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Karen M. Hoffman, Notary Public
City of Harrisburg, Dauphin County
M Commission Expires August 17, 2014
Dauphin County
101 Market Street
Harrisburg, Pennsylvania 17101-2079
ph: (717) 780-6590 fax: (717) 255-2889
Sheri f Dauphin Co , Pa.
By tq^- Dep Sheriff VF' 1VV
De : J MILLER
Sh ffs Costs: $43.25 6/1/2012
Wells Fargo Bank, N.A. : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANI)
V. : Docket No. 2012-3423
Zidane M. Lamchaouri,
Defendant : CIVIL ACTION- MORTGAGE FORECLOSUI
- , -x
PRAECIPE FOR ENTRY OF APPEARANCE
)
TO THE PROTHONOTARY:, -
E c,
e CO
Please enter the appearance of MidPenn Legal Services on behalf of the Defendant,
Zidane M. Lamchaouri, in the above matter, representing the Defendant in the Cumberland
County Residential Mortgage Foreclosure Diversion Program.
Respectfully Submitted,
MIDPENN LEGAL SERVICES
DATE: August 7, 2012
Atto a for Defendant
Supr e Ct. ID # 310094
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
service of the completed Form 2 is to be made and maybe extended. Upon notice to
the Court of the defendant/borrower's failure to serve the completed Form 2 with the
time frame set forth herein or such other date as agreed upon by the parties in writin~
or ordered by the Court, the case shall be removed from the Conciliation
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 must discuss resolution proposals with the authorized representati
in advance of the Conciliation Conference. If the duly authorized representative of
plaintiff/lender is not available by telephone during the Conciliation Conference,
court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the
Conciliation Conference.
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discus and explore all available resolution options which shall include: bringing
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
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or 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.
DISTRIBUTION:
l
~/ Amy Hirakis, Esquire ~~?(}
MidPenn Legal Services
401 E. Louther Street, Ste 103
C D~ 1P.5 ~ I ~
'
Carlisle, PA 17013 8 ~
tw
D
For the Defendant
~ Zucker, Goldberg & Ackerman, LLC
200 Sheffield Street, Ste 101
Mountainside, NJ 07092
For the Plaintiff
WELLS FARGO BANK, N.A., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVIA~ = ,
-p 3 w `-•4
vs. CIVIL ACTION -LAW ~~ ~ ~--
NO. 12-3423 CIVIL v,~ ~, ~,_
ZIDANE M. LAMCHAOURI, ,~`~- ° °~;
Defendant "c ~
Z- C'7
~ ~' `~'
t~ -t' i
-a. .,..
' ~..
T ~.~} L..:%; .,.
IN RE: om
CONCILIATION CONFERENCE ~- _ -
-- _ c~ -
MEMORANDUM AND ORDER
Present at a conciliation conference held November 30, 2012, were Ralph M. Salvia,
Esquire, attorney for the plaintiff; Jaime M. Haley, Esquire, attorney for the defendant; and
Zidane M. Lamchaouri.
This matter continues to be under review. Any outstanding documents will be submitted
within a week from today. It is hoped that the review process will be completed shortly
thereafter. A further conciliation conference will be set by order of even date herewith.
ORDER
AND NOW, this 30 ` day of November, 2012, continued conciliation conference in
this matter is set for Wednesday January 16, 2013, at 9:30 a.m. in Chambers of the undersigned.
/ Ralph M. Salvia, Esquire
For the Plaintiff
~ime M. Haley, Esquire
For the Defendant
:rim
BY THE COURT,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
Plaintiff,
vs.
Zidane M. Lamchaouri;
Defendant.
CIVIL DIVISION
NO.: 12 -3423 CIVIL
PRAECIPE TO SUBSTITUTE SUCCESSOR PARTY
PURSUANT TO PA.R.C.P. 2352
TO THE PROTHONOTARY:
r CD —o
p,) C A c?
•
t,.)
Please substitute the Plaintiff /Party Wells Fargo Bank, N.A. with "CP -SRMOF II 2012 -A Trust, by
U.S. Bank Trust National Association, not in it's individual capacity but solely as Trustee ", pursuant to an
assignment of mortgage dated October 3rd, 2013 and recorded October 21, 2013, in the office of the
Recorder of Deed of Cumberland County as instrument number 201334376, which Assignment was
executed by The Secretary of Housing and Urban Development, and assigned the Mortgage which of the
subject of the above - captioned matter to CP -SRMOF II 2012 -A Trust, by U.S. Bank Trust National
Association, not in it's individual capacity but solely as Trustee. Pursuant to an assignment of mortgage
dated on July 31st, 2013 and recorded on October 2nd 2013 as instrument number 201332584, which
Assignment was executed by Wells Fargo Bank, N.A. and assigned to The Secretary of Housing and
Urban Development.
Bv.
Dated: 3/10/14
ZUCK R, GOLDBERG : MAN LLC
4141%
S A. Dietterick, squire; °A I.D. #55650
Ki •erly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Jana Fridfinnsdottir, Esquire; PA I.D. #315944
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Attorneys for Plaintiff
XFP- 163895/jf
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233 -8500; (908) 233 -1390 FAX
Email: Office @zuckergoldberg.com
$q.5o PQ 11
a ft/ar39
3o3JlaI
EXHIBIT A
Inst. # 201334376 - Page 4 of 4
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717 -240 -6370
Instrument Number - 201334376
Recorded On 10/21/2013 At 12:49:00 PM
* Instrument Type - ASSIGNMENT OF MORTGAGE
Invoice Number - 149729 User ID - SW
* Mortgagor - LAMCHAOURI, ZIDANE M.
* Mortgagee - CP -SRMOF II 2012 -A TRUST
* Customer - SIMPLIFILE LC E- RECORDING
*FEES
STATE WRIT TAX $0.50
STATE JCS /ACCESS TO $23.50
JUSTICE
RECORDING FEES — $11.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $15.00
FEES
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $55.50
* Total Pages - 4
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 OF DEEDS
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
Inst. # 201334376 - Page 3 of 4
Exhibit NA"
Alt. THAT CERTAIN piece or parcel of land, situate in the Borough of Camp Hill, (formerly Hampden Township),
County CE
y of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit•.
BEGINNING at a point on the Southern side of April Drive, which point Is at the division line of lots Nos, 113 and
114 on the hereinafter mentioned plan of lots; thence South 84 degrees 42 minutes East along the
aforementioned April Drive a distance of 65 feet to a point at the division fine of Lot Nos. 112 and 113; thence
South 5 degrees 18 minutes West along the said division line a distance of 100.09 feet to a point on the northerly
right of way line of Route 767; thence North 84 degrees 42 minutes West along the aforementioned right of way,
Route 767 a diatance of 85 feet to a point at the division line of Lots Nos. 113 and 114; thence North 6 degrees 18
minutes East along said division line a distance of 100.09 feet to a point, the PLACE OF BEGINNING.
IT BEING Lot No. 113, Block "E" on plan of Lots of Trindle Wage, Section 3, which plan is recorded in and for the
County of Cumberland In Plan Book 10, Pages 54, 55 and 56.
HAVING THEREON ERECTED a dwelling house known and numbered as 302 April Drive.
Dated: -OCT 0 1 7113
State of TaXIIN
County of Herds
Before me, )vm. t,' • 1/4°,, , duly commissioned Notary Public, on this day personally
Dan Shimmi
appeared Senior ViCe Preelftlthown to me (or proved to me on
the oath of or through N., ) to be the person whose name is subscribed to the
foregoing instrument and acknowledged to me that he/she executed the same for the purposes and consideration
therein expressed,
Inst. # 201334376 - Page 2 of 4
ASSIGNOR: The Secretary of Housing and Urban Development
by Selene Finance LP, its attorney-in-fact*
By:
Name:
Title:
Dan shimmin
Senior Vice President
- • •• -
;...1 4 ••••
fewer ail A-14.071 (exorded 44-
y-mononeni- 4 ori334;7a ;r1 Cumberkrid
e)Pcieti rezeryls.
Given under my hand and seal of office this
day of Odeber , 20 j3_.
Notary Public's Signature
Printed Name: ikplki ()■.c c‘r112)4
My Commission Expires:
,•
Inst. # 201334376 - Page 1 of 4
CERTIFIED PROPERTY IDENTIFICATION NUMBERS
01 -22- 0531 -109 - CAMP HILL BORO
CCGIS REGISTRY 10/21/2013 BY DC
PREPARED BY:
CP -SRMOF II 2012 -A Trust, U.S. Bank
Trust National Association, not in its
individual capacity but solely as Trustee
c/o 9990 Richmond AVE, Suite 400 South
Houston, TX 77042
WHEN RECORDED RETURN TO:
Avenue 365 Lender Services
401 Plymouth RD, Ste. 550
Plymouth Meeting, PA 19462
Parcel ID: 01 -22 -0531 -109
ASSIGNMENT OF MORTGAGE
FOR VALUE RECEIVED, the undersigned, The Secretary of Housing and Urban Development, located at 451
7th Street S.W., Washington, DC 20410 ("ASSIGNOR/GRANTOR"), hereby grants, conveys, assigns to: CP-
SRMOF II 2012 -A Trust, U.S. Bank Trust National Assodation, not in Its individual capacity but solely as
Trustee, located at c/o 9990 Richmond AVE, Suite 400 South, Houston, TX 77042 ( "ASSIGNEE/GRANTEE ")
all beneficial interest under that certain MORTGAGE dated 10/26/2009, and executed by ZIDANE M.
LAMCHAOURI, A MARRIED PERSON, borrower(s) to WELLS FARGO BANK, N.A., as original lender,
and certain instrument recorded 11/62009, in INSTRUMENT NUMBER 200937697, in the Official Records of
Cumberland County, the State of Pennsylvania, given to secure a certain Promissory Note in the amount of
$137,464.00 covering property located at: 302 APRIL DR, Camp Hill, Pennsylvania, 17011.
LEGAL DESCRIPTION ATTACHED AS EXHIBIT A.
TOGETHER with the note or notes therein described and secured thereby, the money due and to become due
thereon, with interest, and all rights accrued or to accrue under said Mortgage including the right to have
reconveyed, in whole or in part, the real property described therein.
CERTIFICATE OF BUSINESS RESIDENCE: 1, j?.(i /tii Jf/ , do certify that the
Assignee's precise residence iscfo 9990 Richmond AVE, Suite 400 South, Houston, TX 77042. Witness my
hand this ;'.3w day of (`i)bbe , 20 F• •
Exhibit g
Inst. # 201332584 - Page 4 of 4
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
Instrument Number - 201332584
Recorded On 10/2/2013 At 3:16:59 PM
* Instrument Type - ASSIGNMENT OF MORTGAGE
Invoice Number - 148486 User II) - BMM
* Mortgagor - LAMCHAOURI, ZIDANE M
* Mortgagee - HOUSING & URBAN DEV SEC
*Customer - SIMPLIFILE LC E-RECORDING
*FEES
STATE WRIT TAX $0.50
STATE JCS/ACCESS TO $23.50
JUSTICE
RECORDING. FEES — $11.50
RECORDER OF DEEDS
PARCEL CERTIFICATION $15.00
FEES
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $55.50
* Total Pages - 4
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
I Certify this to be recorded
in Cumberland County PA
e....0eA'4-vr7°
RECORDER OF DEEDS
* - Information denoted by an asterisk may change during
the verification process and may not be reflected on this page.
Inst. #,201332584 - Page 3 of 4
EXHIBIT A — LEGAL DESCRIPTION
Ald..,THAT dERTAIK pfPCua< or parcel of land, situate in the Borough of Champ HE, (formerly Hampden Township).
County of Cumberland and State of Pennsylvania, more particularly bounded and descn`bed as follows, to wit:
BEGINNING at a point on the Southern side of April Drive, which point is it the division lira of Lals Nos, 1.13 and
114 on the hereinafter mentioned plan of tots: thence South 84 degrees 42 minutes. East along the
atorennentinned April Drive a distance of 65 feet to a point el the division lino of Lot Nos. 112 and 113; thence
South 5 degrees 18 minutes West along the said division line a distance of 100,09 feet to a paint On the northerly
right pf way line of Route 767; thence I Eh 84 degrees 42 minutes West among the aforementioned right of way,
Route 767 a dIstence of 66 feet to a point at the division lira of Lots Nos. 113 and 114; thence North 6 degrees 18
minutes East along said dh riskm lima distance 01100.09 feet to a print, the PLACE OF BEGINNING.
IT BEING Lot No. 113, Block °i_" on plan of Lots, of Trindle Voltage, Section 3, vtch plan la recorded In end for the
County of Cumberland in Plan Book 10, Pages 54, 55 and 5$.
HAVING THEREON ERECTED a dwelling house known and numbered es 302 Aprl Drive,
UNDER AND SUBJECT NEVERTHELESS to easements, restrictions. reservation. conditions end rights of env of
mold.
BEING THE SAME PREMISES which Luther dames Miller and Edna Reath Miller, his wife, by their Deed dated
May 1, 1987 end recorded May 1. 1987 In the Moe of the Recorder of need's in and for the County 0f
Curnberlend, Perm5ylvanta, In Deed Beet( 032, Page 1913, granted end conveyed unto Elton E. Manske and
Aibina E Manske. his wife, Grantors herein.
ALSO BEING the same premises which Wanda G. Phillips, Attome r- tn..pactforAlbina E. Mango.
Grantors, agreed to self by Meta Urn AntSatosContract dated September 2, 200g and recorded September
10, 2006 ln Instrument Number 200830746, In the office of the Recorder Ottawa in and tor the County of
Cumberland, Pennsylvania, to Zldeno M. Lamchaouri and Morten% a Qgcarnzil, husband midwife, Grantee..
BEI the e premises which Elton E. Manske and Patna E. Mend ,, his wife by their Deed dated
, m
.2009 and about t o b e r e c o r d e d I n the O f f i c e of the F t e c m d e r of Deeds in end fort the
County of Cumberland, Pennsylvania, granted and conveyed unto2Idene M. Lanchaou rl ,tiottgegor herein.
Inst. # 201332584 - Page 2 of 4
IN WITNESS WHEREOF, Assignor has caused this Assignment to be executed and delivered by its
duty authorized officer as of the day of -34,1t , 20 .
Wells Fargo Bank, N.A.
By: ��j'��0►w. Gy.S
Name: Siham Canami
Title: Vice President Loan Documentation
State of Minnesota
), ss:
County of Hennepin
NOTARY ACKNOWLEDGMENT
The foregoing instrument was acknowledged before me on
by Siham Danami
31,
L1/41 ,2013
, as Vice President Loan Documentation for Wells Fargo Bank,
N.A., in the capacity noted in the foregoing instrument. �, l
CHRISTINE DAVIS ----
Notary Public: Chrisfine D.p.yi%
My Commission Expires. 13 11
[SEAL]
Notary Public
State of Minnesota
My Commission Expires
January 31, 2015
I do certify that the precise address of the Secretary of Housing and Urban Development is 451
7th Street, S.W., Washington, D.C. 20410.
Attested By: Siham Danami
Inst. # 201332584 - Page 1 of 4
Claim Date: 7/24/2013
After recording, please return to:
Avenue 365 Lender Services, LLC
401 Plymouth Road
Suite 550
Plymouth Meeting, PA 19462
g055.34. ,',
CERTIFIED PROPERTY IDENTIFICATION NUMBERS
01 -22- 0531 -109 - CAMP SILL BORO
CCGIS REGISTRY 10/02/2013 BY TB
FHA Case No.: 441 - 9431796 703
Servicer Loan No.: 1111111111 11111111111111111111111111111M111
IIIIIIFI1M1lI
This instrument prepared by:
Wells Fargo Home Mortgage
Trevor L Haney
2051 Killebrew Drive
Bloomington, MN 55425
ASSIGNMENT OF MORTGAGE AND OTHER LOAN DOCUMENTS
Wells Fargo Bank, N.A., whose address is 1 Home Campus, Des Moines, IA 50328 ( "Assignor"),
in consideration of Ten Dollars ($10.00) and other good and valuable consideration received by
Assignor, hereby assigns, transfers, sets over and conveys to the Secretary of Housing and
Urban Development, whose address is 451 7th Street, S.W., Washington, D.C. 20410
( "Assignee "), and its successors and assigns, without recourse, the following:
1. that certain Mortgage dated October 26, 2009, executed by Zidane M Lamchaouri, a
married person, having an original principal sum of $137464.00 with interest, secured
thereby, and recorded as Instrument Number 200937697 and /or in
Book/Volume /Liber /Reel N /A, at Page /Folio N /A, among the land records of
Cumberland County, Pennsylvania, as amended or modified (the "Mortgage "), which
Mortgage secures that certain promissory note dated October 26, 2009 (the "Note ");
and
2. such other documents, agreements, instruments and other collateral that evidence,
secure or otherwise relate to Assignor's right, title or interest in and to the Mortgage
and /or the Note, including without limitation the title insurance policies and hazard
insurance policies that might presently be in effect.
TO HAVE AND TO HOLD unto Assignee and its successors and assigns forever.
Property Address: 302 April Dr, Camp Hill, PA 17011
Assessor's /Tax ID No.: 01 -22 -0531 -109
Legal Description: See Exhibit "A" Attached Hereto And By This Reference Made A Part Hereof
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Zidane M. Lamchaouri;
Plaintiff,
Defendant.
CIVIL DIVISION
NO.: 12 -3423 CIVIL
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the Praecipe to Substitute
Successor Party was served on the following this \b''day of March, 2014, via First Class U.S. Mail,
Postage Pre -Paid:
Zidane M. Lamchaouri
302 April Drive
Camp Hill, PA 17011 -5008
322 N. SECOND STREET,
STEELTON, PA 17113
Dated:
3\41
By:
ZU KER, GOLDBE
AN, LLC
Aim i1,:
t A. Dietterick, Esquire; P I.D. #55650
Ki berly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Jana Fridfinnsdottir, Esquire; PA I.D. #315944
Brian Nicholas, Esquire; PA I.D. #317240
Denise Carlon, Esquire; PA I.D. #317226
Attorneys for Plaintiff
XFP- 163895/jf
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233 -8500; (908) 233 -1390 FAX
Email: Office @zuckergoldberg.com