Loading...
HomeMy WebLinkAbout12-3599IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FAR60 BANK, N.A., CIVI1 DIVISION / NO: 59` IZ M, l - ?' n Plaintiff, 3 vs. TYPF OF PLEADING Valerie L. Arrington aka Valerie Frombaugh, CIVIL ACTION - COMPLAINT Defendant. IN MORTGAGE FORECLOSURE TO DrrFNDANT YOU ARF HFRFBY NOTIFIFD TO PI FAD TO THr tNCLOSLDCONIPLAIN I V0IIIIN IVVLNIY(20)DAYS FROM >FRVIcr HFRFOF OR A DFFAUI T JUr)GMFNT MAY Fir FIJTFRr F) Ae,AINST YO( , Fit FD ON BFHAI F OF: Wells Largo Bank, N.A. COUNSt_L OF R[ CORD I-OR I HIS I'Ak IY: I tltHtLIYCtRIIF'Y IIIAI IIItADDRESS OF THr PI AINTIrr IS'. M76 Sateview Blvd., MAC 11 X7801 013,_Ft Mill, SC )9715 AND !lit DLFENDANI 101 Plno Ho'id Mount Holly Sprwj,,?, PA 1706"; 1810 (LHllr(-Alt )I LO(, A nC)Iv IHLRL6YCtH,IrY THAI IIItLOCAlIONOI- THF Rr:,i FSTVF AFFFCTrD F," THIS I IFN IS lul ?I n? Ru;iJ, Mount Holly Sunnj;, PA 1701)5 1810 r,1um(I)illly. Soulh Mld(deloii c ?rvIrr r? (A r '101' A I I, NLNC ;<CP 1G')')81 ZUCKER, GOLDBERG & ACKFRMIAN, LLC Scott A. Dietterick, Fsquire Pa. I.P. 4SS650 Kimherly A_ Bonner, Fsquir(, PI. LD. #89!05 ?-_ kwl A. Ackerman, LsquirY? I.D. 4)0)710 tohleigh i evy Marin, I-squirt, C101- 1. a D. #306799 -- Ralph M. Salvia, Esquire Pa I .D. 11202946 Jaime R. Ackerman, Esquire- .? Pa I.D. #311032 - 100 Sheffield Street, Suit(' 101 I`?lountainside, NJ 07092 (908) 233-8.700 (908) 233-1390 FAX ottll f'y luckerfloldberp.c om File No. XCP- I65981/bga 0 /03,76-j2d/ /on C#3737 Zucker, GoldbLr?, & i(kernwn, LI-C XCP-165981 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFF ICEBF ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1691 ET SI_Q. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRIY (30) DAYS OF RECEIPI OF IHIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WIIII WRIIIEIN VERIFICATION (HEREOF, 0 11 1iERWISE, THE DEBT WILL BF ASSUMED IO BE VALID. LIKEWISE, IF REQUESIL1) WI IIiIN IIIIRIY (30) D"'.,YS OF RECEIPI OF 1HIS PLEADING, COUNSEL FOR PLAIN 1111- WILL SEND M 1-1 NDANI(S) IIIt NAM1 AND f DDRESS OF 1 HE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL 1-11E END OF I I1E I HIRIY (30) DAY PFRIC)D FOLLOWING FIRST CONIACI WITH YOU BEFORE SUING YOU 10 COLLECT THIS DEBI. EVEN IHOUGIT THE LAW PROVIDES THAI YOUR ANSWER -10 THIS COMPLAINI IS 1-0 BE FILED IN I1-I1S ACTION wIIIIIN IWFNIY (20) DAYS, YOU MAY OBTAIN AN EXII-NSION OF ALAI IIN1E. FURIIIERMORF, NO RFOUISI WILL BE MADE TO THE COURT FOR A JUDGMENT UNTI1 THE EXPIRATION OF THIR, Y (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUI_ST PROOF OF THE DEBT OR T,HI NAM[_ AND ADDRESS OF THE ORICiINA1 CREDITOR WITHIN THE THIRTY 30) DA`( PERIOD THAT BEGINS JI)0N YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH I ITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL TH1 RLQUI STED INFORMATION TO YOU. YOU SHOULD C:ONSUIT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FII ED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A i)FBT IT IS AN ACTION TO ENFORCE A I IFN ON REAL ESTATI Zucker, Goldbcq & ;Nckcrman, LI.C XCP-16598 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Batik, N.A. vs. Valerie I . Arrington aka Valerie Frombaugh; Plaintiff, Defendant(s). NOTICE TO DEFEND CIVIL DIVISION NO.: You have been sued in court. If you wish to defend against the cl?iim set forth in the loilowing 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 clairns 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 furth_,r 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 ON[,, GO TO OR I ELEPHONE THE OFFICE SET FORT I i BELOW IO FIND OU 1 WIIERF YOU CAN GE I LEGAL M P NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE 10 DEFEND Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 11013 Phone (800) 990-9108 (717) 249 3166 LA`ANYER RIFFRRAt. Cunriberland County Bar Associrition 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990 9"10S (717) 240- /tic, Gol(t)(,,i 'v lu_rman, LLC XCP-165981 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: vs. Valerie L. Arrington aka Valerie Frombaugh; Defendant(s). AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si Listed desea deferiderse de la demanda establ"(ida en las siguientes paginas, debe tornar accion dentro de los proxirnos veinte (20) Bias despues de la notificacion de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demanclas establecidas en su contra. Se le advierte de qUe si usted falla en tornar accion wino se describe anteriormente, el caso puede proceder sin Listed sin previo aviso y Lin fallo por ;.ualquier suma de dinero r?.?cl??mada en la demanda 0 cua Iquier otra reclamacion o remedio solicitado por el dernandante, lM do se,. dictado en contra Suva por la Corte. Usted puede perder dinero o propiedades a otros derechos impOrt,mtes para usted. UST ED DEBE LLEVAR ES I F DOCIJMENTO A SU ABOGADO INNIEDIAI AMEN I L. SI US I E D NO I it NF UN ABOGADO 0 NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA SIGIJEINI E OFICINA PARA AVI RIGUAR DONDF PUEDE ENCON IRAR ASIS IENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOI IC' 10 DEFEND LAWYER RE I-1 RRAL Cumberland County Bar Association Curberland County Bai Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 1701.3 Phone (800) 990-9108 Phone (800) 990 9108 (717) 249-3166 (717) 249 3160 Zucker, Goldbcq€ & ;Ackerman, LLC X(-P- 16S981 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.. VS. Valerie L. Arrington aka Valerie Frombaugh; 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") located at 3476 Stateview Blvd., MAC # X7801-013, Ft. Mill, SC 29715. 2. Defendant, Valerie L. Arrington aka Valerie Frombaugh, is an individual whose last known address is 101 Pine Road, Mount Holly Springs, PA 17065-1810. 3. On or about October 31, 2008, Valerie L. Arrington executed a Note in favor of Integrity Home Funding, LLC in the original principal amount of $147,900.00. 4. On or about October 31, 2008, as security for payment of the aforesaid Note, Valerie L. Arrington, a separated person, made, executed and delivered to Integrity Home Funding, LLC, organized and existing under the laws of Delaware a Mortgage in the original principal amount of $147,900.00 on the premises hereinafter described, with said Mortgage being recorded in the office of the Recorder of Deeds of Cumberland County on November 3, 2008, Instrument #200835954. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "A", attached hereto and made a part hereof. 5. The Mortgage was assigned by Integrity Home Funding, LLC to Wells Fargo Bank, N.A., plaintiff herein, pursuant to an assignment of mortgage dated October 31, 2008 and recorded on November 3, 2008 in the Office of the Recorder of Deeds for Cumberland County, Instrument #200835955. 6.. Defendant is in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest being contractually due for the December 2011 payment, and pursuant to the terms of the aforesaid Mortgage, after written Zucker, Goldberg & Ackerman, LLC XCP-165981 notice of said default to Defendant(s), the entire principal balance and accrued interest due thereunder has been accelerated. 7. Valerie L. Arrington, single person, is the record and real owner of the aforesaid mortgaged premises 8. On January 17, 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. 9. The amount due and owing Plaintiff by Defendant(s) is as follows: Principal $141,533.46 Interest through 05/03/2012 $4,292.55 Escrow Advance $719.33 Suspense Balance ($621.22) Late Charges $35.47 Inspection Fees $45.00 Total $146,004.59 plus interest on the principal sum ($141,533.46) at the daily per diem amount of $23.27, 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. 10. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability under the aforesaid Note in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. Zucker, Goldberg & Ackerman, LLC XCP-165981 WHEREFORE, Plaintiff demands judgment in mortgage foreclosure for the amount due of $146,004.59, with interest thereon at daily per diem amount of $23.27 plus additional late charges, and costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCK s GOLDBERG & ACKERMAN, LLC I ?ffi' iAL z - BY: Dated: Scott A. i terick, 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 XCP-165981/bga 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoIdberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT Puma. Zucker, Goldberg & Ackerman, LLC XCP-165981 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XCP-165981 s ?QOrri?a I. Prepared By: INTEGRITY HOME FUNDING, LLC 111 CONTINENTAL DR, SUITE 114, NEWARK, DE 197130000 Return To: WFHM FINAL DOCS X9999-OIX tx4i?bi k A to O ?rOr'1 dt ??? Parcel Number: aO_36 ?Lyy a?5 ??cfan5??ce (O1 Premises: 101 PINE ROAD MT HOLLY SPRINGS [Space Above't'Ids Line For Recording Dalftl MORTGAGE 1000 BLUE GENTIAN ROAD EAGAN, MN 55121 DEFINITIONS Words used in multiple sections of this document are defined below and other words are defined in Sections 3, 11, 13, 18, 20 and 21. Certain rules regarding the usage of words used in this document are also provided in Section lb. (A) "Security Instrument" means this document, which iS dated OCTOBER 31, 2008 together with all Riders to this document. (B) "Borrower" is VALERIE L ARRINGTON, A SEPARATED PERS Borrower is the mortgagir under this Security Instrument. (?"Lender" is INTE ITY HOME FUNDING, LLC NSYLVANIA -Sin a Family • Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3039 1/01 L #3039 (PACM Rav 12/19/2005 t-6(PAL 1 of 16 V"P-M. Ino. (8001521.7291 1, ' Lender is a LIMITED LIABILITY COMPANY organized and existing under the laws of THE STATE OF DELAWARE Lender's address is P.O. BOX 11701, NEWARK, NJ 0710147 01 Lender is the mortgagee under this Security Instrument. (D) "Note" means the promissory note signed by Borrower and dated OCTOBER 31, 2008 The Note states that Borrower owes Lender ONE HUNDRED FORTY SEVEN THOUSAND NINE HUNDRED AND 00/100 Dollars (U. S. $ ******147, 900.00 ) plus interest. Borrower has promised to pay this debt in regular Periodic Payments and to pay the debt in full not later than NOVEMBER 01, 2038 (E) "Property" means the property that is described below under the heading "Transfer of Rights in the Property. " (F) "Loan" mean.-, the debt evidenced by the Note, plus interest, any prepayment charges and late charges due under the Note, and all sums due under this Security Instrument, plus interest. (G) "Riders" means all Riders to this Security Instrument that are executed by Borrower. The following Riders are to be executed by Borrower [check box as applicable]: ? Adjustable Rate Rider ? Condominium Rider ? Second Home Rider ? Balloon Rider ? Planned Unit Development Rider ? 1-4 Family Rider ? VA Rider ? Biweekly Payment Rider ? Other(s) [specify] (1i) "Applicable Law" means all controlling applicable federal, state and local statutes, regulations, ordinances and administrative rules and orders (that have the effect of law) as well as all applicable final, non-appealable judicial opinions. (1) "Community Association Dues, Fees, and Assessments" means all dues, fees, assessments and other charges that are imposed on Borrower or the Property by a condominium association, homeowners association or similar organization. (.1) "Electronic Funds Transfer" means any transfer of funds, other than a transaction originated by check, draft, or similar paper instrument, which is initiated through an electronic terminal, telephonic instrument, computer, or magnetic tape so as to order, instruct, or authorize a financial institution to debit or credit an account. Such term includes, but is not limited to, point-of-sale transfers, automated teller machine transactions, transfers initiated by telephone, wire transfers, and automated clearinghouse transfers. (K? "Escrow Items" means those items that are described in Section 3. (L) "Miscellaneous Proceeds" means any compensation, settlement, award of damages, or proceeds paid by any third party (other than insurance proceeds paid under the coverages described in Section 5) for: (i) damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the Property; (iii) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the value and/or condition of the Property. (M) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on, the Loan. Initials: ?® 6(PA) 05081 Pape 2 of 1 8 Form 3039 1101 (1) "Periodic Payment" means the regularly scheduled amount due for (i) principal and interest under the Note, plus (ii) any amounts under Section 3 of this Security Instrument. (O) "RESPA" means the Real Estate Settlement Procedures Act (12 U.S.C. Section 2601 et seq.) and its implementing regulation, Regulation X (24 C.F.R. Part 3500), as they might be amended from time to time, or any additional or successor legislation or regulation that governs the same subject matter. As used in this Security Instrument, "RESPA" refers to all requirentents and restrictiom that are imposed in regard to a "federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage loan" under RESPA. (P) "Successor In Interest of Borrower means any party that has taken title to the Property, whether or not that party has assumed Borrower's obligations under the Note and/or this Security Instrument. TRANSFER OF RIGHTS IN THE PROPERTY This Security Instrument secures to Lender: (i) the repayment of the Loan, and all renewals, extensions and modifications of the Note; and (ii) 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 Lender the following described property located in die COUNTY (Type of Recording Jurisdiction] of CUMBERLAND [Name of Recording Jurisdiction): SEE ATTACHED LEGAL DESCRIPTION THIS IS A PURCHASE MONEY SECURITY INSTRUMENT. TAX STATEMENTS SHOULD BE SENT TO: WELLS FARGO HOME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 which currently has the address of 101 PINE ROAD 101 PINE ROAD [Street] MT HOLLY SPRINGS ICity], Pennsylvania 17065 [Zip Code[ ("Property Address"): TOGETHER WITH all die 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." .6(PA) MOO) Papa 3 of 16 Form 3039 1/01 BORROWER COVENANTS that Borrower is lawfully seised 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 Iimited variations by jurisdiction to constitute a uniform security instrument covering real property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Payment of Principal, Interest, Escrow Items, Prepayment Charges, and Late Charges. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and any prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items pursuant to Section 3. Payments due under the Note and this Security Instrument shall be nade in U.S. currency. However, if any check or other instrument received by Lender as payment under the Note or this Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments due under the Note and this Security Instrument be made in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer. Payments are deemed received by Lender when received at the location designated in the Note or at such other location as may be designated by Lender in accordance with the notice provisions in Section 15. Lender may return any payment or partial payment if the payment or partial payment.-, are insufficient to bring the Loan current. Lender tray accept any payment or partial payment insufficient. to bring the Loan current, without waiver of any rights hereunder or prejudice to its rights to refuse such payment or partial payments in the future, but Lender is not obligated to apply such payments at the time such payments are accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay interest on utapplied funds. Lender may hold such unapplied funds until Borrower makes payment to bring the Loan current. If Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or return them to Borrower. If not applied earlier, such funds will be applied to the outstanding principal balance under the Note immediately prior to foreclosure. No offset or claim which Borrower might have now or in the future against Lender shall relieve Borrower from making payments due under the Note and this Security Instrument or performing the covenants and agreements secured by this Security Instrument. 2. Application of Payments or Proceeds. Except as otherwise described in this Section 2, all payments accepted and applied by Lender shall be applied in the following order of priority: (a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments shall be applied to each Periodic Payment in die order in which it because due. Any remaining amounts shall be applied first to late charges, second to any other amounts due under this Security Instrument, and then to reduce die principal balance of the Note. If Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and the late charge. If more than one Periodic Payment is outstanding, Lender may apply any payment received from Borrower to the repayment of the Periodic Payments if, and to the extent that, each payment can be Initials: C?•6(PA) mom) Pape 4 of 16 Form 3039 1101 paid in full. To the extent that any excess exists after the payment is applied to the full payment of one or more Periodic Payments, such excess may be applied to any late charges due. Voluntary prepayments shall be applied first to any prepayment charges and then as described in the Note. Any application of payments, insurance proceeds, or Miscellaneous Proceeds to principal due under the Note shall not extend or postpone the due date, or change the amount, of the Periodic Payments. 3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments are due under the Note, until the Note is paid in full, a sum (the "Funds") to provide for payment of amounts due for: (a) taxes and assessments and other items which can attain priority over this Security Instrument as a lien or encumbrance on the Property; (b) leasehold payments or ground rents on the Property, if any; (c) premiums for any and all insurance required by Lender under Section 5; and (d) Mortgage Insurance premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment of Mortgage Insurance premiums in accordance with the provisions of Section 10. These itenLs are called "Escrow Items." At origination or at any time during the tern of the Loan, Lender may require that Cotrununity Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and assessments shall be all Escrow Item. Borrower shall promptly furnish to Lender all notices of amounts to be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Lender waives Borrower's obligation to pay the Funds for any or all Escrow Item,`. Lender may waive Borrower's obligation to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be in writing. In the event of such waiver, Borrower shall pay directly, when and where payable, the amounts due for any Escrow Item: for which payment of Funds has been waived by Lender and, if Lender requires, shall furnish to Lender receipts evidencing such payment within such time period as Lender may require. Borrower's obligation to make such payments and to provide receipts shall for all purposes be deemed to be a covenant and agreement contained in this Security Instrument, as the phrase "covenant and agreement" is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant to a waiver, and Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lender any such amount. Lender may revoke the waiver as to any or all Escrow Items at any time by a notice given in accordance with Section IS and, upon such revocation, Borrower shall pay to Lender all Funds, and in such amounts, that are then required under this Section 3. Lender may, at any time, collect and hold Funds in an amount (a) sufficient to permit Lender to apply the Funds at the time specified under RESPA, and (b) not to exceed the maximum amount a lender can require under RESPA. Lender shall estimate the amount of Funds due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with Applicable Law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is an institution whose deposits are so insured) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items no later than the time specified under RESPA. Lender shall not charge Borrower for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrower interest on the Funds and Applicable Law permits Lender to make such a charge. Unless an agreement is made in writing or Applicable Law requires interest to be paid oil the Funds, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest IniGala: (0 61PA) 105081 Pape 5 of 16 Form 3039 1101 shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds as required by RESPA. If there is a surplus of Funds held in escrow, as defined under RESPA, Lender shall account to Borrower for the excess funds in accordance with RESPA. If there is a shortage of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with RESPA, but in no more than 12 monthly payments. If there is a deficiency of Funds held in escrow, as defined under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shall pay to Lender the amount necessary to make up the deficiency in accordance with RESPA, but in no more than 12 monthly payments. Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower any Funds held by Lender. 4. Charges; Liens. Borrower shall pay all taxes, assessments, charges, tines, and impositions attributable to the Property which can attain priority over this Security instrument, leasehold payments or ground rents on the Property, if any, and Community Association Dues, Fees, and Assessments, if any. To the extent that these items are Escrow Items, Borrower shall pay them in the nnanner provided in Section 3. 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, but only so long as Borrower is performing such agreement; (b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings which in Lender's opinion operate to prevent the enforcement of the lien while those proceedings are pending, but only until such proceedings are concluded; 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 can attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions set forth above in this Section 4. Lender may require Borrower to pay a one-time charge for a real estate tax verification and/or reporting service used by Lender in connection with this Loan. 5. Property Insurance. Borrower shall keep the improvements now existing or hereafter erected on the Property insured against loss by tire, hazards included within the term "extended coverage," and any other hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance. This insurance shall be maintained in the announLi (including deductible levels) and for the periods that Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of the Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's right to disapprove Borrower's choice, which right shall not be exercised unreasonably. Lender may require Borrower to pay, in connection with this Loan, either: (a) a one-time charge for flood zone determination, certification and tracking services; or (b) a one-time charge for flood zone detennination and certification services and subsequent charges each time remappings or similar changes occur which reasonably might affect such determination or certification. Borrower shall also be responsible for the payment of any fees imposed by the Federal Emergency Management Agency in connection with the review of any flood zone determination resulting from an objection by Borrower. Initials: ?® 6(PA) MOO) Papa 6 of 1 a Form 3039 1101 If Borrower fails to maintain any of the coverages described above, Lender may obtain insurance coverage, at Lender's option and Borrower's expense. Lender is under no obligation to purchase any particular type or amount of coverage. Therefore, such coverage shall cover Lender, but might or might not protect Borrower, Borrower's equity in the Property, or the contents of the Property, against any risk, hazard or liability and might provide greater or lesser coverage than was previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained might significantly exceed the cost of insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. All insurance policies required by Lender and renewals of such policies shall be subject to Lender's right to disapprove such policies, shall include a standard mortgage clause, and shall name Lender as mortgagee and/or as an additional loss payee. Lender shall have the right to hold the policies and renewal certificates. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. If Borrower obtains any form of insurance coverage, not otherwise required by Lender, for damage to, or destruction of, the Property, such policy shall include a standard mortgage clause and shall name Lender as mortgagee and/or as an additional loss payee. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender nay make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, any insurance proceeds, whether or not the underlying insurance was required by Lender, shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such insurance proceeds, Lender shall not be required to pay Borrower any interest or earnings on such proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such insurance proceeds shall be applied in the order provided for in Section 2. If Borrower abandons the Property, Lender may file, negotiate and settle any available insurance claim and related natters. If Borrower does not respond within 30 days to a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may negotiate and settle the claim. The 30-day period will begin when die notice is given. In either event, or if Lender acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender (a) Borrower's rights to any insurance proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the right to any refund of unearned premiums paid by Borrower) under all insurance policies covering the Property, insofar as such rights are applicable to the coverage of the Property. Lender may use the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the Note or this Security Instrument, whether or not then due. InWala: ,-- L/-k 4y s(PA) 10608) Papa 7 of 18 Form 3039 1101 6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within 60 days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal residence for at least one year after the date of occupancy, unless Lender otherwise agrees in writing, which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrower's control. 7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate or conmlit waste on the Property. Whether or not Borrower is residing in the Property, Borrower shall maintain the Property in order to prevent the Property from deteriorating or decreasing in value due to its condition. Unless it is determined pursuant to Section 5 that repair or restoration is not economically feasible, Borrower shall promptly repair the Property if damaged to avoid further deterioration or damage. If insurance or condemnation proceeds are paid in connection with damage to, or the taking of, the Property, Borrower shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such purposes. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of progress payments as the work is completed. If the insurance or condemnation proceeds are not sufficient to repair or restore the Property, Borrower is not relieved of Borrower's obligation for the completion of such repair or restoration. Lender or its agent may make reasonable entries upon and inspections of the Property. If it has reasonable cause, Lender may inspect the interior of the improvements on the Property. Lender shall give Borrower notice at the time of or prior to such an interior inspection specifying such reasonable cause. 8. Borrower's Loan Application. Borrower shall be in default if, during the Loan application process, Borrower or any persons or entities acting at the direction of Borrower or with Borrower's knowledge or consent gave materially false, ntisleading, or inaccurate information or statements to Lender (or failed to provide Lender with material information) in connection with the Loan. Material representations include, but are not limited to, representations concerning Borrower's occupancy of the Property as Borrower's principal residence. 9. Protection of Lender's Interest in the Property and Rights Under this Security Instrument. If (a) Borrower fails to perform the covenants and agreements contained in this Security Instrument, (b) there is a legal proceeding that might significantly affect Lender's interest in the Property and/or rights under this Security Instrument (such as a proceeding in bankruptcy, probate, for condemnation or forfeiture, for enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or regulations), or (c) Borrower has abandoned the Property, therm Lender may do and pay for whatever is reasonable or appropriate to protect Lender's interest in the Property and rights under this Security Instrument, including protecting and/or assessing the value of the Property, and securing and/or repairing the Property. Lender's actions can include, but are not limited to: (a) paying any sums secured by a lien which has priority over this Security Instrument; (b) appearing in court; and (c) paying reasonable attorneys' fees to protect its interest in the Property and/or rights under this Security Instrument, including its secured position in a bankruptcy proceeding. Securing the Property includes, but is not limited to, entering the Property to make repairs, change locks, replace or board up doors and windows, drain water from pipes, elinutate building or other code violations or dangerous conditions, and have utilities turned on or off. Although Lender may take action under this Section 9, Lender does not have to do so and is not under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any or all actions authorized under this Section 9. Initials: A+ Q-6(PA) (0508) Paps a of 16 Form 3039 1/01 Any amounts disbursed by Lender under this Section 9 shall become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from Lender to Borrower requesting payment. If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 10. Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan, Borrower shall pay the premiums required to maintain the Mortgage Insurance in effect. If, for any reason, the Mortgage Insurance coverage required by Lender ceases to be available from the mortgage insurer that previously provided such insurance and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the Mortgage Insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the Mortgage Insurance previously in effect, from an alternate mortgage insurer selected by Lender. If substantially equivalent Mortgage insurance coverage is not available, Borrower shall continue to pay to Lender the amount of the separately designated payments that were due when the insurance coverage ceased to be in effect. Lender will accept, use and retain these payments as a non-refundable loss reserve in lieu of Mortgage Insurance. Such loss reserve shall be non-refundable, notwithstanding the fact that the Loan is ultimately paid in full, and Lender shall not be required to pay Borrower any interest or earnings on such loss reserve. Lender can no longer require loss reserve payments if Mortgage Insurance coverage (in the amount and for the period that Lender requires) provided by an insurer selected by Lender again becomes available, is obtained, and Lender requires separately designated payments toward the premiums for Mortgage Insurance. If Lender required Mortgage Insurance as a condition of making the Loan and Borrower was required to make separately designated payments toward the premiums for Mortgage Insurance, Borrower shall pay the premiums required to maintain Mortgage Insurance in effect, or to provide a non-refundable loss reserve, until Lender's requirement for Mortgage Insurance ends in accordance with any written agreement between Borrower and Lender providing for such termination or until termination is required by Applicable Law. Nothing in this Section 10 affects Borrower's obligation to pay interest at the rate provided in the Note. Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain losses it may incur if Borrower does not repay the Loan as agreed. Borrower is not a party to the Mortgage Insurance. Mortgage insurers evaluate their total risk on all such insurance in force from time to time, and may enter into agreements with other parties that share or modify their risk, or reduce losses. These agreements are on terns and conditions that are satisfactory to the mortgage insurer and the other party (or parties) to these agreements. These agreements may require the mortgage insurer to make payments using any source of funds that the mortgage insurer may have available (which may include funds obtained from Mortgage Insurance premiums). As a result of these agreements, Lender, any purchaser of the Note, another insurer, any reinsurer, any other entity, or any affiliate of any of die foregoing, may receive (directly or indirectly) amounts that derive from (or might be characterized as) a portion of Borrower's payments, for Mortgage Insurance, in exchange for sharing or modifying the mortgage insurer's risk, or reducing losses. If such agreement provides that an affiliate of Lender takes a share of the insurer's risk in exchange for a share of the premiums paid to the insurer, die arrangement is often termed "captive reinsurance." Further: (a) Any such agreements will not affect the amounts that Borrower has agreed to pay for Mortgage Insurance, or any other terms of the Loan. Such agreements will not increase the amount Borrower will owe for Mortgage Insurance, and they will not entitle Borrower to any refund. 1?itfala: 40.6(PA) (06081 Pave 9 or 1 9 Form 3039 1101 (b) Any such agreements will not affect the rights Borrower has - if any - with respect to the Mortgage Insurance under the Homeowners Protection Act of 1998 or any other law. These rights may include the right to receive certain disclosures, to request and obtain cancellation of the Mortgage Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a refund of any Mortgage Insurance premiums that were unearned at the time of such cancellation or termination. 11. Assignment or Miscellaneous Proceeds; Forfeiture. All Miscellaneous Proceeds are hereby assigned to and shall be paid to Lender. If the Property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of the Property, if the restoration or repair is economically feasible and Lender's security is not lessened. During such repair and restoration period, Lender shall have the right to hold such Miscellaneous Proceeds until Lender has had an opportunity to inspect such Property to ensure the work has been completed to Lender's satisfaction, provided Out such inspection shall be undertaken promptly. Lender may pay for the repairs and restoration in a single disbursement or in a series of progress payments as the work is completed. Unless an agreement is made in writing or Applicable Law requires interest to be paid on such Miscellaneous Proceeds, Lender shall not be required to pay Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's security would be lessened, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with the excess, if any, paid to Borrower. Such Miscellaneous Proceeds shall be applied in the order provided for in Section 2. In the event of a total taking, destruction, or loss in value of the Property, the Miscellaneous Proceeds shall be applied to the sums secured by this Security Instrument, whether or not then due, with die excess, if any, paid to Borrower. In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, Or loss in value is equal to or greater than the amount of the sums secured by this Security Instrument immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the sunis secured by this Security Instrument shall be reduced by the amount of the Miscellaneous Proceeds multiplied by die following fraction: (a) the total amount of the sums secured immediately before the partial taking, destruction, or loss in value divided by (b) the fair market value of the Property immediately before the partial taking, destruction, or loss in value. Any balance shall be paid to Borrower. In the event of a partial taking, destruction, or loss in value of the Property in which the fair market value of the Property immediately before the partial taking, destruction, or loss in value is less than the amount of the sums secured immediately before the partial taking, destruction, or loss in value, unless Borrower and Lender otherwise agree in writing, the Miscellaneous Proceeds shall be applied to the sunis secured by this Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the Opposing Party (as defined in the next sentence) offers to make an award to settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the Miscellaneous Proceeds either to restoration or repair of the Property or to the sunis secured by this Security Instrument, whether or not then due. "Opposing Party" means the third party that owes Borrower Miscellaneous Proceeds or the party against whom Borrower has a right of action in regard to Miscellaneous Proceeds. Borrower shall be in default if any action or proceeding, whether civil or criminal, is begun that, in Lender's judgment, could result in forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument. Borrower can cure such a default and, if acceleration has occurred, reinstate as provided in Section 19, by causing the action or proceeding to be Irrti als: -6(PA) (0608) Papa 10 of le Form 3039 1101 dismissed with a ruling that, in Lender's judgment, precludes forfeiture of the Property or other material impairment of Lender's interest in the Property or rights under this Security Instrument. The proceeds of any award or claim for damages that are attributable to the impairment of Lender's interest in the Property are hereby assigned and shall be paid to Lender. All Miscellaneous Proceeds that are not applied to restoration or repair of the Property shall be applied in the order provided for in Section 2. 12. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time for payment or modification of amortization of the sums secured by this Security Instrument granted by Lender to Borrower or any Successor in Interest of Borrower shall not operate to release the liability of Borrower or any Successors in Interest of Borrower. Lender shall not be required to commence proceedings against any Successor in Interest of Borrower or to refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand trade by the original Borrower or any Successors in Interest of Borrower. Any forbearance by Lender in exercising any right or remedy including, without limitation, Lender's acceptance of payments from third persons, entities or Successors in Interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or preclude the exercise of any right or remedy. 13. Joint and Several Liability; Co-signers; Successors and Assigns Bound. Borrower covenants and agrees that Borrower's obligations and liability shall be joint and several. However, any Borrower who co-signs this Security Instrument but does not execute the Note (a "co-signer"): (a) is co-signing this Security Instrument only to mortgage, grant and convey the co-signer'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 can agree to extend, modify, forbear or make any accomunodations with regard to the terms of this Security instrument. or the Note without the co-signer's consent. Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes Borrower's obligations under this Security Instrument in writing, and is approved by Lender, shall obtain all of Borrower's rights and benefits under this Security Instrument. Borrower shall not be released from Borrower's obligations and liability under this Security Instrument unless Leader agrees to such release in writing. The covenants and agreements of this Security Instrument shall bind (except as provided in Section 20) and benefit the successors and assigns of Lender. 14. Loan Charges. Lender may charge Borrower fees for services performed in connection with Borrower's default, for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument, including, but not limited to, attorneys' fees, property inspection and valuation fees. In regard to any other fees, the absence of express authority to this Security Instrument to charge a specific fee to Borrower shall not be construed as a prohibition on the charging of such fee. Lender may not charge fees that are expressly prohibited by this Security Instrument or by Applicable Law. If the Loan is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the Loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sutras already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge (whether or not a prepayment charge is provided for under the Note). Borrower's acceptance of any such refund made by direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out of such overcharge. 15. Notices. All notices given by Borrower or Lender in connection with this Security Instrument must be in writing. Any notice to Borrower in connection with this Security Instrument shall be deemed to Initials; ®® 6(PA) (05081 Page I I of I8 Form 3039 1/01 have been given to Borrower when mailed by first class mail or when actually delivered to Borrower's notice address if sent by other means. Notice to any one Borrower shall constitute notice to all Borrowers unless Applicable Law expressly requires otherwise. The notice address shall be the Property Address unless Borrower has designated a substitute notice address by notice to Lender. Borrower shall promptly notify Lender of Borrower's change of address. If Lender specifies a procedure for reporting Borrower's change of address, then Borrower shall only report a change of address through that specified procedure. There may be only one designated notice address under this Security Instrument at any one time. Any notice to Lender shall be given by delivering it or by mailing it by first class mail to Lender's address stated herein unless Lender has designated another address by notice to Borrower. Any notice in connection with this Security Instrument shall not be deemed to have been given to Lender until actually received by Lender. If any notice required by this Security Instrument is also required under Applicable Law, the Applicable Law requirement will satisfy the corresponding requirement under this Security 16. Governing Law; Severability; Rules of Construction. This Security Instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. All rights and obligations contained in this Security Instrument are subject to any requirements and limitations of Applicable Law. Applicable Law aught explicitly or implicitly allow the parties to agree by contract or it might be silent, but such silence shall not be construed as a prohibition against agreement by contract. In the event drat 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. As used in this Security Instrument: (a) words of the masculine gender shall mean and include corresponding neuter words or words of the feminine gender; (b) words in the singular shall mean and include the plural and vice versa; and (c) the word "may" gives sole discretion without any obligation to take any action. 17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument. 18. Transfer of the Property or a Beneficial Interest in Borrower. As used in this Section 18, "Interest in the Property" means any legal or beneficial interest in the Property, including, but not limited to, those beneficial interests transferred in a bond for deed, contract for deed, installment sales contract or escrow agreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser. If all or any part of the Property or any Interest in die Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written comsent, Lender may require immediate payment in full of all suns secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all suns secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. 19. Borrower's Right to Reinstate After Acceleration. If Borrower meets certain conditions, Borrower shall have the right to have enforcement of this Security Instrument discontinued at any time prior to the earliest of: (a) five days before sale of the Property pursuant to any power of sale contained in this Security Instrument; (b) such other period as Applicable Law might specify for the termination of Borrower's right to reinstate; or (c) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if no acceleration had occurred; (b) cures any default of any other covenants or I rki Wa: Q® 61PA) io6oe) Pape 12 or 16 Form 3039 1/01 agreements, (c) pays all expenses incurred in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees, property inspection and valuation fees, and other fees incurred for the purpose of protecting Lender's interest in the Property and rights under this Security Instrument; and (d) takes such action as Lender may reasonably require to assure that Lender's interest in the Property and rights under this Security Instrument, and Borrower's obligation to pay the sums secured by this Security Instrument, shall continue unchanged. Lender may require that Borrower pay swch reinstatement sums and expenses in one or more of the following forms, as selected by Lender: (a) cash; (b) money order; (c) certified check, bank check, treasurer's check or cashier's check, provided any such check is drawn upon an institution whose deposits are insured by a federal agency, instrumentality or entity; or (d) Electronic Funds Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under Section 18. 20. Sale of Note; Change of Loan Servicer; Notice of Grievance. The Note or a partial interest in the Note (together with this Security instrument) can be sold one or more times without prior notice to Borrower. A sale might result in a change in die entity (known as the "Loan Servicer") that collects Periodic Payments due under the Note and this Security Instrument and performs other mortgage loan servicing obligations under the Note, this Security Instrument, and Applicable Law. There also night be one or more changes of the Loan Servicer unrelated to a sale of the Note. If there is a change of the Loan Servicer, Borrower will be given written notice of the change which will state the name and address of the new Loan Servicer, the address to which payments should be made and any other information RESPA requires in connection with a notice of transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer other than the purchaser of the Note, the mortgage loan servicing obligations to Borrower will remain with the Loan Servicer or be transferred to a successor Loan Servicer and are not assumed by the Note purchaser unless otherwise provided by the Note purchaser. Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an individual litigant or the member of a class) that arises from the other party's actions pursuant to this Security Instrument or that alleges that the other party has breached any provision of, or any duty owed by reason of, this Security Instrument, until such Borrower or Lender has notified the other party (with such notice given in compliance with the requirements of Section 15) of such alleged breach and afforded the other party hereto a reasonable period after the giving of such notice to take corrective action. If Applicable Law provides a time period which must elapse before certain action can be taken, that time period will be deemed to be reasonable for purposes of this paragraph. The notice of acceleration and opportunity to cure given to Borrower pursuant to Section 22 and the notice of acceleration given to Borrower pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective action provisions of this Section 20. 21. Hazardous Substances. As used in this Section 21: (a) "Hazardous Substances" are those substances defined as toxic or hazardous substances, pollutants, or wastes by Environmental Law and the following substances: gasoline, kerosene, other flanuzable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials; (b) "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or envirormiental protection; (c) "Envirommental Cleanup" includes any response action, remedial action, or removal action, as defined in Environmental Law; and (d) an "Environmental Condition" means a condition that can cause, contribute to, or otherwise trigger an Environmental Cleanup. Nflala: 4D•6(PA) MOW Pape 13 or 16 Form 3039 1/01 Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances, or threaten to release any Hazardous Substances, on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property (a) that is in violation of any Environmental Law, (b) which creates an Environmental Condition, or (c) which, due to the presence, use, or release of a Hazardous Substance, creates a condition that adversely affects the value of the Property. 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 (including, but not limited to, hazardous substances in consumer products). Borrower shall promptly give Lender written notice of (a) 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, (b) any Environmental Condition, including but not limited to, any spilling, leaking, discharge, release or threat of release of any Hazardous Substance, and (c) any condition caused by the presence, use or release of a Hazardous Substance which adversely affects the value of the Property. If Borrower learns, or is notified by any governmental or regulatory authority, or any private party, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. Nothing herein shall create any obligation on Lender for an Environmental Cleanup. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following Borrower's breach of any covenant or agreement in this Security Instrument (but not prior to acceleration under Section 18 unless Applicable Law provides otherwise). Lender shall notify Borrower of, among other things: (a) the default; (b) the action required to cure the default; (c) when the default must be cured; and (d) that failure to cure the default as specified may result in acceleration of the sums secured by this Security Instrument, foreclosure by judicial proceeding and sale of the Property. Lender shall further inform Borrower of the right to reinstate after acceleration and the right to assert in the foreclosure proceeding the non-existence of a default or any other defense of Borrower to acceleration and foreclosure. If the default is not cured as specified, Lender at its option may require Immediate payment in full of all sums secured by this Security Instrument without further demand and may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this Section 22, including, but not limited to, attorneys' fees and costs of title evidence to the extent permitted by Applicable Law. 23. 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. Borrower shall pay any recordation costs. Lender may charge Borrower a fee for releasing this Security Instrument, but only if the fee is paid to a third party for services rendered and the charging of the fee is permitted under Applicable Law. 24. 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. 25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shall extend to one hour prior to the commencement of bidding at a sheriff's sale or other sale pursuant to this Security Instrument. 26. Purchase Money Mortgage. If any of the debt secured by this Security instrument is lent to Borrower to acquire title to the Property, Ns Security Instrument shall be a purchase money mortgage. 27. 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. inhiab: -6(PA) (Os= Pepe 14 of 16 Form 3039 1/01 BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Security Instrument and in any Rider executed by Borrower and recorded with it. Witnesses: ? ) aa.- '" (Seal) VALERIE L ARRINGTON -Borrower (Seal) -Borrower _ (Seal) -Borrower _ (Seal) -Borrower _ (Seal) -Borrower _ (Seal) -Borrower (Seal) -Borrower (Seal) -Borrower -6(PA)1o6o61 Pepe 16 of 16 Form 3039 1/01 COMMONWEALTH OF PENNSYLVANIA, e County ss: On this, the 41% day of D CAZ0 K undersigned officer, pemddally appeared VALERIE L ARRINGTON , before me, the 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: COMMONWEALTH OF PENNSYLVANIA Notarial Seat Nina June Davis, Notary &0fNota6j99 Lemoyne Boro, Cw bwtanCommission Expires Oct Member, Pannaylvanla 4s10da111n Ilk of off er Certificate of Residence I, 1, Y) Ar12k. G 1) the correct address of the within-named Mortgagee is P • 0 071014701 Witness my hand this , do hereby certify that BOX 11701, NEWARK, NJ 19, INtlab: -6(PA) (o 609) Pape 18 of 16 Form 3039 1101 . , EXHIBIT A LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with improvements thereon erected situate in the Township of South Middleton, County of Cumberland, and Commonwealth of Pennsylvania, being more fully bounded, limited and described as follows: BEGINNING at a point in the center of the Pine Road, said point being the northeastern corner of land now or formerly of William Lewis; thence by the center line of said Road, North 65 '/4 degrees East 100 feet to a point; thence by land now or formerly of Tom O. Bietsch, et ux of which the herein described premises was a part, South 23'/. degrees East 286 feet, more or less, to line of land now or formerly of James W. Craighead; thence by said lands, South 61 '/7 degrees West 100 feet to a point; thence by land now or formerly of William Lewis, North 23'/, degrees West 293 feet, more or less, to the place of BEGINNING. CONTAINING .66 acres, more or less, and being improved with a dwelling house and other improvements, and being known as 101 Pine Road, Mount Holly Springs, Pennsylvania. . , 1 ,o ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200835954 Recorded On 11/3/2008 At 1:25:06 PM * Instrument Type - MORTGAGE Invoice Number - 31674 User ID - KW * Mortgagor - ARRINGTON, VALERIE L * Mortgagee - INTEGRITY HOME FUNDING LLC * Customer - ASSURED LAND * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $37.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $74.50 I Certify this to be recorded in Cumberland County PA *111 RECORDER O D EDS * Total Pages - 18 Certification Page DO NOT DETACH This page is now part of this legal document. - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. OOONRO 1111111111111111111111111111 ? r . V V RIFI('A I MN Ismael Hermmdez_ hereh\ states tha Oshc is Vice President L.uan I)Ocumentatloll 01 WFI.-I-S FAR(IO BANK'. N.A.- Plaintiifur rllo)., Wa,le scr\ icil <<<?.ent t?)r I)IaiIIt iII' in thi mutter. tha he she is authOri7ed to nYake this crItICM1011, .AIhI ?.-Tit? that thcstatement> made in the ('iv it ActIO11 in NIur11?a(e I OI CIW illc arc true mid correct to the hest of oher in161-11iatiun and heliei'. Ihc undcrsi;?.ned under,t,md," that this statement is made subject to the Penalties ut 18 Pu_ (.'.S. ``'sec. 4904 rel?itiM-1 tc) U11???<)I'n laitiltll all(>n to autht)rltlcti. 5111 C?L, I il?., I(>,-) 981 Narne: ;ARfMOTON Mlmc: I snriel I Icrn<indci I itlc: Vice President I oall Docume11ILal,01l ()_; -P \ - v?_; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. VS. Valerie L. Arrington aka Valerie Frombaugh; Plaintiff, Defendant(s). CIVIL DIVISION NO.: ?2 3S /? C IU?L C°/? 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. t ,T ?f Zucker, Goldberg & Ackerman, LLC XCP-165981 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 BY: Dated: June 4, 2012 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 XCP-165981/ha 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoIdberg.com Zucker, Goldberg & Ackerman, LLC XCP-165981 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: CUSTOMER/PRIMARY APPLICANT 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: State: Zip: Price: $ Realtor Phone: State: Zip: Office: Other: CO-BORROWER Mailing Address: City: Phone Numbers: Email: # of people in household: State: Zip: Office: Other: How long? How long? FINANCIAL iNFORMATION First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: Is the loan in Bankruptcy? Yes ? No ? If yes, provide names, location of court, case number & attorney: Date you closed your loan: Yes ? No ? Yes ? No ? Listing date Home: Cell: Home: Cell: Zucker, Goldberg & Ackerman, LLC XCP-165981 Assets Amount Owed: Value: Home: $ $ _ Other Real Estate: $ $ _ Retirement Funds: $ $ _ Investments: $ $ _ Checking: $ $ _ Savings: $ $ _ Other: $ $ Automobile #1: Model: Year: _ Amount owed: Value: Automobile #2: Model: Year: _ Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV _ Child Support/Alim. Spending Money Day/Child Care/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): Fax: Email: Zucker, Goldberg & Ackerman, LLC XCP-165981 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: I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date 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) Zucker, Goldberg & Ackerman, LLC XCP-165981 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.. VS. Valerie L. Arrington aka Valerie Frombaugh; 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 of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker, Goldberg & Ackerman, LLC XCP-165981 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Vs. Valerie L. Arrington aka Valerie Frombaugh; Plaintiff, 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 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 Zucker, Goldberg & Ackerman, LLC XCP-165981 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 XCP-165981 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i .i Sheriff - i ©??ptr )(Cumber" Jody S Smith Chief Deputy J., Z`! 4 Richard W Stewart Solicitor OFf,e _ F Y,-E SHSRi L All, Wells Fargo Bank, N.A. Case Number vs. Valerie L. Arrington 2012-3599 SHERIFF'S RETURN OF SERVICE 06/18/2012 02:50 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on June 18, 2012 at 1450 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Valerie L. Arrington, by making known unto Michael Frombaugh, Husband of Defendant at 101 Pine Road, Mount Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and Corr ct copy of the s e. EL BARRICK, 15EPUTY SHERIFF COST: $35.00 June 19, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (C) CounfySuite SheifP. Teleosoff. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVI,~NI~,~, ~..~:.. ~ f~fF CE ~;t~ i~~fE Fr~~TH~ I~TA~cY Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, ~~)~ AIJG # 6 ~~ NO.: 12-3599 CIVIL TERM ~s' Ct1M8ERLANQ C Valerie L. Arrington aka Valerie Frombaugh; PENNSYLYAi Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to PlaintifYs Complaint within the appropriate time limits from service thereof, and assess PlaintifYs damages as follows: Amount as set forth in Complaint Interest from Complaint date through 07/24/2012 Late Charges TOTAL $146,004.59 $1,884.87 $70.94 $147,960.40 plus interest on the judgment amount ($147,960.40) from July 25, 2012, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 101 Pine Road address is: Mount Holly Springs, PA 17065-1810 i Dated: ~ _ r~ ZUCKER, GOL ~ LC BY: Joel Ackerman, Esquir , A I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XCP-165981 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 ~ t1El! ~' -~~ "~ _ Prothonotary ~ ~~~ ~~ e~~ 9~ 56 A TY ,. sppd °~L1 3S9sa ~~~ 3'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 12-3599 CIVIL TERM vs. Valerie L. Arrington aka Valerie Frombaugh; 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 law, do hereby depose and say that the statements made herein are true in and correct to the best my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C. 237.1 and that the time limits provided for that notice have expired. ZUCKER, GO R1Gf' LC Dated: ~ a s !(O~ BY: Joe ckerman s uire; LD. #202729 q As leigh L. Marin, Esquire; PA I.D. #306799 ®/Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XCP-165981 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Sworn to and subscribed before me T is 2 S day of ~ G L y , 201'-~ No ublic My Co fission Expires: EDWARD J. SCHWAHL II Commission # 2383239 Notary Public, State of New Jersey My Commission Expires March 09, 2014 Zucker, Goldberg&Ackerman, , !~ Department of Defense Manpower Data Center Rea~~ts ae ot: Jul-2<-~,2 ~:55:0~ scl~A 2.z.2 ~t~ Rtap~o~x~6 P'ursti~nt ~ 3~esncmbtr: Civil Rclicf Act Last Name: ARRINGTON First Name: VALERIE L Active Duty Status As Of: Jul-24-2012 Arave qtr S~wt o.te Aatlw Dwy end owe ssrviw componaM on AAtra Duty a, Aotka oc~ atm. trite NA NA No hIA ThW response reflects the Indhddusle' actve duy staWs 6esed on the Actlve Duty Statue Date keft Aa1Na D4Ky 1~ ~ ~ d~ ~f' ~~ ~ Adthe Ostt' ttliut DrY AdMa dfr}/=rd DNa mlaltu 'ar'ADa QMt~bfYY'It NA NA No NA TMs responte reflects where the Mdhddual left acWa duty statue wlMin 387 days preceding the Acdve Duty Status Date The Member or NMNfisr tkdt YWS NdBeed of s Fukae CablJp b Aclitst tMRy on Aalw Gwty 91sRu Dane Order NoNiCadon 36srt Data Order NaWlcation Etd Data S1shH Sarvka Qappnant NA NA No NA This response reflects whether Me IrdNldual or hldher unit has receNed eery no8flwtlon 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 s tus 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, nd Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. rtw„ r~ ,~c..~_~... Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Reporting System (DEERS) database which is the official source of data on eligibility for milkary medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (b0 USC App. § 501 et seq, as amended) (SCRA) (fonnerty known the Soldiers' and Sailors' Civil Relief Ad 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 fami 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 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:/lwww.defenselink.miUfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty stag date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c) This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left 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 a duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in acx:•ordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods I ss 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 i the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Res rve 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 soma cases and includes some categories of persons on active duty for purposes of the SCRA who would no be reported as on Ad1ve Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty recrords for all the Uniformed Services peri s. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times osiers 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 se ce. 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 hav 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 RI extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the are protected WARNING: This certificate was provided based on a last name, SSN, and alive duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Report ID: OORNR664TQ Results as of : JuF24-201208:56:15 Department of Defense Manpower Data Center II~I SCRA 2.2.2 ~~ Pursnardt ~ 3erviccsncmber~ Civil F-~licf Act. Last Name: FROMBAUGH First Name: VALERIE Active Duty Status As Of: Jul-24-2012 Actlw ov<y st.rr Data Ac1iVe Doer &nd o.le s«rio. Caegsr+artl a, AcrvsDrily on Aeflw Dtdy status Ciele NA NA No NA This resporme reflects the fndHiduals' ecdve duly staus based on the Actlva Duty Statue Date 1-sRAr~w WtywlBiH'.187 DaysdAotN'-Da9>llalln Dsls Af~M ~ fliVl Dots AdFa OtMy Lrilt t7a~ 3hYn 9arvMps t'JNrlpipfMnt NA NA No NA This response reflects where are IndMdual IeR active dory status wtthin 387 days preoerlirp the Active Dury Status Date 1'Ns MMnlbar or IifsMer Unit was Motlfisd d • Fukae CaIFUp to Aaaw Duty an Aothro Duty 9tah» Dats Ordu Nth Stet DNS Order NotlBaatgre End.DNe Status 5ervbs Camponant NA NA No NA This response reflects whether the individual or tdslher untt has received eery notl8catfon b repoA 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 s tus 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, nd Coast Guard). This status includes information on a Servicemember or his/tler unit receiving notification of future orders to report for Acttve Duty. Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and 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 the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicaring 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 fami member, friend, or representative asserts in any manner that the individual was on active duty for the actve duty status date, or is otherwise entitled to 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.miUfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty stag date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c) This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or hislher unit received early notification to report for ai duty on the Active Duty Status Date. More information on "Active Duty Status" Actve 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 I ss than 30 consecxitive days in length were available. In the case of a member of the National GuaM, this includes service under a cell 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. Ail Active Guard Reserve (AGR) members must be assigned against an authorized mobiliaarion position i the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Re rve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S Public Health Service or the National Oceanic and Atmospheric Administration (NOAH Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would no be reported as on Active Duty under this certficate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services peri s. Tirie 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many rimes orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certificarion should check to make sure tfie orders on which SCRA protections are based have not been amended to extend the inclusive dates of se ce. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to lie 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 RI extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the are protected WARNING: This certificate was provided based on a last name, SSN, and active duty status date provided by the requester. Providing erroneous informaton will ruse an erroneous certificate to be provided. Report ID: GNUHQ716MR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION NO.: 12-3599 CIVIL TERM vs. Valerie L. Arrington aka Valerie Frombaugh; Defendant(s). NOTICE OF ORDER, DECREE OR JUDGMENT T0: Valerie L. Arrington aka Valerie Frombaugh 101 Pine Road Mount Holly Springs, PA 17065-1810 [ ] Plaintiff [rJ Defendant [ ] Additional Defendant You are hereby notified that n Order, Decree or Judgment was entered in the above captioned proceeding on $ J ~ I~ [ ] A copy of the Order or Decree is enclosed, or [~] The judgment is as follows: $147,960.40 p cos ~. Protho4iota~ry Zucker, Goldberg & Ackerman, SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~4dKtY at ~G~r~t~~~a ~~ '. v~_ OFFI~ Of TKO §K@RIFF ~6 Webs Fargo Bank, N.A. vs. Valerie L. Arrington Casa Number 2012-3599 SHERIFF'S RETURN Of SERVICE 06/18/2012 02:50 PM -Michael Garrick, Deputy Sheriff, who being duty sworn acconiing to law, states that on June 18, 2012 at 1450 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Valerk L. Arrington, by making known unto Michael Frombaugh, Husband of Defendant at 101 Pine Road, Mount Holiy Springs, Cumbertai~d County, Pennsylvania 17085 its contents and at the same time handing to him personally the said tru~ corr~c ~~th~~aaln/_~ SHERIFF COST: $35.00 June 19, 2012 SO ANSWERS, R ANDERSON, SHERIFF ~~ ca Cartlysuxa sn.Mt. rdewort, inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. Valerie L. Arrington aka Valerie Frombaugh Defendant. NO.: 12-3599 CIVIL TERM IMPORTANT NOTICE TO: Valerie L. Arrington aka Valerie Frombaugh 101 Pine Road Mount Haliy Springs, PA 17085-1810 DATE OF NOTICE: 7/10/2012 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A ~IRITTEN APPEARANCE PERSONALLY OR B Y ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING, AND YOU MAY LOSE YOUR PROPERTY OR OTHER IlVIPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOWT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FII~TD OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND. LAVVYERREFERRAL SERV'IC'E Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlble, PA 17013 Carlisle, PA 17013 Phone (800) ~0-9108 Phone (800) 890-9108 (717) 249-3166 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. Valerie L. Arrington aka Valerie Frombaugh Defendant. NO.: 12-3599 CIVIL TERM AVTSiO Il1+II'ORTANTE TO: Valerie L. Arrington aka Valerie Frombaugh 101 Pine Road Mount Holiy Springs, PA 17065-1810 FECHA DEL AVIS0:7l10/2012 LISTED ESTA EN RE$ELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE LISTED TOME ACCION DENTRO DE LOS PROXIl+IIOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUVA SIN LLEVARSE A CABO UNA VISTA Y LISTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. LISTED DEBE LLEVAR ESTE DOCITMENTO Il~TNIEDIATAMENTE A SU ABOGADO. SI LISTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR LINO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND.t LA~~VYERREFERR~L S~R~~TCE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (600) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford 3tnaet Carlisle, PA 17013 Phone (800) 890-9108 (717) 249-3166 ZUCKER, GDLDBERG ~ACKERMAN BY: S Scott A. Dietterick, Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P. ~. Box 1024 Mountainside, NJ 07092-0424 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 165981 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION File No. 12-3599 CIVIL TERM Wells Fargo Bank, N.A., Amount Due $147,960.40 Plaintiff, Interest from 7/25/2012 to date of sale $9,892.59 VS. Valerie L.Arrington aka Valerie Frombaugh; Costs r M - ' Defendant. cn, ry TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County,for debt, interest and costs upon the following described property of the defendant(s): See Exhibit"A"attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County,for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): a(5 and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). Vxv 3s,oo GaF Baas � C� 7 too &(o oi,Elx�;s G 1t:ki�rnr,rn i J KCI'-16�)XI e- �a� u ),ok '� 2� T�aj (Indicate) Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: Signature: Z"i Print Name: Scott A. Die eric it Kimberly A. Bon er, Esquire Joel A. Ackerman, Esquire Ashleigh L. Marin, Esquire Ralph M. Salvia, Esquire / Jaime R.Ackerman, Esquire t/ Address: Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, N1 07092 Attorney for: Plaintiff Telephone: 908-233-8500 Supreme Court ID No.: 55650 89705 202729 306799 202946 311032 Zucker,Goldberg&Ackerman, LLC XCP-165981 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON ERECTED SITUATE IN SOUTH MIDDLETON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, BEING MORE FULLY BOUNDED, LIMITED AND DESCRIBED AS FOLLOWS,TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE PINE ROAD,SAID POINT BEING THE NORTHEASTERN CORNER OF LAND NOW OR FORMERLY OF WILLIAM LEWIS; THENCE BY THE CENTER LINE OF SAID ROAD, NORTH 65 3/4 DEGREES EAST 100 FEET TO A POINT; THENCE BY LAND NOW OR FORMERLY OF TOM 0. BIETSCH, ET UX OF WHICH THE HEREIN DESCRIBED PREMISES WAS A PART, SOUTH 23 3/4 DEGREES EAST 286 FEET, MORE OR LESS,TO LINE OF LAND NOW OR FORMERLY OF JAMES W. CRAIGHEAD; THENCE BY SAID LANDS, SOUTH 611/2 DEGREES WEST 100 FEET TO A POINT; THENCE BY LAND NOW OR FORMERLY OF WILLIAM LEWIS, NORTH 23 3/4 DEGREE WEST 293 FEET, MORE OR LESS,TO THE PLACE OF BEGINNING. CONTAINING .66 ACRES, MORE OR LESS,AND BEING IMPROVED WITH A DWELLING HOUSE AND OTHER IMPROVEMENTS, AND BEING KNOWN AS 101 PINE ROAD, MOUNT HOLLY SPRINGS, PENNSYLVANIA 17065-1810. BEING THE SAME PREMISES WHICH MAURA COWAN,SINGLE PERSON, BY DEED DATED OCTOBER 31, 2008 AND RECORDED NOVEMBER 3, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA,AS INSTRUMENT NUMBER200835953, GRANTED AND CONVEYED UNTO VALERIE L.ARRINGTON,SINGLE PERSON. TAX MAP NO.: 40-30-2644-045. Zucker,Goldberg&Ackerman,LLC XCP-165981 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 12-3599 CIVIL TERM V5. w Execution No.: r~� : Valerie L. Arrington aka Valerie Frombaugh; ;r ^� - (!) N Defendant(s). > �:a c -- ` 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 101 Pine Road, Mount Holly Springs, PA 17065-1810. 1. Name and Address of Owner(s) or Reputed Owner(s): VALERIE L. ARRINGTON,SINGLE PERSON, 101 Pine Road Mount Holly Springs, PA 17065-1810 2. Name and Address of Defendant(s) in the Judgment: VALERIE L. ARRINGTON AKA VALERIE FROMBALIGH 101 Pine Road Mount Holly Springs, PA 17065-1810 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 INTEGRITY HOME FUNDING, LLC P.O. Box 11701 Newark,. NJ 07101-4701 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 101 Pine Road Mount Holly Springs, PA 17065-1810 UNKNOWN SPOUSE 101 Pine Road Mount Holly Springs, PA 17065-1810 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 W P-10>9x: 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 & C RMAN, L Dated: �0? /„ BY: ((3 Scott A. Diet ck, 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 v 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 File No.: XCP-165981 (908)233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com ..,,iA rz,4. Ackerman 1.1 XCII-165')X1 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON ERECTED SITUATE IN SOUTH MIDDLETON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, BEING MORE FULLY BOUNDED, LIMITED AND DESCRIBED AS FOLLOWS,TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE PINE ROAD,SAID POINT BEING THE NORTHEASTERN CORNER OF LAND NOW OR FORMERLY OF WILLIAM LEWIS; THENCE BY THE CENTER LINE OF SAID ROAD, NORTH 65 3/4 DEGREES EAST 100 FEET TO A POINT; THENCE BY LAND NOW OR FORMERLY OF TOM 0. BIETSCH, ET UX OF WHICH THE HEREIN DESCRIBED PREMISES WAS A PART,SOUTH 23 3/4 DEGREES EAST 286 FEET, MORE OR LESS,TO LINE OF LAND NOW OR FORMERLY OF JAMES W.CRAIGHEAD; THENCE BY SAID LANDS,SOUTH 611/2 DEGREES WEST 100 FEET TO A POINT; THENCE BY LAND NOW OR FORMERLY OF WILLIAM LEWIS, NORTH 23 3/4 DEGREE WEST 293 FEET, MORE OR LESS,TO THE PLACE OF BEGINNING. CONTAINING .66 ACRES, MORE OR LESS,AND BEING IMPROVED WITH A DWELLING HOUSE AND OTHER IMPROVEMENTS, AND BEING KNOWN AS 101 PINE ROAD, MOUNT HOLLY SPRINGS, PENNSYLVANIA 17065-1810. BEING THE SAME PREMISES WHICH MAURA COWAN,SINGLE PERSON, BY DEED DATED OCTOBER 31, 2008 AND RECORDED NOVEMBER 3,2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA, AS INSTRUMENT NUMBER200835953, GRANTED AND CONVEYED UNTO VALERIE L.ARRINGTON,SINGLE PERSON. TAX MAP NO.:40-30-2644-045. Zucker,Goldberg&Ackerman,LLC XCP-165981 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION VS. Plaintiff, NO.: 12-3599 CIVIL TERM Valerie L.Arrington aka Valerie Frombaugh; 27 Defendant. co -0 7� CD C-, NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Valerie L.Arrington aka Valerie Frombaugh 101 Pine Road Mount Holly Springs, PA 17065-1810 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: 101 Pine Road,Mount Holly Springs,PA,17065-1810 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-3599 CIVIL TERM Zucker,Goldberg&Ackerman,LLC XCP-165981 THE NAME(S)OF THE OWNER(S)OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Valerie L.Arrington,single person 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 XCP-165981 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 Sheriff's 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 GOLDBERG CKERMAN, L Dated: BY: �3 Scott A. Di erick, 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 File No.: XCP-165981 (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 XCP-165981 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON ERECTED SITUATE IN SOUTH MIDDLETON TOWNSHIP,CUMBERLAND COUNTY, PENNSYLVANIA, BEING MORE FULLY BOUNDED, LIMITED AND DESCRIBED AS FOLLOWS,TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE PINE ROAD,SAID POINT BEING THE NORTHEASTERN CORNER OF LAND NOW OR FORMERLY OF WILLIAM LEWIS; THENCE BY THE CENTER LINE OF SAID ROAD, NORTH 65 3/4 DEGREES EAST 100 FEET TO A POINT, THENCE BY LAND NOW OR FORMERLY OF TOM 0. BIETSCH, ET UX OF WHICH THE HEREIN DESCRIBED PREMISES WAS A PART,SOUTH 23 3/4 DEGREES EAST 286 FEET, MORE OR LESS,TO LINE OF LAND NOW OR FORMERLY OF JAMES W.CRAIGHEAD; THENCE BY SAID LANDS,SOUTH 611/2 DEGREES WEST 100 FEET TO A POINT; THENCE BY LAND NOW OR FORMERLY OF WILLIAM LEWIS, NORTH 23 3/4 DEGREE WEST 293 FEET, MORE OR LESS,TO THE PLACE OF BEGINNING. CONTAINING .66 ACRES, MORE OR LESS,AND BEING IMPROVED WITH A DWELLING HOUSE AND OTHER IMPROVEMENTS,AND BEING KNOWN AS 101 PINE ROAD, MOUNT HOLLY SPRINGS, PENNSYLVANIA 17065-1810. BEING THE SAME PREMISES WHICH MAURA COWAN,SINGLE PERSON, BY DEED DATED OCTOBER 31, 2008 AND RECORDED NOVEMBER 3,2008 IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA,AS INSTRUMENT NUMBER200835953,GRANTED AND CONVEYED UNTO VALERIE L.ARRINGTON,SINGLE PERSON. TAX MAP NO.:40-30-2644-045. r Zucker,Goldberg&Ackerman,LLC XCP-165981 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-3599 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 VALERIE L.ARRINGTON AKA VALERIE FROMBAUGH (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: $'lby,41.0.+10 L.L.: $.50 Interest FROM 7/25/2012 TO DATE OF SALE-$9,892.59 Atty's Comm: Due Prothy: $2.25 Atty Paid: $183.75 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 a � IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 12-3599 CIVIL TERM . Execution No.: ? ° Valerie L.Arrington aka Valerie Frombaugh; CD T� `a 1 Defendant(s). AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action,sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 101 Pine Road, Mount Holly Springs, PA 17065-1810. 1. Name and Address of Owner(s)or Reputed Owner(s): VALERIE L. ARRINGTON, SINGLE PERSON, 101 Pine Road Mount Holly Springs, PA 17065-1810 2. Name and Address of Defendants) in the Judgment: VALERIE L.ARRINGTON AKA VALERIE FROMBAUGH 101 Pine Road Mount Holly Springs, PA 17065-1810 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 INTEGRITY HOME FUNDING, LLC P.O. Box 11701 Newark,. NJ 07101-4701 S. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 SOUTH MIDDLETON TWP 520 Park Drive Boiling Springs, PA 17007 BOB CAIRNS 520 Park Drive PO BOX 40, Boiling Springs, PA 17007 SOUTH MIDDLETON SCHOOL DISTRICT 4 Forge Road Boiling Springs, PA 17007 SOUTH MIDDLETON TWP MUN AUTH PO Box 8 Boiling Springs, PA 17007 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 101 Pine Road Mount Holly Springs, PA 17065-1810 UNKNOWN SPOUSE 101 Pine Road Mount Holly Springs, PA 17065-1810 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept.280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Amended Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ZUCKER GOLDBERG &ACKERMAN, LLC Dated: 1,�� 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 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, N1 07092 File No.: XCP-165981 (908)233-8500; (908)233-1390 FAX E-mail: Office @zuckergoldberg.com Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON ERECTED SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING MORE FULLY BOUNDED, LIMITED AND DESCRIBED AS FOLLOWS,TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE PINE ROAD, SAID POINT BEING THE NORTHEASTERN CORNER OF LAND NOW OR FORMERLY OF WILLIAM LEWIS; THENCE BY THE CENTER LINE OF SAID ROAD, NORTH 65 3/4 DEGREES EAST 100 FEET TO A POINT; THENCE BY LAND NOW OR FORMERLY OF TOM 0. BIETSCH, ET UX OF WHICH THE HEREIN DESCRIBED PREMISES WAS A PART, SOUTH 23 3/4 DEGREES EAST 286 FEET, MORE OR LESS,TO LINE OF LAND NOW OR FORMERLY OF JAMES W. CRAIGHEAD; THENCE BY SAID LANDS, SOUTH 611/2 DEGREES WEST 100 FEETTO A POINT; THENCE BY LAND NOW OR FORMERLY OF WILLIAM LEWIS, NORTH 23 3/4 DEGREE WEST 293 FEET, MORE OR LESS,TO THE PLACE OF BEGINNING. CONTAINING .66 ACRES, MORE OR LESS,AND BEING IMPROVED WITH A DWELLING HOUSE AND OTHER IMPROVEMENTS,AND BEING KNOWN AS 101 PINE ROAD, MOUNT HOLLY SPRINGS, PENNSYLVANIA 17065-1810. BEING THE SAME PREMISES WHICH MAURA COWAN,SINGLE PERSON, BY DEED DATED OCTOBER 31, 2008 AND RECORDED NOVEMBER 3, 2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA,AS INSTRUMENT NUMBER200835953, GRANTED AND CONVEYED UNTO VALERIE L.ARRINGTON, SINGLE PERSON. TAX MAP NO.:40-30-2644-045. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 12-3599 CIVILTERM VS. TYPE OF PLEADING Valerie L.Arrington aka Valerie Frombaugh; Pa. R.C.P. RULE 3129.2(C)AFFIDAVIT OF SERVICE Defendant. OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D.#55650 Kimberly A. Bonner, Esquire- PA I.D.#89705 Joel A.Ackerman, Esquire- PA I.D.#202729 Ashleigh 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.: XCP- 165981/dsc M s` c ' �y C• Zucker, Goldberg&Ackerman, LLC XCP-165981 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 12-3599 CIVIL TERM Valerie L.Arrington aka Valerie Frombaugh; Defendant. 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. Defendant,Valerie L.Arrington, single person„ is the record owner of the real property. 2. On or about May 17, 2013, Defendant Valerie L. Arrington was served with Plaintiff's Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, via Certified Mail, return receipt requested at the address of the mortgaged premises, being 101 Pine Road, Mount Holly Springs, PA 17065. A true and correct copy of said Notice and Proof of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about July 26, 2013, Plaintiffs counsel served all other parties in interest with Plaintiffs Notice of Sheriffs 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 Defendant/Owner and all other Parties of Zucker, Goldberg&Ackerman, LLC XCP-165981 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 , 2013 DANIEL INGER Paralegal/Legal Assistant Sworn to and subscribed before me this day of ugust, 2013 NotaryIPublic MY COMMISSION EXPIRES: PAUL C. NADRATOWSKI Notary Public of New Jersey ID#2407850 My Commission Expires 4/27/2016 Zucker, Goldberg&Ackerman, LLC XCP-165981 EXHIBIT A Zucker, Goldberg&Ackerman, LLC XCP-165981 Zucker,Goldberg$Ackerman,LLC PO Box 1219 Mountainside,NJ 07092-1219 7196 9006 9296 7002 0007 20130503-102 Ilill����lIll,-0.11IIII 1I1.II1IIIIIII Ili 1111ll'11'I�II'�I��IIII Valerie L. Arrington aka Valerie Frombaugh 101 PINE RD MOUNT HOLLY SPRINGS, PA 1 7065-1 81 0 PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.:12-3599 CIVIL TERM Valerie L.Arrington aka Valerie Frombaugh; Defendant. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Valerie L.Arrington aka Valerie Frombaugh 101 Pine Road Mount Holly Springs, PA 17065-1810 !. TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 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: 101 Pine Road, Mount Holly Springs,PA,17065-1810 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-3599 CIVIL TERM i Zucker,Goldberg&Ackerman,LLC XCP-165981 THENAME(S)OF THE OR REPUTED OWNER(S)OF THIS PROPERTY ARE: Valerie LArriingtpn single person � A SCHEDULE OF DISTRIBUTION, being olist 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 tu 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 6y filing exceptions to it, within ten (1O) days pf the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff nf the Court of Common Pleas of Cumberland County,One Courthouse Square,Carlisle,PA17D13-3387. ' i ' ' �THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. � � it has been issued because there IsoJudgment against you. It may cause your property � tobe held,tobe sold ur taken to pay the Judgment, You may have legal rights to prevent your i 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 mfthe Cumberland � County Bar Association i / . Cumberland County Bar Association � 32 S.Bedford Street ` Carlisle,PA17U13 Phone(800)990-9100 (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 |fyou have meritorious defense against the person or company that has entered judgment against you. You may also 0e a petition with the same Count if you are aware of legal defect in the obligation or the procedure used ' against you. � i Zucker,Goldberg&Ackerman,UC XCP-155981 ' 2. After the Sheriffs Sale, you may file e petition with the Court of - Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed isdelivered. ' 3. A petition or petitions raising the legal issues or rights mentioned inthe preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County' The petition must he served on the attorney for the creditor oron the creditor before presentation tothe Court and a proposed order orrule must be attached to the ' petition. If specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, RA 17D13-3387,before presentation nf the petition to the Court. � Z~C`E`GOLDBERG CKERMAN, L � — � Doted: � Kimberly A. Bonner, Esquire; PA.|.D.#89705 � � Joel A.Ackerman,Esquire;PALD.#2D2729 ' Ashleigh L Morin, Esquire; R4 iD.#3O67B5 ' Ralph NL Salvia,Esquire;FA I,D.#20J946 � Jaime R.Ackerman,Esquire;R4|.O.#31IV32 z,,- / 200 Sheffield Street,Suite 1UI Mountainside,NJ 07032 File No.:XCP'16S981 (308)233'QSD0; (9QD)233-139OFAX ` E-mail: {JfMoe@zuchcr8o/dberQ.como �������G������W�N���S������E�E���� / . VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. ' � ` ' ' ' i � ! ' � Zucker,Goldberg 0`Ackerman,LLC XCP-165981 Exhibit"A" | � LEGAL DESCRIPTION � ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON ERECTED SITUATE IN SOUTH k8|DDLETONTOVVNSH\P,CUMBERLAND COUNTY,PENNSYLVANIA,BEING MORE FULLY BOUNDED, ` LIMITED AND DESCRIBED AS FOLLOWS,TQWIT: BEGINNING AJA POINT)N THE CENTER OF THE PINE ROAD,SAID POINT BEING THE NORTHEASTERN CORNER OF LAND NOW OR FORMERLY QF WILLIAM LEWIS; THENCE BY THE CENTER LINE OF SAID ROAD, NORTH 6G3/4 DEGREES EAST 1O0 FEET TOAPOINT, THENCE BY LAND NOW OR FORMERLY OF TOM 0. BIETSCH,ET UX OF WHICH THE HEREIN DESCRIBED PREMISES WAS A PART,SOUTH 3] DEGREES EAST 286 FEET,MORE 0R LESS,T0 LINE OF LAND NOW | | OR FORMERLY OF JAMES VV'CRA|GHGAD; THENCE BY SAID LANDS,SOUTH 611/2DEGREES WEST 100 FEET TOAPOINT; THENCE BY LAND NOW OR FORMERLY OF WILLIAM LEWIS,NORTH B3/4DEGREE WEST 393FEET, MORE OR LESS,TO THE PLACE QFBEGINNING. CONTAINING .66 ACRES,MORE OR LESS,AND BEING IMPROVED WITH A DWELLING HOUSE AND OTHER IMPROVEMENTS,AND BEING KNOWN AS 101 PINE ROAD,MOUNT HOLLY SPRINGS, PENNSYLVANIA 17065-1810. | BEING THE SAME PREMISES WHICH MAURA COWAN,SINGLE PERSON, BY DEED DATED OCTOBER 31, 2008 AND RECORDED NOVEMBER 3,2008 IN AND FOR CUMBERLAND COUNTY,PENNSYLVANIA,AS INSTRUMENT NUK88ER3O0035953,GRANTED AND CONVEYED UNTO VALERIE L.ARR1NGTOx,SINGLE ! PERSON. |. ' TAX MAP NO.: ^ ` ' . � . . ' . | Zucker,Goldberg&Ackerman,LLC " XCP-155981 =~~~= ' 2- Article Number COMPLETE THIS SECTION • DELIVERY A. eceived by;Please Print Q I B. Date Milli I Delivery C. si�7 1� ?196 9006 9296 7002 0007 XAddressee U. Is delivery a(j(jress different from item i yes If YES.enter delivery address Wow z No 0 3. Service Type CERTIFIED MAIL 0 4. Restricted Delivery? (Extra Fee) 14 yes 1. Article Addressed to: Uy Valerie L. Arrington aka Valerie Reference Information Frombaugh 165981 101 PINE RD PANOSS MOUNT HOLLY SPRINGS, PA 17065-1810 5/312013 7196 9006 9296 7002 D007-102 "S Form 3811,January 2005.-,. Domestic Return Receipt UNITED STATES POSTAL SERVICE 's'-Class Mail Post;age 'F"e e s LISPS G-1 0 -Perrnit Na Zucker, Goldberg & Ackerman, LLC PO Box 9076 Temecula, CA 92589-9076 EXHIBIT B Zucker, Goldberg&Ackerman, LLC XCP-165981 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, VS. NO.:12-3599 CIVIL TERM Valerie L.Arrington aka Valerie Frombaugh; Defendant. NOTICE TO LIENHOLDERS,AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P.3129(b) TO: UNKNOWN TENANT OR TENANTS UNKNOWN SPOUSE 101 Pine Road 101 Pine Road Mount Holly Springs,PA 17065-1810 Mount Holly Springs,PA 17065-1810 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 SOUTH MIDDLETON TWP Carlisle,PA 17013 520 Park Drive Boiling Springs, PA 17007 INTEGRITY HOME FUNDING,LLC P.O.Box 11701 SOUTH MIDDLETON TWP MUN AUTH Newark,.NJ 07101-4701 PO Box 8 Boiling Springs, PA 17007 BOB CAIRNS 520 Park Drive SOUTH MIDDLETON SCHOOL DISTRICT PO BOX 40, 4 Forge Road Boiling Springs, PA 17007 Boiling Springs, PA 17001 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common 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 Zucker,Goldberg&Ackerman,LLC XCP-165981 16598ID1004CO7232013PI On 9/4/2013 at 10:00am,the following described real estate which Valerie L.Arrington,single person, 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: 101 Pine Road, Mount Holly Springs, PA 17065-1810 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). i Zucker,Goldberg&Ackerman,LLC XCP-165981 165981D1004C07232013P2 The said Writ of Execution has been issued on a judgment in the action of Wells Fargo Bank,N.A. Plaintiff VS. Valerie L.Arrington aka Valerie Frombaugh,et al Defendant(s) at EX. NO.12-3599 CIVIL TERM in the amount of$147960.40 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: BY:( 1l 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, NJ 07092 File No.:XCP-165981 (908)233-8500;(908)233-1390 FAX E-mail: Office @zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XCP-165981 165981D1004C07232013P3 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON ERECTED SITUATE IN SOUTH MIDDLETON TOWNSHIP,CUMBERLAND COUNTY,PENNSYLVANIA, BEING MORE FULLY BOUNDED, LIMITED AND DESCRIBED AS FOLLOWS,TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE PINE ROAD,SAID POINT BEING THE NORTHEASTERN CORNER OF LAND NOW OR FORMERLY OF WILLIAM LEWIS; THENCE BY THE CENTER LINE OF SAID ROAD, NORTH 65 3/4 DEGREES EAST 100 FEET TO A POINT; THENCE BY LAND NOW OR FORMERLY OF TOM 0. BIETSCH, ET UX OF WHICH THE HEREIN DESCRIBED PREMISES WAS A PART,SOUTH 23 3/4 DEGREES EAST 286 FEET, MORE OR LESS,TO LINE OF LAND NOW OR FORMERLY OF JAMES W.CRAIGHEAD; THENCE BY SAID LANDS,SOUTH 611/2 DEGREES WEST 100 FEET TO A POINT; THENCE BY LAND NOW OR FORMERLY OF WILLIAM LEWIS,NORTH 23 3/4 DEGREE WEST 293 FEET, MORE OR LESS,TO THE PLACE OF BEGINNING. CONTAINING .66 ACRES, MORE OR LESS,AND BEING IMPROVED WITH A DWELLING HOUSE AND OTHER IMPROVEMENTS,AND BEING KNOWN AS 101 PINE ROAD,MOUNT HOLLY SPRINGS,PENNSYLVANIA 17065-1810. BEING THE SAME PREMISES WHICH MAURA COWAN,SINGLE PERSON, BY DEED DATED OCTOBER 31, 2008 AND RECORDED NOVEMBER 3,2008 IN AND FOR CUMBERLAND COUNTY, PENNSYLVANIA,AS INSTRUMENT NUMBER200835953,GRANTED AND CONVEYED UNTO VALERIE L.ARRINGTON,SINGLE PERSON. TAX MAP NO.:40-30-2644-045. I Zucker,Goldberg&Ackerman,LLC XCP-165981 165981D1004C07232013P4 Page 1 of 6 NOTICE TO LIENHOLDERS .. ...-.. ..........-_...--..._—. �, � plua limos 2 . 0.2" .2 I TMsCertHlateofMailingprovidesevidencethatmailhasbeenpnu entedtoUSPS•forme➢ing.7Nsform 1N1 L26 2013 02 and International mail. !Cj ,a 00 042S2036 rrom: Scott A.Dietterick, Esquire pFRpMZIPCODE47092 ' c/o Zucker,Goldberg&Ackerman, LLC i n 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XCP-1 M C UNKNOWN TENANT OR TENANTS Postmark Here 101 Pine Road Mount Holly Springs,PA 17065-1810 County of P.Q.:CUMBERLAND i i PS Form 3817,April 2007 PSN 7530-02-000-9065 I LIdNITED;ST/ TLS W PON vt ,�, This Ce rtificate of Malllnig provides evidence that mall has been presented to USPS•for malling.This fort 7 i�°�.0 and International mall. 0 2 1M ,JL 26 2013 Prom: Scott A. Dietterick, Esquire �ti' 000428. 7092 FROM Zip CODS c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,suite 101 12 6 2013 I: Mountainside, NJ 07092 CP 981/sd TOi 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 I I I Page 2 of 6 NOTICE TO LIENHOLDERS 111 HTED:ST/1 ES. C , CSaL:SEfV1.EE 40—Ibm 0001M 01Oo This Certifate of Malling provklesevIdente that mall has been presented to LISPS•formal formi I�AI 4282036 `�UL26 2013 end International mall LED FROIUT ZiP CppE 0 70 92 Scott A. Dietterick, Esquire ' �,� • .` c/o Zucker,Goldberg&Ackerman, LLC e? 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 ►'S XCP-165981/sde TEAM C To' CUMBERLAND COUNTY TAX CLAIM BUREAU Postmark Here Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 �t County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 9 P047*F UIIIITED;S.T/ TES , OSF/1L,;-EEVIM a � E 02 1M `P 01-20 'This Certificate of Mailing provides evidence that mall has beenprasentad to USPS•fo tt¢.This 0004282036 JUL 26 2013 and Intematlonal mall. MAILED FROM ZIPGODEi 0 7092 ffOny Scott A. Dietterick,Esquire c/o Zucker,Goldberg&Ackerman, LL --4-126 20 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 vSP XCP-165981/sde TEAM C i T0: SOUTH MIDDLETON TWP Postmark Here 520 Park Drive Boiling Springs, PA 17007 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 fi 1 I I l i 1 Page 3 of 6 NOTICE TO LIENHOLDERS PIN ... z �>~ } This Certificate of Mailing provides evidence that mail has been presented to Uspse oa ng.ThI(� 02 1M $ 01-200 and International mail. i 0004282036 JUL 26 2013 From: O MAILED FROM ZIP GODE07092 Scott A. Dietterick,Esquire c/o Zucker,Goldberg&Ackerman, L C 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 �S RCP-16 EAM C l TO' SOUTH MIDDLETON TWP MUN AUTH Postmark Here PO Box 8 Boiling Springs, PA 17007 i County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 • � T4C a = UNITED=S.T/lTES s �, Z aatvt v ttowrs POML SERVICrF.M $ 01-200 This Certificate of Mailing provides evidence that mall has been presented to Lisps. Ing.T I 0 2 IRA 2013 and International mail. 0004282036 JUL 26 MAILEDFROM 7APGODE-111082 F'°m` Scott A. Dietterick, Esquire -5 i c/o Zucker,Goldberg&Ackerman, LL 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 �S 3 XCP-165981 M C Tot SOUTH MIDDLETON SCHOOL DISTRICT Postmark Here 4 Forge Road Boiling Springs, PA 17007 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000.9065 i I i I Page 4 of 6 NOTICE TO LIENHOLDERS UlUITE�3?/��`FS � �� 02 1M OST/1L SRli'IC>Effi T7hisCertifiwteofMaaingprovkl esevidenathatmailha sbeenpresentedtoUSPS•for TF M000428[LEI) 203$ U 1'200 International mail. �,.] FROIUP zip CODE 26 201$ From: Scott A. Dietterick, Esquire M11 07082 4" c/o Zucker,Goldberg&Ackerman, LLC 204 200 Sheffield Street,Suite 101 Mountainside,NJ 07092 XCP-165981/sde TEA' C 7°' BOB CAIRNS postmark Here 520 Park Drive PO BOX 40, Boiling Springs, PA 17007 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 !?t�STd°L-SEI?UlCF� . 2 °sME'BOWES 2�,m rnis Certiraate or Mauro 1M ��• 2013 s Q provides evidence that mail has been presented to LISPS• np.Thb 0 2 JUL 2 6 and international mail. OOOa282036 070 92 From: Scott A. Dietterick, Esquire MAILED FROM ZIPGOCtE 6 c/o Zucker,Goldberg&Ackerman,L C 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 GS -1 a AM C 70' INTEGRITY HOME FUNDING,LLC postmark Here P.O. Box 11701 Newark,. NJ 07101-4701 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 i I Page 5 of 6 NOTICE TO LIENHOLDERS 41 AT ta!__S� I va-W TFS' �. >�:S�i � -tFkEL p� This Cortlficate of Mailing 02 1M $ 01-200 nyprovidesevkfencethatmallhasbeenpresentedto formagins.1 0004282035 Vr and international mail. JUL 26 2013 Frem: Scott A. Dietterick, Esquire /f +LED t ROM Zip CODi-0 7092 .r c/o Zucker,Goldberg&Ackerman, LLC (/E,; 144"k. . i. 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XCP-165981/sde TEAM C ro: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Postmark Here } Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 f, County of P.Q.:CUMBERLAND Ps Form 3817,April 2007 PSN 7530-02-000-9065 Cases U1NlTFD;ST17 S ��SCFIELo L4Z��: riO Sl/�L:SETi�VlCFa 2fM $ 01200 This Certificate al Mailing provides evidence thatmaahasbeenpreventedtoUs S•for isrpy+ 04282036 JUL 26 2013 and(nternatbnalmap. �fj O1� ILED FROIVF ZIPCODEA 7092 from` Scott A.Dietterick, Esquire v c/o Zucker,Goldberg&Ackerman, LLC { 200 Sheffield Street,Suite 101 �. Mountainside, NJ 07092 XCP-165981/sde TEAM C T°' 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 6 of 6 NOTICE TO LIENHOLDERS t fNITE{7: PN' AMA Sti VISE@ �- • 7 Po1TtEY sOWFS ' This Certfrrcate of Ma111h9Pro v1desevWence that mail has been presented to USPS•formkiff 02 1M mat $ 01-200 and international ��-(�f 0004282036 JUL 26 2013 ' "*'n: Scott A. Dietterick, Esquire y1 MAILED FROM ZIPCODE 0 7092 W,; C/o Zucker,Goldberg&Ackerman, L C 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 TO: UNKNOWN SPOUSE Postmark Here ' 101 Pine Road Mount Holly Springs, PA 17065-1810 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 s' { 7 1 i 1. I I I. l' i I i Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F\�-D-oFFkcF �� F-Q�-����T��Y "�T��p...|.. ."^' = -«* 2014 ^ ."��� mmm~�o A�K �� �� u uw CUMBERLAND COUNTY PENNSYLVANIA OF.F.CE SHERIFF, Wells Fargo Bank, NA. vs. Valerie L. Arrington a/k/a Valarie Frombaugh Case Number 2012-3599 SHERIFF'S RETURN OF SERVICE 06/27/2013 05:45 PM - Deputy Tim Black, being duly sworn accordin to law, states service was performed by posting a true copy of the requested Real Estate Wr , Notice and Description, and Sale Handbill in the above titled action, upon the property located at 101 Pine Road, South Middleton - Township, Mount Holly Springs, PA 17065, Cumberland County. 08/27/2013 05:45 PM - Deputy Tim B|ook, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Valerie L. Arrington a/k/a Valarie Frombaugh at 101. Pine Road, South Middleton Township, Mount Holly 8pringo, PA 17065, Cumberland County. 08/28/2013 As directed by Jaime R Ackerman, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/6/2013 11/06/2013 Ronny R Anderson, Shariff, being duly sworn according to |aw, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $2,181.27 SO ANSWERS, April 21.2O14 woounwStt releo5m'nc. RONNYR ANDERSON, SHERIFF D.S'=�. �L v-,. ' , #4 ��4 3 ��{� On June 13, 2013 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA, Known and numbered as, 101 Pine Road, Mount Holly Springs, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: June 13, 2013 By: &Suz-L-Lcte--7 Real Estate Coordinator LXII 30 CUMBERLAND LAW JOURNAL 07/26/13 2012 -3599 Civil Term WELLS FARGO BANK, N.A. vs. VALERIE L. WARRINGTON a %k /a VALARIE FROMBAUGH Atty.: Jaime R. Ackerman ALL THAT CERTAIN tract of land with improvements thereon erected situate in. South Middleton Township, Cumberland County,' Pennsylvania, being more fully bounded, limited '' and described as follows, to wit: BEGINNING at a point in the 'eel- ter of the Pine Road, said point being the northeastern ,corner of land now or formerly of William Lewis;° ' THENCE by the center line of said road, North 653 /4 degreesEast 100• feet to a point; ' THENCE by land now or formerly of Tom 0. Bietsch, et ux of which the herein described premises was a part, South 233/4 degrees East 286, feet, more or less, to line of land now or formerly of James W. Craighead; THENCE by said lands, South 61 1/2 degrees West 100 feet to a point; THENCE by land now or formerly of William Lewis, North 23.3 /4 degree .. West 293 feet, more or less, to the place of BEGINNING. CONTAINING .66 acres, more or less, and being improved with a dwelling house and other improve ments, and being known as 101 Pine Road, Mount Holly Springs, Pennsyl- vania 17065 -1810. BEING the same premises which Maura Cowan, single person, by deed dated October 31, 2008 and recorded November 3,2008 in and for Cumberland County, Pennsylvania, as Instrument Number200835953, granted and conveyed unto Valerie L. Arrington, single person. TAX MAP NO.: 40 -30- 2644 -045. 22 The Patriot-News Co' 1900 Patriot Drive �� echanicsbiirg, . 17050 Inquiries*- 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 aepatriot Xetus Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss 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 staternent 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 aaidCounb/of Dauphin inyW|aoaUanaous Book ^�W''. Volume 14. Page 317. -- — - _- i LLS FARGO BANK, NA. , vs. ALERIE L ARRINGTON A/K/A VALARIE FROMBAUGH ~~v Jaime "Ackerman ALL THAT CERTAIN TRACT OF LAND WITH IMPROVEMENTS THEREON ERECTED SITUATE IN SOUTH MIDDLETON TOWNSHIP, CUMBERLAND oommr, PENNSYLVANIA, BOUNDED, LIMITED AND n ^ AS FOLLOWS, TO WIT: BEGINNING AT A POINT IN THE CENTER OF THE PINE ROAD, SAID POINT BEING THE NORTHEASTERN CORNER OF LAND NOW OR FORMERLY OF WILLIAM LEWIS; THENCE BY TI-fE CENTER LINE OF SAID R DEGREES ' EAST 100 FEET TO A POINT; THENCE BY LAND NOW OR FORMERLY OF TOM O. nIETxCH, ET ox OF WHICH THE HEREIN DESCRIBED PREMISES WAS A PART, SOUTH 233/4 DEGREES EAST 286 FEET, MORE OR LESS, TO LINE OF LAND NOW OR FORMERLY m/ cmmom�o; ~~-- THENCE ur SAID LANDS, SOUTH mx/2 DEGREES WEST 100 FEET TO A POINT THENCE BY LAND .wmv OR �jar, This ad ran on the date(s) shown below: 07/28/13 08/04/13 08/11/13 Sworn to and sscribed before me thi day of August, 2013 A.D. ic ON OF Notarial Seal Holly Lynn Warfel, Notary Public Washlngton Twp„ Dauphin County My CommIsslon Expires Dec. 12 2016 YLVANIA ASSOCIATION OF NOTARIES MEMBER, PENN