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Home My WebLink About12-6083 c: ~ ;4`:'- -t r i m ~~ ~ ~ ~ r ~ I+r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVI~- "'~ r.,, .~ tiJ fl'j ~ ~ ~ ---i ~ _ ~ WELLS FARGO BANK, N.A., CIVIL DIVISION ~~ ~sA . ~~ ~ }fir Plaintiff, NO.: ~ a_ ~ Q(',1~' ,,,~ V~ ---! ~~ - , vs. TYPE OF PLEADING ROBERT FITTING; CIVIL ACTION -COMPLAINT Defendant. IN MORTGAGE FORECLOSURE T0: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WRHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULTIUDGMENT MAY BE ENTERED AGAINST YOU. FILED ON BEHALF OF: Wells Fareo Bank. N.A. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3476 Stateview Blvd., MAC #X7801-013. Ft. Mill. SC 29715 AND THE DEFENDANT: 603 Park Hills Drive Mechanicsburg. PA 17055 CERTIFICATE OF LOCATION I HEREBY CERTIFY THATTHE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 108 Longs Gap Road. Carlisle PA 17013-1219 Municipality: North Middleton ATTORNEY FO'R PLAINTIFF ATTY FILE NO.: XFP 168746 ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire Pa. I.D. #55650 Kimberly A. Bonner, Esquire Pa. I.D. #89705 Joel A. Ackerman, Esquire Pa I.D. #202729 Ashleigh Levy Marin, Esquire Pa I.D. #306799 Ralph M. Salvia, Esquire Pa I.D. #202946 Jaime R. Ackerman, Esquire Pa I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908)233-1390 FAX office@zuckeraoldbera.com File No.: XFP-168746/hp s Q..\ 4!\oa7~ Q~ Ck-1k UoA4y i~~ aP~335 Zucker, Goldberg & Ackerman, LLC XFP-168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, 2 : ~~.. J NO ~~/ ~-s .. `''' . ~ ' ROBERT FITTING; ~ `'.". ,,may ~~~ ~~ -"{ "~'.,~"~ ~~~ Defendant(s). ~ ~ ~ cnr" !v ~~~~ ~;~ -•~ ~~ ~ ~~ ~ ~~ n ~,. ~ -- ~ ~..~ _~ 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 acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. Zucker, Goldberg & Ackerman, LLC XFP-168746 IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TI05 PROGRAM IS FREE. ZUCKER, GOLDBERG & ACKERMAN, LLC By: Dated: September ~1 , 2012 Scott . Dietterick, Esquire; PA LD. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-168746/jab 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-168746 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete• your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: State: Zip: Yes ^ No ^ Listing date: Price: $ Realtor Phone: Yes ^ No ^ Home: Cell: State _ Office: _ Other: How long? Home: Cell: How long? State: Office: _ Other: 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: Date you closed your loan: Included Taxes & Insurance: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Zip: Zip:- Zucker, Goldberg & Ackerman, LLC XFP-168746 Assets Home: Other Real Estate: Retirement Funds: Investments: Checking: Savings: Other: Automobile #1: Amount owed: Automobile #2: Amount owed: Amount Owed: Model: Model: Value: Year: Year: 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" 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): Email: Fax: Value: Value: Zucker, Goldberg & Ackerman, LLC XFP-168746 Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ^ No ^ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ^ No ^ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: 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: ~ Proof of Income V Past 2 bank statements d Proof of any expected income for the last 45 days J Copy of current utility bill J Letter explaining reason for delinquency and any supporting documentation (hardship letter) ~ Listing agreement (if property is currently on the market) Zucker, Goldberg & Ackerman, LLC XFP-168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.. ROBERT FITTING; 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 acourt-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 Legal Representative Date Signature of Defendant Signature of Defendant Date Date Zucker, Goldberg & Ackerman, LLC XFP-168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. ROBERT FITTING; AND NOW, this day of CIVIL DIVISION ,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 acourt-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 Plaintiff, Defendant(s). NO.. CASE MANAGEMENT ORDER Zucker, Goldberg & Ackerman, LLC XFP-168746 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBTOR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Zucker, Goldberg & Ackerman, LLC XFP-168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA _7 Wells Fargo Bank, N.A. CIVIL DIVISION r.a N ,M: --~+ ~~a ~'' cn :~-.~,-. r~zw. Plaintiff, ~ : ~ ~ NO -- ~~ -v r~ --~ ,~, . vs. cn r . -~ ~ N ca ,ys~..; c~ r--:r_ ROBERT FITTING; .~c..~ ~• --t ~. ~-~~; An cry Defendant(s). ~°' _._. ~~_A -./ r~ NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. ROBERT FITTING; Defendant(s). AVISO NO.. USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demands establecida en las siguientes paginas, debe tomar accibn dentro de los proximos veinte (20) dias despues de la notificaci6n de esta Demands y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falls en tomar action como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier sums de dinero reclamada en la demands 0 cua Iquier otra reclamation o remedio solicitado por el demandante, puede ser dictado en contra Suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes pars usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGAR UNO, LLAME O VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Zucker, Goldberg & Ackerman, LLC XFP-168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. CIVIL DIVISION Plaintiff, NO.. ROBERT FITTING; 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°) through its servicing agent WELLS FARGO BANK, N.A. located at 3476 Stateview Blvd., MAC #X7801-013, Ft. Mill, SC 29715. 2. Defendant, ROBERT FITTING, is an individual whose last known address is 603 Park Hills Drive, Mechanicsburg, PA 17055. 3. On or about February 19, 2009, ROBERT FITTING, Unmarried Man made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for American Mortgage Network, Inc., DBA Amnet Mortgage a Mortgage in the original principal amount of $104,135.00 on the premises hereinafter described in Exhibit "A", with said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on March 5, 2009, Instrument #200906243. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 4. Plaintiff is the current holder of the Mortgage. The Mortgage was assigned by Mortgage Electronic Registration Systems, Inc. as nominee for American Mortgage Network, Inc., DBA Amnet Mortgage to Wells Fargo Bank NA, plaintiff herein, pursuant to an assignment of mortgage dated May 24, 2012 and recorded on May 29, 2012 in the Office of the Recorder of Deeds for Cumberland County, Instrument #201215785. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 5. ROBERT FITTING is the record and real owner of the aforesaid mortgaged premises. Zucker, Goldberg & Ackerman, LLC XFP-168746 062-PA-V2 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 April 2012 payment. 7. On April 16, 2012, Defendant(s) were mailed a Notice of Intention to Foreclose Mortgage, in compliance with Act 6 of 1974, 41 P.S. §101, et seq. 8. As of 09/17/2012, the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $99,684.66 Interest through 09/17/2012 $2,981.68 Escrow Advance $796.71 Escrow Balance ($ 0.00) Suspense Balance ($0.00) Late Charges $92.58 Inspection Fees $75.00 Property Preservation $749.00 Total $104,379.63 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, 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 authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 9. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability under a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. 062-PA-V2 Zucker, Goldberg & Ackerman, LLC XFP-168746 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $104,379.63, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GOLDBERG & ACKERMAN, LLC BY: Dated:~V~~~ - ~p 1 ~ V ~ ~ Scott . D~ tterick, Esquire; PA LD. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-168746/hp 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com lS 1#AN A ~ PT TD COLLECT A D1~8~, A1)!D Ali' INFQ1tM~lT'rQAI f~~~"i~ ,, WIL! BE !lSfD fQR THAT PUS£ Zucker, Goldberg & Ackerman, LLC XFP-168746 062-PA-V2 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-168746 r ~~ ~ LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in North Middleton Township, Cumberland County Pennsylvania, bounded and described as follows: BEGINNING at a take in the South side of Public Road at lands now or formerly of George W. Stambaugh; thence by lands of the same, South 11 degrees, 11 minutes West 166.75 feet to a stake at land now or formerly of Cazlisle Gun Club, Inc.; thence by lands now or formerly of Carlisle Gun Club, Inc.; South 82 degrees, 9 minutes East, 50 feet to the center of a 30 foot driveway; thence by the center of said driveway and by lands now or formerly of Simon B. Jumber, North 11 degrees, 11 minutes East, 161 feet more or less, to a point on the South side of the aforesaid Public Road; thence by the South side of said Public Road, North 76 degrees, 34 minutes West, 50 feet to a stake at the place of BEGINNING. Parcel #29-18-1371-013 VERIFICATION Samir Erian, hereby states tha~'she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, tha~he is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of is r information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Samir Erian DATE: 09/18/2012 Title: Vice President Loan Documentation Wells Fargo Bank, N.A. 086-PA-v 1 Zucker,Goldberg & Ackerman, LLC XFP-168746 SHERIFF'S OFFICE OF CUMBERLAND COUNTY _ Ronny R Anderson ~; ;<<.i-,: ''r' Sheriff ~~, "~r~ M ~~ t,-, k~.r .. . .~ y, _ ~ i ~' a. Jody S Smith ~ `'~°~f Chief Deputy ~ o~`j~~to "'~ ~~ ti~~ 4~ Richard W Stewart f ~~~~ ~ ~~ Solicitor ":..~'~.1~~L~ ~~~Sw ~l~' ~~'-~~~ Wells Fargo Bank, N.A. vs. Robert Fitting Case Number 2012-6083 SHERIFF'S RETURN OF SERVICE 10/01/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Robert Fitting, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Robert Fitting. Deputies attempted service at 1923 Sterretts Gap Avenue, Carlisle, Pennsylvania 17013, but were advised by the Defendants sister on July 25, 2011 Robert Fitting moved over two years ago, and is thought to have moved to the Mechanicsburg, Pennsylvania area. 10/08/2012 Ronny R Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Robert Fitting, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Robert Fitting. Request for service at 603 Park Hills Drive, Mechanicsburg, Pennsylvania 17055 the Defendant was not found. Deputies were advised by the current owners of this residence, Robert Fitting has not resided at this address in over ones year. He is however thought to be currently residing irr the Carlisle, Pennsylvania area. 10/09/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Robert Fitting, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Robert Fitting. Request for service at 141 High Street, Carlisle, Pennsylvania 17013 is owned by Barb Allen. She has owned this residence for the past four years and does not know Robert Fitting. 10/31;2012. Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Robert Fitting, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Robert Fitting. Request for service at 108 Longs Gap Road, Carlisle, Pennsylvania 17013 is currently vacant. To date The Carlisle Postmaster has been unable to provide a good forwarding address for the Defendant. SHERIFF COST. 587.00 November 02, 2012 SO ANSWERS, RONNY R ANDERSON, SHERIFF ^ ` ^ ` ^ ' ^ - ~ IN THE COURT OPCOMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,NJ� � CIVIL DIVISION Plaintiff, ^ C= -- -� VS. � WO.: l3-GD83'C � �� --VS. K/ -o ROBERT FITTING; �o z —?C t-D Defendant. � AND NOW, comes the Plaintiff, Wells Fargo Bank �� by and through its attorneys, Zucker, Goldberg & Ackerman, LLC, and files the within Motion for Special Service pursuant to Pa.R.C.P, 430 as folloxvs | 1. On or about September 38, 2012, Plaintiff filed its original Connmaint in Mortgage � Foreclosure ("Complaint") against the Defendant, ROBERT FITTING ("Defendant(s)"), at the above- captioned number and term. ' ' 2. Plaintiff directed the Sheriff qf Cumberland County tmserve Defendamt(s)atdefendant's � last known address being 108 Longs Gap Road, Carlisle, PA 17013-1219, but service was returned this � property in vacant. A true and correct copy of said Return of Service from the Cumberland County ` Sheriff s Office ks marked Exhibit/,attached hereto and made a part hereof. � 3. A search of the U.S. Postmaster's records for 108 Longs Gap Road, Carlisle, PA 17013- 1219 no change of address order on fi/e. Atrue and correct copy o f Plaintiff's U.S. Postmaster's Search _ is marked Exhibit Q,attached hereto and made apart hereof. 4. Plaintiff directed the Sheriff of Cumberland County to serve Defendant(s)at defendant's . last known address being 603 Park Hills Drive, Mechanicsburg, PA 17055-S496, but service was returned ' defendant does not reside at this location for ayear. A true and correct copy nfsaid Return ofService . from the Cumberland County Sheriff's Office is marked Exhibit A, attached hereto and made part hereof. S. [>n June 28, 2D12a request for confirmation ofmn alternate address for defendanKs\ was forwarded by Plaintiffs counsel 1mthe US Postmaster for 603 Park Hills Drive, Mechanicsburg, PA 17O55-5496, but no such information was provided 6v said postal authorities. ` . . . 6 Plaintiff directed the Sheriff of Cumberland County to serve rt(s)atdefendant's last known address being 141 High Street Carlisle, PA 17013, but service was returned property is owned bx owner for four years and owner does not defendant. A true and correct copy ofsaid Return V7 Service from the Cumberland County Sheriff's Office is marked Exhibit A~attached hereto and made m part hereof. 7. On June 28, 2012 a request for confirmation of an alternate address fordefendent(s) was forwarded by Plaintiff's counsel to the US Postmaster for 141 High Street, Carlisle, PA17O13, but no ' such information was provided 6wsaid postal authorities. ! 8. Plaintiff directed the Sheriff mf Cumberland County to serve Defondmn1(s)atdefendant's � last known address being 1923 Sterretts Gap Ave, Carlisle, RA 17013' but service was returned � defendant moved about two Veers ago. Atrue and correct copy ofsaid Return mf Service from the Cumberland County Sheriffs Office in marked Exhibit/,attached hereto and made apart hereof. � 8. On June 28, 3012 a request for confirmation of an alternate address for defendant/s\ was forwarded by Plaintiff's counsel to the US Postmaster for 1923 Sterretts Gap Ave,Carlisle, PA 17013, � but no such information was provided b*said postal authorities. � 10. An internet person locator search provided no alternative address for Defendant(s). 11. Plaintiff conducted an investigation 10 determine the whereabouts ofDefendant(s), ` ROBERT FITTING, but all sources indicated no alternative address other than that of the Mortgaged � Premises. An affidavit of Plaintiffs counsel regarding the investigation taken to determine the � whereabouts of0e8endant(s}is marked Exhibit C,attached hereto and made o part hereof, � 12. Plaintiff attempted to obtain concurrence of Defendant(s) ROBERT FITTING with the ' Motion, but Defendant(s)cannot be located,therefore no concurrence was obtained. 13. There has been no other motion filed |n this case. i - � � � ' WHEREFORE, Plaintiff respectfully requests that this Honorable Court to permit Plaintiff to serve Defendant(s), ROBERT FITTING, with the Complaint and Notice of Sale, if necessary, by instructing the Cumberland County Sheriffs Office to POST a copy of same on the Mortgaged Premises, being 108 Longs Gap Road,Carlisle PA 17013-1219 and by mailing a copy,via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid, with said service being valid and complete upon such posting and mailing in accordance with Pa R C P 430. ZUCKE G LDBER ACKERMAN, LLC Dated: May 5 , 2013 BY.. Scott A. Dietterick, Esquire; PA I.D.`#55650 Kimberly A. Bonner, Esquire; PA.I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh Levy Marin, Esquire; PA I.D.#306799 Ralph M.Salvia; Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 File No,:XFP-168746 (908)233-8500; (908) 233-1390 FAX E-mail: Office @zuckergoldberg.com EXHIBIT A Zucker,Goldberg&Ackerman,LLC XFP-168746 u SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 10101i,at t*na>yL,ctr�jf� Jody S Smith 10101i, ,,. Chief Deputy Richard W Stewart {J Solicitor OFFICE OF 1)46 SPEltIFF Wells Fargo Bank,N.A. VS, Case Number _ Rube ! ing. SHERIFF'S RETURN OF SERVICE 10101/2012 Ronny R.Anderson,Sheriff,who being duly swom according to law,states that he made a diligent search and Inquiry for the within named defendant to wit Robert Fitting,but was unable to locate him In his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Robert Fitting. Deputies i attempted service at 1923 Sterretts Gap Avenue, Carlisle,Pennsylvania 17013,but were advised by the Defendants sister on July 25,2011 Robert Fitting moved over two years ago,and is thought to have moved to the Mechanicsburg, Pennsylvania area. 10/08/2012 Ronny R,Anderson,Sheriff,who being duly swom according to law,states that he made a diligent search i and inquiry for the within named defendant to wit: Robert Fitting,but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Robert Fitting. Request for service at 603 Park Hills Drive,Mechanicsburg,Pennsylvania 17055 the Defendant was not found. Deputies were advised by the current owners of this residence, x Robert Fitting has not resided at this address in over one year, He is however thought to be currently residing in the Carlisle, Pennsylvania area. 10/09/2012 Ronny R.Anderson,Sheriff,who being duly swam according to law,-.states that he made a diligent search and inquiry for the within named defendant to wit: Robert Fitting,but was unable to locate him In his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Robert Fitting, Request for service at 141 High Street,Carlisle, Pennsylvania 17013 is owned by Barb Allen, She has owned this residence for the past four years and does not know Robert Fitting. i 10131/2012 Ronny R.Anderson,Sheriff,who being duly swom according to law,states that he made a diligent search and Inquiry for the within named defendant to wit: Robert Fitting,but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Robert Fitting. Request for service at 908 Longs Gap Road,Carlisle,Pennsylvania 17013 Is currently vacant. To date The Carlisle i Postmaster has been unable to provide a good forwarding address for the Defendant. SHERIFF COST:$87.00 SO ANSWERS, November 02,2012 :RbNW R ANDERSON,SHERIFF i , x t�cflunsysemc slxntrr,r�lcwan,IaS, i EXHIBIT B Zucker,Goldberg&Ackerman,LLC XFP-168746 LEONARD B.ZUCKER MICHAEL S.ACKERMAN FOUNDED IN 1923 IOEL ACKERMAN- ZUCKER,GOLDBERG&ACKERMAN,LLC AS ZUCKER a GOLDBERG ATTORNEYS AT LAW FRANCES GAMBAROCUA MAURICE 7.ZUCKER(1918-1979) BRIAN C.NICHOLAS•• 200 SHEFFIELD STREET- SurrE 301 LOUIS D.GOLDBERG(1923-1967) STEVEN D.KROL P.O.BOX 1024 LEONARD H.GOLDBERG(1929- 1979) ^HRISTOPHERG.FORD MOUNTAINSIDE,NJ 07092-0024 BENJAMIN WELSS(1949-1981) DENISE CARLON••' -HRISTINE E.POTTER TELEPHONE:908-233.8500 PENNSYLVANIA OFFICE RYAN S.MALC FACTMILE:908-233-1390 P.O.box 650 IENEE K,CICCARELU E-MAIL:OFFTCEOZUCKERGOLDBERG.COM HERSHEY,PA 17033 IAMES R.FREESWICK'•• ASHLEIGH LEVY MARIN•••• FOR PAYOFFJREINSTATEMENT FIGURES PLEASE SEND Of COUNSEL DOUGLAS J.McODNOUGN YOUR REQUEST TO: SCOTT A DIEr4ERICK,ESQ. «rrr. nMOIHY J.ZIEGLER ZUCKERGOLDBERG.COM/PR KIMBERLY A.SONNER,ESQ.••'•• STEPHANIE WOLCHOK HYUN S.OH REPLY TO NEW JERSEY ADDRF55 'ALSO MEMBER OF NY,PA AND CA BAR eUZABETN P.RIZZO '•ALSO MEMBER OF NY AND ME BAR ROBERT D.SALLY 'r'ALSO MEMBER OF NY BAR IAMME R.ACKERMAN*"' •'••ALSO MEMBER OF PA BAR RACHEL G.PACKER'•••'• +'•••MEMBER PA BAK ONLY •"•"ALSO MEMBER NY AND DC BAR Postmaster C_168746PDIPXi C Carlisle,PA 17013-1219 June 30,2012 RE: Request for Change of Address or Boxholder information Needed for Service ofTrocess Please furnish the new address or the name and street address(if a boxholder)for the following: Robert Fitting-408 Longs Gap Road The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxbolder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1)and(2)and corresponding Administrative Support Manual 352A4a and b. I. Capacity orrequester. A77ORNEYS FOR PLAINTIFF 2. Stature or regulation that empowers me to serve process: NOT APPLICAS LE 3. The names of all known parties to the litigation:Wells Fargo Hank,N,A,v,Robert Fitting 4.The court in which the case has been or will be heard: SUPERIOR COURT OF PENNSYLVANIA;CHANCERY DIVISION; COUNTY CUMBERLAND S. The docket number is:F-00000.07 C The capacity in which this individual is to be served(e.&defendant or witness}: DEFENDANT THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RUULT IN CRIMINAL, PENALTIES INCLUDING A FINE OF UP TO 510,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF 'ADDRESS INFdjtmATION'OF NOT.MORE THAN S T'EARS,OR BOTH(TITLE I8:U.S.C:SECTION I Ool). " `` '' I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual orprospective litigation. Very truly yours, By: SCOTT DIETTERICK LBZ/T SCOTT DIETfERICK Enclosures �,� 0'13 jl� f FOR POST OFFICE USE ONLY No Change of Address Order on file. NAME AND STREET ADDRESS Not known at address given. Moved Left no forwarding address �- _No such address C_168746PD1PX1 C EXHIBIT C Zucker,Goldberg&Ackerman,LLC XFP-168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION. Plaintiff, NO.: 12-6083-CIVIL VS. ROBERT FITTING; Defendant., AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SSW COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Ralph M. Salvia, Esquire, attorney for and authorized representative of Plaintiff, who being duty sworn according to law, deposes and says that Plaintiff, or counsel for Plaintiff, conducted an investigation to determine the whereabouts of Defendant(s), which included,but was not limited to searches of the following records: (X) Records of the U.S. Postmaster with results of same attached to the foregoing Motion. (X) Internet Person Locator Records N Credit Report Agency. (X) Telephone Directory N Records of the County Recorder of Deeds and Prothonotary. Finally,Affidavit deposes and says that if Defendants)is/are not located at the address uncovered by this investigation,the whereabouts of Defendants) is/are unknown to Plaintiff. ZUCKER, DBERG &A ERMAN, LLC Dated: May.?O,2013 By:._ Scott A. Dietterick Esquire; PA I.D.#55650 q , Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh Levy Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.R.#311032 Atty File No.:XFP-168746 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 Email: Office @zuckergoldberg.com ' (908)233-8500; (908) 233-1390 FAX Sworn to and su scribed before me this day of ;2013. Public '� My Commission Expires: COMMORMIEALTH OF PENNSYLVANIA N O AF:IAL SEAL DENSE L.FOSTER,tIOTARY PUBLIC H MY COMMISSION EXPIRES RES MA CH 5,02017TM Person Search Page 1 of 3 Person Search Results Records:1 to 12 of 12 Search Terms Used - SSN: 175601010; All Full Name SSN Address Phone Next Steps 1. R FITTING 175-60.1010 603 PARK HILLS DR ROBERT FITTING LeAD:818362141 MECHANICSBURG PA 17055- ROBERT C FITTING 4967 ROBERT C FITTING 3 Jul 11-Nov 12 ROBERT C FITTING #/Probable current address III DOB:7/20/1976(36) Gender:Male Setup Alert We Also Found: Phones Plus n Property Records ❑Email Address 2. ROBERT FITING 175-60-1010 108 LONGS GAP RD 717-241-4428- R FITTING LexID:818362141 CARLISLE PA 17013-1219 EST ROBERT FITTING Dec 07-Feb 12 ROBERT C FITTING ROBERT C FITTING 3 ROBERT C FITTING 111 DOB:7120/1976(36) Gender:Male Setup Alert 3. ROBERT C FITTING 175-60-1010 141 W HIGH ST APT D 717-245.9998- III LexID:818362141 CARLISLE PA 17013-2603 EST DOB:7/20/1978(36) Oct 00-Nov 11 Gender:Male fi yA Sotup Alert 4. ROBERT FITTING 175-60-1010 1923 STERRETTS GAP AVE 717-243-3938- ROBERT C FITTING LexID:818362141 CARLISLE PA 17013-1061 EST ROBERT C FITTING 3 Jul 94-Mar l l ` Active Phone ROBERT C FITTING III FITTING MARY DOB:7/20/1976(36) Gender:Male Setup Alert S. ROBERT C FITTING 176-60-1010 2061 SPRING RD ROBERT C FITTING 3 LexID:818362141 CARLISLE PA 17013-1059 ROBERT C FITTING Jan 99-Oct 07 III C F ROBERT C FITTING ROBERT DOB:7/2011976(36) Gender:Male Setup Alert FROBERT C FITTING 175-60-1010 15927 SW 3RD LN 352-390-2211- III LexID 818362141 OCALA FL 34481-1001 EST https:Hsecure.accurint.com/app/bps/misc 12/12/2012 Person Search Page 2 of 3 DOB:7/20/1976(36) Jul 07 �"'Active Phone Gender:Male FITTING JESSICA Setup Alert 7. ROBERT C FITTING T 175-60.1010 3825 ELMERTON AVE III LexID:818362141 HARRISBURG PA 17109-1247 DOB:712011976(36) May 07 Gender:Male J Setup Avert g, ROBERT C FITTING 175-60-1010 141 W HIGH ST APT 717-245-9998- ROBERT C FITTING LexID:818362141 CARLISLE PA 17013-2913 EST III Oct 00-Aug 03 DOB:7120/1976(36) Gender:Male Setup Alert 9, ROBERT C FITTING 175-60-1010 19231923 STERRETTS GAP 717-243-3938- III LexID:818362141 CARLISLE PA 17013 EST DOB:7/2011976(36), Apr 02 `:i!l'Active Phone Gender:Male FITTING MARY 10. ROBERT C FITTING 175-60-1010 141 HIGH W CRLS PA 717-245-9998- DOB:7120!1976(36) LexID:818362141 CARLISLE PA 17013 EST Gender:Male Oct 00-Feb 01 Setup Alert 11. ROBERT C FITTING 176.60-1010 4530 COVENTRY RD III LexID:818362141 HARRISBURG PA 1 71 09-1 63 8 DOB:712011976(36) Jul 94-Jun 95 Gender:Male Setup Alert 12. ROBERT C FITTING 175-60-1010 1923 STERRETTS GAP AVE'A 717-243-3938- III LexID:818362141 CARLISLE PA 17013-1061 EST DOB:7/20/1976(36) 1"Active Phone Gender:Male FITTING MARY Setup Alert Records: 1 to 12 of 12 Your DPPA Permissible Use: Civil, Criminal, Administrative~ or Arbitral Proceedings Your GLBA Permissible Use: Persons Acting in a Fiduciary Capacity on Behalf of the Consumer VoSCkNipt xk- About LexisNexis I Terms&Conditions https:Hsecure.accurint.com/app/bps/mise 12/12/2012 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 12-6083-CIVIL ROBERT FITTING; Defendant. ORDER OF COURT AND NOW,this day of ,2013, upon consideration of Plaintiff's Motion for Special Service, it is hereby ORDERED,ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendants) ROBERT FITTING, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 108 Longs Gap Road, Carlisle PA 17013-1219, and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid, with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P.430. BY THE COURT: C,-- !'Y Zucker,Goldberg&Ackerman,LLC XFP-168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A., CIVIL DIVISION Plaintiff, NO.: 12-6083-CIVIL VS. MOTION FOR SPECIAL SERVICE ON ROBERT FITTING; DEFENDANT PURSUANT TO Defendant(s). Pa.R.C.P.430 FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: I ZUCKER,GOLDBERG &ACKERMAN,LLC Scott A.Dietterick, Esquire Pa. I.D.#55650 Kimberly A. Bonner,Esquire Pa. I.D.#89705 Joel A.Ackerman, Esquire Pa. I.D.#202729 Ashleigh Levy Marin, Esquire Pa. I.D.#306799 Ralph M.Salvia, Esquire Pa I.D.#202946 Jaime R.Ackerman, Esquire Pa I.D.#311032 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908)233-1390 FAX office @zuckereoldbere.com File No.:XFP-168746/cper Zucker,Goldberg&Ackerman,LLC XFP-168746 u I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff -I- : NO.: 12-6083-CIVIL vs. ROBERT FITTING rn 7-1(3 Defendant PRAECIPE TO REINSTATE COMPLAINT -� TO THE PROTHONOTARY: Please mark the Complaint in Mortgage Foreclosure filed at the above-captioned term and number reinstated. ZUCKER, GOLDBERG &ACKERMAN, LLC a / By: A J[ AJ Dated: November 14, 2013 Scott A. D etteric , Esquire; PA I.e. 155650 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; PALE).#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Attorneys for Plaintiff XFP-168746/jpa 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com X1 .7 � 0 41/ eisQslp/97 R-9 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ' Chief Deputy ` "` Richard W Stewart ~ ,,- Solicitor f i 9�� t 'EN'; dSYlVANI Wells Fargo Bank vs. Case Number Robert Fitting 2012-6083 SHERIFF'S RETURN OF SERVICE 12/06/2013 01:39 PM - Deputy Brian Grzyboski, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Robert Fitting, pursuant to Order of Court by"Posting"the premises located at 108 Longs Gap Road, North Middleton Township, Carlisle, PA 1 013 with a true and ore t copy according to law. 4*(0; , 7.„ / / AN GRZYBO I, 1 SHERIFF COST: $40.78 SO ANSWERS, December 11, 2013 RONNR ANDERSON, SHERIFF ; f - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. ISSUE NO.: 12-6083-CIVIL Plaintiff TYPE OF PLEADING VS. AFFIDAVIT OF SERVICE OF t ROBERT FITTING COMPLAINT PURSUANT TO Pa.R.C.P.,430 SPECIAL ORDER Defendant OF COURT CODE: Cf) 4 C3 A FILED ON BEHALF OF: 37 C--) ; Wells Fargo Bank, N.A. l COUNSEL OF RECORD FOR THIS PARTY: �+ ZUCKER,GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D.#55650 Kimberly A. Bonner, Esquire- PA I.D.#89705 Joel A.Ackerman, Esquire-PA I.D.#202729 Ashleigh Levy Marin, Esquire-PA I.D.#306799 Ralph M.Salvia, Esquire-PA I.D.#202946 Jaime R.Ackerman, Esquire- PA I.D.#311032 Jana Fridfinnsdottir, Esquire- PA I.D.#315944 Brian Nicholas, Esquire- PA I.D.#317240 Denise Carlon, Esquire- PA I.D.#317226 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500 (908)233-1390 FAX office@zuckergoldberg.com File No.:XFP- 168746/dlaw IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff NO.: 12-6083-CIVIL VS. ROBERT FITTING Defendant. AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT I,f:U'i 1 S-Q�, Cajr(6n, Esquire,attorney for Plaintiff,Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiffs Complaint in Mortgage Foreclosure on Defendant, ROBERT FITTING, as follows: 1. On or about June 12, 2013,an Order of Court was entered granting Plaintiffs Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit"A",attached hereto and made a part hereof. 2. Pursuant to said Order,on or about November 25, 2013,Zucker,Goldberg&Ackerman, LLC,the counsel for Plaintiff served Defendant, ROBERT FITTING with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure,via First Class U.S. Mail and Certified Mail, Return Receipt Requested to the defendant's last known address being 108 LONGS GAP ROAD,CARLISLE, PA 17013- 1219. A true and correct copy of said returned receipt and certificate of mailing are marked Exhibit"B", attached hereto and made a part hereof. 3. Pursuant to said Order,on or about December 6, 2013,the Sheriff of Cumberland County posted the property subject to the Mortgage, being 108 Longs Gap Road,Carlisle, PA 17013- 1219 with a true and correct copy of Plaintiff's Complaint in Mortgage Foreclosure. A true and,correct copy of the Service Form from the Sheriff of Cumberland County is marked Exhibit"C",attached hereto and made a part hereof. ZUCKER,GOLDBERG&ACKERMAN, LLC By. Scott A. Dietteric , Esquire; PA I.D.#55650 Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh Levy Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D.#317226 Atty File No.:XFP-168746 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908)233-1390 FAX Dated: April �(�2014 Sworn to and subscribed before me this(30day of April, 2014 a��lv Notary Pub is MY COMMISSION EXPIRES: Cheryl Debeneadto Notary Public My Comm. Expires Oct. 16,2016 10#2280276 State of New Jersey IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, NO.:12-6083-CIVIL vs. ROBERT FITTING; Defendant. ' ORDER OF COURT AND NOW,this IXay of ._. 2013, upon consideration of Plaintiffs Motion for Special Service, it is hereby ORDERED,ADJUDGED AND DECREED that Plaintiff shall serve its Complaint In Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) ROBERT FITTING, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 108 Longs Gap Road, Carlisle PA 17013-1219, and by mailing a copy, via Certified Mail, no signature required and First Class U.S.Mail,Postage Prepaid,with said service being valid and complete upon such posting and mailing in accordan ittr Pa.R.C.P.430. BY THE COURT: .V:K �x Zucker,Goldberg&Ackerman,LLC XFP-168746 S igfi-0 a r. �. 092 � r 213�1p 0'i' �(i t 17 1. T r Ase oto f�,/� _ Marling x 'VSTA.L SERVICE. hto erpay yfet,affix sta.Tps or motor postage i Tills Cartftate of Mallint provides evidence that mall has been presented to USPS*for ma®Ing,This form maybe used for domestic and international mail. Scott A.Dietterick,Esquire c/o Zucker,Goldberg&Ackerman, LLC ` 200 Sheffield Street,Suite 101 } Mountainside,NJ 07092 XFP-168746/Jpa TEAM B emss' Post erkHere �� To- ROBERT FITTING 108 LONGS GAP ROAD CARLISLE,PA 17013-1219 ''=•`w .:✓ `., t ; County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 t i i r r` r Zucker,Goldberg&Ackerman,LLC PO 80,1219 Mountainside,NJ 07092-1219 7196 9006 9297 0786 6301 20131125102 k�rlrrinlurrrr�lrp,pl,.d.,r�,.lrlrrrq,l„Iru4rrlddrlll ROBERT FITTING 108 LONGS GAP RD CARLISLE,PA 17013-1219 ISMTG SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff .`�� Jody S Smith Chief Deputy Richard W Stewart - f Solicitor Wells Fargo Bank Case Number vs. 2012-6083 3 Robert Fitting SHERIFF'S RETURN OF SERVICE . s 12/06/2013 01:39 PM-Deputy Brian Grzyboski, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Robert Fitting, pursuant to Order of Court by"Posting"the premisest located at 108 Longs Gap Road, North Middleton Township, Carlisle, PA ; 13 with a true and,, e I copy according to law. IAN GRZYB.O 1, SHERIFF COST:$40.78 SO ANSWERS, ; RON. R ANDERSON,SHERIFF December 11,2013 ..,. i f 7 Y A ' , 1 fid- 4k M,AT♦ �f..t r �.w• a r ii.:+r ..w a�i •7 �ah� � � r {_:)^cµttt!:• uitn St-.0mr,,o;eosn l-!re, ........... ......................................_.... .. ._.... ..... .. .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. ROBERT FITTING; Defendant. NO.: 12 -6083 -CIVIL PRAECIPE TO REINSTATE COMPLAINT crk TO THE PROTHONOTARY: Please mark the Complaint in Mortgage Foreclosure filed at the above -captioned term and number reinstated. j { �� Dated: �Q11`�' n k By: ZUCKRG & ACKERMAN, LLC cott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-168746/jbenn 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com CTJ 0a14. 6,6061 �� 3o�3i8 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFiCF OF r sH�RIF= KL 1 [.,UMBERLJ D Culi;v PENNSYLVANIA Wells Fargo Bank National Association vs. Robert Fitting Case Number 2012-6083 SHERIFF'S RETURN OF SERVICE 06/17/2014 09:13 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Robert Fitting, pursuant to Order of Court by "Posting" the premises located at 108 Longs Gap Road, North Middleton Township, Carlisle, PA 17013 with a true and correct copy according to law. kfix, DAWN KELL, DEPUTY SHERIFF COST: $40.78 SO ANSWERS, June 19, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. RONR ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff vs. ROBERT FITTING; Defendant(s). Mortgaged Premises: 108 Longs Gap Road, Carlisle, PA 17013-1219 c`a CIVIL DIVISION rfi No.: 12 -6083 -CIVIL r- N c ISSUE NUMBER: t7 C7 A ZC) Cr) , TYPE OF PLEADING: v , PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) FILED ON BEHALF OF: Wells Fargo Bank, N.A. Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa. I.D. #55650 Kimberly A. Bonner, Esquire- Pa. I.D. #89705 Joel A. Ackerman, Esquire- Pa I.D. #202729 Ashleigh Levy Marin, Esquire- Pa I.D. #306799 Ralph M. Salvia, Esquire- Pa I.D. #202946 Jaime R. Ackerman, Esquire- Pa I.D. #311032 Jana Fridfinnsdottir, Esquire- Pa I.D. #315944 Brian Nicholas, Esquire- Pa I.D. #317240 Denise Carlon, Esquire- Pa I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-168746 alto.411, QLL 88�i � S'195 - Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, LLC XFP-168746 hc., 7) z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. ROBERT FITTING; Defendant. NO.: 12 -6083 -CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above -captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to Plaintiff's Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $104,379.63 plus interest on the judgment amount ($104,379.63) from September 18, 2012, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 108 LONGS GAP ROAD address is: CARLISLE, PA 17013-1219 Dated: 7 - a -p ..1 y BY: fl Joel Aerman, Esquire; PA I.D. #202729 O Ashle' h L. Marin, Esquire; PA I.D. #306799 E] Jaime R. Ackerman, Esquire; PA I.D. #311032 ❑ Denise Carlon, Esquire; PA I.D. #317226 0 Brian Nicholas, Esquire; PA I.D. #317240 M Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XFP-168746 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX ` Email: Offic a zucQelIdber.�om DAMAGES ARE H REBY ASSESSED AS INDICATED ZUCKER, GOLBERG & A�MAN, LLC Date /dc//)q � IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. ROBERT FITTING; Defendant. NO.: 12 -6083 -CIVIL AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. Dated: Sworn to and subscribed before me This �Z. day of Jc4_4 , 20 1 y ZUCKER, OLBERG & AACKER AN, LLC BY: O Joel A. erman, s� uire; PA I.D. #202729 • Ashl gh L. Marin, Esquire; PA I.D. #306799 O Jaime R. Ackerman, Esquire; PA I.D. #311032 ❑ Denise Carlon, Esquire; PA I.D. #317226 • Brian Nicholas, Esquire; PA I.D. #317240 154 Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XFP-168746 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Notary Pu•Iic My Commission Expires: Cheryl Debeneadto Notary Public My Comm. Expires Oct. 16, 2016 IDState of New Jersey # 2280276 Zucker, Goldberg & Ackerman, LLC XFP-168746 Department of Defense Manpower Data Center Results as of : Jul -21-2014 06:59:41 AM SCRA 3.0 Status Report: Pursuant to Servicernernbers Civil Relief Act. Last Name: FITTING First Name: ROBERT Middle Name: Active Duty Status As Of: Jul -21-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date '' Status Servtce Component NA NA No NA This response reflects the individuals' active duty status based on the Active Duly Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date I Status Service Component NA NA No NA This response reflects where the Indtdual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA _ No NA This response reflects whether the IndMdual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense•Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(0 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: GB996C0A0008J00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. ROBERT FITTING; Defendant. NO.: 12 -6083 -CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT TO: ROBERT FITTING 108 LONGS GAP ROAD CARLISLE, PA 17013-1219 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on [] or [V] A copy of the Order or Decree is enclosed, The judgment is as follows: $104,379.63 • Prothonotary Zucker, Goldberg & Ackerman, LLC XFP-168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. ROBERT FITTING Plaintiff, Defendant. TO: ROBERT FITTING 108 LONGS GAP ROAD CARLISLE, PA 17013-1219 DATE OF NOTICE: 3/7/2014 CIVIL DIVISION NO.: 12 -6083 -CIVIL IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. ROBERT FITTING Plaintiff, Defendant. TO: ROBERT FITTING 108 LONGS GAP ROAD CARLISLE, PA 17013-1219 CIVIL DIVISION NO.: 12 -6083 -CIVIL AVISO IMPORTANTE FECHA DEL AVISO:3/7/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENDS QT.E USTED TOME ACCION DENTRO DE LOS PROMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS INIPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO TTMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR ONO, VAYA 0 LLAME LA OFICflTA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 ZUCKER GOLDBERG & ACKERMAN BY: ScrH-A. DWteritA, Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. ISSUE NO.: 12 -6083 -CIVIL Plaintiff TYPE OF PLEADING AFFIDAVIT OF SERVICE OF. ROBERT FITTING COMPLAINT PURSUANT TO. Pa.R.C.P., 430 SPECIAL ORDER Defendant OF COURT vs. CODE: FILED ON BEHALF OF: Wells FarRo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 • Ashleigh Levy Marin, Esquire -PA I.D. #306799 Ralph M. Salvia,.Esquire- PA I.D. #202946 Jaime R. Ackerman, Esquire- PA I.D. #311032 Jana Fridfinnsdottir, Esquire- PA I.D. #315944 Brian Nicholas, Esquire- PA I.D. #317240 Denise Carlon; Esquire- PA I.D. #317226 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckerRoldberg.com File No.: XFP-168746/dlaw IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff vs. ROBERT FITTING Defendant. NO.: 12 -6083 -CIVIL AFFIDAVIT OF SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE ON DEFENDANT PURSUANT TO ORDER OF COURT I,e.VV) 02,..H.6nEsquire, attorney 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 Complaint in Mortgage Foreclosure on Defendant, ROBERT FITTING, as follows: 1. On or about June 12, 2013, an Order of Court was entered granting Plaintiff's Motion for Service of Complaint in Mortgage Foreclosure Pursuant to Special Order of Court. A true and correct copy of said Order is marked Exhibit "A", attached hereto and made a part hereof. 2. Pursuant to said Order, on or about November 25, 2013, Zucker, Goldberg & Ackerman, LLC, the counsel for Plaintiff served Defendant, ROBERT FITTING with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure, via First Class U.S. Mail and Certified Mail, Return Receipt Requested to the defendant's last known address being 108 LONGS GAP ROAD, CARLISLE, PA 17013- 1219. A true and correct copy of said returned receipt and certificate of mailing are marked Exhibit "B", attached hereto and made a part hereof. 3. Pursuant to said Order, on or about December 6, 2013, the Sheriff of Cumberland County posted the property subject to the Mortgage, being 108 Longs Gap Road, Carlisle, PA 17013- 1219 with a true and correct copy of Plaintiffs Complaint in. Mortgage Foreclosure. A true and correct copy of the Service Form from the Sheriff of Cumberland County is marked Exhibit "C", attached hereto and made a part hereof. B Dated: April 3t 2014 Sworn to and subscribed before me thisday of April, 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietteric , Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh Levy Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA1.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Atty File No.: XFP-168746 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX MY COMMISSION EXPIRES: Cheryl Debeneadto Notary Public My Comm. Expires Oct. 16, 2016 ID # 2280276 State of New Jersey IN 'THE COURT OF COMMON PLEAS OF CUIVIBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. VS. ROBERT FITTING; Plaintiff, Defendant. CIVIL DIVISION NO.: 12 -6083 -CIVIL ORDER OF COURT AND NOW, this /24kclay of 4,-..,.)LiAt.IP 2013, upon consideration of Plaintiff's Motion for Special Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shalt serve Its Complaint In Mortgage Foreciosure and Notice of Sale, if necessary, on Defendangs) ROBERT FITTING, by Instructing the Sheriff of Cumberland 'County to EMI a copy of same on the Mortgaged Premises, being 108 Longs Gap Road, Carlisle PA 17013-1219, and by mailing a copy, via Certified Mail, no signature required and First Class U.S; Mail, Postage Prepaid, with said service being valid and comPlete uppn such PostIntand.malling in.raccorshinceiatR-PaA.C.P. 430 BY THE COURT: L Zucker, Goldberg & Ackerman, LLC • XFP-168746 tow, ittittaq 1091 Mailing topeie, Obt stns or rnetelniagt here. W54frmaO mitt form marle:usecY009Mq* 4!oil iitiernaffunif mat ''..=.1: SO* A. DiOtteritic; Esquire Zilkirr, Goldberg 8iA4efrOtiN LLC zoasheffievitstrot,SAitela _ _ _ _ • . Mountainslde, Ni 07092 XFP-168746/Jpa TAM 8 14, ROBERT FITTING: • 1T8 V.ONSGAP ROAD " - afftrity off).„W COMOEALAND Kiarm.3.417. 29.11M117.A.49..'009065. Zucker, Waxen d &Icema r, LLC PO Box 1219 Mountainside, NJ 07092-1219 7196 9006 9297 0786 6301 20131125-102 'itj,IluIINsnlisiIri11.111 riopLrrlirpJ'IIII'I'�lill'�I� ROBERT FITTING 108 LONGS GAP RD CARLISLE, PA 17013-1219 Ronny; R Anderson: :Sheriff Jody S Smith Gfifafpepufy Ri liard Vii4tovart Solit tof 'alis:f=ar aBet* Robed Fitting 'IFPS OFF -E OF CUM 3 RLAND C -LINTY Case Number 20=32=608.3 SHERIFF'S REtURN RETURNOF SERVICE 12i 61 013..01:39 PM Deputy Brats .Ggyboslsi, k3eirig duly sworn laogrorig to law, served the requested Notice of Residential Mort age Foree sure Diversion Program and Complaint in Mortgage Fareelosuro upon the within rhareektnefOralettti to wit ROOlatt Fitting, pursuanfto'.ti:NOt ctranilltbY "Posting" the prelrti's s located at 1.018 Lorsgs Gap Road, North Middleton; Township, .Carlisle, PA ; g1:3:witti a true copy according to law. SNEATFP COST440, 8' -thee. , 0 In SI�n7r7:a' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Wells Fargo Bank, N.A., vs. ROBERT FITTING; Plaintiff, Defendant. File No. 12 -6083 -CIVIL Amount Due $104,379.63 Interest from 09/18/2012 to date of sale $15,397.92 Costs TO THE PROTHONOTARY OF THE SAID COURT: 7;--4 Tr 2. 7' 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 Zucker, Goldberg & Ackennan, LLC XFP- I 68746 12 -175s- ' PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland Countyfor debt, interesand costs, as above dinactinga1tachrnen1againsttheahove'namnedgamnishee(s)forthefoUovxingpnopertyUfpea|estate,suppk/six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (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: 10-13 ~, � m� �~ ' Signature: Print Name: Scott A. ietteric , uire Kimberly A. Bonner, Esquire Joel A. Ackerman, Esquire Ashleigh L. Marin, Esquire Ralph M. Salvia, Esquire Jaime R. Ackerman, Esquire Jana Fridfinnsdottir, Esquire Brian Nicholas, Esquire 1DeniseCer|on, Esquire N4Roger Fay, Esquire Address: Zucker, Goldberg & Ackerman, LLC 200 Sheffield StreetSuite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 Supreme Court ID No.: 55650 89705 202729 306799 202946 311032 315944 317240 317226 315987 Zucker, Goldberg & Ackerman, LLC Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in North Middleton Township, Cumberland County Pennsylvania, bounded and described as follows: BEGINNING at a take in the South side of Public Road at lands now or formerly of George W. Stambaugh; thence by lands of the same, South II degrees, 11 minutes West 166.75 feet to a stake at land now or formerly of Carlisle Gun Club, Inc.; thence by lands now or formerly of Carlisle Gun Club, Inc.; South 82 degrees, 9 minutes East, 50 feet to the center of a 30 foot driveway; thence by the center of said driveway and by lands now or formerly of Simon B. Jumber, North 11 degrees, II minutes East, 161 feet more or less, to a point on the South side of the aforesaid Public Road; thence by the South side of said Public Road, North 76 degrees, 34 minutes West, 50 feet to a stake at the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 108 Longs Gap Road, Carlisle, PA 17013-1219. BEING the same premises which Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, by Deed dated November 29, 2007 and recorded December 31, 2007 in and for Cumberland County, Pennsylvania, as Instrument # 200747885, granted and conveyed unto ROBERT Tax Map No.: 18-137aka 29-18-1371-013. Zucker, Goldberg & Ackerman, LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., vs. ROBERT FITTING; Plaintiff, Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129.1 CIVIL DIVISION NO.: 12 -6083 -CIVIL : Execution No.: 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 108 Longs Gap Road, Carlisle, PA 17013-1219. 1. Name and Address of Owner(s) or Reputed Owner(s): ROBERT FITTING 108 Longs Gap Road Carlisle, PA 17013-1219 2. Name and Address of Defendant(s) in the Judgment: ROBERT FITTING 108 Longs Gap Road Carlisle, PA 17013-1219 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 CAVALRY PORTFOLIO SERVICES, LLC, AS ASSIGNEE OF CAVALRY SPV I, AS ASSIGNEE OF CHASE/ WASHINGTON MUTUAL 500 Summit Lake Drive Valhalla, NY 10595 AND c/o Gordon & Weinberg, P.C. 1001 East Hector Street, Suite 220 Conshohocken, PA 19428 Zucker, Goldberg & Ackerman, LLC XFP-I68746 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, INC., DBA AMNET MORTGAGE P.O. Box 2026 Flint, MI 48501-2026 AND 3300 S.W. 34th Avenue, Suite 101 Ocala, FL 34474 AND 1901 E. Voorhees Street, Suite C Danville, IL 61834 AND P.O. Box 85463 San Diego, CA 92186 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 Zucker, Goldberg & Ackerman, LLC XFP-168746 UNKNOWN TENANT OR TENANTS 108 Longs Gap Road Carlisle, PA 17013-1219 UNKNOWN SPOUSE 108 Longs Gap Road Carlisle, PA 17013-1219 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: IQ --(3_ y BY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A ietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XFP-168746/11 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-168746 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION vs. ROBERT FITTING; Plaintiff, Defendant. NO.: 12 -6083 -CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 ROBERT FITTING 108 Longs Gap Road Carlisle, PA 17013-1219 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 March 4, 2015 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: 108 Longs Gap Road, Carlisle, PA, 17013-1219 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12 -6083 -CIVIL Zucker, Goldberg & Ackerman, LLC XFP-168746 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: ROBERT FITTING A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. Zucker, Goldberg & Ackerman, LLC XFP-168746 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. Dated: 10 (3 ft( BY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. pl"etterick, Es e; PA I.D. #55650 Kimber y A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XFP-168746/1 I 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com VIA ORDER OF COURT Zucker, Goldberg & Ackerman, LLC XFP-168746 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net WELLS FARGO BANK, N.A. Vs. ROBERT FITTING WRIT OF EXECUTION NO 12-6083 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $104,379.63 L.L.: $.50 Interest FROM 9/18/2012 TO DATE OF SALE - $15,397.92 Atty's Comm: Due Prothy: $2.25 Atty Paid: $340.81 Other Costs: Plaintiff Paid: Date: 10/15/2014 DDa ' . Bu.ell, Pro honotary (Seal) By: Deputy REQUESTING PARTY: Name: ROGER FAY, ESQUIRE Address: ZUCKER, GOLDBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 101 MOUNTAINSIDE, N.J. 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No. 315987 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., vs. ROBERT FITTING; Plaintiff, Defendant(s). AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 . CIVIL DIVISION : NO.: 12 -6083 -CIVIL : Execution No.: cJ 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 108 Longs Gap Road, Carlisle, PA 17013-1219. 1. Name and Address of Owner(s) or Reputed Owner(s): ROBERT FITTING 108 Longs Gap Road Carlisle, PA 17013-1219 2. Name and Address of Defendant(s) in the Judgment: ROBERT FITTING 108 Longs Gap Road Carlisle, PA 17013-1219 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 CAVALRY PORTFOLIO SERVICES, LLC, AS ASSIGNEE OF CAVALRY SPV I, AS ASSIGNEE OF CHASE/ WASHINGTON MUTUAL 500 Summit Lake Drive Valhalla, NY 10595 AND c/o Gordon & Weinberg, P.C. 1001 East Hector Street, Suite 220 Conshohocken, PA 19428 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, INC., DBA AMNET MORTGAGE P.O. Box 2026 Flint, MI 48501-2026 AND 3300 S.W. 34th Avenue, Suite 101 Ocala, FL 34474 AND 1901 E. Voorhees Street, Suite C Danville, IL 61834 AND P.O. Box 85463 San Diego, CA 92186 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR AMERICAN MORTGAGE NETWORK, INC., DBA AMNET MORTGAGE, ITS SUCCESSORS AND ASSIGNS P.O. Box 2026 Flint, MI 48501-2026 AND 3300 S.W. 34th Avenue, Suite 101 Ocala, FL 34474 AND 1901 E. Voorhees Street, Suite C Danville, IL 61834 AND P.O. Box 85463 San Diego, CA 92186 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 NORTH MIDDLETON TWP 2051 Spring Road Carlisle, PA 17013 And c/o ROBIN K SOLLENBERGER 5 Hill Drive, Carlisle, PA 17013 CARLISLE AREA S/D c/o ROBIN K. SOLLENBERGER 5 Hill Dr. Carlisle, PA 17013 NORTH MIDDLETON AUTHORITY C/O HUBERT X. GILROY, ESQ., 10 E. High St., 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 108 Longs Gap Road Carlisle, PA 17013-1219 UNKNOWN SPOUSE 108 Longs Gap Road Carlisle, PA 17013-1219 .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. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: i! IS BY: ZUCKER, GOLDBER ! y� iii Scott A. D',= /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 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XFP-168746/11 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situate in North Middleton Township, Cumberland County Pennsylvania, bounded and described as follows: BEGINNING at a take in the South side of Public Road at lands now or formerly of George W. Stambaugh; thence by lands of the same, South II degrees, 11 minutes West 166.75 feet to a stake at land now or formerly of Carlisle Gun Club, Inc.; thence by lands now or formerly of Carlisle Gun Club, Inc.; South 82 degrees, 9 minutes East, 50 feet to the center of a 30 foot driveway; thence by the center of said driveway and by lands now or formerly of Simon B. Jumber, North 11 degrees, II minutes East, 161 feet more or less, to a point on the South side of the aforesaid Public Road; thence by the South side of said Public Road, North 76 degrees, 34 minutes West, 50 feet to a stake at the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 108 Longs Gap Road, Carlisle, PA 17013-1219. BEING the same premises which Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Company of Pennsylvania, by Deed dated November 29, 2007 and recorded December 31, 2007 in and for Cumberland County, Pennsylvania, as Instrument # 200747885, granted and conveyed unto ROBERT FITTING. Tax Map No.: 18-1371-0013-0000000-29 aka 29-18-1371-013.