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12-6178
tN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLdANA WELLS FARGO BANK, N.A., Plaintiff, vs. Kevin D. Kuhn; Defendant. TO: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WmiiN TWENTY (20) DAYS FROM 5ERVICE HEREOF OR A DEFAULT IUDGMENT MAY BE ENTERED AGAINST YOU. CIVIL DIVISION c~ r'-? ~-~ "~'' a ~,-,g ~v~~ 1 .~ ~. ~ ~, - NO.: ~ r- I TYPE OF PLEADING .~'"~ ~ '-`~ ~-~ ~ -~- -~ ~ <~ -v ~ -T+ ctdtL ACTtc~+r - CtAtNT ~, ~ w ° g IN MORTGAGE ~ ~ ~, FILED ON BEHALF OF: WELLS FARGO BANK, N.A. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERfIfY THAT THE A<~RESS OF THE PIAINTIfF I5: 3476 Stateview ¢Ilvd.. MAC p X7801-013. Ft. MITI. SC 29715 AND THE DEFENDANT: Mt. HoNv Sorinas. PA 17065-1144 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS UEN IS 23 Trifle Averwe. Mt. HoNv Sorinr[s PA 17065-1144 MunkioaNty: Mr. HvUv SoHnits ATTORNEY ATTY FILE NO.: XFP 169308 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 ofFiceC~zuckereoldberA.com File No.: XFP-169308/mme 0 ~{ g-D3, 75~ Q~ ~,~!{ c/loyS ~Z,~ a9~~soy Zucker, Goldberg & Ackerman, LLC XFP-169308 IN THE COURT Off COMMON PLEAS Off CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. vs. Kevin D. Kuhn; CIVIL DIVISION Plaintiff, NO.. Defendant(s). NOTICE TO fi~#ENO You have been sued in court. If you wlsts W deflerd a~ttst the claim set forth in the following pages, you must take action within tw+ent~r aRer this complaint and notice are served, by entering a written appearance personai#y 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 t© 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 PAPfR 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-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. vs. Kevin D. Kuhn; CIVIL DIVISION Plaintiff, NO.. Defendant(s). Glrl USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar acciGn dentro de los prbximos veinte (20) dias despu~s de la notificacibn de esta Demands y Aviso respondiendo personalmente o por medio de un abogado una cornparecencia esc rita y radicando en la Corte por escrito sus de#ensas y objeciones a las demandas establec'rdas 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 demanda 0 cua Iquier otra reclamacibn o rernedo 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 ABOGA~ D NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA SIGUEINTE OFICiNA PARR AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL 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, LLC XFP-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION Plaintiff, ' NO.. vs. Kevin D. Kuhn; Defendant(s). CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes WELLS FARGO BANK, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is WELLS FARGO BANK, N.A., (hereinafter "plaintiff') having its principal place of business at 3476 Stateview Blvd., MAC #X7801-013, Ft. Mill, SC 29715. 2. Defendant, Kevin D. Kuhn, is an individual whose last known address is 23 Trine Avenue, Mt. Holly Springs, PA 17065-1144. 3. On or about May 9, 2008, Kevin D. Kuhn, a single person made, executed and delivered to Wells Fargo Bank, N.A. a Mortgage in the original principal amount of $112,563.00 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 May 13, 2008, Instrument #200815778. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 3019(8), 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. 5. Kevin D. Kuhn is the record and real owner of the aforesaid mortgaged premises. 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 March 2012 payment. 7. On May 8, 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. Zucker, Goldberg & Ackerman, LLC XFP-169308 062-PA-V2 8. As of September 21, 2012, the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $107,040.25 Interest through 09/21/2012 $4,098.31 Escrow Advance $1,182.10 Suspense Balance ($ 306.80) Late Charges $458.69 Inspection Fees $185.00 Total $112,657.55 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 PlaintifYs 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. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $112,657.55, 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, G'~IOnLDnBE(RIG~& ACKERMAN, LLC BY:~~Y r ~~J~I~~ Dated: ~dl ~ ~ ~~ Joel A. Ackerman, Esquire; PA I.D. #202729 l Ashleigh L. Marin, Esquire; PA I.D. #306799 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-169308/mme 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com - ~' ,t ~. !»f:~R > Zucker, Goldberg & Ackerman, LLC XFP-169308 062-PA-V2 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-169308 . • •• CTA0966 ALL THAT CERTAIN in~ct of land with the buikting ark improvements tF~neon ensued, situate in ~ Borough of [1Aount Nopy Springs, Cnd Ccwnty, Ccunmcx~alEh of Pennayhiania, bounded and described in accordsnce withh a certain Plan of Lots for Gro~re & Grows, Inc., deiced November 17. 1971, revised November 18, 1971 and recxxded in Cumberland County Plan Book 23, Pis ES5, as follows: BEGINNING at a point on ~e westerly line of TrMe Avenue (50 wide) at then comer of Lot No. 11 on ~ hereinai~er mentioned Plx~ of Lots; thence by said Lot No. 11, through the center of a party wall, North 89 45 minutes West, 125.01 feet to a point on line of lands now or formerly of Robert Beeler; thence by saki lands now or formerly of Robert Beeler, North 00 degrees 33 minutes 20 seconds East, 20.33 feet to a point being the southwest comer of Lot No. 13 on the hereinafter menti~r-sd Plan of Lots; thence by the said Lot N. 13, through the center of a party wall, Souk 99 degrees 45 minutes East. 124.90 feet to a point on the vwsleriy line ~ said Trine Avenue; thence by the wealer~ line of the said Trine Avenue, South 00 degrees 15 minutes West, 20.33 feet to a point, the place of beginning. BEING Lot 12 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65, and BEING known and being numbered as 23 Trine Avenue. VERIFICATION Samir Erian, hereby states tha~~she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that~~e 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 hisyher 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: 09/28/2012 Title: Vice President Loan Doc tion Wells Fargo Bank, N.A. 086-PA-vI Zucker, Goldberg & ackerman,LLC XFP-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELlS FARGO BANK, N.A. Plaintiff, vs. Kevin D. Kuhn; CIVIL DIVISION ^~ n NO.: ~ ~.QI / ~ l~ V ~ ~-. j a. `. r:.. ~,~~, rn _-'a ~~ ~ ~ ~ :~ r•, ~.e~^ .R^P F e~ ~=- "'t'E -~~ ~~ ~;~ Defendant(s). ~~ t~ yc ~~ NOl'ICE OF RESIDENTiAI MORTGAGE FORECLOSURE -< DIVERSION PROGRAM -,-~ -a d'~ :~ ~c°> w ° ~' '...c 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 #o 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 appoirrted 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 etigibie 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-169308 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: October ~ , 2012 Scott A. k, Esquire; PA I.D. #55650 Kimberly A. Bcrmer, Esre; PA I.D. #9705 Joel A. Ackerman, Esquire; PA L.D. #202729 Ashleigh L. Mario, Esquire; PA I.D. #3x6799 Ralph M. Sahria, Esquire; PA LD. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-169308/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-169308 Cumberland County Residential Mort~e Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER RElST FOR HARDSHIP ASSISTANCE To compkte• your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: Yes ^ No ^ Listing date: State: Zip: Price: $ Realtor Phone: Yes ^ No ^ Home: Cell: State Office: _ Other: How long? Home: Cell: How long? First Mortgage Lender: Type of loan: Loan Number: Second Mortgage Lender: Type of loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Date you closed your loan: Included Taxes & Insurance: Primary Reason for Default: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: State: Office: _ Other: Zip: Zip: Zucker, Goldberg & Ackerman, LLC XFP-169308 Assets Home: Other Real Estate: Retirement Funds: Investments: Checking: Savings: Other: Amount Owed: $ $ $ $ $ $ $ $ $ $ $ $ $ $ Value: Automobile #1: Model: Year: Amount owed: Value: Automobile #2: Amount owed: Model: Vs1ue: Name of Employers: 1. Year: 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 Mo a e Food 2 Mortgage Utilities Car Payment(s) Condo/Neigfi. 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/Tuit. 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 Agenty: Counselor: Phone (Office): Email: Fax: Zucker, Goldberg & Ackerman, LLC XFP-169308 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: (.enders 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 finder's counsel: V Proof of Income V Past Z 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 setter) V l.istsng agreement (if property is currently on the market) Zucker, Goldberg & Ackerman, LLC XFP-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. Plaintiff, ' Defendant(s). ' CIVIL DIVISION vs. Kevin D. Kuhn; NO.. REgUEST FOR CONCILIATION CONFERENCE P~ 11q t~s Aistrative Order dated February 28, 2012 governing the Cumberland County iAel~ Foreclosure Diversion Program, the undersigned hereby certifies as folbws: 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 Defendants Counsel/Appointed Date Legal Representative Signature of Defendant Signature of Defendant Date Date Zucker, Goldberg & Ackerman, LLC XFP-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION Plaintiff, NO.. vs. Kevin D. Kuhn; AND NOW, this day of ,20 ,the defendant/borrower inthe above- captioned residential mortgage foreclosure action having filed a Request for Conciliation Con#erence verifying that the defendant/borrowerhas 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 ofthe defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 2. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable Defendant(s). CASE MANAGEN~NT R Zucker, Goldberg & Ackerman, LLC XFP-169308 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 ail available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker, Goldberg & Ackerman, LLC XFP-169308 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 DfBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT Of THIS PLEI~NCs, CC>~Nfi~L Ft?Ilt PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION TtiEFtE01~; OTHERWISE, THE DEBT WILL Bf 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, kF 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 THOUGM 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, ND REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) GAYS AFTER YOU HAVE RECEIVED THkS 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-169308 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank:, N.A. vs. Kevin D. Kuhn ,t'~' :~i _.. ~,~ ;; Case Number 2012-6178 SHERIFF'S RETURN OF SERVICE 10/22/2012 06:12 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 22, 2012 at 1812 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Kevin D. Kuhn, by making known unto himself personally, at 23 Trine Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and correct copy of the same. i ~ v a GUTSHA~t~~bEPUTY 10/23/2012 06:10 PM -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: Kevin D. Kuhn, 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 Kevin D. Kuhn. Request for service at 614 Whiskey Springs Road, Boiling Springs, Pennsylvania 17007 the Defendant was not found. Kevin D. Kuhn currently resides at 23 Trine Avenue, Mount Holly Springs, Pennsylvania 17065. SHERIFF COST: $62.00 October 23, 2012 SO ANSWERS, ~/) e. RONNY R ANDERSON, SHERIFF WELLS FARGO BANK,N.A. INTHE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION—LAW NO, 12-6178 CIVIL KEVIN D. KUHN, Defendant IN MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held March 22, 2013, were Douglas Miller, Esquire, attorney for the defendant and Kevin D. Kuhn,the homeowner. Ralph Salvia, Esquire, attorney for the plaintiff, participated by telephone. On or about March 11, 2013, Mr. Miller was notified that the bank required additional documents to conduct its review. These documents are forthcoming. It was suggested that, after ten (10) days, Mr. Miller contact a representative of the plaintiff to assure that no further documents are needed for the review of this matter. It is hoped that the bank will make a decision with regard to a loan modification prior to the time set for a continued conciliation conference. ORDER AND NOW, this 2 5" day of March, 2013, continued conciliation conference in this matter is set for Friday, May 10, 201.3, at 2:00 p.m. in Chambers of the undersigned, BY THE COURT, Kevin, Hess, P. J. Ralph Salvia, Esquire For the Plaintiff Douglas Miller, Esquire For the Defendant t C WELLS FARGO BANK,N.A. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 12-6178 CIVIL KEVIN D. KUHN, Defendant IN MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held May 10, 2013, were Ralph Salvia, Esquire, attorney for the plaintiff, and Douglas Miller, Esquire, attorney for the defendant. Mr. Miller indicates that he has not been able to maintain contact with the defendant. Accordingly, we enter the following order. ORDER AND NOW,this /D' day of May, 2013, unless counsel for the defendant notifies the Court, within two (2) weeks, that the homeowner has been forthcoming with information necessary to pursue a loan modification and that a continued conciliation conference would be efficacious, this matter will be removed from the Mortgage Foreclosure Diversion Program upon written request of counsel for the plaintiff. BY THE COURT, Kevi . Hess, P. J. Ralph Salvia, Esquire C-) w� For the Plaintiff a zz --i M crag = ' r'-' =- '1--<uglas Miller, Esquire For the Defendant .`"� C:) C) :rlm ':" PI � w., 5�&V13 WELLS FARGO BANK,N.A. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 12-6178 CIVIL KEVIN D. KUHN, Defendant IN MORTGAGE FORECLOSURE ORDER AND NOW, this /'-/1 day of June, 2013,this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program,the automatic stay is lifted and Plaintiff may proceed with its mortgage foreclosure action. BY THE COURT, Kevin . Hess, P. J. Ralph Salvia, Esquire For the Plaintiff Douglas Miller, Esquire For the Defendant :rim rn c c �. cn r— r<-Z m� x. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., CIVIL DIVISION cW> Plaintiff No.: 12-6178-CIVIL . , © \(- -0153 yr% vs. ISSUE NUMBER: ) Q N 'Z Kevin D. Kuhn; TYPE OF PLEADING: is, Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT EixtgFAtJtT (MORTGAGE FORECLOSURE) '37 1.' Mortgaged Premises: 23 Trine Avenue, Mt. Holly Springs, PA 17065-1144 FILED ON BEHALF OF: WELLS FARGO BANK, N.A. Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire-Pa I.D.# 55650 Kimberly A. Bonner, Esquire- Pa I.D.#89705 Joel A.Ackerman, Esquire- Pa I.D.#202729 Ashleigh L. Marin, Esquire-Pa I.D.#306799 Ralph M. Salvia, Esquire- Pa I.D.#202946 Jaime R.Ackerman, Esquire- Pa I.D.#311032 Jana Fridfinnsdottir, Esquire- Pa I.D.#315944 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-169308 akikA-1 a CL 57016p po. 616)35 it Praecipe for Entry of Judgment Zucker,Goldberg&Ackerman, LLC F?-1693O 0 V Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION Plaintiff, • vs. NO.: 12-6178-CIVIL • Kevin D. Kuhn; • Defendant. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s),for failure to file a response to Plaintiffs 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 $112,657.55 plus interest on the judgment amount($112,657.55)from September 22, 2012, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 23 -rine Avenue address is: Mt. oily •. i • , 1706 11, E 4 ZUCKER, G ol B ' i AN, LC Dated: V BY: A. �1��1 Joel A.Ack :n, Esquire; PA I.D.#202729 0 Ashleigh L. in, Esquire; PA I.D.#306799 n Jaime R.Ac : man, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-169308 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Offices @zuckergoldberg.com ,�+. ,,1 DAMAGES ARE HEREBY ASSESSED AS INDICATED ")h ! ' 4 r' Date 1''Z'\V?.\I#1 fr , 0.,v..Cr Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION Plaintiff, • vs. : NO.: 12-6178-CIVIL Kevin D. Kuhn; •• Defendant. • AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced .y the attached copies; 2) The Notice of Intent to take Default 1 igme (1. I ailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice i,ve -,l, •. ZUCKE' I I; ;i 1 i CKE'MAN, LLC Dated: )9, `'i) t, BY: lil4.414 KI Joel A. erman, Esquire; PA I.D.#202729 ❑ Ashlei_ ii . Marin, Esquire; PA I.D.#306799 ❑ Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-169308 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 This `b day of L�C , 20(3 Notary Public My Commission Expires: Cheryl Debeneadto Notary Public My Comm. Expires Oct. 16,2016 ID#2280276 State of New Jersey Zucker,Goldberg&Ackerman, LLC XFP-169308 Results as of:Dec-06-2013 01:03:41 Department of Defense Manpower Data Center SCRA 3.0 a a' h�E .5 �f '-> Status Report Act n l l f,! a.Rl t S� neog °•' Po Last Name: KUHN First Name: KEVIN Middle Name: D Active Duty Status As Of: Dec-06-2013 Ravi g �f p$xf ai 6 s iz s` , f gnkkvw- NA NA ✓ ':.1m"._ NA This response refl- dMduals'active`duly sfatuS based on 1he'Acdvg.t)uty Status Date axi ire ,' asp'. '° r � �.. ie ✓,` � 4 � NA /rte, NA This response reflects Where the ind(vidual left activeiftttY UB wUhitt 36 tlays precedilrg the•Acbve Duty Status Date This response reflects whether fhb 'tridira er hislher umt has received � r� �� ����� NA NA P t sally'hptfflftgn sport for active duty w �. �i 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,NOAH,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. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Auk yit. r Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 ' The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA 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(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOM Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on 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: L6G5WD60409C210 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA WELLS FARGO BANK, N.A. • CIVIL DIVISION Plaintiff, • vs. NO.: 12-6178-CIVIL • Kevin D. Kuhn • • Defendant. • • • • IMPORTANT NOTICE TO: Kevin D. Kuhn 23 Trine Avenue Mt. Holly Springs, PA 17065-1144 DATE OF NOTICE: 11/25/2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you.Unless you act within Ten(10) days from the date of this notice,a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION • Plaintiff, • vs. • NO.: 12-6178-CIVIL • Kevin D. Kuhn • Defendant. • • AVISO IMPORTANTE TO: Kevin D. Kuhn 23 Trine Avenue Mt. Holly Springs, PA 17065-1144 FECHA DEL AVISO:11/25/2013 LISTED ESTA EN REBELDL& PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXQVIOS 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 PROPLEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICLNA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER,GOLDBERG &ACKERMAN BY: Salt A. D ietterick Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 169308 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 6613" Sheriff Jody S Smith G9�trLtr of Cumber, -.t Chief Deputy "RNA'k Richard W Stewart OFFICE OF THE SHERIFF Wells Fargo Bank, N.A. vs:._.... – — -- . —ease Numb Kevin D. Kuhn 2012-6178 SHERIFF'S RETURN OF SERVICE 10/22/2012 06:12 PM-Shawn Gutshall,Deputy Sheriff,who being duly sworn according to law, states that on October 22, 2012 at 1812 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant,to wit: Kevin D. Kuhn, by making known unto himself personally, at 23 Trine Avenue, Mount Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and correct copy of the same. TSH/ .�Lt PUTY 10/23/2012 06:10 PM-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: Kevin D. Kuhn, 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 Kevin D.Kuhn. Request for service at 614 Whiskey Springs Road, Boiling Springs, Pennsylvania 17007 the Defendant was not found. Kevin D. Kuhn currently resides at 23 Trine Avenue, Mount Holly Springs, Pennsylvania 17065. SHERIFF COST: $62.00 SO ANSWERS, October 23, 2012 RONNY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. • CIVIL DIVISION Plaintiff, • vs. NO.: 12-6178-CIVIL • • Kevin D. Kuhn; • • Defendant. • NOTICE OF ORDER, DECREE OR JUDGMENT TO: Kevin D. Kuhn 23 Trine Avenue Mt. Holly Springs, PA 17065-1144 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ilD I [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $112,657.55 plu s. rot onotary Zucker,Goldberg&Ackerman, LLC XFP-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WELLS FARGO BANK, N.A., vs. Kevin D. Kuhn; Plaintiff, Defendant. TO THE PROTHONOTARY OF THE SAID COURT: File No. 12- 6178 -CIVIL Amount Due $112,657.55 Interest from 9/22/2012 to date of sale $11,492.69 Costs 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 personalty list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this wfit against the garnishee(s) as a lis pendens against real e e of the defend ant(s) described in the attached exhibit. DATE: sa.2s clot &/may /2_ Pi al 3c4,(4-7 Signature: Print Name: Scott A. E e`tterick, Esquire Kimberly A. Bonner, Esquire Joel A. Ackerman, Esquire Ashleigh L. Marin, Esquire Ralph M. Salvia, Esquire Jaime R. Ackerman, Esquire Jana Fridfinnsdottir, Esquire Brian Nicholas, Esquire Denise Carlon, Esquire Address: Zucker, Goldberg & Ackerman, LLCM —t 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908 - 233 -8500 Supreme Court ID No.: 55650 89705 202729 306799 202946 1 0 315944 317240 317226 \),)(14- (;4 Y.uckcr. Gnldbcrg ,Ackcrnt I XI' Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the building and improvements thereon erected, situate in the Borough of Mount Holly Springs, Cumberland County, Commonwealth of Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove & Grove, Inc., dated November 17, 1971' revised November 18, 1071 and recorded in Cumberland County Plan Book 23, Page 65, as follows: BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 11 on the hereinafter mentioned Plan of Lots; thence by said Lot No. 11, through the center of a party wall, North 89 degrees 45 minutes West, 125.01 feet to a point on line of lands now or formerly of Robert Beeler; thence by said lands now or formerly of Robert Beeler, North 00 degrees 33 minutes 20 seconds East, 20.33 feet to a point, being the southwest corner of Lot No. 13 on the hereinafter mentioned Plan of Lots; thence by.the said.Lot No. 13, through the center of a party wall, South 89 degrees 45 minutes East, 124.90 feet to a point on the westerly line of said Trine Avenue; thence by the westerly line of the said Trine Avenue, South 00 degrees 15 minutes West, 20.33 feet tO a point, the place of beginning. BEING Lot 12 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cu berland County Plan Book 23, Page 65. UNDER AND SUBJECT to a 20-foot wide utility easement on the rear o said Lot as contained on said Plan. HAVING thereon ere edadweUinghnusehcingknovvnandnumberedasJ3TrioeAvenue'K400ntHo|ly Springs, PA, 17065-1144. BEING the same premises which Lloyd E. Herman and Ruth Ann Herman, Husband and Wife, by Deed dated May 7, 2008 and recorded May 13, 2008 in and for Cumberland County, Pennsylvania, as Instrument #2OO8l5777' granted and conveyed unto Kevin D.Kuhn. Tax Map No.: 23-32-2336-377. Zucker, Goldberg & Ackerman, LLC XFP-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., vs. Kevin D. Kuhn; Plaintiff, Defendant(s). : CIVIL DIVISION : NO.: 12-6178-CIVIL c'^ : Execution No.: 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 23 Trine Avenue, Mount Holly Springs, PA 17065'1I44. 1. Name and Address of Owner(s) or Reputed Owner(s): KEVIN D. KUHN 23 Trine Avenue Mount Holly Springs, PA 17065'1144 2. Name and Address of Defendant(s) in the Judgment: KEVIN D, KUHN 23 Trine Avenue Mount Holly Springs, PA 17065-1144 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, NA. Plaintiff Z,*:*.ov/u|urg Ackerman. uz x|'w^0ox 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff 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 23 Trine Avenue Mount Holly Springs, PA 17065 -1144 UNKNOWN SPOUSE 23 Trine Avenue Mount Holly Springs, PA 17065 -1144 AND 85 Greenview Drive Carlisle, PA 17015 -9194 Y.ucl cr. (■■. +ILIhcre Ackcmrtn- I,LC XI I'- 16,7305 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 PaI.S. §4904 relating to unsworn falsification to authorities. Dated: BY: Scott A. Die rick, Esquire; PAiD.#55650 Kimberly A. Bonner, Esquire; PAiD.#897OS Joel A. Ackerman, Esquire; PAiD.#Z027Z9 Ashleigh L. Mann, Esquire; PAiD.#3O6799 Ralph M. Salvia, Esquire; PA I.D. #20I946 Jaime R. Ackerman, Esquire; A4iD.#311U3Z--~^ Jana Fridfinnsdnttir, Esquire; PAiD.#315944 Brian Nicholas, Esquire; PAiD.#317Z4O Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP'169308/1I 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com amer.n^m^u Ackerman. u/C xn`'|o$o8 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the building and improvements thereon erected, situate in the Borough of Mount Holly Springs, Cumberland County, Commonwealth of Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove & Grove, Inc., dated November 17, 1971, revised November 18, 1971 and recorded in Cumberland County Plan Book 23, Page 65, as follows: BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 11 on the hereinafter mentioned Plan of Lots; thence by said Lot No. 11, through the center of a party wall, North 89 degrees 45 minutes West, 125.01 feet to a point on line of lands now or formerly of Robert Beeler; thence by said lands now or formerly of Robert Beeler, North 00 degrees 33 minutes 20 seconds East, 20.33 feet to a point, being the southwest corner of Lot No. 13 on the hereinafter mentioned Plan of Lots; thence by the said Lot No. 13, through the center of a party wall, South 89 degrees 45 minutes East, 124.90 feet to a point on the westerly line of said Trine Avenue; thence by the westerly line of the said Trine Avenue, South 00 degrees 15 minutes West, 20.33 feet to a point, the place of beginning. BEING Lot 12 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. UNDER AND SUBJECT to a 20 -foot wide utility easement on the rear of said Lot as contained on said Plan. HAVING thereon erected a dwelling house being known and numbered as 23 Trine Avenue, Mount Holly Springs, PA, 17065 -1144. BEING the same premises which Lloyd E. Herman and Ruth Ann Herman, Husband and Wife, by Deed dated May 7, 2008 and recorded May 13, 2008 in and for Cumberland County, Pennsylvania, as Instrument #200815777, granted and conveyed unto Kevin D. Kuhn. Tax Map No.: 23 -32- 2336 -377. Zucker, Goldberg & Ackerman, LLC XFP- 169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION Plaintiff, VS. Kevin D. Kuhn; Defendant. NO.: 12-6178-CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Kevin D. Kuhn 23 Trine Avenue Mount Holly Springs, PA 17065-1144 AND 85 Greenview Drive Carlisle, PA 17015-9194 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 9/3/2014 at 10:00 a.m. 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: 23 Trine Avenue, Mount Holly Springs, PA, 17065-1144 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12-6178-CIVIL Zucker, Goldberg & Ackerman, LLC XFP-169308 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Kevin D. Kuhn 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 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: BY: ..441442 Scott A.Dietteri'k'Esquina; k4iD. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PAiD.#2O27Z9 Ashleigh L. K4arin, Esquire; PAiD.#3OG799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; K4iD.#31lO32-- Jana Fridfinnsdotb[ Esquire; PAiD.#31S944 Brian Nicholas, Esquire; P4iD.#317Z4U Denise Carlon, Esquire; PAiD.#3I7226 Attorneys for Plaintiff XFP'169308/1| 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, LLC XFP-169308 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the building and improvements thereon erected, situate in the Borough of Mount Holly Springs, Cumberland County, Commonwealth of Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove & Grove, Inc., dated November 17' 1971' revised November 18' 1971 and recorded in Cumberland County Plan Book 23, Page 65, as follows: BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 11 on the hereinafter mentioned Plan of Lots; thence by said Lot No. 11, through the center of a party wall, North 89 degrees 45 minutes West, 125.01 feet to a point on line of lands now or formerly of Robert Beeler; thence by said lands now or formerly of Robert Beeler, North 00 degrees 33 minutes 20 seconds East, 20.33 feet to a point, being the southwest corner of Lot No. 13 on the hereinafter mentioned Plan of Lots; thence by the said Lot No. 13, through the center of a party wall, South 89 degrees 45 minutes East, 124.90 feet to a point on the westerly line of said Trine Avenue; thence by the westerly line of the said Trine Avenue, South 00 degrees 15 minutes West, 20.33 feet to a point, the place of beginning. BEING Lot 12 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. UNDER AND SUBJECT to a 20-foot wide utility easement on the rear of saidlot as contained on said Plan. HAVING thereon erected a dwelling house being known and numbered as 23 Trine Avenue, Mount Holly Springs, PA, 17065'I144. BEING the same premises which Lloyd E. Herman and Ruth Ann Herman, Husband and Wife, by Deed dated May 7, 2008 and recorded May 13, 2008 in and for Cumberland County, Pennsylvania, as Jnstrument#ZOO8l5777' granted and conveyed unto Key inD.Kuhn. Tax Map No : 23-32-2336-377 Zucker, Goldberg & Ackerman, LLC XFP-I69308 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. KEVIN D. KUHN WRIT OF EXECUTION NO 12-6178 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: $112,657.55 L.L.: $.50 Interest FROM 9/22/2012 TO DATE OF SALE - $11,492.69 Atty's Comm: Due Prothy: $2.25 Atty Paid: $210.75 Other Costs: Plaintiff Paid: Date: 3/31/14 (Scap.. David D. Buell, Prothonota Deputy REQUESTING PARTY: Name: JAIME It ACKERMAN, ESQUIRE Address: ZUCKER, GOLDBERG & ACKERMAN, LLC 200 SHEFFIELD STREET, SUITE 101 MOUNTAINSIDE, NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No. 311032 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION VS. Kevin D. Kuhn; Plaintiff, Defendant. NO.: 12 -6178 -CIVIL Notice of the Date of Continued Sheriff Sale The Sheriff Sale scheduled for September 3, 2014 at 10:00 AM in the above captioned matter has been continued until November 5, 2014 at 10:00 AM. BY: Dated: August 28, 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC C.PC(SrChristina Covert, Lega Assistant File No.: XFP-169308 20USheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX Email: Office@zuckergoldberg.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., CIVIL DIVISION Kevin D. Kuhn; Plaintiff, vs. Defendant(s). NO.: 12 -6178 -CIVIL MOTION FOR ALTERNATE SERVICE ON DEFENDANT PURSUANT TO Pa.R.C.P. 430 FILED ON BEHALF OF: WELLS FARGO BANK, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 Ashleigh Levy Marin, Esquire -PA I.D. #306799 Ralph M. Salvia, Esquire- PA I.D. #202946 Jaime R. Ackerman, Esquire- PA I.D. #311032 Jana Fridfinnsdottir, Esquire- PA I.D. #315944 Brian Nicholas, Esquire- PA I.D. #317240 Denise Carlon, Esquire- PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XFP-169308/jf r..,i:..i LJ Zucker, Goldberg & Ackerman, LLC XFP-169308 UN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION Plaintiff, VS. Kevin D. Kuhn; Defendant. NO.: 12-6178-C1VIL MOTION FOR ALTERNATE SERVICE OF NOTICE OF SHERIFF SALE UPON DEFENDANT PURSUANT TO Pa.R.C.P. 430 AND NOW, comes the PIaintiff, WELLS FARGO BANK, N.A., by and through its attorneys, Zucker, Goldberg & Ackerman, LLC, and files the within Motion for Alternate Service of Notice of Sheriff Sale tipon Defendant pursuant to Pa.R.C.P. 430 as foliows: 1. On or about March 31, 2014, Plaintiff filed its original Praecipe for Writ of Execution ("Writ") against the Defendant(s), Kevin O. Kuhn ("Defendant(s)"), at the above -captioned number and term, scheduling Defendant's property located at 23 Trine Avenue, Mount Holly Springs PA 17O65- 1144,("K4urtgagedPremises")forSheriffSa|eonSeptember3,3Ol4. 2. Plaintiff directed the Sheriff of Cumberiand County to serve Defendant(s) with the Notice of Sheriff Sale at defendant's last known address being 23 Trine Avenue, Mount Holly Springs, PA 17065-1144, but service was returned Defendant not found, property is vacant. Defendant did not leave a forwarding address with the post office. A true and correct copy of said Return of Service from the Cumberland County Sheriff's Office is marked Exhibit "A", attached hereto and made a part hereof. 3. Plaintiff attempted service of the defendant(s) via certified mail, return receipt to defendant(s) at the address of 23 Trine Avenue, Mount Holly Springs, PA 17065-1144, but certified mail was returned unclaimed, defendant moved address unknown. A copy of the tracking record is marked Exhibit "B" attached hereto and made a part hereof. 4. Also, Plaintiff attempted service of the defendant by instructing the Sheriff of Cumberland County to serve defendant(s) at an alternate address being 85 Greenview Drive, Carlisle, PA 17015, but return of service indicated defendant does not reside there, did not leave a forwarding address. A copy of said return is marked Exhibit "C", attached hereto and made a part hereof. S. Plaintiff attempted service of the defendant(s) via certified mail, return receipt to defendant(s) at the address of being 85 Greenview Drive, Carlisle, PA 17015, but certified mail was returned unclaimed, defendant moved address unknown. A copy of the tracking record is marked Exhibit "D" attached hereto and made a part hereof 7. An internet person locator search provided no alternative address for Defendant(s). 8. Plaintiff conducted an investigation to determine the whereabouts of Defendant(s), Kevin D. Kuhn but all sources indicated no alternative address other than that of the last known address being 23Trine Avenue, Mount Holly Springs, PA17O65-1144. An affidavit of Piaintiff's counsel regarding the investigation taken to determine the whereabouts of Defendant is marked Exhibit "E", attached hereto ar,d made a part hereof. 9. [onsequenLky, Plaintiff has continued the Sheriff Sale scheduled for September 3, 2014 to November 5, 2014 in order to provide sufficient time to obtain alternate service of Defendant(s) Kevin D. Kuhn. 10. Plaintiff attempted to obtain concurrence of Defendant(s) Kevin D. Kuhn with the Motion, but Defendant(s) cannot be located, therefore no concurrence was obtained. 10. Default Judgment was entered on or about December 12, 2013. WHEREFORE, Plaintiff respectfully requests that this Honorable Court permit Plaintiff to serve Defendant(s), Kevin D. Kuhn, with the Notice of Sheriff Sale, by instructing the Cumberland County Sheriffs Office to POST a copy of same on the Mortgaged Premises, being 23 Trine Avenue, Mount Holly Springs PA 17065-1144, and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 23 Trine Avenue, Mount Holly Springs, PA 17065-1144, and to 85 Greenview Dr., Carlisle, PA 17015-9194 with said service being valid and co' : - upon such posting and mailing in accordance with Pa.R.C.P. 3129.2 and 430. ZUCKEGOLDBERG & ACK i .4 Dated: October 17, 2014 BY: AV/ R Sc'`j ietterick, Esquire; PA LD. #55650 y A. Bonner, Esquire; PA.I.D #897 j ckerman, Esquire; PA ID. #2 h Levy Marin, Esquire; PA LD. '6799 . Salvia, Esquire; PA I.D. #202946 aime 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 1.D. #317226 Roger Fay, Esquire; PA ID. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-169308 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com EXHIBIT A Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF THE SHERIFF Wells Fargo BankNA. vs. Kevin D. Kuhn Case Number 2012-6178 SHERIFF'S RETURNOF SERVICE 06/17/2014 11:22 AM - Deputy William Cline, being duly sworn according 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 23 Trine Avenue, Mount Holly Springs, PA 17065, Cumberland County. 06/30/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kevin D. Kuhn, but was unable to Iocate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Dmocription, in the above titled action, as "Not Found" at 23 Trine Avenue, Mount Holly Springs, PA 17065, property is Vacant, defendant did not leave a forwarding address with the post office. cab. 08C20/3014 As directed by Jaime R Ackerman, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/5/2014 09/26/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kevin D. Kuhn, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 85 Greenview Drive, Carlisle, PA 17015, defendant does not reside at address stated, did not leave a forwarding with the post office. cab. SHERIFF COST: $1,447.63 SO ANSWERS, September 26, 2014 RONR ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. EXHIBIT B 1 i J 0 0 WALM0164 2. Mile Number 111111 !11u11numuiimuW11i�i11,2u 3. Service Type CERTIFIED MAIL COMPLETE THIS SECTION ON DELIVERY a. Received by (Please Prim Ckarly) C. 9grxtreo X B. D sof 4. Restricted Defiverin (bra Fee) Yes 1. Mk18 Addressed to; Kevin D. Kuhn 23 TRINE AVE MOUNT HOLLY SPRINGS, PA 17065-1144 . t deHrery address different from kin 1? If VES. enter delNery, edtlress below: - Agent Addressee Yes No PS Form 3811, January 2005 Domestic Return Recent Reference Information 169308 PANOSS 5/20/2014 13111 7100 1170 07112 3704 32-102 Zucker. Goldberg d Ackerman. LLC PO Box 1219 Mountainside. NJ 07092-1219 11 1 111 9314 7100 1170 0742 1704 32 11 1.111,11h11r1 Kevin D. 23 TRIP" MOON"478/1:gN • 20140520-102 0 .1.drh11••1 O Af404.4-0 1. f*SSAOO gWifc,„. *e f00 gf"41."41.0-4lof00#ONP014.lpTgCOOSUONlAKF NOHg4Y Dap togffa.ST o etas SI* lei L4 )/1, r ll oR? 1111111111.1111111.11111111111111111111101h111d111. 015M1,15041499 136W499 ..';13034 M $07.19° 06120/20x4 EXHIBIT C Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY CP/ Loo it CI(ift OFFICE Or' T $liERIFF Wells Fargo Bank, N.A. vs. Kevin D. Kuhn Case Number 2012-6178 SHERIFF'S RETURN OF SERVICE 06/30/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kevin D. Kuhn, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 23 Trine Avenue, Mount HoIIy Springs, PA 17065, property is Vacant, defendant did not leave a forwarding address with the post office. cab. SHERIFF COST: $954.24 SO ANSWERS, June 30, 2014 RON1JY R ANDERSON, SHERIFF (c) CournSi.le Siertf, leleosoll. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY .wo?of Cur� ORFICE OF THE SHERIFF Wells Fargo Bank, N.A. vs. Kevin D. Kuhn Case Number 2012-6178 SHERIFF'S RETURN OF SERVICE 06/17/2014 11:22 AM - Deputy Wililam Cline, being duly sworn accoring to Iaw, states service was performeby 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 23 Trine Avenue, Mount Holly Springs, PA 17065, Cumberland County. 08/30/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kevin D. Kuhn, but was unable to Iocate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 23 Trine Avenue, Mount Holly Springs, PA 17065, property is Vacant, defendant did not eave a forwarding address with the post office. cab. 08/29/2014 As directed by Jaime R Ackerman, Attorney for the P|oint\ff, Sheriffs Sale Continued to 11/5/2014 09/26/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kevin D. Kuhn, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 85 Greenview Drive, Carlisle, PA 17015, defendant does not reside at address utoted, did not leave a forwarding with the post office. cab. SHERIFF COST: $1.447]68 SO ANSWERS, September 26.2O14 RONR ANDERSON, SHERIFF wCounty*ite Sheriff, Teleosm/= EXHIBIT ° USPS.com® - USPS TrackingTM English Customer Service ,OUSPS COM USPS Mobile Quick Tools S?* a Package USPS TrackingTM Page 1 of 2 Register/Sign In Search USPS.com or Track Packages Subr ns Customer Service Have questions? We're here to help. Tracking Number: 9314710011700760374096 Updated Delivery Day: Monday, October 6, 2014 Product & Tracking Information Postal Product: First -Class Mail® Features: Certified Mail' DATE & TIME STATUS OF ITEM October 6, 2014 , 9:15 am Delivered Return Receipt LOCATION MOUNTAINSIDE, NJ 07092 Your item was delivered at 9:15 am on October 6, 2014 in MOUNTAINSIDE, NJ 07092. October 5, 2014 11:50 pm October 5, 2014 , 10:39 am September 26, 2014 , 12:26 pm August 28, 2014 , 2:40 pm August 28, 2014 , 9:44 am August 28, 2014 , 4:32 am August 27, 2014 , 7:53 pm August 25, 2014 , 11:46 pm August 25, 2014 , 10:52 pm • Arrived at USPS Facility Arrived at USPS Facility Unclaimed Undeliverable as Addressed Arrived at Unit Departed USPS Facility Arrived at USPS Facility Departed USPS Facility Arrived at USPS Facility KEARNY, NJ 07099 JERSEY CITY, NJ 07097 CARLISLE, PA 17013 CARLISLE, PA 17015 CARLISLE, PA 17013 HARRISBURG, PA 17107 HARRISBURG, PA 17107 PHOENIX, AZ 85043 PHOENIX, AZ 85043 Available Actions Return Receipt Atter Mailing Track Another Package Tracking (or receipt) number Track It LEGAL Privacy Policy > Terms of Use FOIA > No FEAR Act EEO Data > ®U'COM ON USPS.COM Govemment Services Buy Stamps & Shop > Print a Label with Postage > Customer Service > Delivering Solutions to the Last Mile > Site Index > Copyright© 2014 USPS. All Rights Reserved. ON ABOUT,USPS.COM About USPS Home > Newsroom , USPS Service Alerts > Forms & Publications > Careers OTHER USPS SITES Business Customer Gateway > Postal Inspectors > Inspector General > Postal Explorer> National Postai Museum > Zucker. Goldberg & Ackerman. LLC PO Box 1219 Mountainside, NJ 07092-1219 111,110111101 „ 20140825102 'I'lltWutIII'1IIII,1usIIIIII"iIII1"11611IIIII'h11A Kevin D. Kuhn 85 GREENVIEW DR CARLISLE, PA 17015-9194 PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. Plaintiff, vs. Kevin D. Kuhn; Defendant. CIVIL DIVISION NO.: 12 -6178 -CIVIL AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE..3129 Kevin D. Kuhn 85 Greenview Dr Carlisle, PA 17015-9194 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 November 5, 2014, at 10:00am prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A")., The LOCATION of your property to be sold is: 23 Trine Avenue, Mount Holly Springs, PA, 17065-1144 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12 -6178 -CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Kevin D. Kuhn 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. THISPAPER.IS.A..NOTICEDETHE TIMEANDPLACE.OF,THE„SALE.OEYOUR.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 TELEPHONETHE OFFICE ET FORTHRELOW TO ,EiNp OUT WHEREOU CAN GET FREE LEGM.. 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 LA..REF1TS YOU MAY HAVE AK; 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 Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. Dated: August avo , 2014 ZUCKER GOLDBERG & ACKERMAN, LLC BY: Scott A. Dy'ick A I.D. #55650 Kimbe: . 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; PALE). #202946 Jaime R. Ackerman, Esquire; PA ID. #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 File No.: XFP-169308 (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, Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the building and improvements thereon erected, situate in the Borough of Mount Holly Springs, Cumberland County, Commonwealth of Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove & Grove, Inc., dated November 17, 1971, revised November 18, 1971 and recorded in Cumberland County Plan Book 23, Page 65, as follows: BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 11 on the hereinafter mentioned Plan of Lots; thence by said Lot No. 11, through the center of a party wall, North 89 degrees 45 minutes West, 125.01 feet to a point on line of lands now or formerly of Robert Beeler; thence by said lands now or formerly of Robert Beeler, North 00 degrees 33 minutes 20 seconds East, 20.33 feet to a point, being the southwest corner of Lot No. 13 on the hereinafter mentioned Plan of Lots; thence by the said Lot No. 13, through the center of a party wall, South 89 degrees 45 minutes East, 124.90 feet to a point on the westerly line of said Trine Avenue; thence by the westerly line of the said Trine Avenue, South 00 degrees 15 minutes West, 20.33 feet to a point, the place of beginning. BEING Lot 12 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. UNDER AND SUBJECT to a 20 -foot wide utility easement on the rear of said Lot as contained on said Plan. HAVING thereon erected a dwelling house being known and numbered as 23 Trine Avenue, Mount Holly Springs, PA, 17065-1144. BEING the same premises which Lloyd E. Herman and Ruth Ann Herman, Husband and Wife, by Deed dated May 7, 2008 and recorded May 13, 2008 in and for Cumberland County, Pennsylvania, as Instrument #200815777, granted and conveyed unto Kevin D. Kuhn. Tax Map No.: 23-32-2336-377.., EXHIBIT E IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION Plaintiff, *s Kevin D. Kuhn; COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN NO.: 12 -6178 -CIVIL AFFIDAVIT Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Jana Fridfinnsdottir, Esquire, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and says that Plaintiff, or counsel for Plaintiffconducted an investigation to determine the whereabouts of Defendant(s), which included, but was not Iimited to searches of the fotiowing records: (X) Records of the U.S. Postmaster. (X) Internet Person Locator Records (X) Credit Report Agency. (X) Telephone Directory (X) Records of the County Recorder of Deeds and Prothonotary Finally, Affidavit deposes and says that if Defendant(s) isfare of located at the address uncovered by this investigation, the whereabouts of Defendant = f' Jar unknown to Plaintiff. Dated: October 17, 2014 Sworn to and subscribed�/before me this �t day of £ /J ()IO &V ,2014. My Commission Expires: a Fridfinnsd:ttr, sq., P'. ID#315944 y File No.: XFP- 69308 0 Sheffield Street, Suite 01 ountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL KATHERINE N'MILLER Notary Public UPPER ALIEN TWP., CUMBERLAND COUNTY My CoMmission-Expires May 7,'2017 LexisNexis. 1 Accurine for Collections Person Search Results - Contact & Locate Search Terms Used - Last Name: KUHN; First Name: KEVIN; All Full Name SSN Address Phone Page 1 of 2 Records: 1 to 11 of 11 Next Steos KEVIN KING KEVIN D KUHN DOB: 12/20/1981 Age: 32 Gender: Male *View Sources (-3) 13 Setup Alert 85 GREENVIEW DR CARLISLE PA 17015.9194 Sep 2013 - Jul 2014 We Also Found: El Real Property Locator 0 Email Address 2 KEVIN D KUHN DOB: 12/20/1981 Age: 32 Gender: Male *View Sources (-1) V Setup Alert 23 TRINE AVE APT 1 MOUNT HOLLY SPRINGS PA 17065 - 1144 Jul 2008 - Jul 2014 3 KEVIN KING KEVIN KUHN KEVIN D KUHN DOB: 12/20/1981 Age: 32 Gender: Male *View Sources (-5) Setup Alert 23 TRINE AVE MOUNT HOLLY SPRINGS PA 17065 - 1144 May 2008 • May 2014 717-386-0285- EDT 4 KEVIN KING KEVIN D KUHN DOB: 12/20/1981 Age: 32 Gender: Male *View Sources (-3) 1:1 Setup Alert 614 WHISKEY SPRINGS RD BOILING SPRINGS PA 17007-9519 Dec 2011 5 KEVIN KING KEVIN D KUHN DOB: 12/20/1981 Age: 32 Gender: Male *View Sources (-3) ri Setup Alert 9 CHESTNUT ST APT 1 MOUNT HOLLY SPRINGS PA 17065- 1306 Oct 2002- Oct 2006 717-486.7332 - EDT Oct 02 - Jun 03 6. KEVIN KING KEVIN D KUHN DOB: 12/20/1981 Age: 32 Gender: Male *View Sources (-3) 1:7 Setup Alert 9 CHESTNUT ST MOUNT HOLLY SPRINGS PA 17065 - 1306 Feb 2003 • Feb 2008 7. https://secure.accurint.com/app/bps/misc 5/14P('1 tt Page 2 of 2 KEVIN D KUHN 324 N BALTIMORE AVE APT 2 DOB: 12/2011981 MOUNT HOLLY SPRINGS PA 17065 - Age: 32 1601 Gender: Male Jul 2000 - Feb 2008 *View Sources (-1) t, Setup Alert 8. KEVIN KING 9A CHESTNUT ST KEVIN D KUHN ■MOUNT HOLLY SPRINGS PA 17065 - DOB: 1212011981 1306 Age: 32 Jun 2007 Gender: Male *View Sources (-1) Setup Alert 9. KEVIN KING 204 MEALS DR 486-8638 KEVIN D KUHN CARLISLE PA 17015-3179 DOB: 12/2011981 Feb 2000 - Apr 2005 Age: 32 Gender: Male *View Sources (-4) G Setup Alert 10. KEVIN KING 324 N BALTIMORE AVE APT KEVIN D KUHN MOUNT HOLLY SPRINGS PA 17065 - DOB: 1212011981 1601 Age: 32 May 2000 - Apr 2002 Gender: Male *View Sources (-4) Setup Alert 11. KEVIN D KUHN 19 CHESTNUT ST DOB: 1212011981 MOUNT HOLLY SPRINGS PA 17065 - Age: 32 1306 Gender: Male *View Sources (-1) Setup Alert Records: 1 to 11 of 11 Your DPPA Permissible Use: Civil, Criminal, Administrative or Arbitral Proceedings Your GLBA Permissible Use: Persons Holding a Legal or Beneficial Interest Relating to the Consumer Your DMF Permissible Use: No Permissible Purpose Copyright © 2014 LexisNexis. All rights Reserved. Terms & Conditions Privacy & Security https://secure.accurint.com/annihncimiqr IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION vs. Kevin D. Kuhn; Plaintiff, Defendant. NO.: 12 -6178 -CIVIL Notice of the Date of Continued Sheriff Sale The Sheriff Sale scheduled for September 3, 2014 at 10:00 AM in the above captioned matter has been continued until November 5, 2014 at 10:00 AM. Dated: August 28, 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC BY: r Christina Covert, Legal Assistant File No.: XFP-169308 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com r�, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION vs. Kevin D. Kuhn; Plaintiff, Defendant. NO.: 12 -6178 -CIVIL ORDER OF COURT AND NOW, this 2 41 day of 0'ek L-'/ , 2014, upon consideration of Plaintiff's Motion for Alternate Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Notice of Sheriff Sale on Defendant(s), Kevin D. Kuhn, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 23 Trine Avenue, Mount Holly Springs PA 17065-1144, and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 23 Trine Avenue, Mount Holly Springs, PA 17065-1144, and to 85 Greenview Dr., Carlisle, PA 17015-9194 with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 3129.2 and 430. C6I at L L. PY J BY THE COURT: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA � z c")jff; WELLS FARGO BANK, N.A. vs. Kevin D. Kuhn; Plaintiff, Defendant. CIVIL DIVISION NO.: 12 -6178 -CIVIL MOTION TO CONTINUE SHERIFF SALE AND DISPENSE WITH NEW NOTICE PURSUANT TO Pa.R.C.P. 3129.3(a) AND NOW, comes WELLS FARGO BANK, N.A. ("Plaintiff'), by and through its attorneys, Zucker, Goldberg & Ackerman, LLC, and files Motion to Continue Sale and Dispense with New Notice Pursuant to Pa.R.C.P. 3129.3(a) as follows: 1. On or about December 12, 2013, Plaintiff obtained a judgment in mortgage foreclosure against the Defendants at the above -captioned term and number ("Judgment"). 2. Pursuant to said Judgment, the Plaintiff caused the property subject to the Judgment, being 23 Trine Avenue, Mount Holly Springs, PA 17065-1144 ("Mortgaged Premises") to be scheduled for sale by the Sheriff of Cumberland County on September 3, 2014. 3. Plaintiff was unable to serve Defendants with the Notice of Sheriff and Plaintiff directed the Sheriff of Cumberland County to continue the sale of the Mortgaged Premises from September 3, 2014 to November 5, 2014. 4. Pursuant to Pa.R.C.P. 3129.3(a), new notice is required to be given as required by Pa.R.C.P. 3129.2(a), if the sale of real property is stayed, continued, postponed or adjourned, "except as provided in subdivision (b) or by special Order of the Court." 5. Plaintiff is currently trying to complete service of Defendants with the Notice of Sheriff Sale. 6. No parties -in -interest will be prejudiced by this continuance, since the Sheriff will be directed to announce the continued sheriff sale date at the November 5, 2014 sheriff sale. 7. Consequently, Plaintiff requests the sheriff sale scheduled for November 5, 2014 be continued pursuant to Pa.R.C.P. 3129.3(a) to January 7, 2015, and the requirement that advertisement be made and new notice be provided to Defendants, Iienholders and other parties of interest be waived. Zucker, Goldberg & Ackerman, LLC XFP-169308 WHEREFORE, Plaintiff, WELLS FARGO BANK, N.A., requests this Honorable Court to enter a special Order of Court pursuant to Pa.R.C.P. 3129.3(a) continuing the sheriff sale for November 5, 2014 to January 7, 2015 and dispense with the requirement that advertisement be made and a new notice be provided to Defendants, Iienholders or other parties of interest. Dated: October 28, 2014 By: ZU OLDBERG : AC LC .A 1 Ld Pr s' "1141 Esquire; berly A. Bonne , Esquire I A. Ackerman, Esquire; leigh L. Marin, Esquire 1ph M. Salvia, Esquire; . . #55650 .D.#89705 .#202729 .D.#306799 .#202946 aime 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-169308/jf 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. vs. Kevin D. Kuhn; Plaintiff, Defendant. CIVIL DIVISION NO.: 12 -6178 -CIVIL CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of foregoing Notice of Presentation and Motion to Continue Sheriff Sale and Dispense with New Notice Pursuant to Pa.R.C.P. 3129.3(a) was served on the following this 28th of October, 2014, via First Class U.S. Mail, Postage Pre - Pa id: Kevin D. Kuhn 23 Trine Avenue, Mount Holly Springs, PA 17065-1144 85 Greenview Dr Carlisle, PA 17015-9194 Dated: October 28, 2014 ZUCOLDBERG & A A. Dietterick, Esqui'-; PA I.D. #55 erly A. Bonner, Esquire; PA I.D. #8 05 . Ackerman, Esquire; PA I.D. #202729 eigh L. Marin, Esquire; PA I.D. #306799 h M. Salvia, Esquire; PA I.D. #202946 me R. Ackerman, Esquire; PA I.D. #311032 na 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-169308/jf 200 Sheffield Street, Suite 101 Mountainside, Ni 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION vs. Kevin D. Kuhn; Plaintiff, Defendant. NO.: 12 -6178 -CIVIL Notice of the Date of Continued Sheriff Sale The Sheriff Sale scheduled for November 5, 2014 at 10:00am in the above captioned matter has been continued until January 7, 2015 at 10:00am. BY: Dated: November 4, 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC --- Christina Cover , Legal Assistant File No.: XFP-169308 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., vs. Kevin D. Kuhn; Plaintiff Defendant CIVIL DIVISION No.: 12 -6178 -CIVIL TYPE OF PLEADING: Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE' OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: WELLS FARGO BANK, N.A. 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 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XFP- 169308/mag Zucker, Goldberg & Ackerman, LLC XFP-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. vs. Kevin D. Kuhn; CIVIL DIVISION Plaintiff, NO.: 12 -6178 -CIVIL Defendant. Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Margaret Agyepong, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of 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(s) Kevin D. Kuhn, is/are the record owners of the real property. 2. Pursuant to the Order of Court dated October 24, 2014, the Sheriff of Cumberland County posted Plaintiffs Notice of Sheriff's Sale, at the address of the mortgaged premises, being 23 Trine Avenue, Mount Holly Springs, PA 17065-1144, on or about November 13, 2014. A true and correct copy of said Order of Court and Proof of Posting are marked Exhibit "A", attached hereto and made a part hereof. 3. Pursuant to the Order of Court dated October 24, 2014, Plaintiffs counsel served Defendant(s) Kevin D. Kuhn with Plaintiff's Notice of Sheriff's Sale, via Certified Mail no signature required and via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing, at the address(es) of 23 Trine Avenue, Mount Holly Springs, PA 17065-1144 and 85 Greenview Drive, Carlisle, PA 17015-9194, on or about November 6, 2014. True and correct copies of said Notices and Proofs of Mailing are marked Exhibit "B", attached hereto and made a part hereof. 4. On or about July 18, 2014, Plaintiff's counsel served all other parties in interest with Plaintiffs Notice of Sheriff's Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "C", attached hereto and made a part hereof. Zucker, Goldberg & Ackerman, LLC XFP-169308 Finally, the undersigned deposes and says that the Defendants/Owners and all other Parties of Interest were served with Plaintiff's Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P. 3129.2. Dated: December 12, 2014 Sworn to and subscribed before me This / - da • /'G , 2014 Public MY COMMISSION EXPIRES: ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff MARGAR AGYEPONG Paral al/Legal Assistan JANELL URLIN NOTARY PUBLIC OF NEW JERSEY ID # 2364963 My Commission Expires 10/17/2017 Zucker, Goldberg & Ackerman, LLC XFP-169308 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-169308 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. CIVIL DIVISION Plaintiff, vs. Kevin D. Kuhn; Defendant. NO.: 12 -6178 -CML ORDER OF COURT AND NOW, this aay of , 2014, upon consideration of Plaintiff's Motion for Alternate Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Notice of Sheriff Sale on Defendant(s), Kevin. D. Kuhn, by, instructing the Sheriff of Cumberland. County to POST a copy of same on the Mortgaged Premises, being 23 Trine Avenue, Mount Holly Springs PA 17065-1144, .and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 23 Trine Avenue, Mount Holly Springs, PA 17065-1144, and to 85 Greenview Dr., Carlisle, PA 17015-9194 with said service being valid „and complete upon such posting and mailing in accordance with Pa R CP; 3129.2 and 430. int 'THE "COURT: g 2612 J. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY TitE Wells Fargo Bank, N.A. vs. Kevin D. Kuhn Case Number 2012-6178 SHERIFF'S RETURN OF SERVICE 06/17/2014 11:22 AM - Deputy William Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 23 Trine Avenue, Mount Holly Springs, PA 17065, Cumberland County. 06/30/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kevin D. Kuhn, but was unable to locate the Defendant in his bailiwick, He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 23 Trine Avenue, Mount Holly Springs, PA 17065, property is Vacant, defendant did not leave a forwarding address with the post office. cab. 08/29/2014 As directed by Jaime R Ackerman, Attorney for the Plaintiff, Sheriffs Sale Continued to 11/5/2014 09/26/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kevin D. Kuhn, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 85 Greenview Drive, Carlisle, PA 17015, defendant does not reside at address stated, did not leave a forwarding with the post office. cab. 11/04/2014 As directed by Jaime R Ackerman, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/7/2015 11/13/2014 06:32 PM - Deputy Christopher Sharpe, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Kevin D. Kuhn, pursuant to Order of Court by "Posting" the premises located at 23 Trine Avenue, Mt. Holly Springs Borough, Mount Holly Springs, PA 17065, Cumberland County with a true and correct copy according to law. SHERIFF COST: $1,467.63 November 14, 2014 SO ANSWERS, RONIJ' R ANDERSON, SHERIFF EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-169308 Zucker. Goldberg & Ackennan, LLC PO Box 1219 Mountainside, NJ 07092-1219 11 1 1 9314 710 1 1 11 11 1 70 775 2557 48 2010106102 Kevin D. Kuhn 23 TRINE AVE MOUNT HOLLY SPRINGS, PA 17065-1144 PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. vs. Kevin D. Kuhn; CIVIL DIVISION Plaintiff, NO.; 12-6178-CiVtL Defendant AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Kevin D. Kuhn 23 Trine Avenue Mount Holly Springs, PA 17065-1144 And 85 Greenview Dr Carlisle, PA 17015-9194 TAKE NOTICE; That the Sheriff's Sale of Real Property (Real Estate) will be held at Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on January 7, 2015, at time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description of the measured boundaries of the property, together with a brief mention other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "Al, The LOCATION of your property to be sold is: 23 Trine Avenue, Mount Holly Springs, PA, 17065-1144 the Cumberland County 10:00am prevailing local consisting of a statement of the buildings and any The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12 -6178 -CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Kevin D. Kuhn 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 1$ A N+TiCg_OF ME 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 1.EGAL AIVICE. 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 Y U 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 fife 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 Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriffs Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKER GOLDBERG & ACKERMAN, LIC Dated: October 340 , 2014 BY: Scott A. Dre ari .; Esquires PA I.Q. #55650 Kimberly A. Bonner, Esquire; PA.I.D. #89705 Joel A. Ackerman, Esquire; PA I.Q. #202729 Ashleigh Levy Marin, Esquire; PA I.Q. #306799 Ralph M. Salvia, Esquire; PA ID. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.Q. #317240 Denise Carlon, Esquire; PA I.Q. #317226 Roger Fay, Esquire; PA I.Q. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 File No.: XFP-169308 (908) 233.8500; (908) 233-1390 FAX E-mail: Office@zuckergoidberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA ORDER OF COURT Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the building and improvements thereon erected, situate in the Borough of Mount Holly Springs, Cumberland County, Commonwealth of Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove & Grove, Inc., dated November 17, 1971, revised November 18, 1971 and recorded in Cumberland County Plan Book 23, Page 65, as follows: BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 11 on the hereinafter mentioned Plan of Lots; thence by said Lot No. 11, through the center of a party wall, North 89 degrees 45 minutes West, 125.01 feet to a point on line of lands now or formerly of Robert Beeler; thence by said lands now or formerly of Robert Beeler, North 00 degrees 33 minutes 20 seconds East, 20.33 feet to a point, being the southwest corner of Lot No. 13 on the hereinafter mentioned 'Plan of Lots; thence by the said Lot No. 13, through the center of a party wall, South 89 degrees 45 minutes East, 124.90 feet to a point on the westerly line of said Trine Avenue; thence by the westerly line of the said Trine Avenue, South 00 degrees 15 minutes West, 20.33 feet to a point, the place of beginning. BEING Lot 12 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65. UNDER AND SUBJECT to a 20 -foot wide utility easement on the rear of said Lot as contained on said Plan. HAVING thereon erected a dwelling house being known and numbered as 23 Trine Avenue, Mount Holly Springs, PA, 170654144. BEING the same premises which Lloyd E. Herman and Ruth Ann Herman, Husband and Wife, by Deed dated May 7, 2008 and recorded May 13, 2008 in and for Cumberland County, Pennsylvania, as Instrument #200815777, granted and conveyed unto Kevin D. Kuhn. Tax Map No.: 23-32-2336-377; IN THE COURT OF COMMON PLEAS OF WELLS FARGO BANK, N.A. vs. Kevin D. Kuhn; Plaintiff, Defendant. 3ERLAN© COUNTI CIVIL DIVISION NO.: 12 -6178 -CIVIL NNSYLVANIA `,`� ORDER OF COURT AND NOW, this &'o \tay of , 2014, upon consideration of Plaintiffs Motion for Alternate Service, it is hereby ORDERED, ADJUDGED ANP DECREED that Plaintiff shall serve its Notice of Sheriff Sale on Defendant(s), Kevin D. Kuhn, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 23 Trine Avenue, Mount Holly Springs PA 170654144, and by mailing a copy via Certified Mal,, no signature required and First Class U.S. Mail, Postage Prepaid to 23 Trine Avenue, Mount Holly Springs, PA 17065-1144, and to 85 Greenview Dr., Carlisle, PA 17015-9194 with said service being valid and complete upon such posting and mailing In accordance with Pa.R.C.P. 31292 and 430. BY THE COURT: Zucker, Goldberg & Ackerman, LLC PO Box 1219 Mountainside, NJ 07092-1219 1 9314 7100 1170 0775 2 20141106-102 1111111111119411111141111gliii1111111 Kevin D. Kuhn 85 GREENVIEW DR CARLISLE, PA 17015-9194 PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. VS, Kevin D. Kuhn; CIVIL DIVISION Plaintiff, NO.: 12.6178 -CIVIL Defendant, AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Kevin D. Kuhn 23 Trine Avenue Mount Holly Springs, PA 17065-1144 And 85 Greenview Dr Carlisle, PA 17015-9194 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 January 7, 2015, at 10:00arn 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: 23 Trine Avenue, Mount Holly Springs, PA, 17065-1144 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 12 -6178 -CIVIL 410.1, THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Kevin D. Kuhn 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 .A .T C OF THE TIME AND PLACE OF THE S LE 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.. G.O. TO.OR: TELEPHONE THE OFFICE SET FORTH BELOW TO.FIND OUT WHERE.YOU.CAN.ET 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 YQU 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. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKER GOLDBERG & ACKERMAN, LIC Dated: October 3e, , 2014 BY: Scott A Die kiID tik, Esquire, PA. #55650 Kimberly A. Bonner, Esquire; PA.I.D. 489705 Joel A. Ackerman, Esquire; PA ID, 4202729 Ashleigh Levy Marin, Esquire; PA ID. 4306799 Ralph M. Salvia, Esquire; PA ID. 4202946 Jaime R. Ackerman, Esquire; PA ID. #311032 Jana Fridfinnsdottir, Esquire; PA ID. #315944 Brian Nicholas, Esquire; PA I.D. 4317240 Denise Carlon, Esquire; PA ID, 4317226 Roger Fay, Esquire; PA ID. 4315987 200 Sheffield Street, Suite 101 Mountainside, Ni 07092 File No.: XFP-169308 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA ORDER OF COURT Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the building and improvements thereon erected, situate in the Borough of Mount Holly Springs, Cumberland County, Commonwealth of Pennsylvania, bounded and described in accordance with a certain Plan of Lots for Grove & Grove, Inc., dated November 17, 1971, revised November 18, 1971 and recorded in Cumberland County Plan Book 23, Page 65, as follows: BEGINNING at a point on the westerly line of Trine Avenue (50 feet wide) at the northeast corner of Lot No. 11 on the hereinafter mentioned Plan of Lots; thence by said Lot No. 11, through the center of a party wall, North 89 degrees 45 minutes West, 125.01 feet to a point on line of lands now or formerly of Robert Beeler; thence by said lands now or formerly of Robert Beeler, North 00 degrees 33 minutes 20 seconds East, 20.33 feet to a point, being the southwest corner of Lot No, 13 on the hereinafter mentioned Plan of Lots; thence by the said Lot No. 13, through the center of a party wall, South 89 degrees 45 minutes East, 124.90 feet to a point on the westerly line of said Trine Avenue; thence by the westerly line of the said Trine Avenue, South 00 degrees 15 minutes West, 20.33 feet to a point, the place of beginning. BEING Lot 12 on the Plan of Lots for Grove & Grove, Inc., as recorded in Cumberland County Plan Book 23, Page 65, UNDER AND SUBJECT to a 20 -foot wide utility easement on the rear of said Lot as contained on said Plan. HAVING thereon erected a dwelling house being known and numbered as 23 Trine Avenue, Mount Holly Springs, PA, 170654144, BEING the same premises which Lloyd E. Herman and Ruth Ann Herman, Husband and Wife, by Deed dated May7, 2008 and recorded May 13, 2008 in and for Cumberland County, Pennsylvania, as Instrument #200815777, granted and conveyed unto Kevin D. Kuhn. Tax Map No.: 23-32-2336-377, IN THE COURT OF COMMON PLEAS QF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. Kevin D. Kuhn; Plaintiff, Defendant CIVIL DIVISION NO.; 12 -6178 -CIVIL ORDER OF COURT AND NOW, this a of eteldafin-..—. , 2014, upon consideration of Plaintiffs Motion for Alternate Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Notice of Sheriff Sale an Defendant(s), Kevin D. Kuhn, by Instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 23 Trine Avenue, Mount flatly Springs PA 17065-1144, and by mailing a copy via Certified Mali, no signature required and First Class U.S. Mail, Postage Prepaid to 23 Trine Avenue, Mount Holly Springs, PA 17065-1144, and to 85 Greenview Dr., Carlisle, PA 17015-9194 with said service being valid and complete upon such posting and mailing In accordance with Pa.R.C.P. 31292 and 430. BY THE COURT: NOS AMENDED OC CERT SENT UNITED STATES 5ERVICEa Certificate 0 Mailing To U.S. POSTAGE »PITHEVBQWES .,,...,. ZIP 07092 $ 001 0 02 111 000 1396603 NOV 06 2014 This Certificate of Mailing provides evidence that mall has been presented to USPS" for mailing. This form may be used for domestic and International mail. rem' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 miter postage Nov 88 08;44 XFP-169308/wn TEAM- C Tet Kevin D. Kuhn 23 Trine Avenue Mount Holly Springs, PA 17065-1144 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ttN1TEfJ3TATE3. POSTAL SERVICEa • Certificate Of Mailing This Certificate of Mailing provides evidence that mail has leen presented to USPS• for mailing. This form may be used for domestic and international mall. rrem Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC Postmark Here XFP-169308/wn TEAM- C Te: Kevin D. Kuhn 85 Greenview Dr Carlisle, PA 17015-9194 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 61OZ 90 AON£099G£1000 ()OZ.', 00 $ Z60/-0 rZ t fi s3M012 A3N ud «30y1.SOd .s71 Postmark Here Page 1 of 1 EXHIBIT C Zucker, Goldberg & Ackerman, LLC XFP-169308 NTL Page 1 of 4 UNITED STATES POSTAL SERVICE Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and international mail. From Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-169308/nfe TEAM- C To: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.O.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES NW POSTAL SERVICE® Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and Intarhattonel mall, ffem' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-169308/nfe TEAM- C To' COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 b10Z 91n1^f1r0£4LB£�000Ml ZO' o0 Y OO $ Z dIZ ==, -0-11 S3MOO A3N1ld (<3E1VIsOd'sn U.S. POSTAGE» RTNEYaOwes 02 Z P 07092 $ 0!01.20© 0001387430 JUL 18 2014 To pay lee, affix stamps or meter postage here. Postmark Here To pay fee, affb, stamps or meter postage here. Postmark NTL Page 2 of 4 �UNITED STATES PosrnL SERVICE® Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International meg, Ffom Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-169308/nfe TEAM- C T°' UNKNOWN TENANT OR TENANTS 23 Trine Avenue Mount Holly Springs, PA 17065-1144 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STi1TES MO POSTAL SERVICE; Certificate Of Mailing This Cortifieata of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International mall. Frem: Scott A. Dietterick, Esquire NOSTAGE») PITNEY BOWES ..g..,,�"'r wrr 111•MMEMIMF Saar ZIP 02 0ri 092 $ 001.20° 0001387430JUL 18 2014 To pay fee, affix stamps or meter postage here. c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, Ni 07092 XFP-169308/nfe TEAM- C To: UNKNOWN SPOUSE 85 Greenview Drive Carlisle, PA 17015-9194 Postmark Here County of P.Q.: CUMBERLAND To pay fee, affix stamps or meter postage here. P5 Form 3817, April 2007 PSN 7530-02-000-9065 4LOZ 'el lnr 0£t4L8£l000 • °Ov• I.00 $ Z602.0 dIZ Mt ZO .ta.1.1111ari1111111.11.20111i r s3nroe A3N.ud «30V1SOd *s -n NTL Page 3 of 4 maerstramavonium UNITED STATES POSTAL SERVICE0 Certificate Of Mailing Thls Certificate of Melling provkles evidence that mail has been presented to USW for making. This form may be used for domestic and International mall. Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-169308/nfe TEAM- C CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 U.S. POSTAGE >> PiTNEY BOWES kioppr. 1111.01fframar...., ZIP 07092 $ 001.20° 02 1V 00013 874 30 JUL 18. 2014 To pay few, sea stamps or meter pos hose here. County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES Miff POSTAL SERVICE Certificate Of Mailing This Cantu:ate of Mailing provides evidence that mall has been presented to MPS• for mailing. Thls form mey be used for domestic end International mail. Fnm"' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, Ni 07092 XFP-169308/nfe TEAM- C Tb: PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 IPLO et -tor oct7Leet000 zo Z6010 dI2 OZ.100 $ ememeemea To pay fee, affix stamps or meter postage here. Postmark Here 534409 A31111d <<30VISOci •s -fl NTL Page 4 of 4 UNITED STATES POSTAL SERVICED Certificate 0 Mailing This Certificate of MaNIng provides evidence that mall has been presented to WSfor meMni. This form may be used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-169 08/nfe TEAM- C To: UNKNOWN SPOUSE 23 Trine Avenue Mount Holly Springs, PA 17065-1144 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 U.S. POSTAGE >> PITNEY a:MES kieepr ZIP 07092 $ 001.200 02 m 0001387430 JUL 18 2014 To pay fee, affix stamps or meter postage hors, Postmark Here