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HomeMy WebLinkAbout12-7749McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID #16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID #17616 EDWARD D. CONWAY, ESQUIItE - ID #34687 MARGARET GAIRO, ESQUIRE - ID #34419 ANDREW L. MARKOWITZ, ESQUIRE - ID #28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID #87830 KEVIN T. McQUAIL, ESQUIRE - ID #307169 ~-' °`' '~ CHRISTINE L. GRAHAM, ESQUIRE - ID #309480 -~ ~ ~~ _ __ BRIAN T. LaMANNA, ESQUIRE - ID #310321 ~`' ~' '~ ~ _ JOSEPH F. RIGA, ESQUIItE - ID #57716 `~ ''' `m' %' " ` ~ ~~ 123 South Broad Street, Suite 1400 -°~~' ~ ~,';_~., ~ a~_~. Philadelphia, Pennsylvania 19109 ~ ~ ~,,, ~ w (215) 790-1010 ~ ~' ~= m _ ~~-, ~~ ---. ~_ ,- INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: f a, -- `17'x{ ~ l ~IUL(, v ~~ Junia V. Hable Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, National Association, by its attorneys, McCabe, Weisberg & Conway, P.C. and files this complaint in Mortgage Foreclosure as follows: ,Q'l03.75 l~~,~~Y Gam-` ~ryQ~~ 062-PA-V3 ~~ ~,gSlL, ~(o NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice aze served, by entering a written appeazance personally or by attorney and filing in writing with the court your defenses or obj ections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THATMAY OFFERLEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentaz una compazencia escrita o en persona o con un abogado y entregaz a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuaz la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes paza usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO TNMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Cazlisle, PA 17013 (800)990-9108 File # 69694 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Unless, within thirty (30) days after your receipt of this communication, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid. If you notify us in writing within thirty (30) days of your receipt of this communication that the debt, or a portion of the debt, is disputed, we will obtain verification of the debt or a copy of the judgment against you, and we will mail to you a copy of the verification or judgment that we obtain. Upon your written request to us within thirty (30) days of your receipt of this communication, we will provide to you the name and address of the original creditor, if different from the current creditor. Case Name: Wells Fargo Bank, N.A. v. Junia V. Hable Cumberland County 1. The Plaintiff is Wells Fargo Bank, National Association, 3476 Stateview Blvd., Ft. Mill, SC 29715 (hereinafter "Plaintiff'). 2. The Defendant, Junia V. Hable, is an individual whose last known address is 130 East Locust Street, Mechanicsburg, PA 17055. 3. Wells Fargo Bank, N.A., directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit "A," attached hereto and made a part hereof. On or about July 27, 2010, Junia V. Hable, made, executed and delivered to Mortgage Electronic Registration Systems, Incas nominee for Fulton Bank, N.A., a Mortgage in the original principal amount of $128,272.00 on the premises described in the legal. description marked Exhibit "B," attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of Cumberland County in Mortgage Instrument Number 201020707. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 5. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded March 26, 2012, the mortgage was assigned to Wells Fargo Bank, N.A. which Assignment is recorded in the Office of the Recorder of Cumberland County in Mortgage Instrument Number 201208569. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Junia V. Hable is the record and real owner of the aforesaid mortgaged premises. 7. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due June 1, 2012. 062-PA-V3 8. As of 11/28/2012, the amount due and owing Plaintiff on the mortgage is as follows: Principal $ 124, 745.28 Interest Through 11/28/2012 $ 3 401.00 Late Charges $ 256.85 Property Inspections $ 145.00 Suspense Balance $ (33.87) Escrow Balance $ 887 02 TOTAL $ 129,401.28 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 Plaintiffs 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. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendants. 10. This action does not come under Act 9] of 1983 because the mortgage is FHA insured. 11. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant, but reserves its right to do so in a separate legal action if such right exists. If Defendant has received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. 062-PA-V3 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of`5129,401.28, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. McCabe Weisberg & C nway, P.C. By: [ ] TE NCE J. McCABE, ES UIRE MARC S. WEISBERG, ESQUIRE [ ]EDWARD D. CONWAY, ESQUIRE [ ]MARGARET GAIRO, ESQUIRE [ ]ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPIVAK, ESQUIRE [ ]MARISA J. COHEN, ESQUIRE [ ]KEVIN T. MCQUAIL, ESQUIRE [ ]CHRISTINE L. GRAHAM, ESQUIRE [ ]BRIAN T. LAMANNA, ESQUIRE [ ]JOSEPH F. RIGA, ESQUIRE Dated: ~~ m Apr- a 1 , 2012 T 062-PA-V3 VERIFICATION Samir Erian, hereby states tha he she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that~she 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 o h~' /her 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 Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 12/18/2012 086-PA-V2 Junia V. Hable I App # ~ _7 Min # - Muttistate NOTE ~~~ ~' July a7, solo IaL~I 130 E118T I.000ST BTRFLT t~CB>IINICSSUR(i, PA 17055 Ipropeny Addressl 1. PARTIES "Borrower" ttteahs each person signing at the end of this Note, and the person's successors and assigns. POLTplQ HA1tQC, N.A. and its succes~rs and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of One Hundred Twenty Eight Thousand Two Hundred Seventy Two 1-nd Zero/100 Dollars (U.S. $ 128, a7a. 00 }, plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the Loan proceeds by Lender, at the talc of Four and threo Quarters P~'~t ( 4.750 ~o) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promsee to pay is secured by a mortgage, deed of trust or similar security instrurt~nt That is dated the same date as this Note turd called the "security Instrument." The Security Instrutent protects the Lender from losses which might result if Borrower defaults under this Nou. 4. MANNER OF PAYMENT (A) Time . Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on Septomtber O1 ,x010 .Any principal and interest remaining on the first day of August x040 ,will be due on that date, which is called the "Maturity Date." ' (B) Place Payment shall be made at ONE PElHi SQI7ARE, I~ADICASTER, PA 17602 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and inleresl will be in the amount of U. S. $ 669.13 .This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to ibis Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Nou, the covenants of the allonge shall be inca~porated into and shall amend and supplement the covenants of this Note ac if the alionge were a part of this Note. (Check applicable box] ^Graduated payment Allonge ^Growing Equity Allonge ^Other (specify] s MI~w fw• t+ou i VMP ® VMP1 W oq~n KMr a Rnaneiu Serrlep P~ "Lender"• means • S. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the nrortth to the extent t~cquired by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, these will be no changes in the due date or in the amount of the monthly paynxrtt unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late C6atge for Oveidue Payments If Lender has not received the full monthly payttreut required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the pnymer-t is due, Lender may collect a late charge in the amoun[ of Four percent ( 4.000 96) of the overdue amount of eactt payment. (B) Dd'autt If Borrower defaults by failing to pay in full any amnthly payment, then Lender may, except as limited by regulations of the Secretary is the case of payment defaults, require immediate payrra;rtt in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In marry circumstances regulations issued by the Secretary will. limit Lender's rights to require immediate payment in full in the case of payrrxrtt defaults. This Note does not authoriu acceleration when not permitted by HUD regulations. As used in this Note, "Secraary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses [f Lender has required immuiiate payment in full, as described above, Lender may require Borrower to pay coste and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrows and any other person who has obligations under this Natc waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand pavment of amounts due. "Notice of dishonor" means the right to require Lender to give Halite to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrows at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lcndcr under this Note will be given by first class mail to Lender at the address stated in Paragraph 4fB) or at a different addrecc if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE if more than one person signs this Natt, each person is fully and personally obligated to keep all of the promises made in this Note,•including tlu promset to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is al$o obligated to do these things. Any person who takes over these obligations; including the obligations of a guarantor, surety or endorse of this Note. is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any ane person signing this Note may be required to pay all of the amounts owed under this Note. V PM~'tltl" Fi:~d Rtl~ aoN l wai« KluwaFlnmNdS~rvkn _~~ VMP1R Pepi . • _ (Seal) -BOfr'OWEr (JCYJ) lS~) -BOrroWlr -BO[rOWli ~ ~~ ~ sy: ~, _ ~ ,,. rye: ^+~T .......~. -... .- ...~... .....w. WITHOUT RECOURSE PAY TO THE ORDER OF WEC. S FARGO ANK, N.A. ey Scott M. Swanson Assistant Vico President BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Nate. r r.~ ~~3 e'~~.- ~ ' (Seal) (~) Ji]!i<TJ1 V . >~Z.L -Borrower -Borrower (Seal) (Seal) -Borrower -Harrower (Seal) -BOROWlr f S w~oK*m~"Ktuiw or flmnelN Swvlea a 1 ~ , ALL 17iAT CERTAIN lot of ground situate on th0 South side of East .. Locust 9treat.in the.eecond Nalyd o! the Borough of Mechanicsburg, • ~'Cumbarland County, Pennsylvania, bounded and described in accozdance with a survey•aad plan thereof made by Gerrit J. Bets, • "Reg, 9vr., dated May 12,- 1972, ae follows: • • BEGIMNING•at a point on the southern line oL Locust Street, said . point being 332.4 feet Salt of the center lino of 9. Arch etreetj thence along the southern line of Locuet'Straet North 77 degrees . ~45 minutes Bast 20 feet to a corner of property formerly of John ' ~tiouse, iroM or formerly of Reuben E. Lutz; thence along said ;property SoutK 12 degrees l5 mim~tee East 193 test to a point on the 6ozthern skin of a public alleyr thence along said alley ' South 77•degreea 45 minutes Nast 20•teet to a corner of property • fottiaerly.of Edith Albright, now or formerly oL Agnue G. 9oirora; thence along said property, passing through the center of a concrete block partition wall•oE a double one story garage building and passing through the center of a partition wall of the two and one-halt ataxy double frame dwelling house arectad.on • this and the lot adjacent thereto, North 12 degrees ~5 minutes vast 193 feet to the point .and place o! BBGINNING. • HAVING thereon erected the eastern one-half of a two and one-half dtory Erame dwoiling house and the eastern one-half of a one story concrete block garage building, known and numbered as No. - 130 East Locust Street. ~,~+ieiY 6 FORM 1 :.:' :~ Wells Fargo Bank. N.A. TN THE COURT OF COMMON PLEF ~ rte,~ Plaintiff CUMBERLAND COUNTY, PENNS~AI~ ~`' ~' vs. r- ~~~ - ='i ,--_ ~. ~.:, ~„ . .~~ ~- ~k ~a-, Junia V. Hable ~~, - Civil ~~~;' ~:m Defendant -- ~~-; NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. ~~~ ~ ~ ~ a Date Respectfully fitted: -_~ ~~~c [Signature of~ounsel for Plaintiff) c~ i7gs~ y l 69694 Page 1 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # 13UKKUWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Narne: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: State: Zip: Yes ^ No ^ Listing date: Price $ Realtor Phone: Yes ^ No ^ State: Zip: Home: Office: Cell: Other: Email: # of people on household: How long? Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile # 1: Model: Year: Amount owed: Value: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles boats motorc~lesl• Year: Amount owed: Monthly Income Name of Employers: 1. 2. 3. Mosel Year: Value: 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 Mortga a Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fueUrepairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Da /Child Care/Tuft. Other Ex enses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ^ No ^ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: 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 deliquency? Yes ^ No ^ If yes, please indicate the status of those negotiations: Please provide the following information, if lrnpwn, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: Phone: UWe, ,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. UWe understand that I/we am/are under no obiligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements f Proof of any expected income for the last 45 days Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 McCABE,WEISBERG & CONWAY,P.C. "F 1'I U Inn° .kw?BY: HEIDI R. SPIVAK,ESQUIRE -ID#74770 I . 1 Jim t , 123 South Broad Street,Suite 1400 PP1 2: 30 Philadelphia,Pennsylvania 19109 lit'BE fi L F1 No ��U (215) 790-1010 P E N N S YINA0IA Wells Fargo Bank,N.A. Cumberland County Court of Common Pleas Plaintiff No. 12-7749 v. Junia V. Hable Defendant MOTION TO LIFT STAY OF PROCEEDINGS Plaintiff, Wells Fargo Bank, N.A., hereby motions this Court to remove the captioned mortgage foreclosure action from the Cumberland County Residential Mortgage Foreclosure Program("the Program"), and in support thereof avers as follows: 1. This is an action in mortgage foreclosure brought by Wells Fargo Bank,N.A.against Junia V. Hable. 2. This case is currently under a stay pursuant to paragraph (b) of the Cumberland County Administrative Order dated February 28, 2012, which establishes the Mortgage Foreclosure Diversion Program. 3. Junia V. Hable was served a true and correct copy of the original complaint in mortgage foreclosure,filed on January 7,2013 to his/her last known address of 130 East Locust Street,Mechanicsburg Borough,Mechanicsburg,Pennsylvania 17055.the A true and correct copy of the Sheriff's return of service is attached hereto as Exhibit"A". 4. Junia V.Hable was served with the Notice of Residential Mortgage Foreclosure Diversion Program and Financial Worksheet on January 7, 2012 to his/her last known address of 130 East Locust Street, Mechanicsburg Borough, Mechanicsburg, Pennsylvania 17055. A true and correct copy of the Notice of Residential Mortgage Foreclosure Diversion Program is attached hereto as Exhibit`B". 5. It has been more than sixty days since Defendant(s) was served with the Notice of Residential Mortgage Foreclosure Diversion Program and Financial Worksheet and Defendant(s) has not elected to participate in the Program by taking the affirmative steps identified in the Notice of Residential Mortgage Foreclosure Diversion Program, and has not filed a Request for Conciliation Conference. 6. For the reasons set forth herein,the aforementioned stay of proceedings should be lifted to allow Plaintiff to proceed with the instant mortgage foreclosure action. WHEREFORE, it is respectfully requested that the Court enter an Order lifting the stay of proceedings, and for such further relief as the Court deems appropriate. MCCABE, WEI BERG &CONWAY, P.C. r I, , IBy \ ' Heidi ' . Spivak, Esquire McCABE,WEISBERG AND CONWAY,P.C. BY: Heidi R. Spivak,Esquire,Atty I.D.#74770 Attorneys for Plaintiff 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank,N.A. Cumberland County Court of Common Pleas Plaintiff No. 12-7749 v. Junia V. Hable Defendant CERTIFICATE OF SERVICE I, Heidi R. Spivak, Esquire,hereby certify that a true and correct copy of Plaintiff's Motion to Lift the Stay of Proceedings Pursuant to Cumberland County Administrative Order dated February 28, 2012,was served on the below named person(s)by regular first class mail, postage prepaid, on June 10, 2013. Junia V. Hable 130 East Locust Street Mechanicsburg Borough, Mechanicsburg, Pennsylvania 17055 Dated: ' r , Heidi R. Spi .k, squire ((SC/1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 6 (7q(( Sheriff �t l zrrrr p\1so t,i.r'/rya�¢ Jody S Smith Chief Deputy Richard W Stewart Solicitor ;r ,,.E,C,,:rr-G F•= r�� Wells Fargo Bank, N.A. Case Number vs. Junia V Hable 2012-7749 SHERIFF'S RETURN OF SERVICE 01/07/2013 02:43 PM -Deputy Dennis Fry, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Coplaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Junia V Hable at 130 E. Locust Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. DENNI RY, DEPU SHERIFF COST: $38.00 SO ANSWERS, January 08, 2013 RONN(R ANDERSON, SHERIFF Exhibit A jr.)Cour!y$:j Sheriff,'f�l esn!i:Inc. FORM 1 Wells Fargo Bank,N.A. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. �i 1 1 } } Junia V. Hable /a- 77u, Civil Defendant NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference.First,within twenty(20) days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date.During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf.If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference.It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf.If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully t itted: , 14 ‘.A tx,,uctk Date [Signature of ounsel for Plaintiff] kt. 1K F+ 69694 ii Page 1 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMER/PRIMARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes 0 No 0 Listing date: Price$ Realtor Name: Realtor Phone: Borrower Occupied? Yes 0 No 0 Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people on household: How long? CO-BORROWER Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people on household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount$ Included Taxes&Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes 0 No 0 If yes,provide names,location of court,case number&attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ • Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Other transportation(automobiles,boats,motorcycles): Model Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description(not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2nd Mortgage Utilities Car Payment(s) Condo/Neigh.Fees Auto Insurance Med.(not covered) Auto fuel/repairs Other prop.payment Install.Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes 0 No 0 If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: 2 Email: Have you made application for I-Iomeowners Emergency Mortgage Assistance Program(HEMAP)assistance? Yes 0 No 0 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 deliquency? Yes 0 No 0 If yes,please indicate the status of those negotiations: Please provide the following information,if known,regarding your lender or lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): Contact: Phone: I/We, ,authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obiligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements i Proof of any expected income for the last 45 days i Copy of a current utility bill 'f Letter explaining reason for delinquency and any supporting documentation(hardship letter) i Listing agreement(if property is currently on the market) 3 L McCABE,WEISBERG& CONWAy,p.C. BY: HEIDI R. SPIVAK,ESQUIRE-ID#74770 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,N.A. Cumberland County Plaintiff Court of Common Pleas V. No. 12-7749 Junia V.Hable Defendant ORDER AND NOW, this-/y* day of 4,..;, 2011 , upon consideration of Plaintiff's Motion to Lift the Stay ofProceedings Pursuant to Cumberland County Administrative Order dated February 28, 2012, and any opposition thereto, it is hereby ORDERED and DECREED that: The stay of proceedings is hereby lifted, and Plaintiff may proceed with it's action in mortgage foreclosure in accordance with the applicable rules of civil procedure. BY THE COURT: J. r ? �• 5���� � "< 4— -V McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 `f , MARISA J.COHEN,ESQUIRE-ID#87830 c EE KEVIN T.MCQUAIL,ESQUIRE-ID#307169 rte ' rs 9 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 c i �.� ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 ca , r JOSEPH I.FOLEY,ESQUIRE-ID#314675 ,.. r`=3- CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 y c c:a 123 South Broad Street, Suite 1400 �, C 5 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Junia V.Hable Number 12-7749 Defendant ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant, Junia V. Hable, in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Principal $ 129,401.28 Interest from 11/29/12 to 08/02/13 $ 0.00 Total $ 129,401.28 McCAB , EISB/G�AP D CONW ,P.C. BY: d [ ] Te ce J.McCabe,Esq. Marc S. Weisberg,Esq. [ ] dward D. Conway,Esq. [ ]Margaret Gairo,Esq. V a [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. vZ [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. L4 Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. 'P Attorneys fo Pla ntiff Date: �1) Z AND NOW,this day of ,2013,Judgment is entered in favor of Plaintiff,Wells Fargo Bank,N.A.,and against Defendant,Junia V.Hable,in rem only and not in personam,and damages are assessed in the amount of$129,401.28,plus interest and costs. BY THE PROW NOT McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-'ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Junia V.Hable Number 12-7749 Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned,being duly sworn according to law,deposes and says that the Defendant,Junia V.Hable, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act,50 U.S.C.App.§501,et seq.;and that the Defendant,Junia V.Hable,is over eighteen (18)years of age,and resides as follows: Junia V.Hable, 130 East Locust Street Mechanicsburg,PA 1.7055 MICA EISFB ,?R CONWA ,P.C. SWORN AND SUBSCRIBED ,-, BEFORE ME THIS Z DAY [ ]Terr ce J.McCabe Esq. [ ]Marc S. Weisberg,Esq. L [ ward D.Conway,Esq. [ ]Margaret Gairo,Esq. OF f-N^�U S T ,2013 [ Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. °r"' [ ] Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. NOTARY PUB [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. eph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. COMMONWEALTH OF PENNSYLVANIA Attorneys for Plaintiff NQTA1ZIhl SEAL Date: ��'t3 MAIA KUSHICK,Notary Public City of Philadelphia,Phila.County M Commission Expires Ma 10,2 017 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 , Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH L FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,N.A. COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Number 12-7749 Junia V. Hable Defendant AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, attorney for the Plaintiff in the within matter,being duly sworn according to law, hereby depose and say that the last-known mailing address of the Defendant is: Junia V.Hable 130 East Locust Street Mechanicsburg,Pennsylvania 1.7055 McCAB + ISB G SWORN AND SUBSCRIBED t'4 B > BEFORE ME THIIS DAY [ ]Terre .McCabe,Esq. [ ]Marc S.Weisberg,Esq. w u$"► L ]E and D.Conway,Esq. [ ]Margaret Gairo,Esq. OF 2013 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. C� [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. [ ]Brian T. LaManna,Esq. NOTARY PUB [ ]Ann E. Swartz,Esq. [ ] Joseph F. Riga,Esq. XJoseph L Foley,Esq. [ ]Celine P.DerKrikorian,Esq. COMMONWEALTH OF PENNSYLVANIA Attorneys for Plaintiff NOTARIAL SEAL Date: 5J 13 MAIA KUSHICK,Notary Public City of Philadelphia,Phila.County M Commission FYn«?�P4a.r 1 n ?nil McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS r V. Number 12-7749 Junia V.Hable Defendant CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff,being duly sworn according to law,deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against within ten(10)days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit"A". McCABE B RG AND AY,P.C. SWORN AND SUBSCRIBED h0� BY: BEFORE ME THIS 2 DAY [ ] Terre J.McCabe,Esq. Marc S. Weisberg,Esq. [ ] and D. Conway,Esq. [ ] Margaret Gairo,Esq. OF u� -� ,2013 [ Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. <— [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. NOTARY PUBLIC [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. coMMO Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. NW�LT~'0FPENNSy&-V HA w Attorneys for Plaintiff MAIA NOTARIAL SEAL Date: City of Phil SNICK,Notary public My Commiss�elphia,Phila.County on Expires MY a 2617 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and correct to the best of his/her knowledge,information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCAB ISBE A W ,P.C. BY: [ ] Terrenc .McCabe,Esq. [ ]Marc S.Weisberg,Esq. [ ]Ed d D. Conway,Esq. [ ]Margaret Gairo,Esq. [ ] ndrew L.Markowitz,Esq. [ ] Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. [ ] Brian T.LaManna,Esq. [,a Ann E. Swartz,Esq. [ ] Joseph F. Riga,Esq. Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff Date: /2- r`S Wells Fargo Bank,N.A.v.Junia V.Hable Cumberland County;Number: 12-7749 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary June 18,2013 To: Junia V. Hable 1.30 East Locust Street Wells Fargo Bank,N.A. Cumberland County Vs. Court of Common Pleas Junia V. Hable Number 12-7749 NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A USTED SE ENCUEN'IRA EN ESTADO DE REBELDIA POR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA F,SCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE O POR.ABOGADO Y FOR NO HABER RADICADO POR CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(1 O) ESCR.ITO CON ESTE TRIBUNAL,SIDS DEFL"NSAS U OBJECIONES A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY ACCION DF,BIDA DL"NTRO DE D18Z(10)DIAS DF LA FLCLIA DE F,STA OR OTHER IMPORTANT RIGHTS. NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU COMPARECER USTED EN CORTI"U OIR PREUBA AL.GUNA, DICTAR DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTES. I TIRING A LAWYER.. USTED LE DEBE TOMAR ESTE, PAPLL A SU ABOGADO IFYOU CANNOT AFFORD TOHIREA LAWYER,THIS OFFICEMAYBEABLE INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES T14ATMAYOFFL'•R 'I'LLEFONEA LA OFICINA EXPUSO ABAJo. ESTA OFICINA LO PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE,OR NO FEE. PROPORCIONAR CON INFORMAC16N ACERCA DE FMPLEAR A UN ABOGADO. Cumberland County Bar Association SI USTED NO PUEDE PROPORCIONARPARA EMPLL•'AR UN ABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPAZ DE PROPORCTONARLO CON Carlisle,Pennsylvania 17013 INFOIZMAC16NACERCADF LAS AGENCIASQUEPUF,DENOFRECERLOS (800)990-9108 SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. �9 l rl� unty Bar Association 32 South Bed or - ai.'51�;i�cnns I auia 1.7013 • }990-91� MCCA Vh1SRF3RG AND NUJ Y,:P.C. BY: [ ]Terrence J.M.cCab > qKre [ ] Marc Weisberg,Esquire ]Edward D.Con ,Es [ ],IvYargaret Gairo,.Esquire [ ]Andrew L. owit�Esquire [,.e']Heidi R. Spivak,Esquire [ )Marisa J alien,Esquire ]Kevin T.M.cQuail,Esquire ]Christine L. Graham,Esquire [ )Brian T.LaManna,Esquire [ ].Ann E. Swartz,Esquire Vlvoscph F.Riga, Esquire [ ]Joseph I.Foley,Esquire Attorneys for Plaintiff ch Results as of:Aug-02-2013 09:11:05 Department of Defense Manpower Data Center SCRA 3.0 Status Report Pursuant to Ser4r cemembers Civil.Relief Act Last Name: HABLE First Name: JUNIA Middle Name: Active Duty Status As Of: Aucl-02-2013 On Active Duty On Active Duty Status Dale Active Duty Start Date Active Duty End Date Status Service Component NA NA ... Na NA This response reflects the individuals'active duty status based on the_Active Duty Status Date t Left Active Duty Within 367 Days of Active Duty Status Date Alive Duty Start Date Active Duty End Date Status Service Component NA - 'NA No NA This response reflects where the Individual left active duty status vAthin 367 days preceding the Active Duty Status Date t� The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status service Component NA NA No NA This response reflects whether the individual or his/her unll has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 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. y6k 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:hftp://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 USG App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(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: T380S85F20EBV90 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Junia V.Hable 130 East Locust Street Mechanicsburg,Pennsylvania 17055 Wells Fargo Bank,N.A. COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Junia V.Hable No. 12-7749 Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment p ,� Judgment in Replevin Q Judgment for Possession If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway,, P.C. at(215)790-1010. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FILE NO.: 12-7749 Civil Term Wells Fargo Bank,N.A. v. AMOUNT DUE: $129,401.28 Junia V. Hable INTEREST: from 08/03/13 $4,721.94 at$21.27 - ATTY'S COMM.: 4m { COSTS: �, > TO THE PROTHONOTARY OF SAID COURT: ' tea " i The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,ort based on a confession of judgment,but if it does, it is based on the appropriate original proceeding filed pursuant to w.. Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. `' PRAECIPE FOR EXECUTION Issue writ or 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) 130 East Locust Street,Mechanicsburg,Pennsylvania 17055-3840 (More fully described as 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 writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: /�lJ BY: ! C / 6 `- Z� [ ]Terrence J. McCabe,Esq. [ arc S. Weisberg,Esq. [ ]Edward D. Conway,Esq. [ ]Margaret Gairo,Esq. ,�1 /n� [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. �Q 5D )l] (.L [ ]Marisa J. Cohen,Esq. [ ] Kevin T.McQuail,Esq. O � ((ll f- [ ]Christine L. Graham,Esq. [ ] Brian T. LaManna,Esq. Qb C /- [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. �1 [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. O 3 7 s Attorneys for Plaintiff q l it Firm: MCCABE,WEISBERG AND CONWAY J / Address:123 S.Broad Street, Suite 1400 Philadelphia,PA 19109 )�Q/_ 7S �d a 1F Attorney for: Plaintiff [/�P V ,, Telephone:(215)790 1010 12/2, f IZ Supreme Court ID No. 11 (0 I LO Sb GC. ekio?S.4.7 p# agvg0 tOrt/ Pg-73-32-ta LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate on the South side of East Locust Street in the Second Ward of the Borough of Mechanicsburg, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, Reg. Sur., dated May 12, 1972, as follows: BEGINNING AT a point on the Southern line of Locust Street, said point being 332.4 feet East of the center line of S. Arch Street;thence along the Southern line of Locust Street North 77 degrees 45 minutes East 20 feet to a corner of property formerly of John House,now or formerly of Reuben E. Lutz; thence along said property South 12 degrees 45 minutes East 193 feet to a point on the Northern side of a public alley;thence along said alley South 77 degrees 45 minutes West 20 feet to a corner of property formerly of Edith Albright, now or formerly of Agnus G. Sowers;thence along said property, passing through the center of a concrete block partition wall of a double one story garage building and passing through the center wall of the two and and one-half story double frame dwelling house erected on this and the lot adjacent thereto,North 12 degrees 45 minutes West 193 feet to the point and place of BEGINNING. HAVING THEREON ERECTED the Eastern one-half of a two and one-half story frame dwelling house and the Eastern one-half of a one story concrete block garage building, known and numbered as No. 130 East Locust Street, Mechanicsburg, Pennsylvania. UNDER AND SUBJECT,NEVERTHELESS,to any conditions,covenants, restrictions, reservations, easements and rights of way of record or visible upon an inspection of the premises. 1130 East Locust Street, Mechanicsburg, Pennsylvania 17055-3840. BEING the same premises which JUDITH I. SCHOLL,AN ADULT INDIVIDUAL by deed dated July 27, 2010 and recorded July 29, 2010 in the office of the Recorder in and for Cumberland County in Deed Instrument#201020706 and conveyed to Junia V. Hable, an adult individual, in fee. TAX MAP PARCEL NUMBER: 17-23-0565-168 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T. McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 - 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 ` i (215)790-1010 ' Wells Fargo Bank,N.A. CUMBERLAND COUNTY fir-, COURT OF COMMON PLEAS Plaintiff v. NO: 12-7749 Junia V.Hable Defendant AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following information concerning the real property located at: 130 East Locust Street,Mechanicsburg,Pennsylvania 17055-3840,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Junia V.Hable 130 East Locust Street Mechanicsburg,Pennsylvania 17055 2. Name and address of Defendant in the judgment: Name Address Junia V. Hable 130 East Locust Street Mechanicsburg,Pennsylvania 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Wells Fargo Bank,National 3476 Stateview Boulveard Association Fort Mill, South Carolina 29715 4. Name and address of the last recorded holder of every mortgage of record: Name Address Wells Fargo Bank,N.A. 3476 Stateview Boulevard Fort Mill, South Carolina 29715 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 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: Name Address Tenants/Occupants 130 East Locust Street Mechanicsburg,Pennsylvania 17055-3840 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8th Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff s Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. BY: 77 �l L t [ ] Terrence J.McCabe,Esq. [ rc S. eisberg,Esq. DATE [ ] Edward D.Conway,Esq. [ ] Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ] Marisa J.Cohen,Esq. [ ] Kevin T. McQuail,Esq. [ ] Christine L.Graham,Esq. [ ] Brian T.LaManna,Esq. [ ] Ann E.Swartz,Esq. [ ] Joseph F.Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T. McQUAIL,ESQUIRE-ID#307169 t a CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 '_ ` BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 . CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 ' 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW Wells Fargo Bank,N.A. COURT OF COMMON PLEAS v. CUMBERLAND COUNTY Junia V. Hable Number 12-7749 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Junia V.Hable 130 East Locust Street Mechanicsburg,Pennsylvania 17055 Your house(real estate)at 130 East Locust Street,Mechanicsburg,Pennsylvania 17055-3840 is scheduled to be sold at Sheriffs Sale on March 12,2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$129,401.28 obtained by Wells Fargo Bank,N.A.against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Wells Fargo Bank,N.A.the back payments, late charges, costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened,you may call McCabe, Weisberg and Conway,P.C. at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground situate on the South side of East Locust Street in the Second Ward of the Borough of Mechanicsburg, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz,Reg. Sur., dated May 12, 1972, as follows: BEGINNING AT a point on the Southern line of Locust Street, said point being 332.4 feet East of the center line of S. Arch Street; thence along the Southern line of Locust Street North 77 degrees 45 minutes East 20 feet to a corner of property formerly of John House, now or formerly of Reuben E. Lutz; thence along said property South 12 degrees 45 minutes East 193 feet to a point on the Northern side of a public alley;thence along said alley South 77 degrees 45 minutes West 20 feet to a corner of property formerly of Edith Albright, now or formerly of Agnus G. Sowers;thence along said property,passing through the center of a concrete block partition wall of a double one story garage building and passing through the center wall of the two and and one-half story double frame dwelling house erected on this and the lot adjacent thereto,North 12 degrees 45 minutes West 193 feet to the point and place of BEGINNING. HAVING THEREON ERECTED the Eastern one-half of a two and one-half story frame dwelling house and the Eastern one-half of a one story concrete block garage building, known and numbered as No. 130 East Locust Street, Mechanicsburg, Pennsylvania. UNDER AND SUBJECT,NEVERTHELESS, to any conditions,covenants,restrictions,reservations, easements and rights of way of record or visible upon an inspection of the premises. 1130 East Locust Street,Mechanicsburg, Pennsylvania 17055-3840. BEING the same premises which JUDITH I. SCHOLL,AN ADULT INDIVIDUAL by deed dated July 27, 2010 and recorded July 29, 2010 in the office of the Recorder in and for Cumberland County in Deed Instrument#201020706 and conveyed to Junia V. Hable, an adult individual, in fee. TAX MAP PARCEL NUMBER: 17-23-0565-168 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-7749 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK,N.A.Plaintiff(s) From JUNIA V.HABLE (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $129,401.28 L.L.: $.50 Interest FROM 8/3/13-$4,721.94 AT$21.27 Atty's Comm: Due Prothy: $2.25 Atty Paid: $186.75 Other Costs: Plaintiff Paid: Date: 12/4/2013 David D.B ell,Pry othhhoonotary 1(Seal) B . ! �� ���/. Deputy REQUESTING PARTY: Name: MARC S.WEISBERG,ESQUIRE Address: MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17616 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 Wells Fargo Bank, N.A. Plaintiff Junia V. Hable v. Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 12 -7749 AFFIDAVIT OF SERVICE G � rn 1,1 The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 7th day of February, 2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEFORE ME THIS /d71" DAY OF NOTARY PUBLIC , 2014 COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEAN R. JACOBS, 4R., Notary Public City of Philadelphia, Phila. County My Commission Expires June 27, 2017 McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire j'IGlarc S. Weisberg, Esquire ] Margaret Gairo, Esquire ] Heidi R. Spivak, Esquire ] Christine L. Graham, Esquire ] Ann E. Swartz, Esquire ] Joseph I. Foley, Esquire ] Jennifer L. Wunder, Esquire McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 Wells Fargo Bank, N.A. Plaintiff Junia V. Hable v. Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 12 -7749 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 130 East Locust Street, Mechanicsburg, Pennsylvania 17055 -3840, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Junia V. Hable 130 East Locust Street Mechanicsburg, Pennsylvania 17055 2. Name and address of Defendant in the judgment: Name Address Junia V. Hable 130 East Locust Street Mechanicsburg, Pennsylvania 17055 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: File #69694 Page 1 Name Wells Fargo Bank, National Association Address 3476 Stateview Boulveard Fort Mill, South Carolina 29715 4. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff Herein Address 5. Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name None Address 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: Name Tenants /Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Address 130 East Locust Street Mechanicsburg, Pennsylvania 17055 -3840 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8' Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105 -8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 -1230 File #69694 Page 2 PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States 8. Name and address of Attorney of record: Name None PO BOX 280948 Harrisburg PA 17128 -0948 Clearance Support Department 281230 Harrisburg, PA 17128 -1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128 -0946 Attn: Sheriffs Sales c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108 -1754 U.S. Dept. of Justice, Rm 4400 950 Pennsylvania Avenue, NW Washington, DC 20530 U.S. Dept. of Justice, Rm 5111 950 Pennsylvania Avenue, NW Washington, DC 20530 Address File #69694 Page 3 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. f ! McCABE, WEISBERG & CONWAJ, P.C. DATE BY: [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Re: Wells Fargo Bank, N.A. v. Junia V. Hable. et al. Cumberland County; Number: 12 -7749 [ arc S. Wei s erg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire [ ] Jennifer L. Wunder, Esquire File #69694 Page 4 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, N.A. Plaintiff Junia V. Hable v. Defendant DATE: February 7, 2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 12 -7749 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Junia V. Hable PROPERTY: 130 East Locust Street, Mechanicsburg, Pennsylvania 17055 -3840 IMPROVEMENTS: Residential Dwelling JUDGMENT AMOUNT: $129,401.28 The above - captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on March 12, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the fling of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Check type of mail or service: Name and Address o1 Sender McCabe, Weisberg and Conway, P.C. • 123 S. Broad Si., Suite 2080 Philadelphia, PA 19109 ATTN: S. Gorman - 69694 DCertified 0 Recorded Delivery (International) ❑ COD 0 Registered 0 Delivery Confirmation 0 Return Receipt for Merchandise ❑ Express Mail ❑ Signature Confirmation 0Insures Jg .r•;'•: qi. tIN ...;*11.— ,� r _ , • �� 0. - r U.S. POSTAGE » PITNEY �� $ 019 FEB. BOWES 20° 07 2014 04,1•"7"1- ZIP 19109 0 2 000 `���� 1 YY 1377494 _ Line Article Number Postage 2 1 Wells Fargo Bank, N.A. Plaintiff v. Junia V. Hable Defendant Wells Fargo Bank, National Association 3476 Stateview Boulveard Fort Mill, South Carolina 29715 f�,. a > m ��q ■ i. 1 f 2 Tenants /Occupants 130 East Locust Street Mechanicsburg, Pennsylvania 17055 -3840 3 Tax Claim Bureau 1 Courthouse Square, Carlise, PA 17013 4 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 5 Commonwealth of Pennsylvania Inheritance Tax Office 110 North 8th Street Suite #204 Philadelphia, PA 19107 6 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 7 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O. Box 8486 - Harrisburg, PA 17105 -8486 t 8 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 -1230 9 PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128 -0948 i0 - Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg, PA 17128 -1230 ATTN: Sheriff's Sales 11 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 12 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17013 13 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bide. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 14 United States of America c/o United States Attorney for the 2010 -5387 District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108 -1754 15 United States of America c/o Attv General of the United States U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530 -0001 16 United States of America c/o Attv General of the United States U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530 -0001 Total Number of Pieces o Listed by Sender 16 Total Number of Pieces Received at Post Office Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY FILED-OFFi Ems. I: THE PROTHOt40 11`.4 204 P,PR 24 PM 2` 42 CU PE NI SYLVANI COUNTY tut OFFICE .FTHE Wells Fargo Bank, N.A. vs. Junia V Hable Case Number 2012 -7749 SHERIFF'S RETURN OF SERVICE 01/09/2014 11:18 AM - Deputy Ronald Hoover, 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 130 East Locust Street, Mechanicsburg - Borough, Mechanicsburg, PA 17055, Cumberland County. 01/09/2014 11:18 AM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be Kenneth Holzworth, son , who accepted as "Adult Person in Charge" for Junia V Hable at 130 E. Locust Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. 03/12/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on March 12, 2014 at 10:00 a.m. He sold the same for the sum of $ 70,000.00 to Attorney Karl Ledebohm, on behalf of McCabe, Weisberg and Conway, P.C., being the buyer in this execution, paid to the Sheriff the sum of $ 04/11/2014 Proposed Schedule Of Distribution Posted SHERIFF COST: $2,916.36 SO ANSWERS, April 24, 2014 c) C:ountvSLI S'ienf`. teleosoit, inc. RONR ANDERSON, SHERIFF W = 2d �,dE a4 /1 4 4011 3 o4 "9 3 On December 20, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 130 East Locust Street, Mechanicsburg, as Exhibit "A" filed with this writ co and by this Reference incorporated herein. Date: December 20, 2013 By: Real Estate Coordinator LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2012-7749 Civil Term Wells Fargo Bank, N.A. vs. Junia V. Hable Atty.: Marc Weisberg ALL THAT CERTAIN lot of ground situate on the South side of East Lo- cust Street in the Second Ward of the Borough of Mechanicsburg, Cumber- land County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, Reg. Sur., dated May 12, 1972, as follows: BEGINNING AT a point on the Southern line of Locust Street, said point being 332.4 feet East of the center line of S. Arch Street; thence along the Southern line of Locust Street North 77 degrees 45 minutes East 20 feet to a comer of property formerly of John House, now or formerly of Reuben E. Lutz; thence along said property South 12 degrees 45 minutes East 193 feet to a point on the Northern side of a public alley; thence along said alley South 77 degrees 45 minutes West 20 feet to a comer of property formerly of Edith Albright, now or formerly of Agnus G. Sowers; thence along said property, passing through the center of a concrete block partition wall of a double one story garage building and passing through the center wall of the two and one-half story double frame dwelling house erected on this and the lot adjacent thereto, North 12 degrees 45 minutes West 193 feet to the point and place of BEGINNING. HAVING THEREON ERECTED the Eastern one-half of a two and one-half story frame dwelling house and the Eastern one-half of a one story concrete block garage building, known and numbered as No. 130 East Locust Street, Mechanicsburg, Pennsylvania. UNDER AND SUBJECT, NEV- ERTHELESS, to any conditions, covenants, restrictions, reservations, easements and rights of way of record 38 or visible upon an inspection of the premises. 1130 East Locust Street, Mechan- icsburg, Pennsylvania 17055-3840. BEING the same premises which JUDITH I. SCHOLL, AN ADULT INDI- VIDUAL by deed dated July 27,2010 and recorded July 29,2010 in the office of the Recorder in and for Cum- berland County in Deed Instrument #201020706 and conveyed to Junia V. Hable, an adult individual, in fee. TAX MAP PARCEL NUMBER: 17- 23-0565- 168. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 24, January 31, and February 7, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. Lisa Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 7 day of February, 2014 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot -News Co. 2020 Technology Pkwy ° Suite 300 Mechanicsburg, PA 17050 Inquiries - 717 -255 -8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriot News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and /or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M ", Volume 14, Page 317. , Y2012 -7749 Civil erm !Wells Fargo Ban , N.A. Vs Junia V Hable Atty: Marc Weisberg ALL THAT CERTAIN lot of ground situate on the South side of East Locust Street in the Second Ward • of. the Borough of Mechanicsburg, Cumberland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Betz, Reg. Sur., dated May 12, 1972, as follows: BEGINNING AT a point on the Southern line of Locust Street, said point being 332.4 feet East of the center line of S. Arch Street; thence along the South m line of Locust Street North 77 degree-S-45 minutes East 20 feet to a comer of property formerly of John House. now nr This ad ran on the date(s) shown below: 01/19/14 01/26/14 02/02/14 Sworn to an subscribed before m his 18 day of February, 2014 A.D. Public COMMONWEALTH OF PENNSYLVANIA Holly ! Notarial Sea! Y ynn Warfel, Notary Public Washington Twp., Qauphin County My Commission Expires Dec. 12, 2016 ^+EMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Junia V Hable is the grantee the same having been sold to said grantee on the 12th day of March A.D., 202014, under and by virtue of a writ Execution issued on the 4th day of December, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 7749, at the suit of Wells Fargo Bank N A against Junia V Hable is duly recorded as Instrument Number 201408348. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ��f day of 4J , A.D. 62 ©/9 kig,1 ,0 ecorder of Deeds Record Deeds, Cumberland County, Carlisle, PA My Co ission Expires the First Monday of Jan. 2018