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Home My WebLink About13-0075McCABE, WEISBERG & 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 "~~ ~" r ~ CHRISTINE L. GRAHAM, ESQUIItE - ID #309480 ~~ ~• ~ ~ ~" ~ BRIAN T. LaMANNA, ESQUIRE - ID #310321 ~t"' ~ , JOSEPH F. RIGA, ESQUIRE - ID #57716 ~ ~ " ~' a ~~ 123 South Broad Street, Suite 1400 ~ ~~ ~. Z Philadelphia, Pennsylvania 19109 _~ ~ ~~ , (215) 790-1010 ~~ •• --~~~ -.c o, ..l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA C1VIL DNISION 3476 Stateview Blvd. ,~ 5 ~t'V~ Ft. Mills, SC 29715 NO.: ~ 3 Plaintiff, Brian K. Markwood 2240 Canterbury Drive, Mechanicsburg, PA 17055 Lisa K. Markwood 2240 Canterbury Drive, Mechanicsburg, PA 17055 Defendants. 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: 062-PA-V 3 ~~ ~.103.~~~ ~ i~ ~~~ I~oICx~ ~~~84~~ 1. The Plaintiff is Wells Fargo Bank, National Association, 3476 Stateview Blvd., SC 29715 (hereinafter "Plaintiff'). 2. The Defendants, Brian K. Markwood and Lisa K. Markwood, is an/are individuals whose last known address is 2240 Canterbury Drive, Mechanicsburg, Pennsylvania 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. 4. On or about October 31, 2011 Brian K. Markwood and Lisa K. Markwood, made, executed and delivered to Mortgage Electronic Registration Systems, Inc., as nominee for Fulton Bank, National Association, its successors and assigns a Mortgage in the original principal amount of $248,535.00 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 Book Instrument Number 201130528. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), 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 August 8, 2012, the mortgage was assigned to Mortgage Electronic Registration Systems, Inc., as nominee for Fulton Bank, National Association, its successors and assigns to Wells Fargo Bank N.A. which Assignment is recorded in the Office of the Recorder of Cumberland County in Mortgage Book Instrument Number 201223916. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 062-PA-V3 6. Brian K. Markwood and Lisa K. Markwood are/is the record and real owners of the aforesaid mortgaged premises. 7. Defendants are/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. As of 12/27/2012, the amount due and owing Plaintiff on the mortgage is as follows: Principal Interest Through 12/27/2012 Late Charges Property Inspections Escrow Advance TOTAL $ 246,462.26 $ 6,856.37 $ 223.41 $ 60.00 $ 2,981.33 $ 256,583.37 Plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff s attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 9. 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 91 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 Defendants, but reserves its right to do so in a separate legal action if such right exists. If Defendants have/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 $256,583.37, 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, W~ By: -- / [ ] TERRE ~ J. ABE, ESQ IRE [ ] MARC S. WEISBERG, ES IRE [ ]EDWARD D. CONWAY, ESQUIRE [ ]MARGARET GAIRO, ESQUIRE [ ]ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPNAK, ESQUIRE ]MARISA J. COHEN, ESQUIRE [ ]KEVIN T. MCQUAIL, ESQUIRE [ ]CHRISTINE L. GRAHAM, ESQUIRE [ ]BRIAN T. LAMANNA, ESQUIRE [JOSEPH F. RIGA, ESQUIRE z Dated: (~~~ , 20~ 062-PA-V 3 VERIFICATION Samir Erian, hereby states that li /she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, tha 1~/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 his er 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: 12/28/2012 086-PA-V2 Brian Markwood . • o l :. App # Min # NOTE M Uitlstate F1IA Cusc No. October 31, 2011 (Dote) 2240 CANTERBURY DRIVE ~ ~ MECHANICSBURG, PA 17055 (Prnpert~r Address) 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors an ss{gns. "Lender" means FULTON BANK, N.A. and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST in return for a loan received from Lender, Borrower promisors to pay the principal sum of Two Hundred Forty Eight Thousand Five Hundred Thirty Five And Zero/100 Dollars (U.S. $ 248 , 535.00 ), 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 rate of Four and one q u a r t e r percent ( 4.250 %) per year until the full amount of principal has bcx:n paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument th<st is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment ol'principal and interest to Lettdcr on tltc first day of each morttlt beginning on December O1. 2011 .Any principal and interest remaining on the first day of November, 2041 ,will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at ONE PENN SQUARE, LANCASTER, PA 17602 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U. S. $ 1.222.64 .This amount wilt 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 this Note for payment adjustments !fan allonge providing for payment adjustments is executed by Borrower together with this Notc, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [CNeck applicable box] ^Graduated Payment Allonge ^Growing Equity Allonge Other [specify] Y Fla Btl RdIB Nol9 VMP ~ WollBra Kluwer F{na~clal 9ervlcas VMP1R(1103).01 Paga 1 of 3 uiH~~~mii~i~i~~im~uu~ • o 5. BORROW ER' 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 month to the extent required by Lender and permitted by regulations of the Secretary. if Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 8. BORROWER'S FAILURE TO PAY (A) Late Charge far Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Notc, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent ( 4.000 %~) of the overdue amount of each payment. (B) Default if Borrower defaults by failing to pay in full arty monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance retraining due and all accrued interest. Lender may choose rat to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Notc, "Secretary" means the Secretary of Housing and Urban Dcveloplncnt or his or her designee. (C) Payment of Costs and Expenses If Lender has required imtnediatc payment in full, as described above, Lender may require Borrower to pay costs 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 disburserncttt at the same rate as the principal of this Notc. T. WAIVERS Borrower artd any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GfVING 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 Borrower at the property address above or at a different address if Borrower ]tas given Lender a notice of Borrower's different address, Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a rto[ice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Notc, each person is fully and personally obligated to keep all o1'the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser 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 one person signing this Note may be required to pay all of'the amounts owed under this Note. e NOIe VMP1R(11091~01 Kluwer Flnanclal 98rvicee Page 2 of 3 • BY SIGNING BELUW, Borrower accepts atld agrees to the terms and covenants contained in this Note. (Seal) AN K. MARKWOOD -Sorrower (Seal) -Borrower -(Seal ) -Borrower ~Si~u Origirrnl On/t-) ^ Refer to the attached Sil,~rrature addendum for additional parties and signatures. 'day to theQjde~ of_F~QQ„$~-NK N.A.-. Wifhout Ret~urse ~' N ~FICER (Seal) LI K. MARKW00 -Borrower A~ Pay to the Order of it out ecourse W t s Fargo B nk, NA Cott vTi~. wanson Assistant Vice President 023 VM' Pu Flood Rate Nota VMP1 R (1~ Wolfe®Kfuw er Flnanelel Services Page 3 of 3 • , .~,. ALL THAT CERTAIN piece, parcel or lot of land situate in Upper Allen Township, Cumberland County, Pennsylvania, and bounded and described as follows: BEGINNING at a point which is located on the Western right of way line of Canterbury Drive at the Southeastern corner of Lot No. 39; thence along the Northeastern boundary line of Lot No. 39, North 20 degrees 55 minutes 55 seconds West, for a distance of 158.85 feet, to a point which is located at the Northeastern corner of Lot No. 39; thence North 69 degrees 04 minutes 05 seconds East, for a distance of 85.00 feet, to a point which is located at the Northwestern corner of Lot No. 86; thence along the Southwestern boundary line of Lot NO. 86 South 20 degrees 55 minutes 55 seconds East, for a distance of 158.85 feet to a point which is located on the Western right of way line of Canterbury Drive at the Southwestern corner of Lot No. 86; thence along the Western right of way lie of Canterbury Drive, South 69 degrees 04 minutes 05 seconds West, for a distance of 85.00 feet, to a point and the place of BEGINNING. This piece, parcef or lot of land consists of approximately 13,500 square feet of land, has an address of 2240 Canterbury Drive, Mechanicsburg, Pennsylvania, and is known and numbered as Lot No. 40 on the Final Re-Subdivision Plan of Canterbury Estates Phase I, which is recorded in Cumberland Coun#y Plan Book,~4, Page 8. BEING further identified as Tax Parcel #42-29-2458-049. BEING the same premises which William M. Jordan and Phyllis Jordan, his wife, by their deed dated October 31, 2011 and intended to be recorded herewith, granted and convyeed unto Brian K. Markwood and Lisa K. Markwood, his wife, owners/mortgagors herein. ~8~`~' {201100154. PFD/201100154l36) FORM 1 Wells Fargo Bank, NA V S. Plaintiff Brian K. Markwood and Lisa. K. Markwood Defendants IN Tl.1E COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r n 3..'.. -~ ~ .-.e CIVII ~~ ~ .,i..,i" NOTICE OF RESIDENTIAL MORTGAGE DIVERSION PROGRAM e~ ~ ~. --C ~, r c7 FORECL~~ -~ You have been served with a foreclosure complaint that could cause you to lose your home. ~ '4~' .r~- x- ~~ USE -~ 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 MU5T ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM ~" """" ~~ ~ ~~ Date 69606 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: Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ^ No ^ Listing date: Price $ Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email: # of people on household: Yes^No^ Realtor Phone: State: Home: Office: Cell: Other: Zip: Mailing Address (if different): City: State: Zip: Phone Numbers: Home: _ Office: Cell: Other: Email: # of people on household: First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: How long? How long? Total Mortgage Payment Amount $ Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $__ Investments: $ $__ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Amount owed: Value: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles. boats. motorcvclesl: Year: Amount owed: Monthly Income Name of Employers: 1. Year: Year: Model Value: 2 3 Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money 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 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 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 Proof of any expected income for the last 45 days Copy of a current utility bill f Letter explaining reason for delinquency and any supporting documentation (hardship letter) f Listing agreement (if property is currently on the market) 3 2013 MAR 21 AM 11: 36 'UMBULAND COUNTY P J YL AIA 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 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,NA Cumberland County Plaintiff Court of Common Pleas V. 13-16 Number 1-�CIVIL Brian Markwood and Lisa Markwood Defendants PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure in the above-captioned matter. McCABE,WEISBERG AND CONWAY,P.C. BY: ( ]Terrence J.McCabe,Esquir 1 Marc S.Weisberg,Esquire [ ]Edward D.Conway,Esquire ]Margaret Gairo,Esquire ( ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]M isa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire Christme L.Graham,Esquire [ ]Brian T.LaManna,Esquire 4�v [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire OLIA `' �� Q [ 1 Joseph I.Foley,Esquire �N�a Attorneys for Plaintiff t 1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILE07-OF IOE Sheriff at I nt OF THE PRO THON0 Jody S Smith @ � Chief Deputy w 2013 MAR 26 AN 9: 34 �, : Richard W Stewart Solicitor OFFiCEOF kE$#4ERIFP CUMaERLAND COUNTY PEWYLVANIA Wells Fargo Bank, N.A. Case Number vs. 2013-75 Brian K Markwood (et al.) SHERIFF'S RETURN OF SERVICE 03/22/2013 08:19 PM-Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program&Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Lisa K Markwood, pursuant to Order of Court by"Posting"the premises located at 2240 Canterbury Dr., Upper Allen Twp., Mechanicsburg, PA 17055 with a true and correct copy according to law. RYAN BURGETT, SHERIFF COST: $44.46 SO ANSWERS, March 25, 2013 RON R ANDERSON, SHERIFF ici CounrySuite Sheriff,Teleosoft Inc. THE ILED-�C^F(i-gIC [la 1 HE PRO I�HONO AF"' Fr 11113 APP 15 AM It: 03 CUMBERLAND COUNTY PEIMYLVANIA 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 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,NA Cumberland County Plaintiff Court of Common Pleas V. 13-q-6 Number 1375 CIVIL Brian K. Markwood and Lisa K. Markwood Defendants AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF PHILADELPHIA The undersigned attorney being duly sworn according to law, deposes and says that the following is true and correct to the best of his/her knowledge and belief: 1. That he/she is counsel for the above-named Plaintiff; 2. That on April 9, 2013,per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Lisa Markwood by regular mail, certificate of mailing and certified mail,return receipt requested, addressed to his/her last-known address of 2240 Canterbury Drive, Mechanicsburg, Pennsylvania 17055. A true and correct copy of the letter and certified receipt, is attached hereto, made a part hereof, and marked as Exhibit "A". 3. That on March 22, 2013, per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Lisa Markwood, by posting the same at the mortgaged premises of 2240 Canterbury Drive, Mechanicsburg, Pennsylvania 17055. A true and correct copy of the Sheriff's Returns of Service indicating same is attached hereto, made a part hereof, and marked as Exhibit "B". McCABE,WEISBERCy AND CONWAY,P.C. SWORN AND SUBSCRIBED BY: [ ] Terrenc4ft McCabe,Esq. [ ]Marc S eisberg,Esq. BEFORE ME.THIS I DAY [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. l [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. OF r, l , 2013 [ ]Marisa J.Cohen,Esq. [ ]Kevin T. McQuail,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. NOTARY PUB [ ]Joseph I.Foley,Esq. Attorneys for Plaintiff COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL ANDREW SWITKAY,Notary Public City of Philadelphla,Phila. County Commission res March 15,2017 TERRENCE 1.McCABE LAW OFFICES SUITE 303 MARC S.WEISBERG McCABE,WEISBERG & CONWAY,P.C. 216 HADDON AVENUE EDWARD D.CONWAY WESTMONT,NJ 08108 MARGARET LAIRD (856)858.7080 LAURA H.G.O'SULLIVAN SUITE 1400 FAX(856)858.7020 USA L.WALLACE 123 SOUTH BROAD STREET JANET Z.CHARLTON SUITE 210' GAYL C.SPIVAK PHILADELPHIA,PA 19109 - 145 HUGUENOT STREET MARK GOLAB (215)790-1010 NEW ROCHELLE,NY 10801 ANDREW L.MARKOWITZ (914)-636.8900 MICHAEL T.CANTRELL FAX(215)790-1274 GENERAL FAX(914)636.8901 JOSEPH F.RIGA HEIDI R.SPIVAK SUITE 800 CAROL ROGERS COBB 312 MARSHALL AVENUE COLIN AARON LAUREL,MD 20707 DIANA C.THEOLOGOU (301)490.3361 MARISA J.COHEN FAX(301)4904568 MELISSA T�MP SAATO April 9,2013 Alm urvicing the District of Columbia BRIAN ANN E.SWARTZ SUITE 202 LEDEANNA D.ADAMS 4021 UNIVERSITY DRIVE MATTHEW E.RUSSELL FAIRFAX,VA 22030 NATALIE GIRAIAO (866)656-0379 ERIN M.BRADY DIANE BRADSHAW SUITE 100 CHARLES A.HIGGS 30 BUXTON FARMS ROAD LAURA T.CURRY STAMFORD,CT 06905 ANTOINETTE N.MOORE (203)992-8200 KEVIN T.McQUA1L FAX:(855)425.1979 ALEXANDRA T.GARCIA STACYANN B(1LLEN SUITE 130 JONATHAN ELEFANT DELAWARE CORPORATE CENTER I LAURA L.LATTA ONE RIGHTER PARKWAY ABBY K.MOYNIHAN WILMINGTON,DELAWARE 19803 CHRISTINE L.GRAHAM (302)409-3520 SHEERA G.ENGRISSEI FAX 855425.1980 NANCY TOSSON JOSE 0.HASBUN JONATHAN POLLACK RICHARD J.SUZOR JR. LUCAS M.ANDERSON JOHN M.GHERL)NE JEFF WINSTON DANIELFANASELLE WILLIAM D.JENNINGS JOSEPH I.PLEY KYLE J.MOULDING JOHN T.PICCINNINI JON GASIOR JOSEPH C.COLEMAN LILIAN W.MUNGAI STEPHANIE MARIE ASOUS CELME P.DERKRIKORIAN Lisa K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 Re: Wells Fargo Bank,NA v.Brian K. Markwood and Lisa K.Markwood Cumberland County;CCP; Number 1375 CIVIL Dear Lisa K.Markwood: Enclosed please find a true and correct copy of Complaint in Mortgage Foreclosure,along with a copy of the signed Order dated March 12,2013,the original of which has been filed against you in regard to the above- captioned matter. Very truly yours, Diana Metobo Legal Assistant for McCabe,Weisberg and Conway,P.C. SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7012 3050 0002 0795 2577 , RETURN RECEIPT REQUESTED ,�xh ibit A This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. d ° 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 � Q BRIAN T.LAMANNA,ESQUIRE-ID#310321 -0Z ANN E. SWARTZ,ESQUIRE-ID#201926 rnCo t_ r --•- JOSEPH F.RIGA,ESQUIRE-ID#57716 r JOSEPH I.FOLEY,ESQUIRE-ID#314675A~ , CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 P— c 123 South Broad Street,Suite 1400 n �* Philadelphia,Pennsylvania 19109 �c '2 -' C C. (215 790-1010 � s Wells Fargo Bank,NA CUMBERLAND COUNTY -C Plaintiff COURT OF COMMON PLEAS �< V. Brian K.Markwood and Lisa K.Markwood Number 13 75 CIVIL Defendants ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants,Brian K.Markwood and Lisa K. Markwood, in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure,and assess damages as follows: Principal $ 256,583.37 Interest from 12/28/12 to 06/21/13 $ 0.00 Total $ 256,583.37 McCABE,WEISB �N C ,P.C. BY: [ ]Terrenc cCab sq. [ ]Marc S. Weisberg,Esq. [ ]Edward D.Con y,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 L Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for lain iff Date: i6'12r /_3 AND NOW,this day of 40e 2013,Judgment is entered in favor of Plaintiff,Wells Fargo Bank,NA,and against Defendants,Brian K.Markwood and Lisa K.Markwood,in rem only and not in personam,and damages are assessed in the amount of$256,583.37,plus interest and costs. 5dp13 pTH BY TH ROT. ONOTA (�'# 10,1I7 at'goag0 e 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 GA1RO,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,NA CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13 75 CIVIL Brian K.Markwood and Lisa K.Markwood Defendants 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 Defendants,Brian K.Markwood and Lisa K.Markwood, are 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,etseq.;and that the Defendants,Brian K. Markwood and Lisa K.Markwood,are over eighteen(18)years of age,and reside as follows: Brian K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 Lisa K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 McCABE,WEISBERG A SWORN AND SUBSCRIBED BY: BEFORE ME THIS °Z1 S DAY [ ]Terrence J. c a e,Es [ ]Marc S. Weisberg,Esq. OF IQ l [ ]Edward D.Conway q. [ ]Margaret Gairo,Esq. ^2, ,2013 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L. Graham,Esq. Arian T.LaManna, Esq. NOTARY PU IC [ ]Ann E. Swartz,Esq. [ ] Joseph F.Riga,Esq. [ ]OF pE J Joseph 1.Foley,Esq. [ ] Celine P. DerKrikorian,Esq. gYLVA- CpMMOWyyEI►LTti Attorneys for PPain�fiff NOTARIAL SEAL Date: l 3 MAIA KUWICK,Notary Public City of Philadelphia,Phila.County M Commission Ex ices Ma 10 2017 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,NA COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Number 13 75 CIVIL Brian K.Markwood and Lisa K.Markwood Defendants AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS 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 addresses of the Defendants are: Brian K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 Lisa K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 McCABE,WEISBER CO A P.0 SWORN AND SUBSCRIBED Sir BY: BEFORE ME THIS 9_1 DAY [ ]Terrence J. cCabe, [ ]Marc S. Weisberg,Esq. [ ]Edward D.Conwa q. [ ]Margaret Gairo,Esq. OF y�,�_ ,2013 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ]Kevin T. McQuail, Esq. �✓ [ ] Christine L. Graham,Esq. an T. LaManna,Esq. NOTAR PUB C Ann E. Swartz Es [ ] q. ] Joseph F.Riga,Esq. COMMONWEALM OF PENNSYLVANIA [ ]Joseph 1.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. NOTARIAL SEAL Attorneys for 1 'ntiff MAIA KUSNICK,Notary Public Date: �P-t //3 City of Philadel is,Phila.County Commission Tres Ma 10,217 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-1D# 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,NA CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13 75 CIVIL Brian K.Markwood and Lisa K.Markwood Defendants 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 Defendants that judgment would be entered against them within ten(10)days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit"A". McCABE,WEISBERG .. SWORN AND SUBSCRIBED BY- BEFORE ME THIS 2 I DAY [ ]Terrence a sq. [ ]Marc S. Weisberg,Esq. [ ]Edward D. Conway,Esq. [ ]Margaret Gairo,:Esq. OF y ylk ,2013 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. LY /� ` [ J Marisa J.Cohen,Esq. [ ']Kevin T.McQuai1,Esq. 1 AS 444-- [ ]Christine L.Graham,Esq. [Brian T.LaManna,Esq. NOTA PUBqt Ann E. Swartz,Esq. [ ]Joseph F. Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. COMMONWEALtN OF hENNIYI-VGA Attorneys for Plai tiff NNARIAL SEAL Date: MAIA KUSHICK,Notary Pub�D217 City of Philadelphia,Phila.Cou ! M Commission Ex fires Ma 10, 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. McCABE,WEI RG A BY: [ ]Terrence . Xab sq. [ ]Marc S.Weisberg,Esq. [ ]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. [ rian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga, Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. Attorneys for Plain iff Date: 4eeE-z�/3 Wells Fargo Bank,NA v.Brian K.Markwood and Lisa K.Markwood Cumberland County;Number: 13 75 CIVIL OFFICE OF THE PROTIIONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle,Pennsylvania 1701.3 Curt Long Prothonotary June 1.0, 20 13 To: Brian K. Markwood 2240 Canterbury Drive Mechanicsburg, Pennsylvania 17055 Wells Fargo Bank,NA Cumberland County VS. Court of Common Pleas Brian K. Markwood Lisa K. Markwood Number 13 75 CIVIL 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 SF.ENCUENTRA EN ESTADO DE RLBELDIA POR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECE:NCIA. FSCRITA, YA SEA wRtTING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PFRSONALMFNTE O POR ABOGADO Y POR NO HABER RADICADO POR CLAIMS SET FORTH AGAINST YOU: UNLESS YOU ACT WITIIIN TEN(10) F.SCRITO CON ESTE TRIBUNAL SUS DIi:17NSAS 11 OBJECIONES A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA AGAINSTYOUWITHOUTAHEARING AND YOU MAY LOSE YOUR PROPERTY AC,CION DERIDA DENTRO DE DIET.(10)DIAS DE LA FECHA DE ESTA 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 CORTFi U OIR PREUBA ALGUNA, DICTAR DO NOT HAVE A LAWYER,GO TO OR TFL..EPHONE TI IE OFFICE SET FORTH SENTENCIA EN SU CONTRA Y USTED PODRIA PERDFR BIFNES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS 1MPORTANTES. FIIRING A LAWYER. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO IF YOU CANNOT AFFORD TOIIIRFALAWYL"•R,TI Its OFFICE MAYBE ABLE INMEDIATAMEN'TE. Si USTED NO TIENE A UN ABOGADO, VA A O TOPROVIDEYOUWITH INFORMATION ABOUTAGENCIES THAT MAY OFFER TELEFONF.A LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUF..DF.. LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR. CON INFORMATION ACERCA DE F..MPLEAR A UN ABOGADO. Cumberland County Liar Association SI USTED NO PUEDF PROPORCIONA R PARA EMPLEAR UN ABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPA7.. DE PROPORCIONARLO CON Carlisle,Pennsylvania 17013 INFORMAC16N ACERCA DE LAS AGENCIAS QUE PUEDEN OFRFCFR LOS (800)990-9108 SF,RVICIOS LEGALES A PERSONAS ELEGBLES EN UN HONORARIO RFDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle,Penns>430iia 17013 wA0).99.0 1 McCABE,WEI .. GA AY;P.C. BY: [ ]Terrence cC� e,F uire [ ]Marc S. Weisberg,.Esquire Edward I). CoAw4squire [ ]Margaret Gairo,Esquire [ ]Andrew L. MiKowitz,Esquire Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire [ ] even T.McQuail,Esquire [ ]Christine L. Graham,Esquire [*e Brian T. LaManna, Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F. Riga,Esquire [ ]Joseph].Foley,Esquire Attorneys for Plaintiff gdz OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle,Pennsylvania 1.7013 Curt Long Prothonotary Tune 10, 2013 To: Lisa K. Markwood 2240 Canterbury Drive Mechanicsburg, Pennsylvania 17055 Wells Fargo Bank,NA Cumberland County vs. Court of Common Pleas Brian K. Markwood .Lisa K. Markwood Number 13 75 CIVIL, 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 LISTED SE ENCUFNTRA EN ESTADO DE REBELDIA POR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA FSCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES Olt OBJECTIONS TO THE PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10) FSCRITO CON ESTE TRIBUNAL SIDS DLFL'NSAS 11 OBJECIO'NES A LAS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED RECL..AMOS FORMULADOS Er,N CONTRA SUYO. At,NO TOMAR LA AGAINST YOU WI TIIOUTA HEARING AND YOU MAYLOSFYOUR.PROPERTY ACCION DEBIDADENTRO DE DIF/.,(10)DIAS DE LA FECHA DEESTA OR OTHER IMPORTANT RIGHTS. NOTIFICACION, FL TRIBUNAL. PODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU COMPARECER USTF.,D FN CORTE U OIR.PRFUBA ALGUNA, DICTAR DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH SF.,NTF.NCIA EN SU CONTRA Y USTED F'ODRIA PERDERBIENF,S U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DF.RF,CHOS IMPORTANTES. HIRING A LAWYER. LISTED LE DEBE TOMAR ESTE PAPF..L A SU ABOGADO IF YOU CANNOTAFFORDTO HIRE A LAWYER,Tins OFFICE MAY BE ABLE INMEDIATAMENTE. Si USTED NO TFENE,A UN ABOGADO, VA A O TOPROVIDEYOU WITHINFORMATION ABOUTAGENCIES TI IATMAYOFFER TELEFONEA LA OFICINA EXPUSO ABAJO, I STA OFICINA 1.0 PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR CON INFORMACION ACERCA DF FMPLEAR A UN ABOGADO. Cumberland County Bar Association SI USTED NO PUEDL'•'PROPORCIONAR PARA EMPLEAR UN ABOGADO, 32 South Bedford Street ESrA OFICINA PUEDE SER CAP,v DR PROPORCIONARLA CON Carlisle,Pennsylvania 17013 INFORMACIONACF..RCADF LAS AGENCIASQUFPUE-'DENOFRECERLOS (800)990-9108 SERVICIOS LEGALES A PERSONAS ELFGIBLES EN UN HONORAR.10 REDUCIDO NI NINGON IIONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 990-9108 McCARE,WE RG A ) CONW BY: [ ]T rene e, re [ ]Marc S.Weisberg, Esquire [ ] d Conw quire [ ]Margaret Gairo, Esquire [ ]Andrew L.Mar witz,Esquire [ ]Fleidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Kevin T..McQuail,Esquire [ ]Christine L.Graham,Esquire [<Brian'T'. LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph 1.Foley,Esquire Attorneys for Plaintiff gdz Department of Defense Manpower Data Center Results as of:Jun-21-201309:05:39 SCRA 3.0 Status Report Purstian.t to Sery ceimembers Civil Relief Act. Last Name: MARKWOOD First Name: BRIAN Middle Name: Active Duty Status As Of: Jun-21-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA,rr _ Nom NA t This response reflects'the individuals'active duty status based on the Active Duty Status Data Left Active Duty Within 367 Days of Active Duty Status Dale Active Duty Start Date Active Duty End Date Status Sorvlce Component No i NA NA NA This response reflects Where the Individual left active dutystatusttwithln 367 days preceding the Active Duty Status Date The Member or HWHer 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 ti / NA NA NA 4.`_. �, rNo This response reflects whether the individual or his/her unit has r'eeelved early notificatloh 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. ) , _ 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 at 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(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: 4301 L974006AOEO Department of Defense Manpower Data Center Results as of:Jun-21-2013 09:03:53 SCRA 3.0 Statas Report Pursuant to Sery c+members Civil Relief Acct Last Name: MARKWOOD First Name: LISA Middle Name: Active Duty Status As Of: Jun-21-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ,* ' - - Not NA This response reflects the individuals'active duty status based on the Active Duty Status Date r Left Active Duty Within 3`67 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Statue Service Component NA -_ti] NA-��r Z.: ' 7 -No" i NA 3 This response reflects Where th8In4ildual left active,duty status within 367 days preceding the Active Duty Status Date The Member or HWHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order NotiAcation Start Date Order Notification End Date Status Service Component NA NA ��.. �NO NA This response reflects whether the IndMdual or hlsme(unit tias 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. 3! 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/fagipis/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(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: N3600964U06AF70 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Lisa K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 Wells Fargo Bank,NA COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Brian K.Markwood and Lisa K.Markwood No. 13 75 CIVIL Defendants 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 Ob 3q Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway, P.C.at(215)790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 1701.3 Prothonotary To: Brian K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 Wells Fargo Bank,NA COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Brian K.Markwood and Lisa K.Markwood No. 13 75 CIVIL Defendants NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Protho ary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway, P.C. at(215)790-1010. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff of Jody S Smith 'IN4 Chief Deputy fix. Richard W Stewart Solicitor OFFICE OF T14E$RCERMF Wells Fargo Bank,N.A. vs. Case Number Brian K Markwood(et al.) 2013-75 SHERIFF'S RETURN OF SERVICE 03/22/2013 08:19 PM-Deputy Ryan Burgett,being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program&Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Lisa K Markwood,pursuant to Order of Court by"Posting"the premises located at 2240 Canterbury Dr., Upper Allen Twp,,Mechanicsburg, PA 17055 with a true and correct copy according to law. RYAN BURGETT,bS-ftM( SHERIFF COST:$44,46 SO ANSWERS, March 25,2013 RONW R ANDERSON,SHERIFF CaunlySuile Gh*60,Teleosoll,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FILE NO.:2013-0075 CIVIL Term Wells Fargo Bank,N.A. V. AMOUNT DUE: $256,583.37 rl Brian K. Markwood and Lisa K.Markwood INTEREST: from 06/22/13 M rn m _.._ $10,840.26 at$42.18 ' Cn r"' ATTY'S COMM.: > CO .<CD rt CD-q COSTS: q — ?>C ..D 4L- TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs upon the following described property of the defendant(s) 2240 Canterbury Drive Mechanicsburg Pennsylvania 17055 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt, interest and costs,as above, directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession,custody or control of the said gamishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: BY: ® [ ]Terrence J McCabe,Esq. [ ]Marc S.Weisberg,Esq. al$ P 1, A`rTy [ ]Edward D.Conway,Esq. LA'Margaret Gairo,Esq. (09.oa C BF [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. 44. P Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. . 10S.115 Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. It• 15 �� Joseph F.Riga,Es f'(p.50 a_.�.. ___. [ ]Ann E. Swartz,Esq. [ ] P g � q• U —50 Joseph 1.Foley,Esq. [ ] Celine P. DerKrikorian,Esq. Attorneys for Plaintiff Address:123 S.Broad Street, Suite 1400 //�� Philadelphia,PA 19109 4a-as b ue l D Attorney for:Plaintiff 4' iq$151 Telephone:(215)790 1010 P-*605800 Supreme Court ID No. R.E 0-xi+ d 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 C, KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 MCD C/) r BRIAN T.LaMANNA,ESQUIRE-ID#310321rnv � ANN E. SWARTZ,ESQUIRE-ID#201926 C/)r C JOSEPH F.RIGA,ESQUIRE-ID#57716 '<2� ' JOSEPH I.FOLEY,ESQUIRE-ID#314675 , CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 }' 215 790-101.0 - =K� Wells Fargo Bank,N.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 2013-0075 CIVIL Brian K. Markwood and Lisa K.Markwood Defendants 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: 2240 Canterbury Drive,Mechanicsburg,Pennsylvania 17055,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 Owners or Reputed Owners Name Address Brian K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 Lisa K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 and/or 688 Market Street Apt.2 Lemoyne,Pennsylvania 17043 2. Name and address of Defendants in the judgment: Name Address Brian K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 Lisa K.Markwood 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 and/or 688 Market Street Apt.2 Lemoyne,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 Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 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 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 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 8`h 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: n"-a�tJLUAI' [ ] T rrenc .McCabe,Esq. [ ] Marc S.Weisberg,Esq. DATE [ ] Edward .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 LEGAL DESCRIPTION ALL THAT CERTAIN piece,parcel or lot of land situate in Upper Allen Township, Cumberland County, Pennsylvania, and bounded and described as follows: BEGINNING at a point which is located on the Western right of way line of Canterbury Drive at the Southeastern corner of Lot No. 39;thence along the Northeastern boundary line of Lot No. 39,North 20 degrees 55 minutes 55 seconds West, for a distance of 158.85 feet,to a point which is located at the Northeastern corner of Lot No.39;thence North 69 degrees 04 minutes 05 seconds East,for a distance of 85.00 feet,to a point which is located at the Northwestern corner of Lot No. 86;thence along the Southwestern boundary line of Lot No. 86 South 20 degrees 55 minutes 55 seconds East,for a distance of 158.85 feet to a point which is located on the Western right of way line of Canterbury Drive at the Southwestern corner of Lot No. 86;thence along the Western right of way line of Canterbury Drive, South 69 degrees 04 minutes 05 seconds West, for a distance of 85.00 feet,to a point and the place of BEGINNING. This piece,parcel or lot of land consists of approximately 13,500 square feet of land,has an address of 2240 Canterbury Drive,Mechanicsburg,Pennsylvania, and is known and numbered as Lot No.40 on the Final Re- Subdivision Plan of Canterbury Estates Phase I,which is recorded in Cumberland County Plan Book 54,Page 8. BEING further identified as Tax Parcel#42-29-2458-049 2240 Canterbury Drive,Mechanicsburg,Pennsylvania 17055. BEING the same premises which WILLIAM M.JORDAN AND PHYLLIS JORDAN,HIS WIFE by deed dated October 31,2011 and recorded November 3,2011 in the office of the Recorder in and for Cumberland County in Deed Book Instrument#201130527 granted and conveyed to Brian K.Markwood and Lisa K.Markwood,his wife,in fee. 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#3071.69 C) c CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 = w - BRIAN T. LaMANNA,ESQUIRE-ID#310321 rTlcv rt/) Fri ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#31.4675 m 4 C CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 _ Philadelphia,Pennsylvania 191.09 (215)790-1010 ---! CIVIL ACTION LAW Wells Fargo Bank,N.A. COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Brian K. Markwood and Lisa K. Markwood Number 2013-0075 CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Brian K. Markwood Lisa K.Markwood 2240 Canterbury Drive 2240 Canterbury Drive Mechanicsburg,Pennsylvania 17055 Mechanicsburg,Pennsylvania 17055 Your house(real estate)at 2240 Canterbury Drive,Mechanicsburg,Pennsylvania 17055 is scheduled to be sold at Sheriffs Sale on March 5,2014 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$256,583.37 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 piece,parcel or lot of land situate in Upper Allen Township,Cumberland County, Pennsylvania,and bounded and described as follows: BEGINNING at a point which is located on the Western right of way line of Canterbury Drive at the Southeastern corner of Lot No. 39;thence along the Northeastern boundary line of Lot No. 39,North 20 degrees 55 minutes 55 seconds West,for a distance of 158.85 feet,to a point which is located at the Northeastern corner of Lot No.39;thence North 69 degrees 04 minutes 05 seconds East,for a distance of 85.00 feet,to a point which is located at the Northwestern corner of Lot No. 86;thence along the Southwestern boundary line of Lot No. 86 South 20 degrees 55 minutes 55 seconds East,for a distance of 158.85 feet to a point which is located on the Western right of way line of Canterbury Drive at the Southwestern corner of Lot No. 86;thence along the Western right of way line of Canterbury Drive, South 69 degrees 04 minutes 05 seconds West, for a distance of 85.00 feet,to a point and the place of BEGINNING. This piece,parcel or lot of land consists of approximately 13,500 square feet of land,has an address of 2240 Canterbury Drive,Mechanicsburg,Pennsylvania,and is known and numbered as Lot No.40 on the Final Re- Subdivision Plan of Canterbury Estates Phase I,which is recorded in Cumberland County Plan Book 54,Page 8. BEING further identified as Tax Parcel#42-29-2458-049 2240 Canterbury Drive,Mechanicsburg,Pennsylvania 17055: BEING the same premises which WILLIAM M. JORDAN AND PHYLLIS JORDAN,HIS WIFE by.deed dated October 31,2011 and recorded November 3,2011 in the office of the Recorder in and for Cumberland County in Deed Book Instrument#201130527 granted and conveyed to Brian K. Markwood and Lisa K.Markwood,his wife,in fee. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-0075 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 BRIAN K. MARKWOOD and LISA K. MARKWOOD (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: $256,583.37 L.L.: $.50 Interest from 6/22/13 @$42.18 -- $10,840.26 Atty's Comm: Due Prothy: $2.25 Atty Paid: $273.96 Other Costs: Plaintiff Paid: Date: 9/18/13 David D.Buell, tary (Seal) By: Deputy REQUESTING PARTY: Name: MARGARET GAIRO,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.34419 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, NA Plaintiff v. Lisa Markwood and Brian Markwood Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 2013 -0075 CIVIL AFFIDAVIT OF SERVICE C) L- If; ■ ( 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 Sheriff's Sale of Real Property was served on all pertinent lienholder(s) as set forth m 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 McCABE, WEISBERG & C,ONWAY, P.C. BEFORE ME THIS ieWL DAY BY:,_ 4 aP i C. OF r41 , 2014 NOTARY P LIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEAN R. JAC002, 1R., Notary Public City of Philadelphia, Phila. County My Commission Expires June 27, 2017 [ ] 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 [ ]'1c 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, NA Plaintiff v. Lisa Markwood and Brian Markwood Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 2013 -0075 CIVIL 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 2240 Canterbury Drive, Mechanicsburg, Pennsylvania 17055, 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 Owners or Reputed Owners Name Address Brian K. Markwood 2240 Canterbury Drive Mechanicsburg, Pennsylvania 17055 Lisa K. Markwood 2240 Canterbury Drive Mechanicsburg, Pennsylvania 17055 2. Name and address of Defendants in the judgment: Name Address Lisa Markwood 2240 Canterbury Drive Mechanicsburg, Pennsylvania 17055 File #69606 Page 1 Brian Markwood 2240 Canterbury Drive 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 Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 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 Address 2240 Canterbury Drive Mechanicsburg, Pennsylvania 17055 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th 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 File #69606 Page 2 PA Department of Revenue 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 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 -1230 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 8. Name and address of Attorney of record: Name Address None File 469606 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 unworn falsification to authorities. ILD p 1 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 Re: Wells Fargo Bank, NA v. Lisa Markwood. et al. Cumberland County; Number: 2013 -0075 CIVIL [ arc 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 File #69606 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, NA Plaintiff v. Lisa Markwood and Brian Markwood Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 2013 -0075 CIVIL DATE: February 7, 2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Lisa Markwood and Brian Markwood PROPERTY: 2240 Canterbury Drive, Mechanicsburg, Pennsylvania 17055 IMPROVEMENTS: Residential Dwelling JUDGMENT AMOUNT: $256,583.37 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 filing 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. Name and Address of Sender McCabe, Weisberg and Conway, P.C. 123 S. Broad St., Suite 2080 Philadelphia, PA 19109 ATTN: S. Gorman - 69606 Check type of mail or service: O Certified 0 Recorded Delivery (International) 0 COD 0 Registered 0 Delivery Confirmation 0 Return Receipt for Merchandise 0 Express Mail 0 Signature Confirmation 0 Insured ...V U.S. POSTAGE» PITNEY BOWES (0 �itr7403,f• ZIP 191010 Q AA nn0 Line Article Number Postage 0 7 1 0001377494 FEB 07 2014 s F 1 Wells Fargo Bank, NA Plaintiff V. Lisa Markwood and Brian Markwood Defendants Tenants /Occupants 2240 Canterbury Drive Mechanicsburg, Pennsylvania 17055 \AND T? a ! a. F t:7 B RI �'p \'s ll, n1 2 Tax Claim Bureau 1 Courthouse Square, Carlise, PA 17013 `� Y91i0 :: 3 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 4 Commonwealth of Pennsylvania Inheritance Tax Office 110 North 8th Street Suite #204 Philadelphia, PA 19107 5 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 6 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105 -8486 7 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 -1230 . 8 ' PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128 -0948 9 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg, PA 17128 -1230 ATTN: Sheriff's Sales 10 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 11 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17013 12 • 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 13 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 14 United States of America c/o Attv General of the United States U.S. Dent of Justice. Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530 -0001 15 United States of America c/o Attv General of the United States U.S. Dent of Justice. Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530 -0001 Total Number of Pieces Listed by Sender 15 Total Number of Pieces Received at Post Office 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, NA Plaintiff v. Lisa Markwood and Brian Markwood Defendants Attorneys for Plaintiff Cumberland County Court of Common Pleas Number 2013 -0075 CIVIL AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF PHILADELPHIA The undersigned attorney, being duly sworn according to law, deposes and says that the following is true and correct to the best of his/her knowledge and belief: 1. That he /she is counsel for the above -named Plaintiff; 2. That on February 10, 2014, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant, Lisa Markwood, by regular mail, certificate of mailing and certified mail, return receipt requested, addressed to her last -known address of 2240 Canterbury Drive, Mechanicsburg, Pennsylvania 17055. A true and correct copy of the letter and certified receipt, is attached hereto, made a part hereof, and marked as Exhibit "A ". 3. That on January 13, 2014, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Notice of Sheriffs Sale of Real Property upon the Defendant, Lisa Markwood, by posting the same at the mortgaged premises of 2240 Canterbury Drive, Mechanicsburg, Pennsylvania 17055. A true and correct copy of the Sheriffs Returns of Service indicating same is attached hereto, made a part hereof, and marked as Exhibit "13 ". SWORN AND SUBSCRIBED BEFORE ME THIS ) DAY OF , 2014 .R �95 NOTARY PUBLI McCABE, WEISBERG AND CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esq. [•Marc S. Weisberg, Esq. [ ] Edward D. Conway, Esq. [ ] Margaret Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Esq. [ ] Marisa J. Cohen, 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 COMMONWEAL -1 OP PENNSYLVANIA NOTARIAL SEAL DEAN R. JACG�S,. ;R., Notary Public City of Philadelphia, Phila. County MY Commission Expires June 27, 2017 Wells Fargo Bank, NA v. FILED OF THE PRO 2013HAR 13 AN 9: r: CUMBERLAND CbUN 1Y PENNSYLVANIA Cumberland County Plaintiff Court of Common Pleas Number 1375 CIVIL Lisa Markwood and Brian Markwood Defendants ORDER AND NOW, this of / , 2013, the Plaintiff is granted leave to serve all process in this mortgage foreclosure action upon the Defendant, Lisa Markwood, by regular mail and by certified mail, return receipt requested, to his/her last known address of 2240 Canterbury Dr., Mechanicsburg, Pennsylvania 17055, and by posting the mortgaged premises of 2240 Canterbury Drive, Mechanicsburg, Pennsylvania 17055. BY THE COURT: Ke!..1.114/1- 61- J. EXHIBIT A r1 IT' L •? ru m _a O 0 0 0 0 rR 0 .r U. Postal Services,, CERTIFIED MAIL., RECEIPT 04mestic Maii Only; No insurance Coverage Provided) For delivery information visit our website:et t! Postage Certified Fee Return Receipt Fee (Endorsement Required) Resttleted Delivery Fee (Endorsement Required) Total Postage 8 Fee • 't re 5.0, le ,-4 6r .. min, XlA !C .- n L PS Form 3800.'3augtjia 266.6"1:.1..:-. � it See;tiever3'eFior insirucrioi,. I ^ Name and Address of Sender McCabe, Weisberg and Conway, P.C. 123 S. Broad St., Suite 1400 Philadelphia, PA 19109 Attn: Richard Daugherty Check type of mail or service: ❑ Certified 0 Recorded Delivery (international) o COD 0 Registered 0 Delivery Confirmation o Express Mail o Insured 0 Return Receipt for Merchandise 0 Signature Confirmation U S POSTAGE jy PITNEY BOWES ZIP 02 ivq $ 001.200 0001377494FEB 10 2014 Line Article Number Addressee Name, Street and PO Address - Postage wrrm A �,� a SH Fee RD Fee RR Fee 1 Wells Fargo Bank, N.A. `V. Brian K. Markwood and Lisa K. Markwood 69606 Lisa K. Markwood 2240 Canterbury Drive Mechanicsburg, Pennsylvania 17055 .: !, ' '-- �' r =- ;,. y wr 2 t :7"—� ,. 3 4 _ _ • 5 6 7 8 9 10 Total Number of Pieces Listed by Sender Total Number of Pieces Received at Post Office Postmaster, Per (Name of employee) The AID declaration el" value is ranched on all domestic and international registered mail, The nn<innw indemnity payable nonnegotiable documents under Express Mail doautnd reconstruction insurance is S500 per piece subject to additional timitatiens Ins, or damages io a single catastrophic occurrent The maximum indemnity pazbk on E,presoMail memha,dic irmtrans expo, Nail scnice merchandise is asaiiabie for up to S5 000 to some but not all camuies The maximum indemnity payable road Sa Domrauc.lfoil Marva/ 5000 591? and 5911 for limitations of cos crag,. on insured and COD mall 5a larernunonn) .imitatiooS of enrage on international mad Spam) Im dlingehargs apply only to Standard_ .tail (A) and Standard Moil (5) of for for the nconnngion for multipk pieces is 5300. but optional is S 25 ono for registered Vail Vanua! ::xis PS Form 3877 August 2000 Complete by Typewriter, ink. or Ball Point Pen EXHIBIT B , Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Welis Fargo Bank, N.A. '— Brian K Markwood (et al.) Case Number 2013-75 SHERIFF'S RETURN OF SERVICE 01/13/2014 02:21 PM Deputy William Cline, sworn accor inghmlaw.aenxaddhw requested Re l Estate Writ, Notice and Description in the above titled action, upon the within named Defendarit, to wit: Lisa K [Na,icwood.purauent to Order of Court by "Posting" the premises located at 2240 Canterbury Dr., Upper Allen Twp., Mechanicsburg, PA 17055, Cumberland County with a true and correct copy according to law. 01/13/2014 02:21 PM - Deputy WiOlam Cline, beirig duly sworn according to Iaw, 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 th rt located at 2240 Canterbury Drive, Upper Alieri - Township, Mechanicsburg, PA 17055, Cumberland County. 01/27/2014 06:52 PM Deputy Valerie Weary, being dul sworn according 10 Iaw, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Brian K Markwood at 2240 Canterbury Drive, Upper Allen, W1achanicmburg, PA 17056. Cumberland County. . SHERIFF COST: $964.21 C� 1 �ANSVVERS. January 29, 2014 (c) CounlySurte Sheriff, Teleosorlinc, rc.Y .-RONINN R ANDERSON, SHERIFF Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE T $.}.q;F.riF'F t 1LE0-0Ff- 10E iV THE PROTHONOTARY 2B14MAY -I tM10:53 CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Brian K Markwood (et al.) Case Number 2013-75 SHERIFF'S RETURN OF SERVICE 01/13/2014 02:21 PM - 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 2240 Canterbury Drive, Upper Allen - Township, Mechanicsburg, PA 17055, Cumberland County. 01/13/2014 02:21 PM - Deputy William Cline, 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: Lisa K Markwood, pursuant to Order of Court by "Posting" the premises located at 2240 Canterbury Dr., Upper Allen Twp., Mechanicsburg, PA 17055, Cumberland County with a true and correct copy according to law. 01/27/2014 06:52 PM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Brian K Markwood at 2240 Canterbury Drive, Upper Allen, 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 $ 214,000.00 to Kenneth Offidani, on behalf of Benchmarq Holdings, LLC, being the buyer in this execution, paid to the Sheriff the sum of $ 04/11/2014 Proposed Schedule Of Distribution Posted, all parties notified. SHERIFF COST: $5,176.16 SO ANSWERS, April 24, 2014 RONNY R ANDERSON, SHERIFF c) CountySu:ie S:'terlff, •rete) - ft, yr 06 fiee .s a C ---1.1-,40f. 9 7/J 3o.5"�y�� On November 19, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Upper Allen Township, Cumberland County, PA, Known and numbered as, 2240 Canterbury Drive, Mechanicsburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. !iQ M lL C - M Date: November 19, 2013 CL w C._) C.1 co LL. CD �JJ 11.1 (:1-_- " V) ()Li 4-4 By: Real Estate Coordinator LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2013-75 Civil Term Wells Fargo Bank, N.A. Brian K. Markwood Lisa K. Markwood Atty.: Terrance McCabe ALL THAT CERTAIN piece, parcel or lot of land situate in Upper Allen Township, :Cumberland County, Pennsylvania being known as 2240 Canterbury Drive, Mechanicsburg, •Pennsylvania 17055. BEING the same premises which WILLIAM M. JORDAN AND PHYLLIS JORDAN, HIS WIFE by deed dated October 31, 2011 and recorded No- vember 3,2011 in the office of the Recorder in and for Cumberland County in Deed Book Instrument #201130527 granted and conveyed to Brian K. Markwood and Lisa K. Markwood, his wife,in fee. TAX MAP PARCEL NUMBER 42- 29-2458-049. THE IMPROVEMENTS THEREON ARE: Residential Dwelling. REAL DEBT: $256,583.37. SEIZED AND TAKEN IN EXECU- TION AS THE PROPERTY OF: BRIAN K. MARKWOOD AND LISA K. MARK - WOOD. 60 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, Editor L 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. 2,920 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriot 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 Mlllef, 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 Countyof Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2013-75 Civil Term Wells Fargo Bank, N.A. Vs Brian K Markwood Lisa K Markwood Atty: Terrance McCabe ALL THAT CERTAIN piece, parcel i or lot of land situate in Upper Allen Township, Cumberland County, Pennsylvania being known as 2240 Canterbury Drive, Mechanicsburg, Pennsylvania 17055. BEING the same premises which WILLIAM M. Swor• o! d subscribed befor JORDAN AND PHYLLIS JORDAN, HIS WIFE by deed dated October 31, 2011 and recorded November 3,2011 in the office of the Recorder in and for Cumberland County in Deed Book Instrument #201130527 granted and conveyed to. Brian K. Markwood and Lisa K. Markwood, his wife,in fee. TAX MAP PARCEL NUMBER 42- 29-2458-049 THE IMPROVEMENTS THEREON ARE: Residential Dwelling REAL DEBT: $256,583.37 SEIZED AND TAKEN IN EXECUTION AS THE PROPERTY OF: BRIAN K. MARKWOOD AND LISA K. MARKWOOD This ad ran on the date(s) shown below: 01/19/14 01/26/14 02/02/14 is 18 day of February, 2014 A.D. otary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp,, Dauphin County My CAmmla�ta bpirrs cc. 12, 2016 MEMER, OEfi gi Ntt, 3g!0` ? ' 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 Benchmarq Holdings LLC is the grantee the same having been sold to said grantee on the 12th day of March A.D., 2014, under and by virtue of a writ Execution issued on the 18th day of September, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 0075, at the suit of Wells Fargo Bank against Brian K & Lisa K Markwood is duly recorded as Instrument Number 201408811. IN TESTIMONY WHEREOF, I have hereunto set my hand S1 - and seal of said office this / cru( , A.D. a0 ( day of Kailit,(t° Recorder of De ds Mcarderof Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan. 2018