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Home My WebLink About13-0244~~~3- a~ ~-~-~ e~m NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800)990-9108 File #: 302674 r',A '~l ~ `~ rI:JT~~~~'~p~,~~Y f~r~ ~`~~~~ ~~~~ r~ ~ aux ~~ ~,A rr PHELAN HALLINAN & SCHMIEG, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD CIVIL DIVISION FORT MILL, SC 29715 f / Plaintiff, NO.: ~~ - ~yy vs. CHRISTINE MARTINO,IN HER CAPACITY AS CO-ADMINISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH 2 LOGANS RUN ENOLA, PA 17025-0845 PAMELA ANGELOZZI, IN HER CAPACITY AS CO-ADMINISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH 305 FRANKLIN STREET, STE. 102 NAZARETH, PA 18064-2943 CABBIE KRAH, IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH 22 PRINCE STREET, APT 2 NANTICOKE, PA 18634-2141 062-PA-V 3 ~IUII 0 a~~.~~3. ~s~d a e~.~ a~ S •UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER EDWARD G. JONF,S, DECEASED 508 COLONY ROAD CAMP HILL, PA 17011-2009 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER LUCILLE KRAH, DECEASED 508 COLONY ROAD CAMP HILL, PA 1 70 1 1-2009 Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes WELLS FARGO BANK, N.A., by its attorneys, Phelan Hallinan & Schmieg, LLP and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is WELLS FARGO BANK, N.A., 3476 STATEVIEW BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff'). 2. The Defendant, CHRISTINE MARTINO, IN HER CAPACITY AS CO- ADMINISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH, is an individual whose last known address is 2 LOGANS RUN, ENOLA, PA 17025-1845. 3. The Defendant, PAMELA ANGELOZZI, IN HER CAPACITY AS CO- ADMINISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH, is an individual whose last known address is 305 FRANKLIN ST, STE 102, NAZARETH, PA 18064-2943. 4. The Defendant, CABBIE KRAH, IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH, is an individual whose last known address is 22 PRINCE ST, APT 2, NANTICOKE, 062-PA-V3 PA 18634-2141. 5. The Defendants, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER EDWARD G. JONES, DECEASED and UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER LUCILLE M. KRAH, DECEASED, have a last known address of 508 COLONY ROAD, CAMP HILL, PA 17011-2009. 6. 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. 7. On or about August 20, 2005, LUCILLE M. KRAH and EDWARD G. JONES made, executed and delivered to WELLS FARGO BANK, N.A. a Mortgage in the original principal amount of $164,305.00 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 Book 1923, Page 4770. The Mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 8. Plaintiff is the current Mortgagee. 9. Mortgagor EDWARD G. JONES died on January 3, 2012, and CHRISTINE MARTINO and PAMELA ANGELOZZI were appointed Co-Administrators of his estate. Letters of Administration were granted to them on January 19, 2012 by the Register of Wills of Cumberland County, No. 21 12-0071. Decedent's surviving heirs at law and next-of--kin are CHRISTINE MARTINO and PAMELA ANGELOZZI. 10. Mortgagor LUCILLE M. KRAH died on December 11, 2005 and upon information and belief, her surviving heirs are WILLIAM J. KRAH, III, CABBIE KRAH, 062-PA-V3 CHRISTINE MARTINO and PAMELA ANGELOZZI. 11. Plaintiff s representative contacted the Register of Wills of Cumberland County and was informed that no estate has been raised on behalf of the decedent mortgagor, LUCILLE M. KRAH. 12. By executed waiver, WILLIAM J. KRAH, III waived his right to be named as a defendant. in the foreclosure action. Said waiver is attached as Exhibit. "C". 13. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due March 1, 2012. 14. As of December 10, 2012 the amount due and owing Plaintiff on the mortgage is as follows: Principal Balance $ 149,532.88 Interest 02/01/2012 Through 12/10/2012 $ 8,018.64 Late Charges $ 151.74 Property Inspections $ 105.00 Escrow Deficit $ 1,155.07 TOTAL $ 158,963.33 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. 15. 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 Defendant(s). 062-PA-V3 16. Plaintiff does not hold the named Defendants, CHRISTINE MARTINO, PAMELA ANGELOZZI or CABBIE KRAH, personally liable on this cause of action. This action is being brought to foreclose the interest of the said Defendants in the aforesaid real estate only, and the Defendants have been named in accordance with the requirements of Pa R.C.P. 1144(a)(2) and 20 Pa.C.S.A. § 301(b). 17. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $ 158,963.33 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ~ ~ ~ ~~3 By: Date: !Well Esq., Id. No.309519 for aintiff ~.. ~..'~~ ~ 062-PA-V3 Exhibit "A" NOTE At7fiUaT 31, ZOOS (Dstel lcityJ istaul saa caz~ortx aoAD, ~I7aI,, PA x~oxx IPr aaar~s) 1. BORROWER'S PROMISE TO PAY In return for a loan that I have roceived, 1 promise to pay U.S. ~ ""*"*x64, 305.00 (this amount is called "Principal"), plus interest, to the order of the Lender. The Lrnder is 9tELL3 PA'ROt3 tsA1iE, 3t. A, I will make all payments under this Note in ETte form of cash. check or money order. I understand that the Lender may transfer this Note. The Leader or anyone who takes this Note by transfer and who is entitled to rncaive payments tinder this Note is called the "Note Holder." 2. Il1T1'EREST Interest will be chazged on unpaid principal unfit the full aaauat of Principal has been paid. I will pay interest at a yearly rate of 6.250 ~, The interest rate required by this Section 2 is the rate 1 will pay both before and after any default des~ibed in Section 6(B} of this Note. 3. PAYMENTS (A) 'lime and Place of Paymemts 1 will pay principal and interest by making a payment every tmnRh. l will make my taonthly payment on the rIJtST day of each month beginning onOCTOSSR 01, 2005 . 1 will make these payments every month until t have: paid all of the principal and ituetest and any other charges described below that 1 may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be died to interest before Principal. lf, on BtilPTtt~ER 02, 2035 , I still awry amounts under this Nare, l will pay those amounts in full on that date, which is called the "Maturity Date.' 1 will make my monthly paymatts atMiLL6 sAitQO H011~ 1t;DATti11~0E, P.O. B07C 10304, DES t!lDINES, IA 5030ti0304 or at a different place if requited by the Note Holder. (B) Aawuat of Monthly Paym~s My monthly paytttettt will be in the amount of U.S. $ •*x, 011.65 4. BORROWER'S RIGHT' TO PREPAX I have the right to make payments of Principal at any time before they are due. A paytnent of Principal only is known as a "Prepayment." What T make a Pt~epaytttem, I will tell the Note Holder in writing that l am doing so. 1 may tat designate a payment m a Prepayment if 1 have not made all the mamthly paytneats due tinder the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. 'lYte Note Holder will use my Ptepaytnents to reduce the atttotsttt of Principal that I owe under this Note. However, the Note Holder may apply my Prepaymau to the accnted and unpaid inierex on the Prepayment amotmt, before applying my Prepaytent to reduce the Principa! amount of the Note. If 1 make a partial Prepayment. there wilt be ao changes in the due date or in the amount of my monthly paytt>ent unless the Note Holder agrees in writing to those dtattges. Mt1LTI5TATE FIXF.O RATE NOTE-Single Family-rynni~ MaslF~ddltr Mee UNIrORM INSTRUMENT -t3N iooo6t Form 3200 1101 VMP MORTGAGE FORMS - i0001s21.72i1 ~~ Pape 1 013 INtWn S. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in ootuxction with this loan exeood the permitted limits. then: (a) any such hart Charge shall be reduced by the amount necessary to reduce the charge to the permittod limit; and (b) arty sums already collected from me which exceeded permitted limits will be refunded to rtta. The Note Holder rosy choose to mate this refund by reducing the Principal 1 owe under this Note ar by tnaldng a direct payment to toe. If a refund reduces Principal, the redaction will be treated as a partial Prepayment. 6. BORROWER'S FAl[LURE'I'O PAY AS REQU1ll2ED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any mothly paymem by the std of 15 calendar days after the date it is due, [will pay a late charge to the Note Holder. The arttouM of the charge will be 5.000 46 of my overdue payment of principal and iterest, i will pay this late charge promptly but oNy ante on each late paytrrent. (B) Defaati If I do trot pay the full amount of each monthly payment on the date it is due, I wilt be in default. (C) Notice of Defauk If 1 am in default, the Note Holder may send me a written notice telling me that if 1 do not pay the overdue amount by a certain date, the Note Holder may require the to pay imtncdiately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date trust be at least 30 days after the date on which the notice is rttaitod to me or delivered by other rtteatrs. (D) No Waiver $y Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay intrnediatety in full as described above, the Note Holder will still have tl-e right to do so if 1 am in default at a later time. (E) Payment of Note Hohirr's Costs and E:ptn~s ]f the Note Holder hss required the to pay immediately in full as described above, the Nott: Holder will have the right to be paid back by me for all of its costs and expenses in enforoing this Note to the extent not prohibitai by applicable law, Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that roust be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any entice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Secxion 3(A} above or at a different address if 1 am given a notice of that differern address. 8. OBLIGATIONS OF PERSONS UNDEI{ THIS NOTE [f more than one person signs this Note, each person is fully aM persotutlly obligated to reap all of the pt+osrtiaes made in This Note, including the promise to pay the ful! amount owed. Any person who is a guarantor. wrety or ettdorsa of this Note is also obligated to do these things. Arty person who fates over these obligations, including the obligations of a gttatantor, surety or endorser of this Nox, is also obligated to keep all of the promises trade in this Note. The Note Holder may eaforce its rights under this Noce against each persatt individually or against all of us together. This means that any one of us tray be requited. to pay all of the amoutus owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presemtnent and Notice of Dishonor. `Preserutttertt' ttteans the right to require the Note Holder to dettrattd payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. form 3200 1/07 t1N PODS) Paps 2 0l 3 ~it tl O INnals: ",/1l 10. UNIFORM SECURED NUTS This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under This Note, a Mortgage, Deed of Trust, or Security Deed {the "Security Ittstrrrtttertt'), dated the same date as this Note. protects the Note Holder from possible losses which might r+esulr if 1 do trot keep the promises which I make in this Nate. That Stxurity Instrument describes how artd under what conditions 1 tray be requited to make immediate paymeru in full of all amounts 1 owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any ltttertxt in the Property is sold or transferred (or if Borrower is Trot a natural persat and a beneficial inttasat in Harrower is sold ar transferred) without Lender's prior written oonsern, lender rosy require immediate payment in full of ail sutras stxured by this Security Itrstturnent. However, this option shall rat be euxcised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Letrder shall give Borrower notice of at~deration. The notice shall provide a period of not less tlrar 30 days from the date the notice is given in acoottiarsce with Suction IS within which Borrower must pay all sums secured by this Security laurument. If Borrower fails to pay those sums prior to the expiration of this period, Lender may invoke arry rcarmdics permitted by this Security Instrument without further notice or demand on Horr+ow~er. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. {Seal) S>3N1lRD Q. .TCBES -Borrower (Seal) LUC LLB M. ICit71li -Borniwer {Seel) (Seal) -Borrower -Burrower (Seal) {Seal} -Borrower •Borrawer ._ (Seal) -Borrower (~) •Barrt~wer (.SiRR UrYSirrnl ~) ®~ tftlt 100691 Page 3 of 3 FOrfr! 3200 1/01 Exhibit "B" LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the township of Hampden in the county of Cumberland and commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the southern line of Colony road which paint is at the dividing line between lots nos. 158 and 159 on plan of lots hereinafter mentioned; thence south suety (60) degrees twenty-five (25) minutes west and along the dividing line between lots nos. 158 and 159 on plan of lots hereinafter mentioned, a distance of one hundred three (103) feet to a point on the rear lot line of lot no. 147 on plan of lots hereinafter mentioned; thence south twenty-nine (29) degrees thirty five (35) minutes east along parts of the rear lot lines of lots nos. 147 and 76 on plan of lots hereinafter mentioned, a distance of ninety (90) feet to a point at the dividing line between lots nos. 159 and 78 on plan of lots hereinafter mentioned; thence north sixty (60) degrees twenty-five (25) minutes east and along the dividing line between lots nos. 159 and 78 on plan of lots hereinafter, mentioned, a distance of one hundred three (103) feet to a point on the southern line of Colony road; thence north twenty-nine (29) degrees thirty-five (35) minutes west along the southern line of Colony road a distance of ninety (90) feet to a point, the point and place of beginning. APN: 201848332 PROPERTY ADDRESS: 508 COLONY ROAD, CAMP HILL, PA 17011-2009 PARCEL # 10-20-1848-332 File #: 302674 Exhibit "C" WAIVER BY ~t OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE AC'T~ON I, WILLIAM J. KRAH, III, Heir of LUCILLE M. KRAH, Deceased. hereby acknowledge that I may have ao owrusshdp interest in the property located a# SO$ COLO1dY ROAD, CAMP HILL, PA 17011-2009, in accordance with Sedion 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Cade [20 Pa C.S.A. Section 301(b)]. I do hereby waive my right to be named as a dcseadarut in a fm+eclosure action as provided by Pa.R.G.P.1141 et seq., which maybemst<tuted by WELLS FARCiO BANK, N:A., involving abid property, which property was owned by the daxdent at the time of her death. I hereby consent to the foreclosure adios, without say fiuther notice of said adios, including but not limited to the 3heriE's sale, sad and that any merest I may have in the mortgaged premises will be diveat+ed upon completion of the foreclosure action. I do retain any sad all right I may have under Pennsylvania law to reinstate or otherwise payoffthe underlying debt or to make any claim for excess proceeds generated by the SheritY's sale of the mortgage premises. Date: ~iJ~~ V~~1fLI,IAM J. KRAH, Heir ofLUCn.i.F M. KRAFT, Docoased VERIFICATION Denise Goldston, hereby states that he -she Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that hey authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his~r~nformation 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: Denise Goldston Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: O 1 /09/2013 086-PA-V2 File #302674 FORM 1 WELLS FARGO BANK, N.A. [N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. CHRISTINE MARTINO, IN HER CAPACITY AS CO-ADMINISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH PAMELA ANGELOZZI, IN HER CAPACITY AS CO-ADMINISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH f, ~ ~.; _~ --~ r -. c.._ ~~ ~ - ~~+ -~~ . -;~ -C - ~- ..~. ~ ~ ; ; ~ ~; ~ ~ -- 3 [` ~ y ~ , ~~ © ~. ~~..; ~ ~ w ~ ~ CABBIE KRAH, IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER EDWARD G. JONES, DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PF,RSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER LUCILLE KRAH, DECEASED Defendant(s) ~ -~~I~. wil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and 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 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 arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully Date Alli n F. ells, Esquire .Alto r Plaintiff 2~~'~' 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 counseling agency. Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale`? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Nurnbers: Email: # of people in household: Mailing Address: City: Phone Numbers: Home: Cell: State:__Zip: Office: Other: Office: Other: State: Zip: Email: # of people in household: How long? _ First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: State: _ Zip: Yes ^ No ^ Listing date: Price: $ Realtor Phone: Yes ^ No ^ Home: Cell: How long? Included Taxes & Insurance: Primary Reason for Default: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #l: Model: _ Year: Amount owed: Value: Automobile #2: Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net 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 Mort a e Food 2" Mort a e Utilities Car Pa ment s) Condo/Nei h. Fees Auto Insurance Med. (not covered) Auto fuel/re airs Other ro a ment Install. Loan Pa ment Cable TV Child Su ort/Alim. S endin Mone 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: 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 delinquency? Yes ^ No ^ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: Phone: I/We. ,authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Uwe am/are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) U 2013 MAR 26 AN 10: } , C '113ERL.A Np ' tWSYL V IANT�' Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 Attorney for Plaintiff WELLS FARGO BANK,N.A. COURT OF COMMON PLEAS CIVIL DIVISION vs. NO. 13-244-CIVIL CHRISTINE MARTINO, in her capacity as Co- Administratrix and Heir of the Estate of EDWARD CUMBERLAND COUNTY G. JONES ET AL. MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, WELLS FARGO BANK, N.A., respectfully requests that this Honorable Court enter an ORDER granting Plaintiff's Motion for Service Pursuant to Special Order of Court in the above captioned matter and in support thereof avers the following: 1. The property located at 508 COLONY ROAD, CAMP HILL, PA 17011-2009 is owned by LUCILLE M. KRAH and EDWARD G. JONES, as tenants in common by virtue of a deed dated 08/19/2004 and recorded 09/08/2004 in Book 265, Page 674 of the CUMBERLAND County Recorder of Deeds Office. 302674 2. On August 20, 2005, LUCILLE M. KRAH and EDWARD G. JONES made, executed, and delivered a mortgage upon the premises at 508 COLONY ROAD, CAMP HILL, PA 17011-2009. 3. The loan is in default as payments due March 1, 2012 and each month thereafter are due and unpaid. 4. Real Owner EDWARD G. JONES died on January 3, 2012, and CHRISTINE MARTINO and PAMELA ANGELOZZI were appointed Co-Administrators of his estate. Letters of Administration were granted to on January 19, 2012 by the Register of Wills of CUMBERLAND County, No. 21-12-0071. Decedent's surviving heir(s) at law and next-of-kin are CHRISTINE MARTINO and PAMELA ANGELOZZI. A copy of the estate documents, which have been redacted to remove personal identifying information, are attached hereto, made part hereof, and marked as Exhibit "A". 5. Plaintiff performed a Good Faith Investigation in an attempt to identify and locate the heirs of EDWARD G. JONES. Plaintiffs investigation was unable to locate any additional heirs. Attached hereto, marked as Exhibit "B" is a true and correct copy of Plaintiffs Affidavit of Good Faith Investigation. 6. Real Owner LUCILLE M. KR.AH died on December 11, 2005. 7. Plaintiffs representative contacted the Register of Wills of CUMBERLAND County and was informed that no estate has been raised on behalf of the decedent mortgagor. 302674 8. Plaintiff performed a Good Faith Investigation in an attempt to identify and locate the heirs of LUCILLE M. KRAH. Plaintiff's Investigation located an Obituary for LUCILLE M. KRAH. The Obituary states the deceased borrower is survived by four children DR. WILLIAM KRAH, III, CARRIE ANN KRAH, CHRISTINE MARTINO and PAMELA ANGELOZZI Attached hereto, marked as Exhibit "C" is a true and correct copy of Plaintiffs Affidavit of Good Faith Investigation. 9. Upon information and belief, the surviving heirs at law and next-of-kin of LUCILLE M. KRAH are CARRIE ANN KRAH, CHRISTINE MARTINO, PAMELA ANGELOZZI and WILLIAM J. KRAH, III. 10. By letter dated August 30, 2012, Plaintiff contacted CARRIE ANN KRAH, WILLIAM J. KRAH, III, CHRISTINE MARTINO and PAMELA ANGELOZZI to inform them of the foreclosure action. Plaintiff attached with its letter a Waiver by Heir of Right to be Named as a Defendant. Plaintiff also requested information regarding the heirs of LUCILLE M. KRAH. Attached hereto,marked as Exhibit "D" is a true and correct copy of Plaintiffs letter. 11. By executed waiver(s), WILLIAM J. KRAH, III waived his right to be named as a defendant in the foreclosure action. Said waiver(s) is attached as Exhibit" E ". 12. On January 15, 2013, Plaintiff filed an Action in Mortgage Foreclosure. Attached hereto, marked as Exhibit "F" is a true and correct copy of the Complaint in Mortgage Foreclosure. 302674 13. Plaintiff named as a defendant, the unknown heirs, successors, assigns, and all persons, firms or associations claiming right, title or interest from or under the decedent record owner in order to ensure that all possible parties with an interest in said property are notified of these proceedings and in order to ensure that good and marketable title to said property is conveyed by any future sheriffs auction. See Exhibit "F." 14. Because there may be parties with an interest in the mortgaged premises that are unknown, Plaintiff must effectuate service through Special Order of Court. 15. In compliance with Cumberland County Local Rule 208.3(a)(2), Plaintiff avers that choose: "No Judge has previously entered a ruling in this case". 16. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to the Defendants on February 27, 2013, and requested the Defendants' concurrence. Plaintiff did not receive any response from the Defendants. A true and correct copy of Plaintiffs letter pursuant to Local Rule 208.3(9) and postmarked certificate of mailing is attached hereto, made part hereof, and marked as Exhibit "G." WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint, and all future pleadings,by regular mail,by posting of the mortgaged premises, and by publication. Respectfully submitted, PHELAN H INAN, LLP Date: / /3 By: J!yffn M. Kolesnik, Esq., Id. No. 308877 ttorney for Plaintiff 302674 Phelan Hallinan,LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 Attorney for Plaintiff WELLS FARGO BANK,N.A. COURT OF COMMON PLEAS CIVIL DIVISION VS. NO. 13-244-CIVIL CHRISTINE MARTINO, in her capacity as Co- Administratrix and Heir of the Estate of EDWARD CUMBERLAND COUNTY G. JONES ET AL. MEMORANDUM OF LAW According to Pa.R.Civ.P. 430(a), a plaintiff may petition the court to provide an alternative to personal service if the plaintiff cannot serve a party personally. The rule requires the affidavit presented in support of the motion for alternative service to state "the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why personal service cannot be made." Pa.R.Civ.P. 430 (a). The purpose of this procedure is to provide proof that a good faith effort has been made to effect service under normal methods. Only after such proof has been offered is the Court authorized to direct another method of substitute service. Deer Park Lumber, Inc. v. Major, 384 Pa.Super. 625,559 A.2d 941, 944 (1988), appeal denied, 525 Pa. 582, 575 A.2d 113 (1990). 302674 Plaintiff has attached a report to its Motion, which sets forth the nature and extent of the investigation that has been made to determine the whereabouts of the heirs and assigns and the reason that such service cannot be made. Attached hereto, marked as Exhibit`B & C"is a copy of the Affidavit of Good Faith Investigation. A deceased mortgagor need not be named as a party in a foreclosure action. Federal Land Bank of Baltimore v. King, 294 Pa.86, 143 A. 500 (1928). The personal representative, heir or devisee of a deceased mortgagor, if known, (unless released from liability) must be named as a defendant in a mortgage foreclosure action. Moyer v. Diehl, 130 Pa.Super. 115, 196 A. 575 (1938). In the instant action, Plaintiff has appropriately named the unknown heirs, successors, assigns and all persons, firms, and associations claiming right title or interest from or under the decedent mortgagor as a defendant in order to convey clear and marketable title after a foreclosure sheriffs sale. Title companies customarily require foreclosing mortgagees to name the unknown parties in order to assure that any potential party with an interest in the mortgaged premises has an opportunity to defend the foreclosure. Finally, Plaintiff is seeking only to enforce an in rem judgment through the foreclosure of the mortgaged premises and is not pursuing a deficiency judgment in this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant the requested relief. PHELA LLINAN, LLP Date: j �� By: M. Kolesnik, Esq., Id. No. 308877 ttorney for Plaintiff 302674 Phelan Hallinan,LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 FAX#: 215-568-7616 March 19,2013 CHRISTINE MARTINO 2 LOGANS RUN ENOLA, PA 17025-1845 PAMELA ANGELOZZI 305 FRANKLIN ST, STE 102 NAZARETH,PA 18064-2943 CARRIE ANN KRAH 22 PRINCE ST,APT 2 NANTICOKE,PA 18634-2141 UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER EDWARD G. JONES,DECEASED 508 COLONY ROAD CAMP HILL,PA 17011-2009 UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER LUCILLE M.KRAH,DECEASED 508 COLONY ROAD CAMP HILL,PA 17011-2009 RE: WELLS FARGO BANK,N.A.vs.CHRISTINE MARTINO,in her capacity as Co- Administratria and Heir of the Estate of EDWARD G.JONES ET AL. Civil Docket No. 13-244-CIVEL Dear Defendant: Enclosed please find a copy of my proposed Motion for Special Service of the Complaint and all future pleadings and Order. In accordance with CUMBERLAND County Local Rule 208.3(9) I am seeking your concurrence with the requested relief. Please respond to me within one week,by {Date). Should you have any further questions or concerns,please feel free to contact me. Otherwise,please be guided accordingly. Sincerely, SEAN MCLAUGHLIN Legal Assistant PHS#302674/SNM Exhibit "A" Full Spectrum Services Document Retrieval PA Order Date: ure 25, 2012 Doc. Type: Estate Documents Notes:P?ease pull the full estaze documents for Edward G. Jones - Estate fi;.le # 2012-00071 FRS n; FRS1054280 P`fS FILE #: 302674 LOAN #: 0058853821 Defendant: EDWARD G. JONES (DECEASED) aah: XXX-xx-S 0? LUCILLE M. KRA:; (DECEASED) SSN: Address: 506 COLONY ROAD CAMP HILL, PA 17011-2009 counLV: Cumberland Resat PETITION FOR GRANT OF LETTERS REGISTER OF WILLS OF CUMBERLAND COUNTY,PENNSYLVANIA Petitioner(s) named below, who istare 18 years of age or older, aWly(ies) for Letters as specified below, and in support thereof aver(s)the following and respectfully request(s)the grant of Letters in the appropriate form: :s Inkrinaftu Name:�WARD•G.JONES File Vs: ?r mwa: (Assigned by Red ter) a/k/a; allele: Social Smalrity No: Date of Death: JANUARY 3.2012 Age at death:65 Decedent was domiciled at death in CUMBERLAND County,PF.NNSYi.VANiA (State)with his/her last principal residence at 508 Colony Road.Came Hill.Hampden Trnmship.Cttmbalaad Co>"ty,PA street addreat,Poet once sad Ztp Code City,Towas tip or Borough Coauty Decedent died at Foot Chase Cancer Center Street address,Post Once sad Zlp Code City,Towaship or Bomeo cmey State Estimate of value of decedi ttfs property at death: If dowlcAW in PassuWmaia............................ All personal property S 25.000.00 If ner doeaklidttt Is Paruasylpanla. ............... ..... Personal property in Pennsylvania S If net demkl4d In PemuDdvan la. ....................... Personal property in County S Valve of real estate in Pevensyl wtnia......................................................... S 2S f1M.M TOTAL ESTIMATED VALUE.... S 50.000 00 Real estate in Pennsylvania situated at 508 Colony Road.CA=Hill.lLattiglen Township Cumberlited Qglty,PA (Anach additional skew,lfnecessary.) Street address,Post OAke sad Zip Code City,Towadelp or Bseaagh Ceuaty © A. Petition f Pqr altar to and Grant of Letters Testam"Marx, Petitioners)aver(s)ha/dw they is/are the Execator(s)named In the last Will of the Decedent,dated and Codicil(s) thereto dated State relevant eireuaaaames(egg.reaancizdon,dmA of"Waaor,ere) Except as follows:after the execution ofthe instrument(s)offered for probate Decadent did not marry,was not divorced,was not a party to a pending divorce proceeding wherein the grounds for divorce had been established as defined in 23 Pa.C.S.§3323(g),and did not have a child born or adopted;and Decadent was neither the victim of a killing nor ever adjudicated an incapacitated person, 0 NO EXCEPTIONS Q EXCEPTIONS m B. Petttdon fsr Grant of Letters of Administration (ifappiicable) c.r.a.,d.b.n.,d.b.n.c.ta..pendentelite,daranteabserttia,duranteminMtate If Administration,eta or db.n.ata,enter date of Will in Section A above and colwkte Rst of heirs. Except as follows: Decedent was not a party to a pending divorce proceeding wherein the grounds for divorce had been establisbed as defined in 23 Pa.C.S.§3323(g)and was neither the victim of a killing nor ever adjudicated an incapacitated person. NO EXCEPTIONS ®EXCEPTIONS Petitioner(s),aftera proper search hasihave ascertained that Decedent left no Will and was survived by the following spouse(ifany)and heirs(attach additional sheets,if necessary): Name Relado"ship, Address Christine Martino Daughter 2 Logans Run,Enola,PA 17025 Pamela Angelozzi Daughter 305 Franklin Street,Apt. 102,Nazaroth,PA 18064 c� Form RW-02 rev.10/11 011 P949 1 of-2 T. C: Oath of Personal Representative COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF C'� � } `" . ` Petitioner(j)Printed Name Polid"s(a Printed Address (77M" .ao ru, Pamcia An ozzi The PedtWner(s)above-named sacat(s)or affirm(s)the statements in the faopins Petition an We and correct to the beat of the Imowkdya and belief of Petitionet(s)and that,as Personal Reprosemad (s)of the the Pedtionet(a) ' well and truly administer the estate WAM Sworn to or firmed turd subscribed before Date me this 031 day of ,v-1 A_ D.ce By: Date r the Reem", pate BOND Required: 0 YES G NO re the Register of Wills. FEES: !1 Please eater my appearance by my signature below: Loners.......... . .... .... ..I S l/ Attorney Signature: { �}Short Certificate(s)...... ( }Renunciation(s)...... ... ( }Codicil(s). .... ........ ( }Affidavit(,)... . ..... ... Bond... .. .. ... .. .. . ..... .... Printed Name: Ti M.F' Commission. . .. .. .. .. ........ Supreme Court Othcr ID Number: 76048 ... Firm Name: McNees Wallace&Nuriek LLC ... Address: Inn Pine Su=P.QBox 1166 Rjarric utrg,pA 1710$=1166 - - �� Phone: 717-237-5394 Automation Fee. ..... ........ . _1a ?= Fax: 212:Z&1691 JCS Fee. .. .... .. ... . . ... .... S" Email: entn ry TOTAL.. . .. .. ...... ....... . S $, )3?,M DECREE OF THE REGISTER �7 Estate of EDWARD G.JONL5 File No: a/k/a: AND NOW, L�1 .in consideration of the foregoing Petition, satisfactory proof having n pre ted before me,Tf IS DECREED#hat Letters of Administration are hereby granted to Christina Martino and Pamela Ammiozzi in the above estate and(if applicable)that the insttvment(s)dated described in the Petition be admitted to probate and filed rd a the last VIM(and Codicil of Decedent. inter of W1l a Farm a W-01 rev,)a/11/2011 C 1 Page 2 of 2 McNees Wallace & Nurick «C 100 Pine Street+ PO Box 1166 + Harrisburg,PA 17108-1166 Linda M.Eatw*nan,Pa.C.P. Estate ftw Tel- 717.232,8000•Fax: 717.237.5300 DDared �° irect Dial:71 7-237-5210 Dired Fax:717.260.1640 leap ".corn January 17, 2012 Register of Wills VIA FEDERAL INPRESS Cumberland Cqq'unty Courthouse 1 Courthouse$quare Room 102 Carlisle, PA 17b13 RE: Estate of Edward G.Jones Probate Documents Ladies and Gentlemen: Our Firm is counsel to Christine Martino and Pamela Angelozzi,the daughters of Edward G. Jones,who passed away on Janu*3, 2012. Enclosed are the following documents for appointing the daughters as Administrators: • Petition for Grant of Letters--Ms. Martino and Ms. Angelozzi were administered the oath by the Dauphin County Register of Wills; • Estate information Sheet; • Certified Death Certificate; and • Check for the probate fees of$138.50(Letters-$90;Automation/JCP Fee-$28.50; 5 short certificates -$20) If you have any questions, please call me. Thank you. o rs truly, a . Eshelitran, a. C.P. - 71 Estate Paralegol - c;: Enclosures c: Christine Martino(w/copy of enclosures) Pameld Angelozzi(w/copy of enclosures) r ri T1 G 1A wWiiillil111■com HARRMFIG,PA LANCA$Tei,PA STATE COLLEGE,PA HA&mN,PA • COLumus,OH • T1AMMM,DC I o Tn c, CL a m •Q w 0 Z � a co WO it o � tJ � g c I 1 t yj W � va a rb y ti r C W 6 r CERTIFICATION OF NOTICE UNDER Pa. O.C. Rule 5.6(a) REGISTER OF WILLS CUMBERLAND COUNTY,PENNSYLVANIA Name of Decedent: Edward G.Jonas Date of Deader: January 3,2012 File Number.-3R1_2-M71 Data Lettats Gmted: January 3,2012 To the Register: I certify that Notice of Estate Administration required by Pa.O.C.Rule 5.6(a)of the Orpharus'Court Runes was served on or mailed to the following beneficiaries of the above-captioned estate on March 26 2012 NAM: Christine Martino 2 Logos Ruts,Ermla,PA 17025 Pamela Angdozzi 305 Franklin St.,Apt. 102,Numeth,PA I11 64 (If more space is needed, attach separate sheet.) Notice has now been given w all persons entitled thereto under Pa.O.G.RutJe 5.6(a)except: NIA QM March 26, 2012 t5 S1PNIre snow mhw At Fame Capacity: p PersorAl Representative ®Counsel LA— Timothy NL Finnerty �C Name ojPemw Fogg dins Fom McNees Wallace&Nurick LLC It Amen o � 100 Pine St.,Harrisbum PA 17101 717.237.5394 J Teteplwme f/ Form RW-W m.10.13.06 J Exhibit "B" AFFIDAVITOF GOOD FAM'I Iii` FSTICA'I'I0'v F IEr Numbel: N)2674 .t'etueg Irr)r: Phel w Halli wn&Schrrrieg,I•!I° Subji'ct: —rdward-0.ji)w" s roper ly Ad(,rest: 50F Cc4 iy.Road,Camp}fill,FA 170.111. !.CRi.DIT IPdFORr vlAt10N Our swar b ved 4CQw�wiiiR inlo r'i-a:ait i bu uil awt C C rr`:ci Edward G. �. Cr;�lPi,nS'�4L!�sTSTAY.�,?l. Edward G. nnes-A rivietw o lm er ld ep H,,r>!vrntS t)loviu.ci ni n0 } ettZV.ii�pnte it iniarrr,atii�n. Ow IrgW J d omditars that Rlward.G.Pon n i,BJQ at NV Cvlony Moad.:Uun"p Hill,PA 170i?. . 11 (N[,11:IRY O 'I-ELFYHC)i\E CCiA,4PA[v i' A. �<IitEC'""l"O:ZY \SSIS'i AivC E"5t:;nF.(l; Our office s(:aLdled tlirecti)ry MOW=datal m',vk-,O and atr d All:dvvard C. resineisl at:i0s t'nLtt;�`!Zli,d,C:itnY Fli!l,Pr1 i?i111 C}l.n^_!SC.i3 e±:r t?jtiC'ria[le a t±']r��l!onl!call t.)il-,e s;;t?jNrt'S l;hc)ne 11nin)c<( S.,t 972&385 and reveivcd i telto vh intonnation not ist t;+rvka Ow(:dtP W.u,r We a locate 'in y beir for Etii;w d i�t'cBrrtptCri,t0 tl3hi-J4:IlatsrY t`lli'l?ttl::. t:%t.r;�t?`3I:linl{,Ci);7;. E. Fnur!ri nbtttiArL'l?tlbl6shc`d?an!-r u•4� '('t1 it rho 7atrioi-lVr`tvs,7"tic fliarris4)ru��,:'A).SEe dt:•.1CIii Ct. Or lP?-JMM m C•ftiGe was,).,dl3 a to NA:'•e ar'y --thi vv of F.Aword(.I inn,.s. Or wow w 5 M"1.Ke Wa4 unahl(`to lli='nte any[.Rkurndtioll for\.Dank le641 V nr W"M IJ.'n. Or,l l_ f;-13 ou r rffirc:was unalilo to 12"re anti'infk rvnr.tlov-1'oi A,s:'i;ir r,l4,,i,r;'l,ttivr-,)%Fdw,:td G� joiws• t u,i.:-iN.;"S.,:^ttr alto e v>:'a�'w!abti:to..-..�[e•a, trtir;r)riafil:r fur I{oi;ert,retat*t'l•of r.dw ;�.i C.".tones. On 1?,1;:.l.I,1:11'r rifite was unaWe to - � . ti ,';�t�`;tn.>,r�lcrtr;<it:onictr C:tzr.1.�rh'n:;,ru�,itic:•[1~'(Iw3rclr::;.•for.M. t r 1;,_I.kj l.a Qu? o1fir:e ii%]S.!t., Y N motor!)c vnhlYi,wsm h)T D'uLiel_t, r,,:!iwe'., F IY:i)Ilt.0 mm's. . O!t'.C(* ;'fair C:-l.cr-v"s briatll^_b:1 l=tE wiv i(tt0t?)t<ith>rl i(:i 44ili�{;rr, ngclo)tei,vf-,Ja1.i4•! ,t._Ct`xurd G 1 M MdlW 3 ow We ms urahk S I(u'ate my hAmAsun for Net`€ie G odwin, K No of Ed drd f h Ions, CA 211V c,tt:of K e.;iteintwG m c+-om,I f.'ilK Wai ke of is ;W G. nnos by 2 U i= t,,�rs[tun,::::,..�.':."n RR .hm ('i9 U.hW t my phWWAWMbn t`C h0n. On{;L'K"1 •Isr'A W ali.agMev t!).:.itl:)i t I.isi A, h',r:lh'p0h7116a0 ri',trk-of 4idv:,inl l .ir?n r;at:I,W Giibert .t e!:S.-:E;•ir)r.,PA iBRK but ww,tmue to ;et my 1?i-m ntu);li(rt fur hrr. :'7 4040 char c:rf,te atte;rt Avj's,t:;:da;t lo,;(`ph K h H ;),t_d A:c'.altiri M lsia,ertt 0;ones A. I:,6 S+11'�'I'.r;x; �Frar"riser i,Scu:lam !<iL,."t t t ti^-:d,h.rt w,ns;ut,t4•l�t: i! za` ptr;�.._ rn.,u;t'arr Isii�;n. T G,:-ilh 1.3!?l[Y; IfiCr!)tlitr_Sever:rl 1r CUP CdtlS let alt a,twr;t.f,f lU!glaail l r"fP i).a)',1'114,r.!ct'.>�d! '.I.vli;tl t , +n,-=:f y_. tr:�', !!i1f,;.7 .ittc< ir'(•el.�ua,hricn*.�,Nant.; >kr,i`.=, ,hl.'• :ar.t •:'trot;tt_x:F.,lr'. On 02-(6-:1.3 our office made several phGne.calli in an attempt tc)::ortaet W(Ilimu j•Krah IiI,relative of Edward G,(anal at 1570)1549-7517;910[.ine Road l.1 Jtafter rm Township.PA o436:answerhig mrch:tte.. on 0^-4)(113 our officc made Slvertli phone call"in an at mpt to :outalt Pamei�Angatoz.1..retattw cif Uwa rd G.jitimes at(4841298-3795,3Q'i Craill,lirt 51SULL 31.1i'C '02,Naz arch,PA 180(A:answering nk7(hirie. On(r•(16-13 nor office rr►ade lz veral phone cilis m art atternlrt t-)cuutact Christine Martino,n1aItve of Edivaid C jcrr.e.s at(,17)72&321.5,2 Ltyarts Run,Eimla,PA;7025:arwiverinl;nmctun:, Ott 02-06-13 our office ntade a phone c+tit in an l,terilm to onta:f VVillian't J.Y ntt Ir.,heteraw t relative of Edward C.►ones at(570)457-2714S,5Q*Weed Street.Duryea. PA 18642:not hi servic.-t,. Ort 02.07.13 txir office made several phom,calls lrl:11i attempt it 1'(jtucacl Williarn Kr:ih,polenliai relative of Edward G.Janes it(570)457-7'3:13,11.4'Prd;,M.rr Street,OIL'?Urge,PA 1451 K:sntswering rnachitte. Oil ;2-00-13 cut office tirade several pl'one calls in all atter ipl to cowatt Michael D:Hancock,reighhor of the Snbjee:t at( 17)4.174/474,5117 Cadmiv Road,Camp Ed!,PA 1.74';1:no ansvef. 01102-06-13 uu.r uffict'maid st=reral,.torte calls in an attl mpi to:crta:'t Kenneth C-Doerr),nf•ir!hbnr(It bola subject at(rT';)761-573',501 Colonp r{oacL{.:-1u;p.H W,r'.l 7.1011'answering rnawhil e. Quo ('2-(*P 13 our office.lnade a phone call in im Oteml'lt to conktct.Gera+id 'i),Rasmus,vA .iibor of the subject at l?IT<?i 97^a),a4G Colony Road,C,unp.Hi)l, FIA 1701,:.poke with aia uhidl-ittiliCal telltale tsho ccnild not cbniirm aj+tv br.ir Jttformation For rdivard-G loves. :;situ oux white pal, s J aiabase e err office v,�as lutiitolC to ltlx i!tam•neighbors tor:-0,4(=olmiy Road,Hampden, PA 1701:1.Otry otfiee was m aisle to 143i av,'1111'licit for r;lw.+rd JOTWIS. A. NAT tiNALADnl r--S5 UPDATE On 0^_-06-13 1vc:ryievved the National iound thrxull;sr,•irtp,irlfnhnatir+n Edward G, Jones-51121 Colomy Road,IJantrclen,PA.I7DIi. B. ADVIHONAL AC TI E MA',UNG Al)r)rvs`il!S Per uur iuriuiry of creti!ihus!tero folklwiltl,is s pot:6 blr Lra Ili ae,add1vis t)$CoJa:ry RIMI .t tampden:PA vl OTHER INCIUMIL-5 A. DFA 111 t�1 ell: tti As of 02-06-13 Vital P,ma.rrds-au d aJ1 pubh,:daul*u.)�et have a Je i'?t r(�:-mc. o:-ldu,oi Ptlwxa l toll AI)T)ITI(,)NAL.INI�'Ok%Tik'l'l(.-jN t'1 •UIUR.l A Y3AJ?',?I,311ci'1t btwarci C.. lc'rita:5-.t +•l!; E I11r1TG OF MU TI Rdwa: l C`-.,j tee -014,-T*11 '4 u accessibre dat abasos ha.-e been cha'.ched anti rrrr7;--referenced Ior the above:named indiniduaJJst, ' Please be adrrised otlr database infermatinn indicates the tlbic t resid s at[lie cunent address. I itete}! vcrifV th<,,thQ slat-.Innis rttat.c.`l:rsu Clew t-oa _ld:-ur: ti: t a bps`of env kr1k, igat, rfurntatinr kid l.c l e f,tn;i that ti Js artid,rit i`it .aai+;lti:m is nlad. sue:+.e t rri the I t, da,t of 7 T'a C_,`.tx.4441 .clatinl;to ns,'trr;lalsi(tcahnit to acrllolitiae —e i. 1 i, "Ifi o itl :: to f,, ;h' U rf.,.,r... Exhibit "C" AFFIDAVIT OF GOOD FAITH ENVESTIGAIION "ile�iurnher; 30267t Attorney Firm: Phelan,Hallinan&Schmieg,LLP Suh;ect: Lucille hl. 'ropertp Address: A)h Colony Lead.C,_r..0 Hill:YA 11t)11 'oss))Ie Mailing Address: 508 CEik%ny Road,llampclen,PA 17011 2 bi-i ns Rurr.Fnola:VA 171)2" CRE TAT 1NFORMATION1 A. `OC:1A1.SFC:URITY NUKiRI'.R Om.•search verified ttte following iiticrana ion to be true and cur;;Yt I.ucilte Ai.I�ah�� B. EMPLOYLliENTSGAF.CH l.•udUc M.Krah-A review of the credit rrpo_rtino agenci+'s prwidcd nn eanlninymeni in.forrnation. C. INQl JRY OF CREDITORS Our inquiry of ereditors indicated thai Lucille fvl,KIRli n:side(s)a t:508 i_olcanv Road,Cramp Hill,PA 1701'1; 11.INQUIRY OF TELEP ONES COMPANY A. UIRELI.OR�'A%L;T,-,NCE SE.ARCII r, Our utftce searched dar+;'n•tCrt•y;,sstsrancc d�atabas.:<;,nvhu.'n indicated that Lucille 41.Rrah resale{s}at.;�t)fI Colony Road,Clamp Hill,P.1,17011.On 06-21 6-12 cur uffire nn.lie:5t:ver d U kPIPue ca}I,,to the sutrject's phone number(717)972-8385 ar:d nTeined the follum41lg informatit;n tndrhine,Our,>fficr_wasunrnble to locate filly heir far Lucille N1. Krali. lli.OBITUARY SEARCH A. Attempted to find obituer+ via i ill p;/i oa.itcu sbaiai<.2 ona ti Found obituary publistned Deceinber 1.-I,20011 in the Patriot-`Jew,,,Ttte 1Fiarri<:burg,PA) Soo attached. IN' INQUIRY OF HEIRS AND NEIGHBORS Oil 06-26-i.2 out office was uneblc to Ir,.ate ant irfnratatiov fc;:C ii' .intir,e martiro,rol.itive of ,urilli:'.vi.Krala. On 06-2(1 '12 crux office was ivwbl;to Iecate dill'infonrnatiun for F.-mi ngclo?zi,telat:ve c)l 1,1.1rille M. Krah. On 06->6-12 uur office was tntuble tv 1k)(-we ally infer.naaPkar f o! Kim 1`1311;mLatit•c c?t Lueillc M.Kral:. On 05.26-12 our office was unable te,.lr,caie any inforntatiou fur loilu A,igt Son,relative of Luc Fc hi Krah On fit 'L-1 2 Otle Off ce rests unable tt,lc"a!e tiny ir,forrnatiou ;or Carol DcStdix. c,rclativu tit i ucille hf Kralt. On t16.25-12 our othc^::us unab'o te 1,ca:,.:uv u-.fo:rnah.nn fu; T3:9 traaa i:ran.rr,ahva o! Lc;c;itc tit Krah. Oo 06-26 12 our office was urwb-,n ti-,locato dr.y inform ati,n fo! Be edv Guidovi.h,rokib-,e of Lucille M.Krall. Ora 06-2'6-12 our office was uimb e to locate any iathnraraiion fO."'0.-v f-anucci,rcla.ty:of .tit Li::it'.:Crap. Gin C16-26-12 our,rtff.U'e wns uimb e to lw:aw erny irformation iOr it-muv!1,ahi* relalive lit I t;,7AIt'hi Krnh. Un 0616-12 our offrcc was unable.to{oca„alt.} .r.,fUrr:na :,n:nr l:r ,,l rilsxd,,rr.lative of Luc:alt.hi Kral C?n 05-2i;--12 our c'affiio.was i nc:blo:to Incatr,tr., a;f:rrnat':<}at'ur KaNtaut:: vlattino;relfrirve,>;L at:;lie 1tT.torah: On C6-265-12 our:fire was tIN81ilc to I cat?..ao.�.;rali,troai,?•,a for 1)anic1ld, «.!at+vc cot ucill. NI.Itiali: Oil 06-26-12(,t:.l-office was unable to locate ow, ;nforrnaiic;n f,w t illi,in., 1.agi•ln i, rrl;;live of Iuc:.ific 1'l.J rafn. Cart l'i 26 12 our,;flee was nnabh> ca locate any infnrmsakon tor hlidthe.v Krah, t lit vE cit Iasi ifie ht. Krah (..)at ton-26-12 00 r Office 1c;t5 tnth"le to In<ate im inti±rntation for I tar-,:'s(,ra mvy$ki relaiivi,of L.Uc:Ile V.Mali, Oil 06-26-12 our office attempted to cotlOct Cal tic:Anal Klah,relative of LilcilleM.KILL T-PAncvS'-PFt, Ap11100lt2 Nanticcokc,VA 1h634,but was unable to tget mw 11!-icine nunl1ler for I-er. (hl 06-26 oil Jr,of Fice, 10:4 111 Pted to eis.nvict I isa Ctirliji,j-dative of Ludlic'K Krah at:cy(Ol Gilhert Street, x:ranturi,PA lM5t**18,btii%va-;titi,-ible',o get aiiNplI tne rttr_mb r for ilm Ou(6-20-12 our dFice ittemphid to c3oritacl Wffliam 1:Krah id.,relative of Lucille A Mehat.91(i Line Road T. Jefferson township,TPA 18416,but was unable to gret any phone number for him. Ou 06-26-12 our office attornpted to conLict Edward G. arcs,relative ul''i-tidue M.Krall dt:508 Co lon).Rol-.-Al, Catlip Flifi;PA 170111,but was unable io get my plione mlimber fr;r him. (..hi 00-26-12 our offico attempted to contact Heather L fewer,potertHal relative of Lucille M.Krah at,37.k Pluo Ridge Drivc,Levittown,EA IM57,but was amble to gwt any plume nixtriber for hiln a On 06-:2b-'12 MIT OffiCe tuade several plione halls in All attempt to contact Wilhain.l.Krah,potential relative.of Duc.illc NEK-ah at 1,828)6877-0503,4-00 Carcilinal-killy Way,Fletcher,NC 2$732:answering machnw, Ou 06-26-12 our office made a phone call in an attempt to contact C1-Lrjm;tirka J. I'llsignaili,potential relative of Lu(.-.jllp M.Kn-di at.(5 ())%2-21561,1012 Prhice.Strei-it,'raylor,PA 13517:spoke with am ItilideritiritAi fieniale tvho could not confirm aniv heir isiforniatiorl for Lucille M,Krah. On 06-2-6-12 ciur office made it phulle call-in all attem"A to col'tact Grace M.Bisigntud,poteritial mative of A-Ildlle.,M.Kialial(�5770)346 2911,4714 Prospect Avenue,Scranton,PA 18503:spoke with<ui uilidellWied felilah.-who could vot colifirm ally heir iriformal-en for Lucille N• KraL an 06-26-12 our office made stiveral phorle calls in an attempt to contact I.-Vilhitill.l.Krah Jr.,po-clitial relative. -2146,826 Wocxi Street,Dinven, PA 18642:answe,jiig maddlie of Lmcillc�M.Krah at(570)457, C >-26-12 our office mmic it phon•call in an attempt to contact Carol it Louise Krah,J;ole!Wal relative ti, Lticille M Kralt at(95-1)4522-3675,2251 1,;outlr%vest 8511,Way, Davie,IT M,?-24,spckc,,vitl,,an iinickmtified tenlilIe who could not confirm any heir information for Jxcille M.Kral, 011 06-26-12 our office 111W.lic•SeVei'cil P.110110.(ifll!j;n an attempt to rontact D.Hallco(1,neighbor of tits 17)4'1.2-i1 1,507 Colony lRood,Camp Hill,PA 17011.ansvvering machilie. Oil 06,26-t'2 OUT Office 3MAc sevela-1 pilont.,calls in all atle(rP1 10 C-Ilacf RLd-1,11' Pizu-,nv-iglihoi o "lie subject callip Wt,PA On 06-26-12 our oil ice made i1 phone k all ill 111 al f.:iIiint to cor.1-act l,usar,1-1 subject at (71")"(11-2/4-77,3U6 Lolorty Road,C."itnip PA 1-70-11:t-ot-Ao with all Inlioelitifl(.41 fe,llaale,vAio otflo not corthimt imy lloir in(olimmion fill Lucille N-1.Krah. On 06-26-12 our office:made seve7:•1 plimle ra]14.;ill all attim.pi to colliad I.Vml 1) Oosal) th" subicct a.('2'i-132 10B,I I-orgims 'Om,1;ncln.PA 17,024 -, �j ar 5�all w( I ,n 011 00-2o-12 chit office makie a Phurik•dill in rill attempt to,-onfacl Shar.L.Adanis.neiglillc-:,f di stlb,i2ctat .117)1 - h an &,ij 1�mtifjcd w.t-jo c) —thrin ati-, 732-229"l,6 Logan-,Run,Pnola,T-A i'7025 spoke ,.,j.L uld not �'I lic-ir information for 1-mcille TVIL Krah, Oil 06-26-12 oor officti made.several plione call?in P.P atleirpt to rentaict Daniel S.Cpu:-lir,,newtij,or it flic sr.cl,ject at(71—,)732-97':V3,3 Loinns Run,EnijM,PA 17025:answi-.Tiny,filacA,11c. Using-,)ij r wliitr pages database our office.was unabic.k;ltxatt' la-ldnboi z;for T18 coli'liv RoaJ. lam P(JI-I-L- ?A 170-11.0til office ti as ulial,le V.AD DR FS�I N Q U I R Y ANA TIO. N"Al.ADDR, ;S U'DATT. On 4Wi-26-12,i,,e reviewed the Nationa).Addess datkibm"',anti fatind ttic followhilf,intorinatityri hicill(-.M. Krah :<)S Colony Road, Hampden,PA 17011. B, AT)D171ONAI-kCl'IVE MAILING ADDltBS1S Iles our inquiry of creditors,the followring is a possible-railing address:508 Colony Road,Hampden,PA 17011&'-?Logans Run,Enola,P?.17j125. VL OT1113R INQUIRIES A. DEATH RECORDS As of 06-26-12 Vital Records and all public databases have a death record on file for Lucille M.Krah. VII.ADDITIONAL INFORXIk ION 017.7UBJECT A. YEAR OF BIRTH Lucille M Krah-19145 B. DATE OF DEAT1-1 Lucille M..Kralr-12-11-2005 C`.. A.K.A. Lucille G.Krah •Our accessible databases have been checked and cross-referenced for the above named individual(s), •Please be advised our database information indicates the subject resides at the current address. Mereby verify that the statements made herein are true and correct to th.e best of my knowledge,information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S.Sec.4901 relating to tfnssao t�f l lfit'aE Mauthorities. t t J j l._ f..t. above information-s ubtained f-cm available public records and we are only liable for the cost of+lee affidavit. OWBArehivc.com: Docutnent Display Paige 1 Of 1 ObitsArehivexoan Patriot-Newc,'The(Harrisbulrg; IIA)-December l4,2005 Deceased Name: Lucille AEI. Krah Lucillc M, Ki-ah, age 150, of Cai1 p Hill, died Sunday trrortiing at holy Spitit Hospital in Camp Hill. She was the wife of Edward G. Jones. Born on September 24,1945 in Dunmore, She was the daughter of the late.1olln anci f lizabeth Lovitio Angerson. She was it graduate of Dunmore High School and was also a certified Pharmacy Technician and ,ti7edical Assistant. She was a graduate.of Empire Beauty Academy.Prior to her retirement, she was employed by Blue Ridge Paper Products, Morristown,NJ. She had currently been employed by Delta Dental, Camp Hill. She was a lovi.n wife, mother, and grandmother, who cxpressed an unselfish willingness to help others. She touched the lives of everyone she knew and will.be greatly missed. She.is also 51.i1'Vlved by her son. Dr. William Krah 111 and his wife,Lisa of Scranton: three.daughters, Carrie Krah of Scranton, Christine Martino of Enola, 4nd Film Angelozzi of Bushkin; a step-daughter, Kim Krah of Old Forge: a brother, John Angerson of Jacksonville, FL,; five sisters, Carol DeStefano of Hughestown, Barbara Tallo of.lessup, Beverly (3oldovich of Archbald, Mary Fanucci of Tenlpe, AZ, and Joanne Balint of Dunmore.; six grandchildren,Tara Fritsch, Katherine Martino,Daniella and William Angelozzi, Matthew Krah, and Francis Grabowski, and nieces and neohews. The funeral will be Saturday at 9 a.rn., with a blessing service in the Thomas:P. Kearney Funeral Home,, 517 N. Mai„ :Su-eel, Old Forge. lnmeraient will be at Cathedral Cemetery in Scranton. friend, nut-v coil Friday from 6 9 p.m. For directions car to send an online condi:lellCt, pleasu visit www. 1CeutreyFuneral.tlotnc..curn www.pennlive. :om/obits Patriot-'dews,The (Harrisburg,PA) Date: December 14, 2005 Edition: FINAL, Page.: B06 Record Number, 2 258466 Copyright, 2005, The Patrirn.-News (.o. All Rig uti Reserved. Used with permission. http://wwv�.obitsarcltive.coal!oa-search/t;e,,!lreliives'?p_acti(it;-print X p_docid=1 15D1350)... 6!162011 Exhibit "D" PHEIAN HALL JAN R SCHMMIG9 LLP 1617 JFK Bmds"ud 9d*1100 One Pniest cukior Plana Plelladel�eila,PA 19M XM007 F*c 215410-M August 30,2012 CARIM ANAL KRAH,Heir of LAM=X KRAK Deemsed 22 PVJNCE ST.APT 2 NANtMOKE,PA 10634-2141 WUIJAM J KRAH,III,Heir of K XXAK Pecemsed 910 L1 1D JEPMMMN TOWNSHIP,PA 13436-3325 t 1R l't11�1B MARTw,Heir Of LU LE K KRAH,Deoessed 2 L*GA RUN ENOLA,PA 17025-1345 PAMA A OM-Beir oof, LIB K XRAJK Demnd 303 P"AMUM STRUT,SM 102 NAZARM PA 13064-2943 ME: ZVWARD G.JMU and LUCKLE K KRAS;S00 COLONY ROAD, CAW 16MLL,,PA 170011,21R1; WILLS FARGO BANK,N.A.;PH1W 38M4 Doan ShMsdam(s): KimAy be advised that the Law Offices of Phelan EM dt Sdunieg,LLP WELLS FARGO HANK,N.A.,the holder of the nwrWV saint the above--refaraace d. mortgaged p u2ieses. Our office has been retained.to bring a fo w4osm actin. Our offm lass been informd of LUCILLE X KRAWs unfortunate death. We are nosey for your loss. As a possible hear of LUCILLE M.KRAK,you may have a veted hA test in the mowed pramim upon her death under 28 Pa.C.S.A. f3t11(b), As sew, Pennsylvania law requires that you be hwAuded as a deft solely in your cam►m b*in order to 001*0te the foreclomre. Please be advised dart yo®are not Haile fsr qm debt,as you did not execute the mortgage or note. *TMa m is a debt ooUector. Any Wf+otn ation we receive will be and for dW putpoee. If your personal liablllty for the debt has hem discharged in b@Whvpecy,we we only prooseding spinet the real estate secured by the moripp. Thy lefter act to afford you an opporbn*to waive your rik to be netsed as a defiedaat m die hr+eelosare acdco. Please find MMdwd a Waiver w I would a!*"w your czecaft and roftwft to the uadeisigned within harms(14)days of the date of this aorreapoodmoe. If the Waiver is d Mdy returned it will not be aeee seany to no ie you as a dehodsit in the fareeio acre swim However,if the Waiver is not timely named mid his believed do you are as bait ofGo tm our awe may have no dwioe but to naie you m a dWbWw in the acdw in order to divest any awrnadiip interest you may have in the p t operty. Our 026M also reque+ets the you plan provide us wish say ad Mosel heir h&nmdm for LUCRU K KRAH,Decessed. Thank you for your coopetstian in Ibis Please nM do this waiver does nut preclude you freer awoWft to self the vAjea I odsss aed nwveriap any poodble equity is the mead prs %isorrpder to documpktim of d a fieadosure aeon. We waseld eacouwge you to essrbset yew own atwmay In r+s" to NO lMMillr. if yOU wwiY No to eeque a payoff or w pbso mil G"Kj- ami s*fsr lie oam R =IlWei R'y" asgr ewe 9wdem �" I I —I*jailer,plosse orated a sepeeestadee Of ow smog secodeed Illormiteasait at (z15) sincerely, Allism F. ifW&Wiio 19 Attorney for Plaintiff •This firm is a debt wUoclw. Any bhreaAm we reaeive wM be Used for dwt peepno, Ifytw Peesoml HdA ty for die debt has been discharged in bedavptcy,we we only peoceedbig die mal ewe smnW by Ow mortgage. Exhibit "E" WAIYBR RYMMOFF4GIrrTO=NAMED AS A DEFV(DANT IN FORKCI OMM ACTON I,WILLIAM I KRAII,III,Hak of LUCILLE M.KRAH,Deoeaeed,hereby aolrlao-rl-d—e dart I may have an ownerft in ft Peopacty loaded at 508 COLONY ROAD,CAMP HEU.PA 17011-2009,in mcordwe wide Section 301(b)of dw PORwivemia Probde,Ewa aad Fidacisdes Code 120 Ps C.S.A.Secdon 301(b)]. I do he mby wahms my Io be arned a x ddmdmt in a fOeeclowo action m provided by PaJLC.P. 1141 d seq., may be budeded by WELLS FAROO RAbTK,NA,itwohdng odd Ply,veldc h prop"was owned by die decedew at dw time of her death. I hemeby consent to the hmeclomme acdoo,without ate►f w&w notice of said acuM hwbmft but m HWW to dw Sbuffs ode,mad usdarvowd that any intemst I mmy have is the arroetged I P 11 P wM be divestod upon compi edoo of the foredo mm action. I do retain any and all dOb I aeaq have under Peamylva da law to rchio be or o&Kvhse payoff dw u mbrlying debt or to nate any claim for excess Proceeds gamed by the Sheriff's sale of the mode . Date: 9 WHI IAM J.KRAH,Iff,.Heir of LUCILL E M.KRAH,Deceased Exhibit "F" Supreme Can- of Pennsylvania CQiIE '� ��caS For Prothonotary Use Only: i # _ t' C OU 11 t Docket i4o< The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the jt'eeng anal serviee:rtt ' ,3u9ts or other `t r as".t iu e.ar t'lute or rules f:r court. _ Commencement of Action: ®Canplaint ❑Writ of Summons ©Petition L Transfer from Another Jurisdiction ❑Declaration of Taking. S Lead Plaintiff s Flame: WELLS FARGO BANK,N-A- Lead Defendant`s T'Iarnc. CHMST INE MARTTNO,IN HER E CAPACITY AS CO-ADMINISTRATRIX AND HEIR OF THE ESTATE is C OF EDWARD G.JONES AND IN HER T _ T CAPACITY AS.H$iR OF L UCILLE M KRAII O Are money damages requested'' ❑Yes ®No 1 Dollar Amount Requested: El within arbitration limits m N (Check one} 0 outside arbitration limits A Is this a Class Action Suit? ❑Yes X No Is this an M3)J Appeal? 0 Yes 0 No Name of Plaintiff/Appeliant's Attorney: g Ii n F•Wells,Egg..Id.No309519.PtWw Hallman&Schmim LIP C Check here If you have no attorney(ore a Self-Represented[Pro Se[Utigsnt) Piece an"X"to the left of the ONE can category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim,check the one that you consider most important. t TORT(Ito not include Muss Tort) CONTRACT("do not include Judgments) CIVIL APPEALS D Intentional 0 Buyer Plaintiff Administrative Agencies D Malicious Pro=ution q Debt Collection;Credit Card ❑Board of Asseatnent ❑Motor Vehicle 0 Debt Collection:Other D Board of Rlections E 11 Nuisance ❑Dept.of Transportation ❑Premises Liability ^„ v- 0 Statutory Appeal:Other ❑Product Liability(does not include mass torn) ❑:Employment Dispute: ��.,.:...................___,___..._. _�m.m... 1 Slander/Libel/Defamation Discrimination S LOtlten l=1 Ernployment Dispute:Other ❑Zoning Board E 0 Other: T C.Other: O MASS TORT T]Asbestos _ N ❑Tobacco �: - C7 Toxic Tort-DES I t �.« .... B ❑Toxic Tort-Implant REAI.PROPERTY ?4IlSCELLANEOUS ❑Toxic Waste 0 Ejectment C7 Common Law/Statutory Arbitration ❑Other, 0 Eminent Domain/Condemnation 0 Declaratory Judgment ❑Ground Rent ❑Mandamus ❑.Landlord/Tenant Dispute ❑Non-Domestic Relations ®Mortgage Foreclosure.Residential Restraining Order "- _ - ❑Mortgage Foreclosure:Commercial ❑Quo Wnrranto PROFNSSIOIYAL LIABILITY ❑Partition ❑Replevin O Dental Cl Quiet Title ❑Other. ❑Legal ❑Other: ❑Medical a - ❑tither Professional; P&R.0 P.205.5 Updated©1101120!1 NOTICE You have been sued in Count. Ii'you wish to defend against the claims set forth ill the following pages, you must take action within twenty (24)days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are wamed that if you fail to do so,the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you, YOU SHOULD TAKE THIS PAPER TO YOUR. LAWYER AT ON'C'E. IF YC)I_' DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE. YOU WITH LNTFORMATION AB(:)L'`I' ITIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE.A LAWYER,'THIS OFFICE MAY BE A.BL:E TO PROVIDE YOU WITH INFORMATION ABUT.T AGENCIES THAT ,MAY OFF -'R LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSCCIA'TI(aN Ct.1i1tI3ERI,A1�7?COI;TI rY COURTHOCI5E 2 LIBERTY"At<ENLIL CARLISLE,P.4 17013 (711)249-3 166 (80?)990-9108 ��h. :'ray,^a . . . . . . . . . . FORM 1 rl�l THE COURT OF COMMON MON PLI_AS WELLS FA1CG0 BANK,N.A. _ OF CUMBERLAND COUNTY,PENNSYLVANIA P lairitiift�t j vs. , CHRISTINE MAU INO, IN FIi R CAPACITY AS CO-ADMINISTRATRIX AND HEIR OF THIS, ESTATE OF EDWARD G,JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH PAMELA ANGE:LOZZL IN HER CAPACITY AS CO-ADMINISTRA11UX AND HEIR OF THE ESTATE OF EDWARD G. JONES AND 111 HER. CAPACITY AS IfIEIR OF LUCILLE M.KRAUT CARRI.E KRAH, IN HER CAPACITY AS HEIR OF LUCILLE,IM. KRAH UNKNOWN HEIRS,SUCCESSORS, ASSIGNS,AND ALL PERSONS,.FIRA4S, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UDDER EDWARD(1-10NES, DECEASED UNKNOWN HEARS, SUCCESSORS, ASSIGNS,AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR L'NDF.R ILUCII.LE KRAFI, DECEASED Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM. you have beeru served with a foreclosure complaint that could cause you to lose your home. if you ov;;and live in the.residential property which is the subject of this foreclosure action,your may be able,to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the followings steps to be eligible for a conciliation conference. First,Within twenty(20)day;of}our receipt of this notice,you must contact hlidPenn Lcgai Services at('117)'1435-9400 extension 1510 or(800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to yott. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appou,trnent date. During[hat meeting,you must provide the legal representative with all requested 11-mmcial information so that a loan resolution proposal can be prepared on your behalf. if you and your legal representative complete a financial xvorksheet in the forn►at attaclied hereto,the legal representative will tirepure and it Rc-quest `'err Ci1n61.136011 Conftzence 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.volt will:gave an t>}?portunity to nneet with a representative of vour.lender in an attempt to-,vork out reasonable arran2emcnis with your lender LiQro'e the nio lga�e fnreClos'llr suit 1;rot:e' ds:t>rward. v If%rou are represented 1)),a lawyer, you and your lawyer must take the following steps to be eligible fora cal)(Aliation conference, It is nDt necessilly for you to contact NlidPe ui Legal.Smice for the appointment of legal representative.. However,you must provide your lavycr with 1(1 requested luttu.cial ttifor..uatian so that a loan re;;alntivn propo�al C"11 e. ?repared on your behalf. If you and your law}ter complete a financial worksheet in tho format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference tvith the Court. which must be filet's within sixty(60) (Jays of the service upon you of the foreclosure complaint.If you do so and a conciliation con*-rence is scheduled, you will have an oppomtnity to,nect with a representative of your lender in ar ati mpt to%work out reasonable arguments with your lender before:the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully.. Nn tai: Sop Date f', eX1s,Esquim, Alter Plaintiff 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 counseling agency. 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 Ej Listing date: Price: $ Realtor Name: . .. ... . . . Realtor Phone: Borrower Occupied? Yes Q No Mailing ��Address(if different _ _ )' City: »,M, �,.,,.,..w.._�.....,.�,�._.__� _ State: ---,. ._Zip, -----. Phone Numbers: Home: Office: - Cell: _. �. _. Other ._.._.._._.__........ ___ Email: #of people in household: How long? Mailing Address: City: __vses_� State: Zip: . . . _ Phone Numbers: I Tome: Office: Cell Other: Email: #of people in household: How loiig? First Mortgage Lender Type of Loan: Loan Number: _ Date You Closed Your Loan: _ Second Mortgage Lender, hype of Loan: ..._...v...._._......._:._.._:._ _ -_------ --u Loan Number: Total Mortgage Payments Amount: $ _ Included Taxes &Insurance;_., .: _.T k Date of Last Payment: 1'rirrar Reason_fc:r Ietiault; Is the loan in Bankruptcy? Yes❑ No ❑ If yes,provide names, location of court,case number&attorney: Assets A tiount()wed_ Value: Home: $ .. .... $ Other Real Estate: $_. . ............................... Retirement Funds-., $ Investments: $ ,..,__._ Checking: $_._...._...._.......................__. Savings: Other: ,_...,.. ..,... __.._ .,. Aotoinobile-#_1 Model: Year: Amount owe; Value: AM—MO lg.12:Modet -- ... . . Year,.. . �.W Amount awed: Vatue Other tranaMrtation Law tomob1les,._boats.rack c�c�les1; Model-;-----W Year: Amount owed: Value. MoathW jageme Name of Employers: l rlont h.kv Gross 2 Monthly Gross 106n'day Net 3. _ _ ____ ti :th;ty Gross_. Monthly Net _._ ___ Additional income Description(not wages)., monthly amount: 2. __monthly amount: Borrower Pay Days; Co-Borrower Pay Days: Muathly Expenses:_(Please only include expenses you are currently paying) EXPENSE AMoUN'r ExPENSE AMO>: N r __ Food. . . 2 _Utilities Car Payrnentcs) Condo/Neigh..Tees. ._ Auto Insurance Med_(not coverer!) Auto fue!r:Watrs Other prop.pa►went Install Loan Payment Cable TV Child Spppo din Mon ..ri.:.: _ _ ..... .:..:_:; Day/Chid Care/Tu�t. Other Expenscs�__� Amount Available for Monthly Mortgage Payments Based on Income&Expenses. Have you been working with a flousing Counseling Agency? Yes❑ No ❑ If yes,please provide the following information: Counseling Agency- Counselor: Phone (Ofti e): Fax 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 delinquency? Yes ❑ No ❑ if ves, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company C,ender's C:.ontaet(Name).---� _ µ rPhone: . Servicing;Company (Name):`- C;c�ntrrct: Phone:.,...,. T WC, :authorize the above named _ to uselrefer this information to lily lender/se rvi cer for the sale purpose of evaluating my financial situation for possible mortgage options. We understand that Uwe wzi/are under no obligation to use the counseling services provided by the above named..,.,,- _ Boat,wer Signature Date Co-Borrower Sianature Date Please forward this document along with the following information to lender and lender's counsel: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) PHELAN HALLINAN& SCHMIEG,LLP ATTORNEY FOR PLAINTIFF Allison F. Wells,Esq., Id.No.309519 1617 JFK.Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVAN71A "WELLS FARGO BANK,N.A. 3476 STATEVIEW BOULEVARD CIVIL DIVISION FORT MILL, SC 29715 Plaintiff, NO.: VS. CHRISTINE MARTINO, IN HER CAPACITY AS CO-ADMINISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH 2 LOGANS RUN ENOLA, PA 17025-0845 PAMELA ANGELOZZI, IN HER CAPACITY AS CO-AD'vQNISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M. KRAII 305 FRANKLIN STREET,STE. 102 NAZARETH, PA 18064-2943 CARRIE KRAH, IN HER CAPACITY AS HEIR OF LUCILLE M. KRAI4 22 PRINCE STREET, APT 2 NANTICOKE, PA 18634-2141 062-PA.-V3 U- KNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS,FIRMS, OR ASSOCIAI1ONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER EDWARD C►, JONES, DECEASED 508 COLONY ROAD CAMP HILL, PA 1 701 1-2009 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS. AND ALL PERSONS, FIR_MI S, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER L IXILL:E KRAH, DECEASED 55,08 COLONY ROAD CAMP HILL, PA 17011-2009 Defendants. .CiVI!rL,&CTION.:.-.CQNI PLAIN`-.IN VIORT ACE FORECLOSURE And now come, WELLS FARGO BANK, N.A., by its attorneys, Phelan 1-lallinan& Schmieg, LIA' and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is WELLS FAROO BANK, N.A., .3-476 S'FA' 'FVT.FW ROI f-FVARD, FORT MILL, SC 29715 {hereinafter "PIdintitT'}. 2. The Defendant, CHRISTINE r\ZAR7"i;�TO, 1N FIER CAPACITY AS CO- ADMINISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G, JONFS AND INI HER CAPACITY AS I-1EIR OF 1.14ALLE N-1. KRAH, is an individual «-hose iasi kiiov,-•n address is LOUANS RUN, ENOLA, PA 1-1025-1845. 3. The Defendant, PAMEI..A ANGELOZZI. FIN HER. CAPACITY AS C`.O- ADMI NI ISTRATRIX AND HEIR OF THE ESTA':C:E OF FL)WARtD G. JONES AND IN HER C AI'ACl'l Y ,'-S IIFIR OF' LUCIL,I,L M. KRAH, is an individual whose last known address is 0 5 FKANKLIN ST, STE 102, NAZARE?TIl. PA 1806 -294 4. The Defendant, C::ARRIE KR-U-1, IN H.ER. CAPAC -FY AS HEIR OF LLiCILLE M. KRAH, is an individual whose last known address is ?2 PRINCE ST. APT -2. NANITCOKE, PA 18634-2141. 5. The Defendants, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR A:SSOCfA—FIONS CLAIMING RIGHT, 11TLE. OR. .INTER5ST FROM OR ENDER EDWARD G, JONES, DECEASED and L-NKNONVN HEIRS, SUCCESSORS, ASSIO' S, AND ALL PERSONS, FIRMS, OR. ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER. L UCILLE M. KRAH, DECEASED, have a last known address of 508 COLONY ROAD, CAMP IIILI„ PA 17011-2009. 6. WELLS LARGO BANK, N,A., direettv 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 tripe quid correct copy of said Promissoii, Note is marked Exhibit "A",attached hereto and made a Dart hereof. 7. On or about August 20, 2005. LUCILLE; M, KRAH and EDWARD (). JONES made, executed and delivered to WELLS FARGO BANK, N-,A. a Mortgage in the original principal amount of $164,305.00 on the premises described in the legal description ina.rl:ed Exhibit "B". attached hereto and made apart hereof. Saki ti4ortgage .being rem)rded in the Office of the Recorder of CUMBERLAND County in Book 1923, Page 4710. The Mortgage is a.matter of public record and is incorporated herein by rererence in accordwice with Pa.R.C.P. 1019(8), w-hich rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public: record. 8. Plaintiff is the curTent-Moagagee. 9. Mortgagor EDWARD G. JONES died on JanuaiA 3, 2012. and CHRISTINE MARTINO acid P:\tiTELA ANGELOZZI were appointed Co-Administrators of his estate. betters of Administration Nvere granted to them on January 19, 2012 by the Register of Wills of Cumberland County, Iti'o. 21 12-0071. .Descedent's surviving heir: at law and next-of'kin are CHRISTINE MARTINO and PAMELA ANG1 'LOZZ_.1. 10. Mortgagor LUCILLP M. KR II (lied on December 11, 200s and Lipon inforriation and belief; her snrvilin�_ heirs are ��'11.,I..IAM J. KR I-l.. 1I1. CARRIL? KIt11i.I. CHRISTINE MARTINU and PAMELA ANGELOZZI. 11. Plaintiffs representative contacted the Register of Wills of Cumberland County and was informed that no estate has been raised on behalf of the decedent mortgagor, LUCILLE M.'KRAR. 12. By executed waiver, WILLIAM J. KRAII, 1II waived his right to be named as a defendant in the foreclosure action. Said waiver is attached as Exhibit:"C". 13. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due March 1,2012. 14. As of December 10, 2012 the amount due and owing Plaintiff on the mortgage is as follows: Principal. Balance $ 149,532.88 Interest 02/01/2012 Through 12/10/2012 $ 8,018.64 Late Charges $ 151.74 Property Inspections $ 105.00 Escrow Deficit $ 1,155.07 TOTAL $ 158,963.33 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 P1ai.ntif:rs 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. 15. 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 Defendant(s). 062-PA-V3 16. Plaintiff does not hold Elie named Defendants, CHR.ISTI',�E MARTINO, PAMELA. ANIGELOZZI or CARR.IF K.R.AH, personally liable on this cause of action. This action is beinu brought to foreclose the interest of the said Defendants in the aforesaid real estate only, and the Defendants have been named in accordance with the requirements of Pa R.C.P. 1144(a)(2)and 20 Pa.C.S.A. 17, T'his is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking; a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendants) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liabilitN 'Vv'IJEREFORE,Plaintiff demands an iri rem judgment in mortgage foreclosure for the amount due of$ 158,963.33 with interest thereon plus additional costs(including additional escrow advances). additional attorneys' fees and costs and for foreclosure and sale of the .norigaged premises. By: : Date: �� l1` °, 4"�el .1 ., Id. No,3095I9 .:1<)I1C31t1. A""i.. /+.rr�c-/) iii2 Exhibit "A" NOTE AVOWT 31, 3005 low IC%l Solt Comm niolw, tzar W haft„ 17011 P I. >d011tWWOrs immm TO PAT fe ratum for a loan dun 1 Ism wepdxod,11 ,m to pq U.S.$*****104,195.00 (trb alnormst is cWW'Prkmipal'), plus ineerem to Hre order of the l elyder.Mo Lou*is 1tMA VAWD 9M, X.A. I will make all pgnrsom trier tads Notes in the form of.tuslf.oiWA os mtatty otter. i andenind dmil tlla Li ader melt traoolkr this Noon.rho Lander or anyone wbo tabus this Nate by traostan and wbo is eatWmd ao rewin payer reader ibb Note is called dw"Note Holder." 2. II� ZMW h meu uM be dared an mapdd principal wdi the AM amount of PTitlelpd kss been paid.l will pay im"m at a yearly rage of 6.350 IUa I ee I rata mo ired by thin Section 2 is The rate l will'pay both botom and after any debak described an Section 6(13) of this Notes 3. PAYMIiYV'1'S (A)Tbsa and Race at Paymmis i will pal►I and istesrost by cackle#a payment every momb. I wW maids*V nlarMy paymm on ate o=ff dW of eadt awNh b onOCTOM 01, 2005 .F wlli make ftw pal►afaola 4my mood!until i haus paid ail of die prbx*d and hmm and my arbor dames deawibed below an 1 Tiny awe under dhls Noon, Hsd1 nwn t y Paymem will be ap$W m of its xboduled due date ad wM be applied to i before Pebadpd,if,on 6111111101' 01, 2035 ,1 still owe& -unfit ttla Note,I wM pay these my nda in fim on d1n am,*Nob is pilled the"mo ift Date.' I will 20111M.&V=11111 y Paymaa3*tWWAA 1`W0 uaamt stMM=, P.O. BOX 10304, OU ml0IM, 1A $03860304 or at a daf omd plate if rneriui ed by the Nm Holder. (8)Amwj t4 of bleeft Payasraft My Y Payman.rin be in do nma®t of U.S.S ''1,011.65 4. 'S PJQW TO.FWAY 1 hwm dye sight to m4be pepnitates of Principal at any time bcfm May are due.A payment of Principal ordy is known m a "Prapaymana.' When T meta a Prepsyromm, I will tall the Now Holder in writing the I am doing so. I may not desigaate a Prg M4 ea a PMPKMwlt if T have net aoade aU rho moothty Payments due under the Note. T may melee a NU Phgwymear or puts]Prepayments w4boat paying a Prepayment than.Mm Note holder will use my Psepayerenss to rattles the asrtotlrp of Prholpal diat I we under tltie Now However, the Nate Holder any apply my Prepryinesrt to the somw and UsTpaid interest on the Pmaya mlt nmolun, before awykv toy Prepayrnaht to reduce the Pdreipat amount of the Note. if T mats a pettier Pmpayrn m4 dwre will be.no changes in the duo dale or is the alnmmt of my xmmt ly payment unless tit Note Holder agrees in wrkting to thorn dmger, MULTISTATE nXM RATE NOTE-Singh Family Fvmis IWoMro o MW i1M[i"tlM INaTWUMMT (k-GN too" Pam 3200 1101 VmP MORTC.4"FORMS mo"31.7" P,pa 1 an s 1etlp1W� t S. WAR CHAMPS Ifs taut,dtie3n applies to this loan and which wets ntaximuns loan charges, is drolly interpreted so that the intetaat or otbar tones charges callecutd or to be oollected in comiection with this lean exceed the pemtitted limits, then:(a)any Mich town dwr shall be reduced by the amount necessary to reduce the charge to the petmitted!unit.and(b)any sm a rw*collociod fiorn these whkb otea,ded pwadtted limits will be refunded to me.The Now Holder may choose to make this m(md by r+edut*die Principal 1 ma tinder this Note or by matting a direct paytneatt to me.if a refund reduces Principal.the retAtedon will be treated as a ptutial Prepayment, 6. BORROW 19R'S IRAII.UU TO PAY AS RI UIRRD W Luse Gila,hr Owsdre Paynnmts If this Now Holder has not tmosived On frill Mount of ahoy nuttxhly paynm by the end of 15 calendar days after die drys it is dire,I will pay a late ndtwp to the Note Holder.The amount of the charge will be 5.000 %of my overdtsa pttytnM of ptindpal and Istet+at.I will pay this late charges promptly but oNy ortec out each laic peyst". f�ladasdt If f do not pay rite frill amount of each monthly payment on the date it is due,t will be in default. (C)Notiias or Derojult If 1 am in-defsttlt,the Note Holder any send roe a written notice telling me that if I do not pay the overdue amottrtt by a certain due.rite tea Holder troy regtAM ne w pay immediately the bill amount of Principal which has not been paid and all the imerwt drat 1 owe on that amount.That daft am be at least 3D daps after the date an witich ft mice is mailed to me or delivered by outset nneans. (M No Wahw By Note Boldw Evert if, at a t[tue wbw I stn in defattit, the Note Holder does not require are to pay iminesdiately in full as described above.the Now Holder will still We the right to do.so if[.am in.default at a Later titne. (E)hF<itymsat or Nate 11"llar'sCoots end Expiruse If the Norte Holder has required no to pay immediately in full as described above, the Notti Hoker will have the right to be paid but by as for all of its costs sad wVmm in ev&rcing this Note to the extent not prohibited by apphloable law.Thou: expenses include,hr example.reasonable stomeW fees. 7. GPAM O►NOTICES Unless appikiblo law rmquires a diflferent method, any notice that must be givers to me tinder this Note will be given by delivering it or by fcatiling it by first Class mail to mte at rite Property Address above or at a diffcrctht address if I give the!dote Holder a notice of my different address. Any notice that tmrst be given to the Note Holder under this Note will be given by delivering it or by mailiag it by firs class nail to the Note Holder at the address stated in Section 3(A)above or at a different address if 1 am given a notice of that differe to address. S. 013LIGATMS OF PERSONS UNDER IMRS 1401T if mate then one person signs this Note:,each person is fully and personally obligated to keep all of tote:promises trade in ibis Note,inolu ttlag the promise to pay the full amount owed, Any yersrxt wbo Is a guarantor,surety en endorser of this Note is also obligated to do these things. Any person who tales over these obligations,including the obligations of a guarantor, surety or endorser of this Biota, is also obligated to keep all of the promises made in this Note.The Now Holder may enforce its rights under this Note against each portion individually or against all of us together."Ns means that any one of us rnay be required to pay all of the attaxtmrs owed under this Note. 9. WAIVERS I .-tuts any other petsort who has obligations under this We waive the rights of Prescniitteatt and Notice of Dishonor. "presantncat,means the right to require the Note Holder to demand payment of aurtnunts due. "Notice of Dishonor"means the right to require the Noe Holder to give notice to other persons that arrroums due have not been paid. snub i•tan 10005) rao.2 of 3 10. UMFOM SKCVAUD NM -Ab Note is a o dlbon.instrurrrertt with limited vatiatians in some jurisdictions, In addition to the ptotmions Sivas to the Note Heider trnda this Note, a ldatgage, bend of Tntst,or Security Deed(ttre'Security batruteem"),dated the saws date as this Note,poteas do Nate Flakier ftvm puss*)*!om wbich trrl#t molt if I do not keep the promises which J take in this Note.'hat Smau ity kiswomm describes how and under what coadkions t may be roquhnd to make itt mWime paysnestt in Rill of all aatsoatsas 1 awe uWw*is Nose.Som of dxm t oaditions are described as hollows; it all or say past of the Prapmy or arty b terest In qtc Property Is sotd or trash knW(or if Botrawer is sat a a mural pawn astd a bethoft d bgffost in Borrov"is sold or t ansfoarOM witlmut Lsnda's p&w written eospeM, Llhhder mq require imediate paymem In full of all sums seared by this Spiny lasimment. Howow,M opOon malt not be awelsed by Lender if such exercise is proitibitied by Appiicsltte Law. If Lander exeram this opnost, Lender shall give Borrower turtles of asosleratm. The notice shell peevish a period of not Ids then 30 days Sum the dot the notice is given in aarotda= with Section IS vritltin wtick Bwmwar iris M all sums secured by this Samby instrtmwm.If Borrower fails to pay then mm prior to hbe expbsfm of this period, Lender Wray invoke any amedies pemdued by this Seemity Imwamat whbont fiutGbar ttatloe at dtanattd on Borrower. WIT`4M T14E HAND(S)AND SEAL(S)OF THE UNDERSIGNED, w� �:• ._._..t'Stesij � � (Seal} XPIO RD $. 3Gg -Sommer LuC LLB M. 5axm Bnrmwer ... -aomrriu -8urrv+ru m_. _($tal) Sornnrer -Borrower -Barrmrer Ltcmlwpr /Sion OrigimW 0"1 44-ON t00os1 r,,e 3 at 3 Farm 3200 a K)1 Exhibit "B" LEGAL DESCRIPTION ALJ,THAT CERTAIN tract or parcel of land and premises,situate, lying and being in the township of Hampden in the county of Cumberland and commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the southern line of Colony road which point is at the dividing line between lots nos. 158 and 159 on plan of lots hmrinafter mentioned; thence south sixty(60) degrees twenty-five(25) minutes west and along the dividing line between lots nos. 1.58 and 159 on plan of lots hereinafter mentioned, a distance of one hundred three (143) feet to a point on the rear lot line of lot no. 147 on plan of lots hereinafter mentioned;thence south twenty-nine (29) degrees thirty five (35) minutes east along parts of the rear lot lines of lots nos. 147 and 76 on plan of lots hereinafter mentioned,a distance of ninety(90) feet to a point at the dividing line between lots nos. 159 and 78 on plan of lots hereinafter mentioned;thence north sixty(60) degrees twenty-five(25) minutes east and along the dividing line between lots nos. 159 and 78 on plan of lots hmvinatter, mentioned,a distance of one hundred three (143) feet to a point on the southern line of Colony road; thence north twenty-nine(29) degrees thirty-five(35) minutes west along the southern line of Colony road a distance of ninety (90) feet to a point, the point and place of beginning. APM 2018411332 PROPERTY ADDRESS: 5011 COLONY ROAD,CAMP HILL, PA 17011-2009 PARCEL#10-20-1848-332 Filef: 3M34 Exhibit "C" WAMM BY EMR OF Wiffr TO BZ NAN= AS A DZP C+iDANT JN FORZtXA)6 AM" I,WILLIAM J.KRAFT,.III,PAk of LUMIE M.KRAH,Dwem4 bw*y scbtaa is IV flat I nor im sn vi moldp ialarssc In An poporly k Wod A 506 C*LQNY ROAD,CAW HII.L.FA 17011-2009,in aos a Pilop vft Sermon 3O1(b)of tba Pfeaetitiylrania Phi Homm and FWwimdwCode[0 Pa C.S.A.SeWm 3O1(b)). I do ham+aby waive my to be stead as a delmdow In a hndomm aotbss as psartddad by Pa.R.CJ?. 1141 st seq., wb be hadismad by WlisdS FARGO R N:A.,ivdviag saidpmparty, property ryas ow nd by do dacadaa t at for tbam of ter death. I humby aounut to the kwwJoatire stun, may fta*w nodes ofaaid atdon, inchnfing but sat lisped w dw Sha fi"s esie,and umimmomoi stet may I may taw in the preoaaisros will be divested upon conq*dca of tl o f xodkm arric ate. I do rctdn any and ail ftW I may bow under Panasylvatuia law to or o�riae pqW the amikilying debt or to mace any claim lbr access p gmavad by the Sheriff's sale afthe mmtpp prnmisd. Ie�e: 9j, ? ...� � � Hdr o IU +ifM, RAK YVWmm{d VEMKIGATIDi�i Denise Goldston, hereby states that h she Vice President Loam Documentation of WELI.:S FARGO BANK,N.A., plaintiff in this matter,that h �� s authorized to make this Verification,and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of hiy�formation 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 atithorities, . y Name: Denise Goldston 'Title: Vice President Loan Documentation Company: Wells .Fargo Bank,N.A. Date: 01/09/2013 sVi:PA—'t Fiie;i 026-4 Request for Service R.11omas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle,PA 17013 Ph: 717.240.6390 Fx: 71.7.240.6397 .... . . . . . . . . . . WELLS FARGO BANK,N.A. Court Number: ; F Expiration.Date: ` Type of Action: MagMe Foreclosure lawt Defers: CHRIS"1"M MARTINO,PAMELA ANGELOZ2I andCARRIE ANN KRAH, Serve Upon: CHRISTINE MARTINO Address for Service: 508 COLONY ROAD CAMP HILLS PA 17011-2009. ..... Alternate Alternate Address for Service: .2 LOGANS RUN .ENOL PA.17025-184.5 Type of Service: ®Personal ❑Adult in Charge ❑Deputize 0 Certified Mail Q Posting(copy of court order required) ; Special Service Instructions. Filing Attorney's Information: F Name: Phelan Hallinan, LLP ' Address: 1617 JP-K Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Telenhcxne: 215-563-7000.x 1482 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx 71.7..240.6397 . . . . . ... . .... . . . .... —y : WELLS FARGO BANK,N.A. CourtNiiiiiber: Expiration Date: Type of Action: Mort _..m._._. g Boreclosue.Cmplaunt ... Defendant/s: CRISTINE.MARTINO,. AMLA _ - ANOEL-OZZI anal(�ARW ANN KRAII, Serve Upon: CHRISTINE MARTINO Address for Service: 2 LOGANS RUN PA 17025-1845 Altemate Address for Service: . . 508 COLONY ROAD CAMP E LL PA 17011-2009 Type of Service: -- ®Personal ❑Adult in Charge ❑ Deputize ❑ Certified Mail p Posting(copy of court order required) Special Sen ice Instructions: :Filing Attorney's Information. is Nance: Phelan Hallinan, LLP Address: 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 T+, twna.:�2,15-563-7000 x 1482. Request for Service R. Thomas Kline Sheriff Ctunberland County Office of the Sheriff One Courthouse Square Carlisle,PA 1701.3 Ph: 717.240.6'90 Fx: 717.240.6397 WELLS FARGO BANK,N.A. Court Number.: Expiration Date: Type of Action: ..... . ... IVtorta e.Foreclosure..CvmpleTt Oefendands: CHRISTINE MARTINO,PAMELA ANGFLOZZI and CARRIE ANN KRAH, _--__ --- ----- _ ____� .. _..W. .___._._._._._ _._ . ... ....... .:_._ Serve Upon: PAMELA ANGELO77I Andress for Service: 508 COLONY ROAD CAMP.DILL,.PA..1701.1-2009 . .... 1:�Iternate Address for Service: � ._.._._. 305 FRANKLIN ST, STE 102 ENAZARETH, PA 18064-2943 1 2 LOGANS RUN :�:.EN_OL&YA.170_2_5_-_1845 Type of Service: El Personal El Adult in Charge ❑Deputize ❑ Certified Mail ❑ Posting(copy of court order required) Special Service Instructions. **If service is to be made by deputized service to another county please specify which Filing Attorney's Infor radon. Name: Phelan Hallinan, LLP Address: 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 ele hone: _215-56'-7000.x._1482 T Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717.240.6397 NWELL:S FAROO 8A14K,N.A. Court Number: Expiration Date: Type of Action: Mort a Foreclosure Com hint Defendants: CHRISTINE MARTINO,PAMELA ANGELOZZI and CARRIE ANN KRAH, . . . . . . . . . . ............................ . . Serve Upon: P MELA ANGELOZZI t E Address for Service: 305 FRANKLIN STREET, STE 102 N.AZARF TL.PA 18064-2943 Alternate Address for Service: ' 508 COLONY ROAD CATNIP HILL, PA 17011-2009 � e 2 LOGANS RUN ENOLA, PA 17025-1845 'T)Te of Service: ® PersonaI ❑ Adult:in Charge ® Deputize ❑ Certified Mail ❑Posting(copy of court order required) Special Service Instructions: -----------._-----�� µ **If service is to be made by deputized service to another county please specify which county. --MMAMPTO N . Filing Attorney's Infonnation: Name: Phelan Hallinan, UP Address: 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Telephone: 2.15-563.7000 x l.482 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle,PA 17013 Ph: 717.240.6390 Px: 717.240.6397 V4'ELLS I;ARGO BANK,N.A. Curt Nw:n er: E Expiration Date: Type of Action: Mr►c�Foreclosure Wit.- T-- _ �.Defendant/s:CHRISTINE MARTINO,PAMELA ANGELOZZI and CARRIE ANN KRAH, Serve Upon- CAP ME ANN KRAH F Address for Service: 508 COLONY ROAD CAMP HILLx PA 170.11-200.9 - Alfiernate Address for Service:... . .-- . 22 PRINCE-S'IREEET, APAR'T'MENT 2 1*LAl? 'I'ICO LA 18634-2.141 Type of Service: � .-.... ❑ Personal p Adult in Charge p Deputizes p Certified Mail p Posting(copy of F court order required) Special Service Instructions: k I. j. E Filing Attorney's lnforirration: Name: Phelan Hallinan,LLP Address: 1617 JIa K Boulevard, Suite 1400 One Penn Center Plaza Philadelphia. PA 19103 `ielopho -` 215-163-7000 x 1.482 ---- Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle,PA 17013 Ph: 717.240.6390 k x: 71.7.240.6397. WELLS FARGO BANK,N.A. Court Number: Expira#ion Date: Type of Action: Mo!V Ac Foreclosure.Complaint Defendants: CHRISTfNE MARnNO,PAMELA ANOELOZZI and CARRIE.ANN KRAH _ _ , r Serve Upon: CARRIE ANN KRAH Address for Service. :22 PRINCE STREET,APARMENT 2 NANTII ►PA 186342141 Alternate Address for Service: 508 COLONY ROAD CAMP tM7G.,PA 17011-2009 Type of Service p Personal p Adult in Charge ® Deputize ❑Certified Mail ❑Posting(copy of court order required) Special Service Instructions: **If service is to be made by deputized service to another county please specify which F E Filing Attorney's Information: Naive: Phelan Ilallinan, LLP s Address: 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 y _ `1e1 s� tiilu 21�-5:63-7000 x 148 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle,PA 17013 Ph: 717.240.6390 Fx:717.24.0.6397. ........ ___�.� WELLS FARGO.SANK,N.A. Court Ndrrilier: Expiration Date: Type of Acton. Mo Fozeelosureli . . . : Deferidands. CHRISTINE MARTINO,PAMELA ANGELOZZI and CARRIE ANN KRAH, Serve Upow.PAMELA ANGELOZZI Address foie Sendce: 2 LOGANS RUN ENOj,.A, PA..1.7025-1845 Alternate Address for Serviee�� 305 FRANKLIN STREET, STF, 102 NA."Z,ARETI3, PA 18064-2943 E. 508 COLONY ROAD CAMP HIU, PA 17011-2009 .�_.__ .. . . _ - Type of Service: 0 Personal ❑Adult in Charge ❑ Deputize ❑ Certified Mail 0 Posting(copy of court order required) Special Service Instructions: **If service is to be made by deputized service to another county please specify which f Filing Attorney's Information: Narne: Phelan Hallinan, LLP Address. 1617 JFK:Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 1el hone: 215-5603-'P000 x 148 Exhibit "G" Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 Attorney for Plaintiff WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISION vs. NO. 13-244-CIVIL CHRISTINE MARTINO, in her capacity as Co- Administratrix and Heir of the Estate of EDWARD CUMBERLAND COUNTY G. JONES ET AL. CERTIFICATION OF SERVICE I hereby certify a true and correct copy of the foregoing Plaintiff's Motion for Special Service was served by regular mail on Defendant(s) on the date listed below: CHRISTINE MARTINO 2 LOGANS RUN ENOLA, PA 17025-1845 PAMELA ANGELOZZI 305 FRANKLIN ST, STE 102 NAZARETH, PA 18064-2943 CARRIE ANN KRAH 22 PRINCE ST,APT 2 NANTICOKE, PA 18634-2141 302674 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER EDWARD G. JONES, DECEASED 508 COLONY ROAD CAMP HILL, PA 17011-2009 UNKNOWN HEIRS, SUCCESSORS,ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER LUCILLE M. KRAH, DECEASED 508 COLONY ROAD CAMP HILL, PA 17011-2009 PHELAN HALLINAN, LLP Dated: / /.3 By: Jo M. Kolesnik, Esq., Id. No. 308877 ttorney for Plaintiff 302674 WELLS FARGO BANK, N.A., Plaintiff V. IN THE NINTH JUDICIAL DISTRICT COURT OF COMMON PLEAS CHRISTINE MARTINO, in her capacity as Co-Administratrix and Heir of the 2013-00244 CIVIL TERM Estate of Edward G. Jones, ET AL, Defendants MORTGAGE FORECLOSURE IN RE: MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER ORDER OF COURT AND NOW, this 28th day of March 2013, upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of Court, it is ORDERED and DIRECTED that service of the Complaint and Notice of Sheriffs Sale upon the Unknown Heirs, Successors, Assigns, and All Persons, Firms, or Associations Claiming Right, Title or Interest From or Under Edward G. Jones, Deceased, and Lucille M. Krah, Deceased, (hereinafter "Defendants") may be made in the following manner: (1) by First Class and Certified Mail, return receipt requested, no signature required at the mortgaged property, 508 Colony Road, Camp Hill, Pennsylvania 17011-2009, service to be deemed complete upon mailing; (2) by posting a copy of the same on the most public portion of the property located at 508 Colony Road, Camp Hill, Pennsylvania 17011- 2009; and (3) by publication once in the Cumberland County Law Journal and once in a newspaper of general circulation in Cumberland County, Pennsylvania, in the form directed by the applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules of Procedure. SUBSEQUENT papers may be served by first-class mail to Defendants at the aforesaid Colony Road address, with service to be deemed complete upon mailing. PLAINTIFF shall file a certificate of service to assure compliance with this Order of Court, Thomal Placey, C.P.J. Distribution: mal =c m =M =MW Christine Marino X-;0 r 2 Logans Run Enola, PA 17025-1845 Pamela Angelozzi 305 Franklin Street, Ste 102 Nazareth, PA 18064-2943 Carrie Ann Krah 22 Prince Street, Apt 2 Nanticoke, PA 18634-2141 Unknown Heirs, Successors, Assigns, and All Persons, Firms, or Associations Claiming Right, Title or Interest From or Under Edward G. Jones, Deceased 508 Colony Road Camp Hill, PA 17011-2009 Unknown Heirs, Successors, Assigns, and All Persons, Firms, or Associations Claiming Right, Title or Interest From or Under Lucille M. Krah, Deceased 508 Colony Road Camp Hill, PA 17011-2009 111h IC Pul SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILEO-OFFICt' Sheriff 01V ot cumb THE PRO TH0N6'Nry Jody S Smith APR -2 AN 10-- 4 7 Chief Deputy Richard W Stewart COUNtY, Solicitor OPPCE or THE SKRIFr Pt iTSYLVANIA Wells Fargo Bank, N.A. Case Number vs. Christine Martino(et al.) 2013-244 SHERIFF'S RETURN OF SERVICE 01/15/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Carrie Ann Krah, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Luzeme, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 01/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Christine Martino, but was unable to locate the' in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 508 Colony Road, Hampden Township, Camp Hill, PA 17011. Residence is vancont and there is a"For Sale"sign on the property.To this date the Camp Hill Postmaster has not been able to provide any information regarding the defendant other than she is a daughter of Edward G. Jones,deceased. 01/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Pamela Angelozzi, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 508 Colony Road, Hampden Township, Camp Hill, PA 17011. Residence is vancant and there is a"For Sale"sign on the property.To this date the Camp Hill.Postmaster has not been abie to provide any information regarding the defendant other than she is a daughter of Edward G. Jones, deceased. 01/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Carrie Ann Krah, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 508 Colony Road, Hampden Township, Camp Hill, PA 17011. Residence is vancant and there is a"For Sale"sign on the property.To this date the Camp Hill Postmaster has not been able to provide any information regarding the defendant other than she is a daughter of Edward G. Jones, deceased. 01/17/2013 05:39 PM-Deputy Ryan Burgett, being duly sworn according to law,served the requested Complaint in Mortgage Foreclosure by"personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Christine Martino at 2 Logans Run, East Pennsboro, Enola, PA 17025, -0 RYAN BUIRG�, DEPLItL'��j 01/23/2013 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Pamela Angelozzi, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 2 Logans Run, East Pennsboro, Enola, PA 17025. Defendant does not reside at this address. Deputies were advised that the defendant may reside in Wind Gap, PA. 02/06/2013 The Sheriff of Luzeme County, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Carrie Ann Krah, but was unable to locate the Defendant in his bailiwick.The Luzeme County Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Served"at 22 Prince Street,Apt.#2, Nanticoke, PA 18634-2141. 03/07/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Pamela Angelozzi, but was unable to locate the Defendant in the Sheriff's bailiwick.The Sheriff therefore deputizes the Sheriff of Northampton, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. (c)CountySuite Sheriff,Telaosoft,Inc. 03/18/2013 11:15 AM -The requested Complaint in Mortgage Foreclosure served by the Sheriff of Northampton County upon Brian Holmes, boyfirend of defendant,who accepted for Pamela Angelozzi, at 305 Franklin Street, Suite 2, Nazareth, PA 18064-2943. Randall Miller, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $162.90 SO ANSWERS, March 25, 2013 RONIrY R ANDERSON, SHERIFF (c)CountySuite Sheriff.Teleosoft..Inc. t PHELAN HALLINAN,LLP Allison F.Zuckerman,Esq.,Id.No.309519 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 1.9103 215-563-7000 COURT OF COMMON PLEAS WELLS FARGO BANK,N.A. Plaintiff CIVIL DIVISION vs. CUMBERLAND COUNTY CHRISTINE MARTINO,IN HER CAPACITY AS CO-ADMINISTRATRIX AND HEIR OF No. 13-244-CIVIL THE ESTATE OF EDWARD G.JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M.KRAH PAMELA ANGELOZZI,IN HER CAPACITY AS CO-ADMINISTRATRIX ANS HEIR OF THE ESTATE OF EDWARD G.JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH r CARRIE ANN KRAH,IN HER CAPACITY AS cn r- :;D M HEOR OF LUCILLEM. KRAH UNKNOWN -<> cn o HEIRS, SUCCESSORS,ASSIGNS, AND ALL DQ o PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST ° `''� FROM OR UNDER EDWARD G. JONES, �"` T' DECEASED cr UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER LUCILLE M. KRAH,DECEASED Defendants S -,2g g«� PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. PHELAN ffNIAN,LLP By ckerman,Esq., Id. No.309519 Attorney for Plaintiff Date: /vla, Svc Dept. File#302674 tr Phelan Hallinan,LLP ATTORNEYS FOR PLAINTIFF Jonathan Lobb,Esq.,Id.No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 c-.,C-) WELLS FARGO BANK,N.A. rn Plaintiff iV ;;0 cj VS. Z- 3;' M- CHRISTINE MARTINO, IN HER CAPACITY AS CO- C.) = ADMINISTRATRIX AND HEIR OF THE ESTATE OF C5 EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M.KRAH COURT OF COMMON PLEAS PAMELA ANGELOZZI, IN HER CAPACITY AS CO- ADMINISTRATRIX AND HEIR OF THE ESTATE OF CIVIL DIVISION EDWARD G.JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M.KRAH CUMBERLAND COUNTY CARRIE ANN KRAH, IN HER CAPACITY AS HEIR OF LUCILLE M. KRAH No.,13-244-CIVIL UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER EDWARD G. JONES,DECEASED UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER LUCILLE M. KRAH,DECEASED Defendant(s) AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular mail and certified mail,return receipt requested,to the following persons, UNKNOWN]HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER EDWARD G.JONES,DECEASED and UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER LUCILLE M.KRAH,DECEASED at 508 COLONY ROAD,CAMP HILL,PA 17011-2009 on April 22,2013,in accordance with the Order of Court dated March 28,2013 . The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsification to authorities. Phelan Hallinan,LLP DATE:April 22,2013 Jonatflan Lobb,Esq.,Id.No.312174 Attorney for Plaintiff Phelan Hallinan,LLP PHS:302674/VLA SHERIFF'S OFFICE OF CUMBERLAND COUNTY CZ Ronny R Anderson rnug 3po 3 Sheriff = -C r fit C111rib", :0 Jody S Smith ° 1141 -C� Chief Deputy F t. Richard W Stewart r. Solicitor OFF CEOFIPESPERIF'r r` *AMENDED* "� N Wells Fargo Bank, N.A. Case se Number Christine Martino (et al.) 2013-244 SHERIFF'S RETURN OF SERVICE 01/15/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Carrie Ann Krah, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Luzerne, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 01/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Christine Martino, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 508 Colony Road, Hampden Township, Camp Hill, PA 17011. Residence is vancant and there is a"For Sale"sign on the property. To this date the Camp Hill Postmaster has not been able to provide any information regarding the defendant other than she is a daughter of Edward G. Jones, deceased. 01/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Pamela Angelozzi, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 508 Colony Road, Hampden Township, Camp Hill, PA 17011. Residence is vancant and there is a"For Sale"sign on the property. To this date the Camp Hill Postmaster has not been able to provide any information regarding the defendant other than she is a daughter of Edward G. Jones, deceased. 01/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Carrie Ann Krah, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 508 Colony Road, Hampden Township, Camp Hill, PA 17011. Residence is vancant and there is a"For Sale"sign on the property. To this date the Camp Hill Postmaster has not been able to provide any information regarding the defendant other than she is a daughter of Edward G. Jones, deceased. 01/17/2013 05:39 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Christine Martino at 2 Logans Run, East Pennsboro, Enola, PA 17025. i RYAN BURGETT, DEPU 01/23/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Pamela Angelozzi, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found" at 2 Logans Run, East Pennsboro, Enola, PA 17025. Defendant does not reside at this address. Deputies were advised that the defendant may reside in Wind Gap, PA. 02/06/2013 The Sheriff of Luzerne County, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Carrie Ann Krah, but was unable to locate the Defendant in his bailiwick. The Luzerne County Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Served" at 22 Prince Street,Apt. #2, Nanticoke, PA 18634-2141. Deputies were advised by the current resident that the defendant has not lived here for at least three years. �c)CountySuile Sheriff,T©leosoft Inc. .03/07/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Pamela Angelozzi, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Northampton, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 03/18/2013 11:15 AM-The requested Complaint in Mortgage Foreclosure served by the Sheriff of Northampton County upon Brian Holmes, boyfirend of defendant, who accepted for Pamela Angelozzi, at 305 Franklin Street, Suite 2, Nazareth, PA 18064-2943. Randall Miller, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $162.90 SO ANSWERS, March 25, 2013 RON R ANDERSON, SHERIFF (c)CountySuite Sheriff,Tefeosoft,Inc, APR,•,23. 2013 10: 50AM NO. 585 _ P. 1 200 NaztE R1ver S re-t pt=sylvaaia 18711 (570)925-1651 1qQ SERVICE pi e G u ALL 7 TS M4-DE- 1. DATE: ADDRESS: 2. DA'1-: ME: ADDRESS: 3. DATE: Tom" ADDRESS: R EMARKS: 5h ALaz= C d �Drp ,ERIFF 51GNAiURE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson )J r r LED-OFt"ICS. 711E PR0TH014 '""A F,,, � Sheriff � Jody S Smith 2013 MAY -g PH 13 Chief Deputy Richard W Stewart k 0MBERL,4ND COUN i Y Solicitor ='° m�.= <x :rF PENNSYLVANIA Wells Fargo Bank, N.A. Case Number vs. Christine Martino (et al.) 2013-244 SHERIFF'S RETURN OF SERVICE 04/16/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Pamela Angelozzi, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Northampton, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 04/24/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Northampton County upon Pamela Angelozzi, personally, at 305 Franklin Street, Suite 2, Nazareth, PA 18064-2943. Randall P. Miller, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, May 07, 2013 R-ONW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoft,Inc. Date: 'bettor:SS • Northampton County ��. sheriff's Department ORDER FOR SERVICE-"REQUEST ! 669 Washington St, Easton, PA 18042 I I 610-559-3084 SHE" 4 F >�E 1) ALL information in the"Plaintiff/Attorney"section MUST be filled in n U R T H A I I✓ p TO� t,' completely and LEGIBLY before service can be attempted. 2)Prepare a separate"Order For Service Request"form for EACH service to be 1 APR I 4-A" f11 2 3� made clearly indicating the specific defendant,garnishee,property to be Z613 p�7Q 22 1 posted/levied/etc.. 3) Location of service MUST be a valid,PHYSICAL,street address. "P.O."or "R.D."boxes will NOT be accepted. Provide-include actual municipality if different from"Post Office"mailing city. 4)All copies for service must be certified by Plaintiff/Attomey as"True&Correct" in accord with Pa.R.C.P.401(c). 5)All service shall be made in accordance with the Pennsylvania Rules Of Civil SHERIFF-CIVIL DIVISION SHERIFF'S OFFICE Procedure. 6)Supply a self-addressed,stamped,envelope for Sheriffs Return of Service. TIME STAMP 7)When the Sheriff levies or attaches property,it will routinely be left without watchman,in the custody of whomever found,upon notice of Sheriffs Levy. By signature below,the Plaintiff/Attomey are providing written authorization for same in the manner of Pa.R.C.P.3109(b)(1),releasing the Sheriff from any/all liability for protecting same. If Plaintiff/Attorney demand otherwise,in the manner of Pa.R.C.P.3109(a),the Sheriff will require bond or security in the manner of Pa.R.C.P.3109(d)in advance. PLAINT FF(S O,r b Y t J)EFENDANT(S) �� MI 1n�1�YC a QSC,P- 11I1i1► I'K iv-OF-f-E W6u A •�i^fS 0.1 Ai?A � (Wcr4 ERNE UP N: �'�a r � QT� a�, � LOCATION: NO P.O.BOX OR R.D`" 1y t Jam• 3b5�p F'rw 1`v� �,,� TYPE OF WRIT: ccww %±0 �Ot�ee a�r-z , PLAINTI F/ATTORNEY NAM ,A �S,EMAIL PHONE:, � - an y�lJ.AA b l r�3 PVC) f(� PLAINT F/A O:7z U : 11Q1 T 1` &\,& ph1` pKa,$ i�iO3 S CIALI TRUCTIONS: " C21� 3- Ict AiM0 MYe Atr pm. -- - (MW. - DOCKET NUMBER: LAST DAY FOR SERVICE- FEES P D: INDIVIDUAL SERVED: DATE: TIME: �Al+r•L�`� Lin �`�'rr's.t Zf�Z,+.i`1.3 >r sj LOCATION:(IF DIFFER NT FROM ABOVE) ( )BOROUGH OF: ( )CITY OF: ( )TOWNSHIP OF: SERVED IN THE FOLLOWING MANNER: Not Found ( )Moved ( )No Answer ( )Vacant ( )Unknown (W_Defendant personally served ( )Adult family member with whom said defendant resides ( )Adult in charge of defendant's residence ( )Manager/Clerk of place of lodging in which defendant resides ( )Agent of person in charge of defendant's office or usual place of business ( )Officer of said defendant company ( )Posted property ( )Levy on property ( )Other: SO ANSWERS: RANDALL P.MILLER SHERIFF OF NORTHAMPTON COUNTY I hereby deputize the Sheriff of County,to execute BY: and make a return on the above and attached action according to law. deputy Sheriff Badge# Sheriff of Northampton County Date I accept service of the on behalf of and certify that I am authorized to do so. (Mailing Address) Defendant of Authorized Signature) Date: Time: De-<_1 I Notes: 1S A' Date: Time: Dep: Notes: Date: Time: Dep: Notes: Date: Time: Dep: Notes: ORDER FOR SERVICE REQUEST NCSD FORM#138/rev.SEPT2011 AFFIDAVIT OF SERVICE CUI4LF`_:R.LAND VLA PLEASE POST BY:05/15/2013 EPLAINTIFF F--Eviction Y: CUMBERLAND RGO BANK,N.A. NO. 13-244-CIVIL NT_---�--�------- - UNKNOWN HEIRS, SUCCESSORS,ASSIGNS, TYPE OF ACTION AND ALL PERSONS, FIRMS, OR ASSOCIATIONS Mortgage Foreclosure CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER EDWARD G. JONES,DECEASED XX_ Civil Action ' SERVE AT: __p_ Complaint on Promissm;y N 508 COLONY ROAD, CAMP HILL,PA 17011-2009 -ram � t ***PLEASE POST THE PROPERTY*** °o rr ***IN ACCORDANCE WITH THE***** ***ATTACHED COURT ORDER****** �� © C Served —� Co Posted and made known UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIA'T'IONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER EDWARD G. JONES, DECEASED, Defendant on the _._R%i— 20 11 a day of at--:sy o'clock, M.,at 508 COLONY ROAD,CAMP HILL,PA 17011-2009,in the manner described below: Defendant personally served. Adult family member with whom Defendant(s)reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name/relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. Other: an office of said deferdant company. Plf 7F(— LLr Description: Age Height Weight Race _ Sex_ _ Other I, a competent adult,being duly sworn according to law,depose and state that I personally poste copy of the Complaint in Mortgage Foreclosure issued in the captioned case on the date and the address indicated above.I understand that this statement is made subject to the penalties of 18 Pa.C.S.Sec.4904 relating to unsworn falsification to authorities. DATE: 1p(S NAME: PRINTED NAME: GF'r+ l (Et1N TITLE: S - NOT SERVED On the_day of 20_,at_o'clock_.M.,Defendant NOT FOUND because: _Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) _No Answer on at at _Service Refused Other: PHS#302674 AFFIDAVIT OF SERVICF — C U1��R�F�I.f?;ND vLA PLEASE POST BY:OS/1C T H PLAINTIFF WELLS FARGO BANK, N.A. COUNTY: CUMBERLAND COURT NO. 13-244-CIVIL DEFENDANT;°------------ -- UN ALL P HEIRS, Sl C'CE,SSORS,ASSIGNS, AND ALL PERSONS; F__ TYPE OF ACTION CI-AIMING RIGHT, TITLE �T,ERE T FR ASSOCIATIONS OR UNDER LUCILLE:�i. •-�--Mortgage Foreclosure kRAH,DECEASED I �T C — Eviction ivil Action SERVE AT: (:om�laint on Promissory Note 508 COLONY ROAD, CAMP HILL,PA 17011-2009 ***PLEASE POST THE PROPERTY*** ***IN ACCORDANCE WITH THE***** I ***ATTACHED COURT ORDER****** Served RIGHTPosted and made known UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AW R INTERS. FROM OR UNDER L AND ALL PERSONS,20 UCILLE M. KRAH, DECEASED, Def nddaant on theSSOCIATIONS CLAIMING o'clock, served.at 508 COLONY ROAD CAMP HILL PA 17011-2009,in the manner described below: day of Defendantpersonl served. Adult family member with whom Defendant(s)reside(s). Relationship is Adult in charge of Defendant's residence who refused to give natne/relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's.office or usual place of business. �- Other: Z TK an office of said defendant company. Description: Age Height T- Weight Race S -_ ex Other copy of the Complaint in Mortgage Foreclosurissued adult,being g duly sworn according carng the date and the addr statement e made subject to the e Fo c 1s re C.S.Sec.he ca relati d . to law,depose and state that I personally posted a true and correct penalties uth indicated above.I understand that this DATE; /'Lv�� to unsworn falsification to authorities. NAME: /bA �✓�. PRINTED NAME: Fq�SCG� 1�� TITLES SC•(Z(, - On the NOT SERVED day of 20 ,at r o'clock M.,Defendant NOT FO W F1 _Vacant FOUND because: rri T°' i _Does Not Exist —Moved _No Answer on at _Does Not Reside(Not Vacant) -C C: Cf)� f`+3 ----_, c4? _;G _Service Refused Other: at . ' CD:3s p CD PHS#302674 r FILED-OFFICE F THE f' OTHONO fARY Phelan Hallinan,LLP 2013 JUN 12 AM €0. 0 4 Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 CUMBERLAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia,PA 19103 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division vs CUMBERLAND County CHRISTINE MARTINO, IN HER CAPACITY AS CO- ADMINISTRATRIX AND HEIR OF THE ESTATE OF No.13-244-CIVIL EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M.KRAH PAMELA ANGELOZZI, IN HER CAPACITY AS CO- ADMINISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G. ,JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M.KRAH CARRIE KRAH, IN HER CAPACITY AS HEIR OF LUCILLE M.KRAH UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER EDWARD G. JONES,DECEASED UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER LUCILLE M. KRAH,DECEASED Defendant PRAECIPE TO THE PROTHONOTARY: ❑ Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ® Please mark the above referenced case Settled, Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑ Please ac e the Judgment entered. Date: G 7 PHE AN HArEsq., By: Joseph A. Deo.200479 Atto rney for Plaintiff PHS#302674 Phelan Hallinan,LLP Attorney for Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division V. CUMBERLAND County CHRISTINE MARTINO, IN HER CAPACITY AS CO-ADMINISTRATRIX AND No. 13-244-CIVIL HEIR OF THE ESTATE OF EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M.KRAH PAMELA ANGELOZZI, IN HER CAPACITY AS CO-ADMINISTRATRIX AND HEIR OF THE ESTATE OF EDWARD G. JONES AND IN HER CAPACITY AS HEIR OF LUCILLE M.KRAH CARRIE KRAH,IN HER CAPACITY AS HEIR OF LUCILLE M.KRAH UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER EDWARD G.JONES,DECEASED UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER LUCILLE M.KRAH,DECEASED Defendant PHS#302674 CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: CHRISTINE MARTINO 2 LOGANS RUN ENOLA,PA 17025-1845 PAMELA ANGELOZZI 305 FRANKLIN ST STE 102 NAZARETH,PA 18064-2943 CARRIE ANN KRAH 22 PRINCE ST APT 2 NANTICOKE,PA 18634-2141 UNKNOWN HEIRS 508 COLONY ROAD CAMP HILL,PA 17011-2009 UNKNOWN HEIRS 508 COLONY ROAD CAMP HILL,PA 170-11-2009 Date: (' 12 PHE AN HALLIN ,LLP By: Joseph A. Desso sq.,Id.No.200479 Attorney for Plaintiff