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HomeMy WebLinkAbout13-0384~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., Plaintiff, vs. loselito B. Nevalga; Karen M. Nevalga; Defendants. T0: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3476 Stateview Blvd.. Ft. Mill, SC 29715. AND THE DEFENDANT: 1883 Douglas Drive Carlisle. PA 17013-4612 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 1883 Douglas Drive, Carlisle PA 17013-4612 Munir: lit r: North Middleton ATTOR IN F ` ~ ATTY FILE NO.: XFP 175134 CIVIL DIVISION -~ ~ N w w ~~ --t I ~ ~r W.~ ~ r ~, ~ ~ ~ w ' TYPE OF PLEADING r - .Ke:~ ~- _~,° ~-~-~ c~ -,~; ~~ _ ~~ CIVIL ACTION -COMPLAINT S>~ ~ ~' +i IN MORTGAGE FORECLOSU RE ,,~ ~ ~' ,~ FILED ON BEHALF OF: Wells Fargo Bank. N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire Pa. I.D. #55650 Kimberly A. Bonner, Esquire Pa. I.D. #89705 Joel A. Ackerman, Esquire Pa I.D. #202729 Ashleigh Levy Marin, Esquire Pa I.D. #306799 Ralph M. Salvia, Esquire Pa I.D. #202946 Jaime R. Ackerman, Esquire Pa I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908)233-1390 FAX office@zucker>zoldbere.com File No.: XFP-175134/cpad ~.~~io3.~S~d aft ~~43~C~g IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.. Joselito B. Nevalga; Karen M. Nevalga; Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.. Joselito B. Nevalga; Karen M. Nevalga; Defendants. AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en Las siguientes paginas, debe tomar accibn dentro de Los prbximos veinte (20) Bias despubs de la notificacibn de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a Las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar action como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamacibn o remedia solicitado por el demandante, puede ser dictado en contra Suva por la Corte. Usted puede perder dinero 0 propiedades u otros derechos importantes pars usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO O NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. NO.. Joselito B. Nevalga; Karen M. Nevalga; Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff") with its place of business located at 3476 Stateview Blvd., Ft. Mill, SC 29715. 2. The Defendant, Joselito B. Nevalga, is an individual whose last known address is 1883 Douglas Drive, Carlisle, PA 17013-4612. 3. The Defendant, Karen M. Nevalga, is an individual whose last known address is 1883 Douglas Drive, Carlisle, PA 17013-4612. 4. 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. 5. On or about October 29, 2008, Joselito B. Nevalga and Karen M. Nevalga, husband and wife made, executed and delivered to Wells Fargo Bank, N.A. a Mortgage in the original principal amount of $128,877.00 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 Deeds of Cumberland County on November 7, 2008, Instrument #200836612. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which Zucker, Goldberg & Ackerman, LLC XFP-175134 062-PA-V3 rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Plaintiff is the current mortgagee. 7. loselito B. Nevalga and Karen M. Nevalga are record and real owners of the aforesaid mortgaged premises. 8. 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 July 1, 2012. 9. As of 01/11/2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $123,241.65 Interest through 01/11/2013 $ 4,892.39 Escrow Advance $ 1,071.33 Late Charges $ 174.40 Inspection Fees $ 30.00 Total $ 129,409.77 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiffs attorneys' fees and expenses. Plaintiff reserves the right to fife 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. 10. 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). Zucker, Goldberg & Ackerman, LLC XFP-175134 062-PA-V3 11. This action does not come under Act 91 of 1983 because the mortgage is FHA insured. 12. 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 $ 129,409.77 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GOLDBERG & ACKERMAN, LLC BY:~~~~~1 ~~ Y Dated: l ~ l 1 l t~ Scott A. Dietterick, Esquire; PA LD. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-175134/cpad 200 Sheffield Street, Suite 101 Mountainside, N1 07092 {908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com THtS /S AN ATTEMPT TO CO!lECT A DEBfi, AND ANY HV~~MAT'ION 08TAAlItfD W!!! BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP-175134 062-PA-V3 EXHIBIT A 062-PA-V3 Zucker, Goldberg & Ackerman, LLC XFP-175134 ff-- I) JI NOTE FHA Case Nu. Multistate OCTdBER 29, 2008 ~ Datel 7.883 DOUGLAS DR, CARLISLE, PA 17013 (Property Addrrssl 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means WELLS FARGO BANK, N.A. and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST to return for a loan received from Lender, Borrower promises to pay the principal sum ofONg ~~RED TWENTY-BIGHT THOUSAND EIGHT HUNDR8D SEVENTY-SEVEN AND NO/100 Dollars (U.S. $ ***128, 877.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of SIX AND ONE-HALF percent ( 6.500 ~) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or sitttilar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on DEC81rffiER 2008 ,Any principal and interest remaining on the first day of NOVEl~ER 2038 ,will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at WSLLS FARGO BANK, N.A. P. 0. BOX 4148, >rREDERICR, tYID 21705-4148 or a[ such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ *******814.60 .This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an alonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the altonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the alonge were a part of this Note. [Check applicable boxj ^Graduated Payment Allonge ^Growing Equity Allonge ^Other [spet:ify] 5. BORROWER'S RICIHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. „W„„Y,."„~,.,.,,,w„„,,,,,,.,W,.._.._...,.,.,.,__W.._.._~..._.._.__. ® FHA A1ultistate Fixed Rate Note -~ 95 ®•7R t96ot1 VMP MORTGAGE FOAMS • 1800]521-7297 Pape 1 of 2 Initials: 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described~in Paragraph 4(C) of this Note, by [he end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Fot7R percent (4.000 ~) of the overdue amount of each payment. (B} Default if Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note dory not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interes[ from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive [he rights of presentment and notice of dishonor. "Presentmen[" means the right to require Lender to demand payment of amounts due. "No[tice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable taw requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above ar at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at [he address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep ail of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SiGNiNG BELOW, Borrower accepts and agrees to the terms and cove~ttts contained in this Note. _ (Seal) ~~ v -Borrower 30 L (Seal) -Borrower M (Seal) -Borrower _ (Seal) -Borrower WtY TNE~~O~~~ Olt _ (Seal) -Borrower _ (Seal} -Borrower _ (Seal) -Borrower (Seal) -Borrower ®®-1R 198011 Pape 2 of 2 ~ ~~ ~ ~'~ rRo..'"" EXHIBIT B 062-PA-V3 Zucker, Goldberg & Ackerman, LLC XFP-175134 AYi~ 1~Ik3 ~r ter ~~ i iii > ~ ~t~~trt Yx aia~~t011 tit a~ _ ~~ / LEGAL DE3CRIt''YION i ~ ~M~ atlr ~! M~ Y11a d ~tMrt sliirr~ew tri1 W IM~r~l~w~r~f aNll~1~ ~ iNllsos sat~~Maq- ~s+ta•~ra! ~~a »~dw1 t rlk >lnm. t~iYt.~ ~, a+a wr~lc~lr taltttl eft tt~ r~att~r il~ttir~ iloMatltM BEING trot. carne pr+ehtieies whk~t RO6~RT.8, CORMANY AND SHARLENE R. C4RMANY, HW38AND AND WIRE, by C)eed~4+~sd AuEuat 31, 20U5, and rocordod Auguut 31, 2006, In the Oltice pf ~ ~ordet' of Deeds kt and for the County of Cumberland, PertMytveacia, M Book 270, Pbge 3519, gnnteo and conveyed unto ,kAMI~$ R. BENNlrTT. 7haeaid JAMES R. BENNETT, ons of ttre yrantare heregh, Is nov„ marrlet! to GORRfNE E, BtiFlE7T, one of the qre~ heroin. The said CORIWNE E. t3ENNET'I' joins in the exeeutron of this deed to convey any Mterest she may have kt thii property. Also BEING the same Wises which JAMES R, l3ENNE't'1' AND CORtNNt E, t~ENNETT ~ Decd dated Ck~- ,~ti ~ ~~-~S and about to n3coMed, M the Oflta of #re Raoordir d Daec~ to ~rnf ibr ~ County of Cumberland, Pennayh+ania, ~rbribed acid conveyed +Ktbp JOSEi.RO p, Ntl/ALGA /~ KAREk M. NEVALGA, H1S WIFE, Mor~agote herein. n~r~ ca„n~trnenc schebute A (condnuadJ. VERIFICATION Denise Goldston, hereby states that he/~ie 's Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that he/ em'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 h' er ormation 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. ~c Name: Denise Goldston Title: Vice President Loan Documentation Company: Wells Fazgo Bank, N.A. Date: 01/15/2013 086-PA-V2 File # XFP175134 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION vs. Joselito B. Nevalga; Karen M. Nevalga; Defendants. NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM ~~ r-n,r ~~ /~ N ~~ ~~ ~.y~~y~ i.~ ~~ -~ -< N w c-. „~.. 1 V r"~S rv x-- You have been served with a foreclosure complaint that could cause you to lose your home. "rF _~ ~i.rt ~n .nX p .^ 1 ly.~ ~ ~ `r-r1{ ~ 1 If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you. must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPe~nn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to Zucker, Goldberg & Ackerman, LLC XFP-175134 work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST AC'f QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TIDS PROGRAM IS FREE. ZUCKER, GOLDBERG & ACKERMAN, LLC By: Dated: January ~~ , 2013 Sco . Di tteric , squ A I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #3()6799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-175134/jab 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-175134 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete• your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email: # of people in household: State: Zip: Yes ^ No ^ Listing date: Price: $ Realtor Phone: Yes ^ No ^ State: Zip: Home: Office: Cell: Other: How long? Mailing Address: city: Phone Numbers: Email: # of people in household: First Mortgage Lender: Home: Cell: State Office: _ Other: How long? Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Date you closed your loan: Zip: Zucker, Goldberg & Ackerman, LLC XFP-175134 Assets Home: Other Real Estate: Retirement Funds: Investments: Checking: Savings: Other: Automobile #1: Amount owed: Automobile #2: Amount owed: Amount Owed: Model: Value: Model: Value: Year: Monthly Income Name of Employers: 1. 2. 3. __ Additional Income Description (not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ^ No ^ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Email: Fax: Value: Year: Zucker, Goldberg & Ackerman, LLC XFP-175134 Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ^ No ^ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ^ No ^ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: Phone: I/We, ,authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information to lender and lender's counsel: V Proof of Income V Past 2 bank statements V Proof of any expelled income for the last 45 days V Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) V Listing agreement (if property is currently on the market) Zucker, Goldberg & Ackerman, LLC XFP-175134 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.. vs. loselito B. Nevalga; Karen M. Nevalga; Defendants. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property, which is defendant's primary residence; 2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in acourt-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Signature of Defendants Counsel/Appointed Date Legal Representative Signature of Defendant Signature of Defendant Date Date Zucker, Goldberg & Ackerman, LLC XFP-175134 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. Joselito B. Nevalga; Karen M. Nevalga; CIVIL DIVISION NO.. Plaintiff, Defendants. CASE MANAGEMENT ORDER AND NOW, this day of ,20 ,the defendant/borrower in the above- captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in acourt-supervised conciliation Conference on at .M. in Cumberland County Courthouse, Carlisle, Pennsylvania. at the 1. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 2. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/tender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable Zucker, Goldberg & Ackerman, LLC XFP-175134 resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 3. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse martgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker, Goldberg & Ackerman, LLC XFP-175134 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C:) C=:? ZS Moo rn= Wells Fargo Bank, N.A., CIVIL DIVISION CD' Plaintiff No.: 13-384 CIVIL C) CD VS. ISSUEAUMBER: Joselito B. Nevalga; Karen M. Nevalga; TYPE OF PLEADING: Defenclant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) Mortgaged Premises: 1883 Douglas Drive, Carlisle, PA 17013-4612 FILED ON BEHALF OF: Wells Fargo Bank, N.A. Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER,GOLDBERG&ACKERMAN, LLC Scott A. Dietterick, Esquire-Pa I.D.# 55650 Kimberly A. Bonner, Esquire- Pa I.D.#89705 Joel A.Ackerman, Esquire-Pa I.D.#202729 Ashleigh L. Marin, Esquire-Pa I.D.#306799 Ralph M. Salvia, Esquire- Pa I.D.#202946 Jaime R.Ackerman, Esquire- Pa I.D.#311032 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500 Atty File No.: XFP-175134 Praecipe for Entry of Judgment Zucker,Goldberg&Ackerman, LLC XFP-175134 ce r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-384 CIVIL Joselito B. Nevalga; Karen M. Nevalga; Defendants. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s),for failure to file a response to Plaintiffs Complaint within the appropriate time limits from service thereof,and assess Plaintiffs damages as set forth in Complaint: Amount as set forth in Complaint $129,409.77 plus interest on the judgment amount($129,409.77)from January 12,2013,at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 1883 Douglas Drive 41 E North St, address is: Carlisle, PA 17013-461 Carlisle PA 17013-2429 ZUCKER,GOLBEER &,AeKERMAt, Dated: BY: R Joel A.Adkefi'man, Esquire; PA I.D.#202729 R Ashlej(h L. Marin, Esquire; PA I.D.#306799 ©� Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-175134 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com DAMAGES ARE HEREBY SSESSED AS INDICATED 0 0e` Date sju/ 3 Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 13-384 CIVIL VS. Joselito B. Nevalga; Karen M. Nevalga; Defendants. AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. ZUCKER,GOLBJ:'RG,.&ACKERMAN' LLC Dated: BY: zx//y ❑ JoeI`A. dkerman�squire; PA I.D.#202729 ❑ Ashler L. Marin, Esquire; PA I.D.#306799 ®/Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-175134 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoIdberg.com Sworn to and subscribed before me This QO day of Mai , 20 1 3 Notary P lic My Commission Expires: Cheryl Debeneadto Notary Public My Comm.Expires Oct 16,2016 ID#2280276 state of New Jersey Zucker,Goldberg&Ackerman, LLC XFP-175134 Department of Defense Manpower Data Center Results as of:May-16-201310:22:50 SCRA 3.0 �i Status J!"Lup Pursuant to Siervicernembers Ciwyl.Relief Act. Last Name: NEVALGA First Name: JOSELITO Middle Name: B Active Duty Status As Of: May-16-2013 On Active Duty On Active Duty Status Data Active Duty Start Date Active Duty End Date status Service Component NA NA ,!\ .'�V _ - -1` No\ NA _ r-+.::- This response reflecl1iia'1ndidivlaual active duly status based n tha Acflve Duty Status Data Left Active Duty Within 367 Days of Acute Duty Status Date Active Duty Start Date Active Duty End Date * Status Service Component NA r!, :'Nq '� '%3x'"d'� .� �'�.r .=tJo'7 j' :r.,...; NA This response reflects where ttie Ind Mduat left active duty status within 367 days preceding the',Active Duty Status Date The Member or HlstHer Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component {. NA1. This response reflects whether the 1rQdual rnhislhe unit h�as mmNed-early notl6cation"M report for active duty '� tit ire, Upon searching the data banks of the Department of Defense Manpower Data-Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. hiwt A 464-..A�M__ Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.miVfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: C2K207DE200A9B0 I Department of Defense Manpower Data Center Results as of:May-16-20131020:54 SCRA 3.0 Status Report Pursuant to Sery cemniben Civil.Relief Act. Last Name: NEVALGA First Name: KAREN Middle Name: M Active Duty Status As Of: May-16-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date t�yy Status Service Component NA NA �.irj . _. L�I -,�. Nom NA This response reflects the IridNiduals'active dory status basedion the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA j��`�7NA '`+w."�:.�c.� 1 i!�`ra.�.No'3 r!�'fir, NA 1 . This response reflects Wre'the,IndMdual left actnre Bury status within 367 days preceding the Active Duty Status Date The Member or HisMer Unit Was Notified of a Future CaIWp to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA �N,A 7 �,T,+.S-::._._ .� ��Xr�_tJo -",� NA ";( e`'v.. '`.+:_ter�:.+�.r �a+!f "�`..r This response reflects whether the Individual or hW4r unit has_received early noUficat h ro report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,bated on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAH,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. 41a�� { '~ Jr, Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA maybe invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(9 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAH Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 82W 1 X70E700AF60 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-384 CIVIL Joselito B. Nevalga; Karen M. Nevalga; Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Joselito B. Nevalga 41 E North St, Carlisle PA 17013-2429 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on /)12/1 [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows:$129,409.77 pl s costs. Y ,t Prothonotary Zucker,Goldberg&Ackerman, LLC XFP-175134 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-384 CIVIL Joselito B. Nevalga; Karen M. Nevalga; Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Karen M. Nevalga 1883 Douglas Drive Carlisle, PA 17013-4612 [ ] Plaintiff [-4] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $129,409.77 p us costs. i 1 Prothonotary .. Zucker,Goldberg&Ackerman, LLC XFP-175134 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-384 CIVIL Joselito B. Nevalga Karen M. Nevalga Defendant. IMPORTANT NOTICE TO: Joselito B. Nevalga 41 E North St, Carlisle PA 17013-2429 DATE OF NOTICE: 3/4/2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten(10)days from the date of this notice,a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one,go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-384 CIVIL Joselito B. Nevalga Karen M. Nevalga Defendant. AVISO IMPORTANTE TO: Joselito B. Nevalga 41 E North St, Carlisle PA 17013-2429 FECHA DEL AVISO:3/4/2013 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS D4PORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INNIEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYERREFERR.AL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER,GOLDBERG &ACKERMAN BY: Scctt A. D ie taick Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.U. Box 1024 Mountainside,NJ 07092-0024 (717) 5 33-35 60 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 175134 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-384 CIVIL Joselito B. Nevalga Karen M. Nevalga Defendant. IMPORTANT NOTICE TO: Karen M. Nevalga 1883 Douglas Drive Carlisle, PA 17013-4612 DATE OF NOTICE: 3/4/2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten(10)days from the date of this notice,a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one,go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-384 CIVIL Joselito B. Nevalga Karen M.Nevalga Defendant. AVISO IMPORTANTE TO: Karen M. Nevalga 1883 Douglas Drive Carlisle, PA 17013-4612 FECHA DEL AVISO:3/4/2013 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOM-AR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUNIENTO MIYEDIA.TAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFICRQA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER,GOLDBERG &ACKERMAN BY: Soon A. D ietterick Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 175134 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff at cumber��fr4 Jody S Smith Chief Deputy J } Richard W Stewart SO/lcitor pFFiCE OF THE&t+ FF Y Wells Fargo Bank, NA. Case Number vs. Joselito B. Nevalga(et al.) 2013-384 :{ SHERIFF'S RETURN OF SERVICE 01/31/2013 08:36 PM-Deputy Shawn Gutshall, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Joselito B. Nevalga at 41 E. North Street,,Carlisle Borough,Carlisle, PA 17013. t I S S EPUTy j 01/31/2013 08:51 PM-Deputy Shawn Gutshall, being duly swom according to law, served the requested Notice of } Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to-a person representing themselves to be the Defendant,to wit: Karen M Nevalga at 1883 Douglas.Drive, North Middleton Township, Carlisle, PA 17013. i • TSH , EPUTY d SHERIFF COST:$56.00 SO ANSWERS, a 6z Cy February 06,2013 RbNW R ANDERSON, SHERIFF .l ;l t ±j 3 - l - F - (c)CounlySuita SherSH,ToleosoR,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Joselito B. Nevalga; Karen M. Nevalga; Defendants. TO THE PROTHONOTARY: NO.: 13-384 CIVIL PRAECIPE TO SATISFY JUDGMENT Please mark the judgment filed at the above -captioned term and number satisfied without prejudice. By: Dated: May 2, 2014 Respectfully submitted: ZUCKER, GOLDBERG & AGKERMAN, LLC Scott A. Dietterick, Euire; I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-175134/dcr 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com ; op Q6J co- lov/p3 Zucker, Goldberg & Ackerman, LLC XFP-175134