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HomeMy WebLinkAbout13-0492 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., Plaintiff, V5. Corey S. Shumberger; Crystal L. Shumberger; Defendants. TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULTJUDGMENT MAY BE ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF I5: 3476 Stateview Blvd.. Ft. Mill, SC 29715. AND THE DEFENDANT: 189 KonhausRoad Mechanicsburg. PA 17050-3127 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTE~BY THIS LIEN IS ATTORNEY Fi6R PLAINTIFF ATTY FILE NO.: XFP 175414 CIVIL DIVISION NO.. 1 ~, (.'~~~ C"') N ..'r'! TYPE OF PLEADING ~~ w T CIVIL ACTION - COMPLAINTS IN MORTGAGE FORECLOSU~ c" ~ ; o .. ~.., r cs ^3 FILED ON BEHALF OF: z~c' ~~ ,.,, =' ~'~ C~ Wells Far>;o Bank, N.A. ~~ ~ -~i -f i1J ''"' GJ 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(c?zucker~oldber~.com File No.: XFP-175414/cpad am+.~~03.7~z~~ C~~ U~ao ~3 l2~ a~s~(n~ 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 Wells Fargo Bank, N.A. vs. Plaintiff, Corey S. Shumberger; Crystal L. Shumberger; CIVIL DIVISION NO.. 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. vs. Plaintiff, Corey S. Shumberger; Crystal L. Shumberger; Defendants. AVISO CIVIL DIVISION NO.. USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demands establecida en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demands 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 falls en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier sums de dinero reclamada en la demands 0 cua Iquier otra reclamacibn o remedio 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 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, NO.. vs. Corey S. Shumberger; Crystal L. Shumberger; 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, Corey S. Shumberger, is an individual whose last known address is 189 Konhaus Road, Mechanicsburg, PA 17050-3127. 3. The Defendant, Crystal L. Shumberger, is an individual whose last known address is 189 Konhaus Road, Mechanicsburg, PA 17050-3127. 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 March 30, 2004, Corey S. Shumberger and Crystal L. Shumberger made, executed and delivered to The Washington Savings Bank, FSB a Mortgage in the original principal amount of $145,800.00 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 April 12, 2004, in Mortgage Book\Volume 1860, Page 1888. 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. 6. By Assignment of Mortgage recorded March 31, 2005, the mortgage was assigned to Washington Mutual Bank, FA which assignment is recorded in the Office of the Recorder of Deeds for Zucker, Goldberg & Ackerman, LLC XFP-175414 062-PA-V3 Cumberland County in Assignment Book 716, Page 1595. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 7. Plaintiff is the current Mortgagee. By further Assignment of Mortgage recorded August 31, 2010, the mortgage was assigned to Wells Fargo Bank, N.A., which assignment is recorded in the Office of the Register of Deeds for Cumberland County, Instrument #201024190. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 8. Corey S. Shumberger and Crystal L. Shumberger, husband and wife are record and real owners of the aforesaid mortgaged premises. 9. 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 April 1, 2012. 10. As of 01/04/2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $126,369.13 Interest through 01/04/2013 $ 6,114.92 Escrow Advance $ 1609.25 Late Charges $ 170.15 Inspection Fees $ 45.00 Total $ 134,308.45 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and PlaintifYs attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 11. 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 Zucker, Goldberg & Ackerman, LLC XFP-175414 062-PA-V3 Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 12. This action does not come under Act 91 of 1983 because the mortgage is FHA insured. 13. 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 $134,308.45 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, GOLDBE ACKERM ,LLC BY: ~• Dated: /~~ Scott ietterick, Esquire; PA LD. #55650 `7 I ~ Kim rly 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-175414/cpad 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com THIS /S AN ATTEMPT TO COLLECT A DEBT, ANO ANY INFORMATION 08TAfNED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP-175414 062-PA-V3 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-175414 062-PA-V3 Loda ID #~ Multistate NOTE FFIA Caar Nu. March 30th, 2009 New Cumberland, PA IDateJ (City) Istarel 189 Konhaua Road, Machaaiceburg, PENNSYLVANIA 17050 [Pn,txny AldrcssJ 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" trtCans The 1lashingtoa Savings Bask, FSB and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of one Hundred Forty Pive Thousand Bight Hundred- - - - - - - - - - - - - - - - - - - -" Dollars (U.S. $ 145, 800.00 )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 Five and three quarters percent ( 5.750 ~,) 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 similar security instruntem that is dated the same dale 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 utt May lot, 2004 .Any principal and interest remaining on the first day of April, 2034 will be due on chat date, which is called the "Maturity Date." (B) Puce Payment shall be made at 4201 Mitchellville Road, Ste. 300, Bowie, Maryland 20716 ar at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 850.85 This amount will be part of a larger monthly payment required by the Security Instrument, [hat shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Alloage to this Note for Payment Adjustments if an allonge providing for paytttent adjustments is executed by Borrower together with this Note, the covenams of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allottge were a part of this Note. [Check applicable box] Graduated Payment Allonge ^ Otlter [specify] Growing Equity Atlonge 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in pan, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays imctts[ 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 prepayntcnt, there will be rto changes in the due date or in the amoum of Ole monthly payment unless Lender agrees in writing [o those changes. 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 the end of Fifteen calendaz days after the payment is tiuc, Lender nk~y collect a late chazge in the amount of Fouz 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 Leader may, except as limited by regulations of the Secretary in the case of paymem defaults, require immediate payment in full of the principal b:dance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the Initials: ~_ FHA atultistste Rate Note - IZ/95 AAFNIC -09112001 Page I of 2 xww.hlortgegdirmkingtipstems.com Loan ID # event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights [o require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Larder 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 [o the extent no[ 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 the rights of presentt»ent and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8, GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borcower under this Note wilt be given by delivering is or by mailing it by first class mail to Borrower at the property address above or a[ a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Linder under this Note will be given by first class mail to Lcndcr at rite address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of chat different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person if 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 wito is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person wlta takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories [ogether. 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 ag to [he to and covenants contained in this Note. (Seal) rey S. hwtrborgt+r -Borrower (Seal) C~Shttmberger -Borcower ry PAYTO THE ORDER OF washingttin Mutual Bank, FA (seal) ' WITHOUT RECOURSE -Borrower THE. HIN ' e~/~i~S BANK, FSH fr.~~-;~ tS... (Seap E zabeth A. Manition -Borrower Mortgage Origination Manager (Seal) -Borrower Pay to the order of Bank of America, N.A, Without Rsc~urae W hington M uatl Bank Je:;s Alrnan VP (Seal) -Borrower WASHINGM~~IJ ~ANK WASHINGTON MUTUAL BANK, FA By BRENDA F BRENDLE FIRST VICE PRESIDENT MFlC2G -09142001 Page 2 or 2 www.~lorlgugcnanl:ingtiysrens.com EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-175414 062-PA-V3 zacu>a azsca=~rztnr A.LL THAx ~~ItTA~! pt~e or parcel of lead situate in the Township of Silver Sig, County of C?tttobarl~d and State of Fennsylvsnia, bounded and deaaibed as follow=, to wit; BSt~INNING at a point in.the center line of a publLc towgship road (T-366), known us ~Conhseu; Road, wht'ch said point is iu ~ the diviaiatt line betwee.it Lots Nos. 12 and 13 ova the baeinaftar meettio~+od Plan of Lots; dvcace along tho divi~on lirw beta+~ Lots Nos. 12 and 13, South 88 degrees 0$ minutes ZO seconds Weat, thctie huu-dred eighty-eight wind tllirty~fiva ane hundredths 0$8,35) fact to a point; dice along the division line between lots Nos. 13 and 21, Lot9 Nos. 13 and ZO amd Lots; Nos. l3 and (9, North l 7 dew 03 minutes 02 seconds Bast, ono hundred sew~oaty andthirty-tie one kwadre~s (17A.33) tit to a point he tlm division liua between Loq Nos,13 and 14 on said Play; thence alonb the division tine bdween Lots Nan. l 3 sad 14, lYorth $$ dogroes 08 minutes 20 panda last, three hundred thirgr-tluraa sad fourteen auahuetchedths (333.14) £eet to a point ~ the r line of Konhaus Road, (Townshfp Road 'f•S66); theaex along dta center line of said road, South 01 degree S 1 ntinutee a0 sacoads East, one hundred sixty-one sad fourtoai one lsaZtdt+odlltt (Id1.14} feet to a palm iet the dlvlsicm l~aa batwoe~a, Late Nos. 12 And 13 sat said P'laxt, a1"o~tnerttiot~ad, at thQ powt and plane of SBQ, BE,tNG Lot No: ~13 on tl~ ~ of Lots of Clapper Ferran, Inc., and k~novvn as ~Rittar INsnAr, which Play is rmccrtic~d iun the Cumbactaitd County Rac~order's Cdllce iq P1aa Hook 2 t, at f 8. HA~VIfi1G TI~RE0F1 aatted a sirtgle family' dwelling house 8$I~6 .'ERIC S~ >'~.~ ~ Qaul E. Shumberger, a married man, by h~.s deed, tlatgd ~i,Q,~t'~_,, 2009, and about to be recorded S.n the Office of the Recoxde.r of beads. in and for Cumberland~County, Pennsylvania, granted an~~on~gye.~l unt;~ Corey S. Shumbe~rger, a single man, Mortgagor Here t'+Xiiy N1S t0 ~ 1't3~~~T~1~'e! .Fn Cumberland Cowrty 1'l1 ' Recorder of Dads VERIFICATION Darren Britt, hereby states that~'she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., Plaintiff in this matter, thati h~'she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of~her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. ~Y`r Name: Darren Britt Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 01/16/2013 (~ ~ ~~ Fii~ 1714 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, vs. Corey S. Shumberger; Crystal L. Shumberger; Defendants. ,~ -~ CIVIL DIVISION ~;, ~„ --+~„ 1 u3 ~-- r ° ' ~-T-s ~ ,, ~ c-~ ~y ~ ,..A `_~ `=-~ ~~'t~ .+ ~, ~ . ~ r.~ w ~, _~ NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Zucker, Goldberg & Ackerman, LLC XFP-175414 Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TIDS PROGRAM IS FREE. ZUCKER, GOLDBERG & KERMAN, LLC By: Dated: January ~~ , 2013 Scott A. i rick, Esquire; PA I.D. #55650 Kimberly .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-175414/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-175414 ' 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: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: First Mortgage Lender: Yes ^ No ^ Yes ^ No ^ Listing date Home: Cell: State: Zip: Price: $ Realtor Phone: State: Zip: Office: Other: Type of Loan: Loan Number: Second Mortgage lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Included Taxes & Insurance: Primary Reason for Default: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: How long? Date you closed your loan: Zucker, Goldberg & Ackerman, LLC XFP-175414 Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Amount owed: Automobile #2: Amount owed: Model: Model: Value: Monthly Income Name of Employers: 1. Year: Year: 2. 3. Additional Income Description (not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT 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: Zucker, Goldberg & Ackerman, LLC XFP-175414 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 ~ Past 2 bank statements ~ Proof of any expected income for the last 45 days ~ 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-175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION vs. Plaintiff, NO.. Corey S. Shumberger; Crystal L. Shumberger; 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 Defendant's Counsel/Appointed Legal Representative Signature of Defendant Signature of Defendant Date Date Date Zucker, Goldberg & Ackerman, LLC XFP-175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.. Corey S. Shumberger; Crystal L. Shumberger; 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/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable Zucker, Goldberg & Ackerman, LLC XFP-175414 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 mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker, Goldberg & Ackerman, LLC XFP-175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA C) Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, MCD NO.: 13-492 CIVIL -VM vs. r") ;:0 - C) Corey S.Shumberger;Crystal L.Shumberger; 6 Defendants. C> 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 Plaintiff's Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $134,308.45 plus interest on the judgment amount($134,308.45)from January 05, 2013,at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known' 189 Konhaus Road address is: Mechanicsburg, PA 17050-3127 ZUCKER',GO ACKERMAP, LLC Dated: RIO BY: Joel A Ackerman, squire; PA I.D.#202729 Ash /Tigh L. Marin, Esquire; PA I.D.#306799 Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-175414 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX Email: Office@zuckergoldberg.com DAMAGES ARE HEREBY ASSESSED AS INDICATED Date 4MC =3V Prothonotary q ?#c1loS39 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-492 CIVIL Corey S.Shumberger; Crystal L.Shumberger; 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 1, 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,GOLBE sfi� &-_ACKER�MAN, LL Dated: BY: ❑ Joel A.Ac4(efman, Esquire; PA I.D.#202729 ❑ Ashleigh L. Marin, Esquire; PA I.D. #306799 71 Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-175414 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX Email: Office @zuckergoldberg.com Sworn to and subscribed before me This 'f day of �a7 , 20/3 Not ry Pu lic My Commission Expires: Cheryl Debeneadto Notary Public Cheryl Debeneadto Nolo My Comm.Expires Oct. 16,2016 My Comm.Expires Oct. ' o ID#2280276 ID#2280276 State of New Jersey State of New Jersey Zucker,Goldberg&Ackerman, LLC XFP-175414 Department of Defense Manpower Data Center Results as of:May-17-2013 08:17:00 SCRA 3.0 0 Status Repott Pursuant to Servicemembers Civil Relief Act 1 Last Name: SHUMBERGER First Name: CRYSTAL Middle Name: L Active Duty Status As Of: May-17-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA `No`,\ NA This response reflects the iridiiRduais active i64 sitrtus based w'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 ji- NA dui�st!iy�within 36�jays preceding the Active Duty Status Data This response reflects 6ere the'IndlUldual left act ng The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA ANA� N�o NA This response reftects,whether the lndfvldual orhisther 1inli ta-s received 0;dy notification I to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard), This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Aak� )Ffk Ava 4- ,AF Mary M.Snavety-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)(formeriy 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/fagtpis/PC09SLDR.htmi. 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(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 USG§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: 72XBC9DEP05CS80 Results as of:May-17-2013 08:12:56 Department of Defense Manpower Data Center SCRA 3.0 Status Report PUrSU&nt to Sery cernembers Civil Relief Act. Last Name: SHUMBERGER First Name: COREY Middle Name: S. Active Duty Status As Of: May-17-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End,Date Status Service Component NA NA// \��,V ;_ -- +,�.� °� No�t NA This response reflesis the indrvtduals'active duty status based own the Active Duly Status Date kwl Left Active Duty Within 367 Days of Acute Duty Status Date Active Duty Start Data Active Duty End Date Status Ser ce Component NA �11_ iNA� .��`'.. �� �. � a: �'�� '1 NA This response reflects vfie a th9 Individual left actnre duty status vdlhin 367 days preceding the Active Duty Status Date 1,4 The Member or His/Her Unit Was Notified of a Future Gall-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA "or L 4�:._Win. J. This response reflects whether the Individual hisrher unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,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. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. ' The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.htmi. 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(1)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: N2P3592ES05BE00 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 13-492 CIVIL VS. Corey S. Shumberger;Crystal L.Shumberger; Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Corey S. Shumberger 189 Konhaus Road Mechanicsburg, PA 17050-3127 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on 1 [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $134,308.45 plus costs. ORO oar r Zucker,Goldberg&Ackerman, LLC XFP-175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 13-492 CIVIL vs. Corey S.Shumberger; Crystal L.Shumberger; Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Crystal L.Shumberger 189 Konhaus Road Mechanicsburg, PA 17050-3127 [ ] Plaintiff [V] 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: $134,308.45 plus costs. Prothonotary Zucker,Goldberg&Ackerman, LLC XFP-175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank,N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-492 CIVIL Crystal L.Shumberger Corey S.Shumberger Defendant. IMPORTANT NOTICE TO: Corey S.Shumberger 189 Konhaus Road Mechanicsburg, PA 17050-3127 DATE OF NOTICE: 3/412013 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.: 13-492 CIVIL Crystal L.Shumberger Corey S.Shumberger Defendant. AVISO IMPORTANTE TO: Corey S.Shumberger 189 Konhaus Road Mechanicsburg, PA 17050-3127 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 PROXIMMOS 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 EVIPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO IN1-/1EDIA.TAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO O NO PUEDE PAGAR UNO, VAYA O LLAME LA OFIC NA 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: Scott A. D ietteridc 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 175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-492 CIVIL Crystal L.Shumberger Corey S.Shumberger Defendant. IMPORTANT NOTICE TO: Crystal L.Shumberger 189 Konhaus Road Mechanicsburg, PA 17050-3127 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.: 13-492 CIVIL Crystal L.Shumberger Corey S.Shumberger Defendant. AVISO IMPORTANTE TO: Crystal L.Shumberger 189 Konhaus Road Mechanicsburg, PA 17050-3127 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 PROXIMMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUVA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS DOORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INIVIEDIATAIVENTE 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 &•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: Slodt 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 175414 l 5 • C • SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson / Sheriff 1 1 - ��c��tY cif�curctiriy� � ' Jody S Smith Chief Deputy Richard W Stewart " ' Solicitor OFFlCE•PF THE SHERIFF i i i a Wells Fargo Bank, N.A. vs. Case Number i Corey S. Shumberger(et al.) 2013-492 SHERIFF'S RETURN OF SERVICE 01/31/2013 08:32 PM-Deputy Shawn Harrison, being duly swom.according to law, served requested Notice of Residential Mortgage Foreclosure Diversion Program&Complaint in Mortgag Fo closure by handing a true copy to a person representing themselves to be Corey Shunberger us b nd defendant,who accepted as"Adult Person.in Charge"for Crystal L.Shumberger at 18 us ad, Silver Spring } Township, Mechanicsburg, PA 17050. j - S HARRISON, DEPUTY 01/31/2013 08:32 PM-Deputy Shawn Harrison,being duly swom according to law,served the requested Notice of Residential Mortgage Foreclosure Diversion Program&Complaint in Mortgage o closure•by "personally"handing a true copy to a person representing themselves tVe D endant,to wit:Corey S. Shumberger at 189 Kbnhaus Road,Silver Spring Township, Mecha i 9t PA 17050. S WN H ISON, DEPUTY { J SHERIFF COST:$54.00 SO ANSWERS, I February 06,2013 RON R ANDERSON,SHERIFF i 1 i tj 1 j icy County$00Swriti,Tdoomit,Irm IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION • File No. 13-492 CIVIL Wells Fargo Bank,N.A., • Amount Due $134,308.45 • Plaintiff, • Interest from 01/05/2013 to date of sale $7,347.13 vs. • Corey S.Shumberger;Crystal L.Shumberger; Costs • • • Defendants. • • • • TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract of account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs upon the following described property of the defendant(s): See Exhibit"A"attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description;supply four copies of lengthy personality list): and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the endant(s)described in the attached exhibit. DATE: 1( t11 gnature: =Print Name: Scott A. Ciette, Jt ire Kimberly A. a onner,Esquire 4448 50 p, Orri Joel Ackerman,Esquire DO oar Ashleigh Levy Marin,Esquire �� 7 Ralph M.Salvia,Esquire /03.95 Jaime R.Ackerman,Esquire 140.50 n Address: Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 + PO A f l"y Mountainside,NJ 07092 . - xv, Attorney for: Plaintiff em' '' Telephone: 908-233-8500 Supreme Court ID No.: 55650 rn 89705 r t't 202729 '' '' 011 CZ+ 306799 {b , //11 202946 2 3 oZ•a 5 60e l 0 311032 c. es t"'.� •50 U- alit ©to�8 /ticker.Goldlmg,& •Ukennan.I,I( 12#X47 7�� XI l'-175-114 PE 10--it 46-sruici IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION '113 4.4 7, • z o ;= Plaintiff, NO.: 13-492 CIVIL tri vs. 1 —4 • Execution No.: y"C _ Corey S. Shumberger; Crystal L. Shumberger; �en �" • Defendant(s). • ..< Jr- AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 189 Konhaus Road, Mechanicsburg, PA 17050-3127. 1. Name and Address of Owner(s)or Reputed Owner(s): COREY S.SHUMBERGER AND CRYSTAL L. SHUMBERGER, HUSBAND AND WIFE 189 Konhaus Road Mechanicsburg, PA 17050-3127 2. Name and Address of Defendant(s) in the Judgment: COREY S. SHUMBERGER 189 Konhaus Road Mechanicsburg, PA 17050-3127 CRYSTAL L. SHUMBERGER 189 Konhaus Road Mechanicsburg, PA 17050-3127 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, N.A. Plaintiff 4. Name and Address of the last record holder of every mortgage of record: t4 ,1c:I<c^rnrin I.1( XI I'-175-I II WELLS FARGO BANK, N.A. Plaintiff WASHINGTON SAVINGS BANK 2900 Comly Road Philadelphia, PA 19154 WASHINGTON MUTUAL BANK, FA 270 Park Avenue New York, NY 10017 HOUSEHOLD REALITY CORPORATION 6226 Wilmington Pike Dayton,OH 45459-7008 DISCOVER BANK 6500 New Albany Road New Albany,OH 43054 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 Zucker,( oldhcra&Ackerman I,I(. XI l'-175414 UNKNOWN TENANT OR TENANTS 189 Konhaus Road Mechanicsburg, PA 17050-3127 UNKNOWN SPOUSE 189 Konhaus Road Mechanicsburg, PA 17050-3127 PA DEPT.OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to au horities. ZUCKER, GOLDB &A RMAN, BY: / L/ Dated: 7 (r„ Scott A. I let"Ick, Esq- re; PA I.D.#55650 ((((JJ�! Kimberly ;!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-175414/cal 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com /uckcr.Goldner!,8z Ackerman.I (� XI P-175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, • vs. NO.: 13-492 CIVIL • Corey S.Shumberger; Crystal L. Shumberger; • • Defendants. W • NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO o PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Corey S. Shumberger 189 Konhaus Road Mechanicsburg, PA 17050-3127 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on-37L05-/-2-01-4-at 10:00am prevailing local time. 3//0/010ly THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). The LOCATION of your property to be sold is: 189 Konhaus Road, Mechanicsburg,PA, 17050-3127 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 13-492 CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S)OF THIS PROPERTY ARE: Corey S. Shumberger; Crystal L. Shumberger A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, Zucker,Goldberg&Ackerman, LLC XFP-175414 within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800)990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. Zucker, Goldberg&Ackerman, LLC XFP-175414 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKER,GOLDBE• &ACKERMA t,/'LLC BY: A y � Dated: Ikp Scott . D i- i••, E ,f ire; PA I.D. #55650 Kimberly Bonner, Esquire; PA I.D. #89705 Joel A.A erman, 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.#311012,.. Attorneys for Plaintiff XFP-175414/cal 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker,Goldberg&Ackerman, LLC XFP-175414 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows,to wit: BEGINNING at a point in the center line of a public township road (T-566), known as Konhaus Road, which said point is in the division line between Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots;thence along the division line between Lots Nos. 12 and 13, South 88 degrees 08 minutes 20 seconds West,three hundred eighty-eight and thirty-five one hundredths(388.35)feet to a point; thence along the division line between Lots Nos. 13 and 21, Lots Nos. 13 and 20 and Lou Nos. 13 and 19, North 17 degrees 03 minutes 02 seconds East, one hundred seventy and thirty-three one hundredths(170.33)feet to a point in the division line between Lots Nos. 13 and 14 on said Plan;thence along the division line between Lots Nos. 13 and 14. North 88 degrees 08 minutes 20 seconds East,three hundred thirty-three and fourteen one-hundredths(333.14)feet to a point in the center line of Konhaus Road, (Township Road T-566);thence along the center line of said road, South 01 degree 51 minutes 40 seconds East, one hundred sixty-one and fourteen one hundredths(161.14)feet to a point in the division line between Lots Nos. 12 and 13 on said Plan, aforementioned, at the point and place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 189 Konhaus Road, Mechanicsburg, PA, 17050-3127. BEING the same premises which Paul E. Shumberger, married man, by Deed dated March 30, 2004 and recorded April 12, 2004 in and for Cumberland County, Pennsylvania, in Deed Book Volume 262, Page 2197,granted and conveyed unto Corey S. Shumberger and Crystal L.Shumberger, husband and wife. Tax Map No.: 38-22--0135-011. Zucker,Goldberg&Ackerman, LLC XFP-175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION T Plaintiff, a •vs. NO.: 13-492 CIVIL C� m - 'a • Corey S.Shumberger; Crystal L.Shumberger; Defendants. • • L NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Crystal L.Shumberger 189 Konhaus Road Mechanicsburg, PA 17050-3127 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 onetOrst2OTtrat 10:00am prevailing local time. 3l/ahlb/L/ THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). The LOCATION of your property to be sold is: 189 Konhaus Road, Mechanicsburg, PA, 17050-3127 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 13-492 CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Corey S. Shumberger; Crystal L. Shumberger A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be Zucker,Goldberg&Ackerman, LLC XFP-175414 disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone(800)990-9108 (717)249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. Zucker, Goldberg&Ackerman, LLC XFP-175414 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKER, GOL' :R :• ,C RM' , , LLC BY: / ti Dated: -2 l� Scott A. D.. trick, squire; PA I.D.#55650 �� Kimberly 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-175414/caI 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg&Ackerman, LLC XFP-175414 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring,County of Cumberland and State of Pennsylvania, bounded and described as follows,to wit: BEGINNING at a point in the center line of a public township road (T-566), known as Konhaus Road,which said point is in the division line between Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots;thence along the division line between Lots Nos. 12 and 13, South 88 degrees 08 minutes 20 seconds West, three hundred eighty-eight and thirty-five one hundredths(388.35)feet to a point; thence along the division line between Lots Nos. 13 and 21, Lots Nos. 13 and 20 and Lou Nos. 13 and 19, North 17 degrees 03 minutes 02 seconds East, one hundred seventy and thirty-three one hundredths(170.33)feet to a point in the division line between Lots Nos. 13 and 14 on said Plan;thence along the division line between Lots Nos. 13 and 14. North 88 degrees 08 minutes 20 seconds East,three hundred thirty-three and fourteen one-hundredths (333.14)feet to a point in the center line of Konhaus Road, (Township Road T-566);thence along the center line of said road,South 01 degree 51 minutes 40 seconds East, one hundred sixty-one and fourteen one hundredths(161.14)feet to a point in the division line between Lots Nos. 12 and 13 on said Plan, aforementioned, at the point and place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 189 Konhaus Road, Mechanicsburg, PA, 17050-3127. BEING the same premises which Paul E. Shumberger, married man, by Deed dated March 30, 2004 and recorded April 12, 2004 in and for Cumberland County, Pennsylvania, in Deed Book Volume 262, Page 2197,granted and conveyed unto Corey S.Shumberger and Crystal L. Shumberger, husband and wife. Tax Map No.: 38-22--0135-011. Zucker,Goldberg&Ackerman,LLC XFP-175414 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-492 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK,N.A., Plaintiff(s) From CORY S. SHUMBERGER; CRYSTAL L. SHUMBERGER (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $134,308.45 L.L.: .50 Interest from 1/5/13 to Date of Sale -- $7,347.13 Atty's Comm: Due Prothy: $2.25 Atty Paid: $202.75 Other Costs: Plaintiff Paid: Date: 1 I/5/13 •.JCa :tt62/1 David D. Bu-11,Prothonotary (Seal) : , / �� - i//_ _ Deputy REQUESTING PARTY: Name:JAIME R. ACKERMAN,ESQUIRE Address: ZUCKER,GOLDBERG&ACKERMAN,LLC 200 SHEFFIELD STREET, SUITE 101 MOUNTAINSIDE,NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No. 311032 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION (-1 — Plaintiff, NO.: 13-492 CIVIL vs. fir-1 . Execution No.: r'-- c� Corey S. Shumberger; Crystal L. Shumberger; V".? ,` • Defendant(s). • G •••s • . AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 189 Konhaus Road, Mechanicsburg, PA 17050-3127. 1. Name and Address of Owner(s)or Reputed Owner(s): COREY S. SHUMBERGER AND CRYSTAL L. SHUMBERGER, HUSBAND AND WIFE 189 Konhaus Road Mechanicsburg, PA 17050-3127 2. Name and Address of Defendant(s) in the Judgment: COREY S. SHUMBERGER 189 Konhaus Road Mechanicsburg, PA 17050-3127 CRYSTAL L.SHUMBERGER 189 Konhaus Road Mechanicsburg, PA 17050-3127 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, N.A. Plaintiff 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff WASHINGTON SAVINGS BANK 2900 Comly Road Philadelphia, PA 19154 WASHINGTON MUTUAL BANK, FA 270 Park Avenue New York, NY 10017 HOUSEHOLD REALITY CORPORATION 6226 Wilmington Pike Dayton, OH 45459-7008 DISCOVER BANK 6500 New Albany Road New Albany,OH 43054 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 SILVER SPRING TWP 6475 Carlisle Pike Mechanicsburg, PA 17050 AND C/O DEBRA WIEST,TAX COLLECTOR 269 Woods Drive, Mechanicsburg, PA 17050 CUMBERLAND VALLEY SCHOOL DISTRICT 6746 Carlisle Pike, Mechanicsburg, PA 17050 AND C/O DEBRA WIEST,TAX COLLECTOR 269 Woods Drive, Mechanicsburg, PA 17050 PENN WASTE P.O. Box 3066 York PA 17402 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 189 Konhaus Road Mechanicsburg, PA 17050-3127 UNKNOWN SPOUSE 189 Konhaus Road Mechanicsburg, PA 17050-3127 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Amended Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ZUCKER,GOLDBERG &ACKERMAN, LLC BY:flik Dated: gl 0 4.... Scott A. Dietterick, Esquire; PA I.D.#55650 Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A. Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 —Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-175414/cal 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows,to wit: BEGINNING at a point in the center line of a public township road (T-566), known as Konhaus Road,which said point is in the division line between Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots; thence along the division line between Lots Nos. 12 and 13, South 88 degrees 08 minutes 20 seconds West,three hundred eighty-eight and thirty-five one hundredths (388.35)feet to a point; thence along the division line between Lots Nos. 13 and 21, Lots Nos. 13 and 20 and Lou Nos. 13 and 19, North 17 degrees 03 minutes 02 seconds East, one hundred seventy and thirty-three one hundredths (170.33)feet to a point in the division line between Lots Nos. 13 and 14 on said Plan; thence along the division line between Lots Nos. 13 and 14. North 88 degrees 08 minutes 20 seconds East,three hundred thirty-three and fourteen one-hundredths (333.14)feet to a point in the center line of Konhaus Road, (Township Road T-566);thence along the center line of said road, South 01 degree 51 minutes 40 seconds East, one hundred sixty-one and fourteen one hundredths(161.14)feet to a point in the division line between Lots Nos. 12 and 13 on said Plan, aforementioned, at the point and place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 189 Konhaus Road, Mechanicsburg, PA, 17050-3127. BEING the same premises which Paul E.Shumberger, married man, by Deed dated March 30, 2004 and recorded April 12, 2004 in and for Cumberland County, Pennsylvania, in Deed Book Volume 262, Page 2197,granted and conveyed unto Corey S. Shumberger and Crystal L. Shumberger, husband and wife. Tax Map No.: 38-22--0135-011. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO 13492 CIVIL ` - r vs. ? �,C ' ) _ Corey S. Shumberger; Crystal L. Shumberger; TYPE OF PLEADING ` . Defendants. Pa. R.C.P. RULE 3129.2(C)AFFIDAVIT O ' . SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST C FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D.#55650 Kimberly A. Bonner, Esquire- PA I.D.#89705 Joel A.Ackerman, Esquire- PA I.D.#202729 Ashleigh Levy Marin, Esquire- PA I.D.#306799 Ralph M.Salvia, Esquire-PA I.D. #202946 Jaime R.Ackerman, Esquire- PA I.D.#311032 Jana Fridfinnsdottir, Esquire- PA I.D.#315944 Brian Nicholas, Esquire- PA I.D.#317240 Denise Carlon, Esquire- PA I.D. #317226 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500 (908)233-1390 FAX office@zuckergoldberg.com File No.: XFP- 175414/mag Zucker, Goldberg&Ackerman, LLC XFP-175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION • Plaintiff, • vs. NO.: 13-492 CIVIL • • Corey S.Shumberger; Crystal L. Shumberger; Defendants. • • Pa.R.C.P. RULE 3129(c)AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Margaret Agyepong, a paralegal with the firm of Zucker, Goldberg&Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiffs Notice of Sheriff's Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendants, Corey S. Shumberger and Crystal L. Shumberger, husband and wife, are the record owners of the real property. 2. On or about January 7, 2014, Corey S. Shumberger and Crystal L. Shumberger, were served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland County, at the address of the mortgaged premises, being 189 Konhaus Road, Mechanicsburg PA 17050-3127. A true and correct copy of said Return of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about February 7, 2014, Plaintiffs counsel served all other parties in interest with Plaintiffs Notice of Sheriffs Sale according to Plaintiffs amended Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre-Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit"B", attached hereto and made a part hereof. Finally,the undersigned deposes and says that the Defendants/Owners and all other Parties of Zucker, Goldberg&Ackerman, LLC XFP-175414 Interest were served with Plaintiff's Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER,GOLDBERG &ACKERMAN, LLC Attorneys for Plaintiff Dated: February-, 2014 MARGp AGYEPONG���� Paralegal/Legal Assistant Sworn to and subscribed before me this'll-day of February, 2 14 'YctC )\( Notary Public MY COMMISSION EXPIRES: PAUL C. NADRATOWSKI Notary Public of New Jersey ID# 2407850 My Commission Expires 4/27/2016 Zucker, Goldberg&Ackerman, LLC XFP-175414 EXHIBIT A Zucker, Goldberg&Ackerman, LLC XFP-175414 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff nntOrti Jody S Smith Chief Deputy Richard W Stewart Solicitor CFFICE CF T,,E SF'ERIFF Wells Fargo Bank, N.A. Case Number vs Corey S. Shumberger(et al.) 2013-492 SHERIFF'S RETURN OF SERVICE 01/08/2014 10:35 AM-Deputy Valerie Weary, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description;and Sale Handbill in the above titled action, upon the property located at 189 Konhaus Road, Silver Spring-Township, Mechanicsburg,PA 17050, Cumberland County. 01/08/2014 10:35 AM-Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ,Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant,to wit: Crystal L. Shumberger at 189 Konhaus Road, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County. 01/08/2014 10:35 AM-Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be crystal shumberger spouse,who accepted as"Adult Person in Charge"for Corey S. Shumberger at 189 Konhaus Road, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County. SHERIFF COST: $964.21 SO ANSWERS, January 29, 2014 RONNY R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleoaofi,Inc EXHIBIT B Zucker, Goldberg&Ackerman, LLC XFP-175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 13-492 CIVIL •vs. Corey S.Shumberger;Crystal L.Shumberger; Defendants. NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P.3129(b) TO: UNKNOWN TENANT OR TENANTS UNKNOWN SPOUSE 189 Konhaus Road 189 Konhaus Road Mechanicsburg, PA 17050-3127 Mechanicsburg,PA 17050-3127 COMMONWEALTH OF PENNSYLVANIA PA DEPT.OF REVENUE-INHERITANCE TAX DEPARTMENT OF WELFARE DIVISION P.O. Box 2675 Dept.280601 Harrisburg, PA 17105 Harrisburg, PA 17128-0601 CUMBERLAND COUNTY TAX CLAIM BUREAU CUMBERLAND COUNTY DOMESTIC RELATIONS Cumberland County Courthouse OFFICE One Courthouse Square Domestic Relations Section Carlisle, PA 17013 13 N. Hanover Street PO Box 320 SILVER SPRING TWP Carlisle, PA 17013 6475 Carlisle Pike Mechanicsburg, PA 17050 WASHINGTON SAVINGS BANK 2900 Comly Road SILVER SPRING TWP Philadelphia, PA 19154 C/O DEBRA WIEST,TAX COLLECTOR 269 Woods Drive, WASHINGTON MUTUAL BANK, FA Mechanicsburg, PA 17050 270 Park Avenue New York, NY 10017 CUMBERLAND VALLEY SCHOOL DISTRICT 6746 Carlisle Pike, HOUSEHOLD REALITY CORPORATION Mechanicsburg, PA 17050 6226 Wilmington Pike Dayton,OH 45459-7008 CUMBERLAND VALLEY SCHOOL DISTRICT C/O DEBRA WIEST,TAX COLLECTOR DISCOVER BANK 269 Woods Drive, 6500 New Albany Road Mechanicsburg, PA 17050 New Albany,OH 43054 Zucker,Goldberg&Ackerman,LLC XFP-175414 175414D1004CO2032014P1 PENN WASTE P.O. Box 3066 York PA 17402 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania,and to the Sheriff of Cumberland County,directed,there will be exposed to Public Sale in: the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 On 3/12/2014 at 10:00am,the following described real estate which Corey S.Shumberger and Crystal L. Shumberger, husband and wife are the owners or reputed owners and on which you may hold a lien or have an interest which could be affected by the sale of: 189 Konhaus Road, Mechanicsburg, PA 17050-3127 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). Zucker,Goldberg&Ackerman,LLC XFP-175414 175414D 1004CO2032014P2 The said Writ of Execution has been issued on a judgment in the action of Wells Fargo Bank, N.A. Plaintiff vs. Corey S.Shumberger,et al Defendant(s) at EX. NO. 13-492 CIVIL in the amount of$134308.45 plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty(30)days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriff's Sale or this Notice,you should contact your attorney as soon as possible. ZUCKER,GOLDBERG&ACKERMAN, LLC --) , By: 7 , .A- -�� ^�w-- Dated: /5/62.0 I '- Scott A. Dietterick, Esquire; PA I.D.#55650 I 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-175414/sde 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500;(908)233-1390 FAX Email: Office @zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XFP-175414 175414D1004CO2032014P3 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Silver Spring,County of Cumberland and State of Pennsylvania, bounded and described as follows,to wit: BEGINNING at a point in the center line of a public township road(T-566), known as Konhaus Road,which said point is in the division line between Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots;thence along the division line between Lots Nos. 12 and 13,South 88 degrees 08 minutes 20 seconds West,three hundred eighty-eight and thirty-five one hundredths(388.35)feet to a point; thence along the division line between Lots Nos. 13 and 21, Lots Nos.13 and 20 and Lou. Nos. 13 and 19, North 17 degrees 03 minutes 02 seconds East,one hundred seventy and thirty-three one hundredths(170.33)feet to a point in the division line between Lots Nos. 13 and 14 on said Plan;thence along the division line between Lots Nos. 13 and 14. North 88 degrees 08 minutes 20 seconds East,three hundred thirty-three and fourteen one-hundredths(333,14)feet to a point in the center line of Konhaus Road, (Township Road 1-566);thence along the center line of said road,South 01 degree 51 minutes 40 seconds East,one hundred sixty-one and fourteen one hundredths(161.14)feet to a point in the division line between Lots Nos. 12 and 13 on said Plan,aforementioned,at the point and place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 189 Konhaus Road, Mechanicsburg, PA, 17050-3127. BEING the same premises which Paul E.Shumberger, married man, by Deed dated March 30,2004 and recorded April 12, 2004 in and for Cumberland County, Pennsylvania, in Deed Book Volume 262, Page 2197,granted and conveyed unto Corey S.Shumberger and Crystal L.Shumberger, husband and wife. Tax Map No.: 38-22--0135-011. Zucker,Goldberg&Ackerman,LLC «Field2»-«Field 1» «Field I»D I004CO2/12/2008P4 Page 1 of 8 NOTICE TO LIENHOLDERS 2 UNITED STATES Certi i POSTAL S R I Mailing V E To pay fee,aftla stamps or meter postage r hen, This Certificate of Mailing provides evidence that mall has been presented to USPSe for malNng•This form may be used for domestic and international mall, From: Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 '_.__. ‘W Mountainside, NJ 07092 i XFP-175414/sde TCANI C To` UNKNOWN TENANT OR TENANTS Postmark Here 189 Konhaus Road Mechanicsburg, PA 17050-3127 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 S,+ U.S POSTAGE>>PITNEY BOWES 5 r (414' UNITED STATE5 0 120 POSTAL SERVICE® r «,,, This Certificate of Mailing provides evidence that mall has been presented to USPSe for mailing,This I and International mall. From Scott A. Dietterick, Esquire c/o Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM-C To' COMMONWEALTH OF PENNSYLVANIA Postmark'Here DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 County of P.Q.: CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 1 of 8 c+govt S J S POSTA' ...h,�1*1- x Page 2 of 8 NOTICE TO LIENHOLDERS � � t , ��i.ZOo .1 21P 07092 - 2'_1,. UNITED STATES Certificate Of 0001387 4+� E Mailing POSTAL SERVICES To,ay fee,affix stamps or meter postage This Certificate of Mailing provides evidence that mall has been presented to USPS'for mailing.This form may be used for domestic and International milli. From: Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM-.0 To: CUMBERLAND COUNTY TAX CLAIM BUREAU i Postmark Here - , Cumberland County Courthouse `o One Courthouse Square ; �, ; Carlisle, PA 17013 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 °ate ' % t i4,47 U S POSTAGE> PiTNEY BOWES ' 'UNITED STATES ,* 4` 02 07092 $ 001.200 1,44 0001387430FEB 07 2014 rPOST1LSERVICE S This Certificate of Mailing provides evidence that mall has bean presented to LISPS'for mailing.This form may be used for domestic and International mail. From, Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM.C To: SILVER SPRING TWP Postmark Herd 6475 Carlisle Pike Mechanicsburg, PA 17050 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 2 of 8 U S POSTAGE)>PTNEY BOWES Page 3 of 8 NOTICE TO UENHOLDERS e i""" . I ,F - 001 a UNITED STATES Certificate Of °� �POSTAL SERVICE Mailing To pay he,affix stamps or motor postage hen. This Certificate of Moiling provldea evidence that mall has been presented to USPS•for mailing.This form may be used for domestic and international mail. From` Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 3� XFP-175414/sde TEAM-G' _, v Toi SILVER SPRING TWP ; Postmark Here ' . '. C/O DEBRA WIEST,TAX COLLECTOR 269 Woods Drive, Mechanicsburg, PA 17050 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 ' it U.S.POSTAGE))FlTNEYBOWES r , as °'_, UNITED STATES 00120° w POSTAL SEl[p Yt, ICEiB 0001387430 FEB 07 2014 This Certificate of Mailing provides evidence that mall has been anointed to USPS°for mailing.This form may be used for domestic and International mall. From' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM G To: CUMBERLAND VALLEY SCHOOL DISTRICT Postmark Here 6746 Carlisle Pike, Mechanicsburg, PA 17050 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 3 of 8 I�S POSTAGE>>PITNEY BOWES Page 4 of 8 NOTICE TO LIENHOLDERS " zip 00i.2CP UNITED STATES Certificate Of Mailing POSTALSERVICES heroy fee,Mt stamps or meter postage This Certificate of Melling provides evidence that mall has been presented to LISPS•for mailing.This form may be used for domestic and International mall, from' Scott A. Dietterick, Esquire c/o Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM-C To' CUMBERLAND VALLEY SCHOOL DISTRICT Postmark-Here' C/O DEBRA WIEST,TAX COLLECTOR 269 Woods Drive, Mechanicsburg, PA 17050 County of P.O.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 U S POSTAGE>>PITNEY BOWES UNITED STATES xe `P \)' POSTAL SERVICES ., . r : ;, 9 This Certificate of Melling provides evidence that mall has been presented to UPS*for mailing• used for domestic and international mail. ffom' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM*C To' PENN WASTE Postmark Here P.O. Box 3066 York PA 17402 County of P.Q.: CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 4 of 8 US POSTAGE*PITNEY BOWES Page 5 of 8 NOTICE TO LIENHOLDERS1 �` jj � UNITED STATES Certificate Of � ` 0001387430 FFB 07 2014 / il/ POSTAL SERVICE Mailing To pay fee,affix stamps or mater postage hen. This Certiftcete of Mailing provides evidence that mall has been presented to USPS•for mailing.This form may be used for domestk and International mall. From' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC N 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM-C To' DISCOVER BANK Postmark Here 6500 New Albany Road New Albany,OH 43054 County of P.Q.: CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 oxerostooko UNITED STATES POSTAL SERVICES ` This Certificate of Mailing provides evidence that mall has been presented to USPS•for mailing.Thi end international mall. From' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM-C To: HOUSEHOLD REALITY CORPORATION Postmark Here 6226 Wilmington Pike Dayton,OH 45459-7008 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 5 of 8 US POSTAGE>>PITNEY BOWES Page 6 of 8 NOTICE TO LIENHOLDERS <h v.18 wow-t r { 01,20° --< « 0001387430 FEB 07 2014 jj UNITED STATES Certificate Of POSTAL SERVICES Mailing To pay fee,affil stamps or miler postage here. This Certificate of Mailing provides evidence that mall has been presented to USPS,for mailing,Thls form may be used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM-,C To' WASHINGTON MUTUAL BANK, FA Postmark Here 270 Park Avenue New York, NY 10017 County of P.Q..CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 `" UNITED STATES $ 0 POSTAL SERVICES This Certificate of Mailing provides evidence that mall has been presented to USPSW for mailing.This forr and International mall. From Scott A. Dietterick, Esquire c/o Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM-C To: WASHINGTON SAVINGS BANK ,Postmark Here 2900 Comly Road Philadelphia, PA 19154 County of P.Q.:CUMBERLAND PS Form 3817,AprIl 2007 PSN 7530-02-000-9065 Page 6 of 8 Page 7 of 8 NOTICE TO LIENHOLDERS qtr UNITED STATES Certificate Of Mill A SERVICES Mailing • OSTA L SE•`VI+ES hm y fee,affix stamps or meter postage This Certificate of Mailing provides evidence that mall has been presented to USPS•for mailing.This form may be used for domestic and Intemetional mall. From' Scott A. Dietterick, Esquire c/o Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 • XFP-175414/sde TEAM-C To' CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Po{tmark Here , i Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 •#$ 4 US.POSTAGE>>PITNEYBOWES UNITED STATES POSTAL SERVICE This Certificate of Melling provides evidence that mall has been presented to USPS•for mailing.This foi and inte,n,tsonel mat From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM-C To: PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Postmark Hai! �'__ Dept.280601 Harrisburg, PA 17128-0601 County of P.Q.:CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 7 of 8 U S POSTAGE>>PITNEY BOWES Page 8 of 8 NOTICE TO LIENHOLDERS e` 7, $ 001.2 UNITED STATES Certificate Of Mailing POSTALSERVICES To pay fee,affix stamps or meter postage here. This Certificate of Melling provides evidence that mall has been presented to USPSe for mailing,This form may be used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 XFP-175414/sde TEAM-C re g To: UNKNOWN SPOUSE Postmark Here 189 Konhaus Road Mechanicsburg, PA 17050-3127 County of P.O.: CUMBERLAND PS Form 3817,April 2007 PSN 7530-02-000-9065 Page 8 of 8 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff :'C\'v f f ON•31"Ai' , Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF C,E OF _t4f; : &rFIFF r� JI.!fri( 10 PM CU C3 R LA D COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Corey S. Shumberger (et al.) Case Number 2013 -492 SHERIFF'S RETURN OF SERVICE 01/08/2014 10:35 AM - Deputy Valerie Weary, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 189 Konhaus Road, Silver Spring - Township, Mechanicsburg, PA 17050, Cumberland County. 01/08/2014 10:35 AM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Crystal L. Shumberger at 189 Konhaus Road, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County. 01/08/2014 10:35 AM - Deputy Valerie Weary, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be crystal shumberger spouse, who accepted as "Adult Person in Charge" for Corey S. Shumberger at 189 Konhaus Road, Silver Spring Township, Mechanicsburg, PA 17050, Cumberland County. 03/11/2014 As directed by Jaime R Ackerman, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/9/2014 04/09/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed" as there was no representative for the Plaintiff present at the April 9, 2014 Sheriffs Sale of Real Estate. cab. SHERIFF COST: $992.05 SO ANSWERS, April 09, 2014 CountvS Sh..rif eloosoft, inc. RONIR ANDERSON, SHERIFF 07,2s -iod ctier- ek4 9s�t Y erfl 3© On November 6, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Silver Spring Township, Cumberland County, PA, Known and numbered as, 189 Konhaus Road, Mechanicsburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: November 6, 2013 By: Real Estate Coordinator S. • LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2013 -492 Civil Term Wells Fargo Bank, N.A. vs. Corey S. Shumberger Crystal L. Shumberger Atty.: Jaime R. Ackerman ALL THAT CERTAIN piece or par- cel of land situate in the Township of Silver Spring, County of Cumberland and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the center line of a public township road (T -S66), known as Konhaus Road, which said point is in the division line between Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots; thence along the division line between Lots Nos. 12 and 13, South 88 degrees 08 minutes 20 seconds West, three hundred eighty-eight and thirty -five one hundredths (388.35) feet to a point; thence along the divi- sion line between Lots Nos. 13 and 21, Lots Nos. 13 and 20 and Lou Nos. 13 and 19, North 17 degrees 03 minutes 02 seconds East, one hundred seventy and thirty -three one hundredths (170.33) feet to a point in the division line between Lots Nos. 13 and 14 on said Plan; thence along the division line between Lots Nos. 13 and 14. North 88 degrees 08 minutes 20 seconds East, three hun- dred thirty -three and fourteen one - hundredths (333.14) feet to a point in the center line of Konhaus Road, (Township Road T -S66); thence along the center line of said road, South 01 degree 51 minutes 40 seconds East, one hundred sixty -one and fourteen one hundredths (161.14) feet to a point in the division line between Lots Nos. 12 and 13 on said Plan, afore- mentioned, at the point and place of BEGINNING. HAVING thereon erected a dwell- ing house being known and num- bered as 189 Konhaus Road, Me- chanicsburg, PA, 17050 -3127. 70 BEING the same premises which Paul E. Shumberger, married man, by Deed dated March 30, 2004 and recorded April 12, 2004 in and for Cumberland County, Pennsylvania, in Deed Book Volume 262, Page 2197, granted and conveyed unto Corey S. Shumberger and Crystal L. Shumberger, husband and wife. Tax Map No.: 38 -22 -- 0135 -011. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 24, January 31, and February 7, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. sa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this a of February, 2014 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 - . The Patriot -News Co. 42020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717 - 255 -8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 he atriotXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and /or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M ", Volume 14, Page 317. It 2013 -492 Civil T m _Wells Fargo Bank, .A. ty Vs Corey S. Shumbe ger rystal L. Shumberger : Jaime R Ackerman ALL THAT CERTAIN piece or parcel of land situate in the Township of 1 Silver Spring, County of Cumberland °' and State of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point in the center line of a public township road (T -S66), known as Konhaus Road, which said point is in the division line between l Lots Nos. 12 and 13 on the hereinafter mentioned Plan of Lots; thence along the division line between Lots Nos. 12 and 13, South 88 degrees 08 minutes 20 seconds West, three hundred eighty-eight and thirty-five one ' hundredths (388.35) feet to a point; thence along the division line between Lots Nos. 13 and 21, Lots Nos. 13 and 20 and Lou Nos. 13 and 19, North 17 degrees 03 minutes 02 seconds East, one hundred seventy andthirty-three ' one hundredths (170.33) feet to a This ad ran on the date(s) shown below: 01/19/14 01/26/14 02/02/14 Sworn t and s scribed before me this of February. 014 A.D. is COMMONWEALTH OF PENNSYLVANIA Notarial seal Holly Lynn Vticrfel, Notary Public Washington Twp., IbuphIn County My Comml,slon Explrrs Dec. 12 201 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES IN TI-It COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Corey S. Shumberger; Crystal L. Shumberger; Defendants. NO.: 13 -492 CIVIL PRAECIPE TO SATISFY JUDGMENT TO THE PROTHONOTARY: Please mark the judgment filed at the above - captioned term and number satisfied without prejudice. By: Dated: April 14, 2014 Respectfully submitted: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032— Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP- 175414/dcr 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com CLii-1037v2 ki-Zoqcpc Zucker, Goldberg & Ackerman, LLC XFP - 175414 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Corey S. Shumberger; Crystal L. Shumberger; Defendants. TO THE PROTHONOTARY: NO.: 13 -492 CIVIL • PRAECIPE TO SATISFY JUDGMENT Please mark the judgment filed at the above - captioned term and number satisfied without prejudice. Respectfully submitted: ZUCKER, GOLDBERG & ACKER , LLC Bv: Dated: April 14, 2014 Scott A. Dietterick, squire; 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 r 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- 175414/dcr 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com D)14 Pa BLIklioEq-23 Zucker, Goldberg & Ackerman, LLC XFP- 175414