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HomeMy WebLinkAbout13-0628McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID #16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIItE - ID #17616 EDWARD D. CONWAY, ESQUIRE - ID #34b87 MARGARET GAIItO, ESQUIRE - ID #34419 ANDREW L. MARKOWITZ, ESQUIRE - ID #28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID #87830 KEVIN T. McQUAIL, ESQUIRE - ID #307169 CHRISTINE L. GRAHAM, ESQUIRE - ID #309480 BRIAN T. LaMANNA, ESQUIRE - ID #310321 JOSEPH F. RIGA, ESQUIRE - ID #57716 JOSEPH I. FOLEY, ESQUIRE- ID #314675 ~'~ ~-.~ ~' 123 South Broad Street, Suite 1400 .~ --,,~' w Philadelphia, Pennsylvania 19109 ~°r' '~ ~=": (215) 790-1010 r- ~ -<~ ati c.ra r ~ --tc IN THE COURT OF COMMON PLEAS OF ~Q ® ~-, r ``,' CUMBERLAND COUNTY, PENNSYLVANIA --f w T> -~; crr Wells Fargo Bank, N.A. CNIL DNISION I ~V( Plaintiff, NO.: v Kelly A. Johnson and Michael D. Johnson Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, National Association, by its attorneys, McCabe, Weisberg & Conway, P.C. and files this complaint in Mortgage Foreclosure as follows: 062-PA-V3 ~/ Y lSaol~ ~~aBla~S9 NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 AVISO Le han demandado a usted en la cone. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) Bias de plazo al partir de la fecha de la demanda y la notification. Hate falta asentar una comparencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la torte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notification. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LISTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI LISTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 File # 70925 Page 2 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Unless, within thirty (30) days after your receipt of this communication, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid. If you notify us in writing within thirty (30) days of your receipt of this communication that the debt, or a portion of the debt, is disputed, we will obtain verification of the debt or a copy of the judgment against you, and we will mail to you a copy of the verification or judgement that we obtain. Upon your written request to us within thirty (30) days of your receipt of this communication, we will provide to you the name and address of the original creditor, if different from the current creditor. Case Name: Wells Fargo Bank, N.A. v. Kelly A. Johnson and Michael D. Johnson Cumberland County File # 70925 Page 3 1. The Plaintiff is Wells Fargo Bank, National Association, 3476 Stateview Blvd., Ft. Mill, SC 29715 (hereinafter "Plaintiff'). 2. The Defendants, Kelly A. Johnson and Michael D. Johnson, are individual whose last known address is 211 South Enola Drive, Enola, PA 17025, respectively. 3. Wells Fargo Bank, N.A., directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit "A," attached hereto and made a part hereof. 4. On or about January 25, 2008, Kelly A. Johnson and Michael D. Johnson, made, executed and delivered to Sovereign Bank a Mortgage in the original principal amount of $115, 090.00 on the premises described in the legal description marked Exhibit "B," attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of Cumberland County in Mortgage Instrument Number 200802856. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 5. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded March 13, 2008 the mortgage was assigned to Wells Fargo Bank, N.A., which Assignment is recorded in the Office of the Recorder of Cumberland County in Mortgage Instrument Number 200807594. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Kelly A. Johnson and Michael D. Johnson are the record and real owners of the aforesaid mortgaged premises. 7. 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 8/1/2012. 062-PA-V3 8. As of O 1 /25/2013, the amount due and owing Plaintiff on the mortgage is as follows: Principal $ Interest from 07/01/2012 to 01/25/2013 $ Pre-acceleration Late Charges $ Property Inspections $ Escrow Advance $ TOTAL $ 108,149.07 3,671.17 3 72.94 75.00 732.50 113,000.68 Plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiffs attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendants. 10. This action does not come under Act 91 of 1983 because the mortgage is FHA insured. l 1. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendants, but reserves its right to do so in a separate legal action if such right exists. If Defendants have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. 062-PA-V 3 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $113,000.68, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. McCabe, Weisberg & Conway, P.C. By: [ ] TERRE E J. McCABE, ESQUIRE [ ] MARC . WEISBERG, ESQUIRE [ ]EDWARD D. CONWAY, ESQUIRE [i]'MARGARET GAIIZO, ESQUIRE [ ]ANDREW L. MARKOWITZ, ESQUIRE [ ] HEIDI R. SPNAK, ESQUIRE [ ]MARISA J. COHEN, ESQUIRE [ ]KEVIN T. MCQUAIL, ESQUIRE [ ]CHRISTINE L. GRAHAM, ESQUIRE [ ]BRIAN T. LAMANNA, ESQUIRE [ ]JOSEPH F. RIGA, ESQUIRE [ ]JOSEPH I. FOLEY, ESQUIRE Dated: Feb r v ~"`1T_~ , 2013 062-PA-V3 VERIFICATION Sonya Moore, hereby states that he/~is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that he he s authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of hi er ormation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Sonya Moore Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: O 1 /29/2013 086-PA-V2 JOHNSON ~xh~b~t . • r, ~1 ~ ~ ,` Irl NOTE FFfA Case No, State of Pennsylvania January 25, 2008 [Datcl 211 South Enola Drive Enola, PA 1?025 IPrc~peny Address) 1. I'ARTIisS ' "Borrower" means etch person signing at the end of this Note, and the person's successors and assigns. "Lender" means Sovereign Bank and its successors and assigns. 2. BORROWER'S PROlv115E TO PAY; !N'fEREST In return For a loan received from Lender, Borrower promises to pay the principal sum of one Hundred Fifteen Thousand Ninety And Zero/100 Dollars (U.S. $ 115, 090.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of Six percent { 6.000 ~) per year anti! the full amount of principal ltas been paid. 3. !'ROMISIs'!'O PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the slrtte date as this Note and called the "Security Instrument." 'The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OH PAYMiF,NT (A) 'l'ime Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on March Ol 2008 .Any principal and interest remaining on tltc first day of February , 2038 ,will be due un that date, which is called the "Maturity Datc." (B) Plurc PI-yntcnt shall I>e made at 1130 Berkshire Blvd. , Wyomissing, PA 19610 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Cach monthly payment of principal and interest will be in the amount of U.S. $ 690.03 .This amount will be part of a larger nwnthly payment required by the Security Instrument, that shall be appliod to principal, interest and other items in Ore order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an alonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the alonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Cltcck applic<iblc box] ^Graduated Payment Allonge ^Growing Equity Allonge ^Other [specify] S. IIORR014'ER'S RICH'1' TO I'REI'AY 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 interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. F1iA Pennsylvania Fixed Ftutc Note - IO/95 Wolters Kluwer Financial Services ~~ Pale 1 of 2 Initiols: . :, tf. BORROWER'S FAILURE TO PAY (Aj Latc 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 calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent ( 4.000 %) of the overdue amount of each payment, (B) Default If Borrower defaults by failing to pay in fitll any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender nkly choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note 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 Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not proltibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Notc, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed, Any person who is a guarantor, surety or endorser of this No[e is also obligated to do these things. Any person who takes over these obligations, .including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. This is a contract under seal and may be enforced under 42 PA. C.S. Section 5529(b). BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. ~r~ (Seal) Michael D Johnson -Burrower _ (Seal) -Burrower _ (Seal) -);orrower (Seal) Kelly A Joh n -Borrower wtTHOUT A~cot,ASE PAY TO THE OApER OF ey (Seal) Larl K. Venego _ ., _ WITHOUT RECOURSE -Harrower L PAY TO THE ORDER OF ' WELLS FARGO BAIhC, l~•A. VMP~-1RtPQ) io~o7~ SOVEREIGN BANK /~ Page 2 of 2 `_ . i%i MARCIA D SPIESS, AS/$/!I~S AN SECRETARY _ {Seaq -Burrower _ (Seal) -Burrower _ (Seal) -Borrower Wti65 ~ 6 8002/tiZ/+r0 First Amdrican Title Insurance Company Commitment Number: 08028 SCHEDULE C PROPERTY DESCRIPTION The land referred to in this Commitment is described as follows: \~~ V '' , ~~ ~~ ALL THAT CERTAIN tot or p'ece of ground th the bu(Idings and improvements thereon erected, situate in the Township of Est Pennabor Cumberland C unty, Pennsylvania, bounded and described according to a Map showing property of `T'homas red by Gerrit J. Betz Associates, 1nc., dated April 5, 1976 as follows: BEGINNING at s point in the center line of South Enola Drive at the distance of 116.40 feet measured northw®rdiy from ~e center line of Covert Street; thence extending along the center line first above mentioned, North 04 dsgroes 20 minutes West, i~t3 feet to a paint; thence extending South 81 degrees 4t3 minutes 07 seconds West, passing through and beyond a partition well between this and premises to the North, 249.20 feet to a hub in Bne of land now or late of Ronald E. and Gayte'V. Bdrner; thence extending along said land, South 06 degrees 28 minutes East, 16 feet to a hub; thence extending along land now or late of Clinton Orris, North 83 degrees 45 minutes East, 243.80 feet to the Tirst mentioned point and place of t3EGINNING. BEING commonly known and generally referred to as No, 211 South Enoia Drive, Enola, Pennsylvania. BEING the same premises which Nancy M. Stuck by deed dated September 7, 2007 and recorded September 11, 2007 in the Office of die Recorder of Deeds in and for Cumberland County, Pennsylvania, in instrument Number 20Q73S386, granted and conveyed unto David Bailey. SUBJECT to Easements, Restrictions, Covenants, and Conditions of record, including matters shown on recorded Plats. ALTA Commitrrunt Schaduts C (Oao2N0802d/24) ztoiiZOfA1 x~r~ z6 =ot gns 800z/6z /9o ~~ FORM 1 -~,~ ~-°-' Wells Far4,o Bank, N.A. Plaintiff vs. Kelly A. Johnson and Michael D..Iohnson Defendants n ~~ r~rt ~ IN THE COURT OF COMMON PLEA ' rn CUMBERLAND COUNTY, PENNSYI~( I~,„ n ~ ca ~~, c~ . . ._~ n Civil. ~.J~ ~ a.. G~ s -~~~ -~ ~, r~ ~:.. -,~ .:-~ ~.t --+ ~~~ NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. ~Il III Date T Resp tfully submitted: [Si atur of Counsel for Plaintiff) 70925 Paee 1 FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email: # of people on household: Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: How long? How long? Date You Closed Your Loan: Total Mortgage Payment Amount $ Date of Last Payment: Primary Reason for Default: Included Taxes & Insurance: State: Zip: Yes ^ No ^ Listing date: Price $ Realtor Phone: Yes ^ No ^ State: Zip: Home: Office: Cell: Other: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile # 1: Model: Amount owed: _ Value: Automobile #2: Model: Amount owed: _ Value: Other transportation (automobiles boats motorc cY les)• Year: Amount owed: Monthlv Income Name of Employers: 1. Year: Year: Model Value: 2. 3. Additional Income Description (not wages): l . monthly amount: 2• monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthlv Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Da /Child Care/Tuft. Other Ex enses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes (] No ~ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ^ No ^ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your deliquency? Yes ^ No ^ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): 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 obiligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information to lender and lender's counsel: Proof of income f Past 2 bank statements Proof of any expected income for the last 45 days Copy of a current utility bill f Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 31 NARY :T/3 Are 1 Q OW: CUt RERL4Nd PENVSYLVAN1a TY McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE- ID#57716 JOSEPH I. FOLEY, ESQUIRE- ID#314675 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank, N.A. Cumberland County Plaintiff Court of Common Pleas v. Number 13-628 civil Kelly A. Johnson and Michael D. Johnson Defendants MOTION TO ALLOW SERVICE ON THE DEFENDANTS PURSUANT TO PA RULE OF CIVIL PROCEDURE 430 1. Plaintiff attempted to personally serve a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendants,Kelly A.Johnson and Michael D.Johnson,at their last- known address of 211 South Enola Drive,Enola,Pennsylvania 17025. The process server was not able to serve the Defendants because the property is vacant. A true and correct copy of the Return of Service indicating the same is attached hereto, made a part hereof as Exhibit"A". 2. Pursuant to Pennsylvania Rule of Civil Procedure 430,Plaintiff has conducted a good faith investigation to determine the current whereabouts of Defendants and the attached Affidavit sets forth in detail the nature and extent of the investigation. See Affidavit of Good Faith Investigation attached hereto and marked Exhibit "B". 3. As a result of the investigation,a special Order of Court is required permitting service by regular and certified mail at the Defendants last known address and by posting a copy of the original process on the mortgaged premises. 4. No judge has ruled upon any other issue in this matter or in any related matter. 5. No attorney has entered an appearance in this matter on behalf of the Defendants and, therefore, no concurrence of opposing counsel was sought with regard to the instant motion. 6. If service cannot be made on the Defendants, Kelly A. Johnson and Michael D. Johnson, the Plaintiff will be prejudiced. WHEREFORE,Plaintiff prays this Honorable Court grant an Order allowing the Plaintiff to serve the Complaint in Mortgage Foreclosure, and all other subsequent pleadings that require personal service, and the Notice of Sheriff's Sale, upon the Defendants, Kelly A. Johnson and Michael D. Johnson, by regular mail; certified mail, return receipt requested, and by posting at the last-known address of Defendants and the mortgaged premises known in this herein action as 211 South Enola Drive, Enola, Pennsylvania 17025-2808. McCABE,WE SBERG AND C NWAY, .C. BY: ./ [ ] Terrence J. McCabe,Esquire [' Iarcl S. isberg,Esquire [ ]Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire [ ] Andrew L. Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ] Marisa J.Cohen, Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F. Riga,Esquire [ ]Joseph I.Foley, Esquire Attorneys for Plaintiff • McCABE,WEISBERG AND CONWAY, P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN, ESQUIRE-ID#87830 KEVIN T. MCQUAIL, ESQUIRE-ID#307169 CHRISTINE L. GRAHAM, ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,N.A. Cumberland County Plaintiff Court of Common Pleas v. Number 13-628 civil Kelly A. Johnson and Michael D. Johnson Defendants MEMORANDUM OF LAW If a resident Defendant has obstructed or prevented service of process by concealing his whereabouts or otherwise, the Plaintiff shall have the right of service in such a manner as the Court by special order shall direct service pursuant to P.R.C.P. 430. WHEREFORE, Plaintiff prays this service be made. McCABE,W BERG AND CO VAY,P. . BY: ��( ✓ [ ]Terrence J. cCabe,Esquire [ arc S. Weisberg,Esquire [ ] Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L. Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ] Marisa J. Cohen,Esquire [ ]Kevin T. McQuail,Esquire [ ] Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Aim E. Swartz,Esquire [ ]Joseph F. Riga,Esquire [ ] Joseph I. Foley,Esquire Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA, ESQUIRE-ID#57716 JOSEPH L FOLEY, ESQUIRE- ID#314675 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank, N.A. Cumberland County Plaintiff Court of Common Pleas v. Number 13-628 civil Kelly A. Johnson and Michael D. Johnson Defendants CERTIFICATION OF SERVICE The undersigned attorney for the Plaintiff hereby certifies that he/she served a true and correct copy of the foregoing Motion for Alternative Service, by United States Mail, first class, postage prepaid, on the 18th day of April, 2013, upon the following: Kelly A. Johnson Michael D. Johnson 211 South Enola Drive 211 South Enola Drive Enola, Pennsylvania 17025 Enola, Pennsylvania 17025 McCABE,WEIS BERG AND QNWAY,P.C. BY: ll///w [ ] Terrence J. McCabe,Esquire [ n-arc S. eisberg,Esquire [ ] Edward D.Conway,Esquire [ ]Margaret Gairo, Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire [ ] Kevin T. McQuail,Esquire [ ] Christine L. Graham,Esquire [ ]Brian T. LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F. Riga,Esquire [ ] Joseph I.Foley,Esquire Attorneys for Plaintiff VERIFICATION The undersigned attorney hereby certifies that he/she is the attorney for the Plaintiff in the within action and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of this jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE,WEISBERG AND ONWAY,P.C. BY: /���` [ ] Terrence . McCabe,Esquire [.T1-arc S. Wei erg,Esquire [ ] Edward D. Conway,Esquire [ ]Margaret iro,Esquire [ ]Andrew L. Markowitz,Esquire [ ] Heidi R. Spivak,Esquire [ ]Marisa J. Cohen,Esquire [ ] Kevin T. McQuail,Esquire [ ]Christine L. Graham,Esquire [ ]Brian T. LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ] Joseph F. Riga,Esquire [ ]Joseph I.Foley,Esquire Attorneys for Plaintiff Wells Fargo Bank,N.A. v.Kelly A.Johnson and Michael D. Johnson Cumberland County;CCP;Number 13-628 civil File Number: 70925 • SHERIFF'S OFFICE OF CUMBERLAND COUNTY / ��c Ronny R Anderson Sheriff J (+� Jody S Smith ofalafLrryrx�G Chief Deputy - 1 Richard W Stewart - ' Solicitor orFIC=_∎;:r; :.!-=RIFF Wells Fargo Bank, N.A. Case Number vs. Kelly A Johnson (et al.) 2013-628 SHERIFF'S RETURN OF SERVICE 02/26/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Kelly A Johnson, but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program & Complaint in Mortgage Foreclosureas"Not Found"at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025-2808. Residence is vacant and per the Enola Postmaster the defendant moved and left no forwarding address. 03/06/2013 Ronny R Anderson, Sheriff, being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit: Michael D. Johnson, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025. Residence is vacant. Per the Enola Post Master the defendant moved and left no address. SHERIFF COST: $64.00 SO ANSWERS, March 06, 2013 RONNY R ANDERSON, SHERIFF ., A (c)Counl)Suiic Sheriff,Tcleosofl Inc. AFFIDAVIT OF GOOD I �"EII 11111 1III"III� II��I �II) FAITH INVESTIGATION • *45626* • , File#:302-2383PA•• • • Subject: Michael Johnson • • Last-known Address: 211 South Enola Drive,Enola,PA 17025 • • • STATE OF NEW YORK.` 1 COUNTY OF SUFFOLK ss.: • s. Susan Farbizio,the undersigned,being duly sworn,deposes and says that I am over the age of eighteen and not a party to this action.I reside in the STATE OF NEW YORK. On 12/12/2012,I completed a good faith investigation into the whereabouts of the Michael Johnson at the last-known/property address indicated below and the extent of the investigation and the results are as follows: Date Investigation Remarks Inquiries 12/12/2012 PROPERTY 211 South Enola Drive Enola,PA 17025 ADDRESS: INQUIRY OF LOCAL Directory Assistance: Search was unable to 12/12/2012 TELEPHONE locate a telephone listing for the subject. COMPANY: Search results show the subject resides at the 12/12/2012 INTERNET SEARCH: above stated last-known address.Results also provided the phone number of 717-732-2172. 12/12/2012 DEATH RECORDS: Social Security Death Index Search was unable to locate a death record for the subject. 12/12/2012 LOCAL TAX Search was unable to confirm a mailing address RECORD INOUIRY: for the above stated property address. INQUIRY OF Said postal inquiry for 211 South Enola Drive • 03/22/2013 POSTAL Enola,PA 17025,returned indicating Moved, AUTHORITY: left no forwarding address The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best knowledge,information and belief. Sworn to and subscribed before me on X , 1,27,2,20 /3 Susan arbizio I Attorney Outsourcing Support Services,Inc. /� 1 Huntington Quadrangle,Suite 2504 //"->'i' ��(�� Melville,NY 11747 N/Up-ie.-x.2-1 blic, MARYANNE HANLEY NOTARY PUBLIC.State of New York No.01HA6108108 Qualfied in SUFFOLK Commission Expires April 12,2016 f' , , 3'''Et' st'' I IHIU X1111 X1111 11111 111111111 X111 *45626* Attorney Outsourcing Support Services,Inc. 1 Huntington Quadrangle, Suite 2SO4 Melville,NY, 11747 RETURN SERVICE REQUESTED Agency Control:45626 Date:March 12,2013 POSTMASTER Enola,PA 17025-9998 Request of change of address or box holder information needed for service of legal process Please furnish the new address or the name and street address(if a box holder)for the following: Regarding: Michael Johnson,211 South Enola Drive,Enola,PA, 17025 The following information is provided in accordance with 38 CFR 265.6(D)(6)(II).There is no fee for providing box holder information.The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2)and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of Requester: Process Server 2. Statute that Empowers me to serve process: CPLR 308 3.Names of parties known to litigation: WELLS FARGO BANK NA vs Kelly Johnson and Michael Johnson 4. Court in which the case has been or will be heard: COURT OF COMMON PLEAS OF PENNSYLVANIA,CUMBERLAND COUNTY 5.The docket or other identifying number if one has been issued: 6.The capacity in which the individual is to be served(e.g.defendant, witness,etc): Defendant(s) Warning The submission of false information either(1)to obtain and use change of address information or box holder information for any purpose other than the service of legal process in connection with actual or prospective litigation or(2)to avoid payment of the fee for change of address information could result in criminal penalties including a fine up to$1.0,000 or imprisonment of not more than 5 years,or both(title 18 U.S.C. Section1001) I certify that the above information is true and that the address information is needed and will be used solely for service of gal proces. in connection with actual or prospective litigation. Signature:_... Susan Farbizio,Attorney Outso rcing Spport Services,Inc. POST OFFICE USE ONLY POSTMARK/DATE STAMP HERE ()MAIL IS DELIVERED TO ADDRESS GIVEN ()NOT KNOWN AT ADDRESS GIVEN (O CHANGE OF ADDRESS ORDER ON FILE � OVED,LEFT NO FORWARDING ADDRESS a.A„, ti ()NO SUCH ADDRESS `� 0)DECEASED tzr 0)MOVED,FORWARDING ADDRESS ON FILE: AGENCY RETURN ADDRESS: 1;;,' , " Attorney Outsourcing Support Services,Inc. / .., 1 Huntington Quadrangle, Suite 2SO4 �., Melville,NY 11747 This response can be faxed to: (855) 427-1281 Free People Search I WhitePages Page 1 of I WhitePages • First name 'Michael • * Last name Johnson I • City, State or ZIP 'Enola PA # I ?' rSubm4t Query }`l Michael D Johnson 211 S Enola Dr Enola, PA 17025-2808 Age: 65+ Associated: Kelly Johnson Save to Mailer Claim & Edit L ! �) 1 Th ! i O L151.1 t l e l it 1 41 ti 1r 1[t1 SCI .. .fit. o ata taa ft ecor atian. ®ao10 NA1370, Atm Loading... View My Mailer © 2012 WhitePages Inc. - Privacy Policy and Terms of Use http://www.whitepages.com/name/Michael-D-Johnson/Enola-PA/6utv4w7 12/12/2012 Page 1 of 3 * I B earch Person Search Results Records: 1 to 25 of 37 Result Page: 1 2 All Full Name Age/DOB Address Dates Phone Information 1. MICHAEL D JOHNSON 32 211 S ENOLA DR 2008-Nov 12 717.732.2172•EST M»� Gender:Male Mar xx,1980 ENOLA PA 17025-2808 PENNSYLVANIA REGIONAL 067.74•xxxx BALLET LexiD:1261663328 We Also ❑ Phones ❑ Property ❑ Professional ❑ Email Found: Plus Records Licenses Address • 2. MIKE JOHNSON 32 211 S ENOLA DR Feb 08•May 10 —� Gender:Male Mar xx,1980 ENOLA PA 17025-2808 067-74-xxxx LexID:1261663328 3. MICHAEL D 32 211 S ENOLA DR Feb 08•May 10 TESTLASTNAME Mar xx,1980 ENOLA PA 17025.2808 Gender:Male 067-74-xxxx LexID:1261663328 4. MICHAEL D JOHNSON 32 201 S PITT ST APT Al2 Nov 04•Sep 09 717-448-6567 Gender:Male Mar xx,1 98 0 CARLISLE PA 17013 067•74•xxxx LexID:1261663328 5. MICHAEL D 32 201 S PITT ST APT 12 Feb 04-Jun 07 TESTLASTNAME Mar xx,1980 CARLISLE PA 17013-3811 Gender:Male 067-74-xxxx LexID:1261663328 6. MIKE JOHNSON 32 201 S PITT ST APT 12 Jun 07 Gender:Male Mar xx,1980 CARLISLE PA 17013-3811 067-74-xxxx LexID:1261663328 7. MICHAEL D JOHNSON 32 201 PITT ST APT S Jul 05•May 07 717.448-6567•EST Gender:Male Mar xx,1980 CARLISLE PA 17013 067-74-xxxx LexID:1261663328 [8. MICHAEL D JOHNSON 32 201 S PITT ST APT S Oct 03•May 07 717-960-0640-EST Gender:Male Mar xx,1980 CARLISLE PA 17013 JOHNSON JERRY ( 067-74-xxxx LexID:1261663328 9. MIKE JOHNSON 32 340 W 4TH ST APT 8 Apr 02-Dec 05 Gender:Male Mar xx,1980 CINCINNATI OH 45202-2638 067.74-xxxx LexID:1261663328 10. MICHAEL D 32 340 W 4TH ST APT 8 Apr 02•Dec 05 TESTLASTNAME Mar xx,1980 CINCINNATI OH 45202.2638 Gender:Male 067.74-xxxx LexID:1261663328 iMICHAEL D JOHNSON 32 340 W 4TH ST APT 8 Feb 02•Dec 05 717.960.0640-EST 12/12/2012 https://secure.accurint.com/app/bps/main Page 2 of 3 11. Gender:Male Mar xx,1980 CINCINNATI OH 45202-2638 JOHNSON JERRY 067-74-xxxx LexID:1261663328 12. MICHAEL D JOHNSON 32 1202 REDWOOD HILLS CIR Oct 05 717-960-0640 Gender:Male Mar xx,1980 CARLISLE PA 17015.9735 JOHNSON JERRY 067.74-xxxx .. LexID:1261663328 13. MIKE JOHNSON 32 1202 REDWOOD HILLS CIR Oct 05 717.960.0640 Gender:Male Mar xx,1980 CARLISLE PA 17015-9735 JOHNSON JERRY 067-74-xxxx LexID:1261663328 14. MICHAEL D 32 1202 REDWOOD HILLS CIR Oct 05 717-960-0640 —� TESTLASTNAME Mar xx,1980 CARLISLE PA 17015.9735 JOHNSON JERRY Gender:Male 067-74-xxxx LexID:1261663328 15. MICHAEL D JOHNSON 32 201 PITT ST A 12 Nov 04 Gender:Male Mar xx,1980 CARLISLE PA 17013 067.74•xxxx LexID:1261663328 16. MICHAEL D JOHNSON 32 24A GUARDHOUSE IN _ — Jul 03-Nov 04 Gender:Male Mar xx,1980 CARLISLE PA 17013-5115 067-74-xxxx LexID:1261663328 17. MICHAEL D JOHNSON 32 340 W 4TH ST APT 10 Feb 02•Aug 04 717.960-0640-EST Gender:Male Mar xx,1980 CINCINNATI OH 45202-2638 JOHNSON JERRY 067-74-xxxx LexID:1261663328 18 MICHAEL 0 JOHNSON 32 340 W 4TH ST APT A Feb 02-Aug 04 717.960.0640-EST Gender:Male Mar xx,1980 CINCINNATI OH 45202-5608 JOHNSON JERRY 067-74-xxxx LexID:1261663328 19. MICHAEL D JOHNSON 32 340 W 4TH ST APT 10 Jul 04 513-929-0252-EST Gender:Male Mar xx,1980 CINCINNATI OH 45202-2638 067.74•xxxx LexID:1261663328 20. MICHAEL D JOHNSON 32 201 S PITT ST APT Al2 Oct 03-Feb 04 717.960.0640•EST Gender:Male Mar xx,1980 CARLISLE PA 17013.3811 JOHNSON JERRY 067-74-xxxx LexID:1261663328 21. MICHAEL D JOHNSON 32 24 GUARDHOUSE LN APT Sep 03-Jan 04 513.929.0252•EST Gender:Male Mar xx,1980 CARLISLE PA 17013.5115 067-74-xxxx LexID:1261663328 22. MIKE JOHNSON 32 24A GUARDHOUSE LN Jul 03 Gender:Male Mar xx,1980 CARLISLE PA 17013-5115 067•74-xxxx LexID:1261663328 23. MICHAEL D 32 24A GUARDHOUSE LN Jul 03 TESTLASTNAME Mar xx,1980 CARLISLE PA 17013-5115 Gender:Male 067-74-xxxx LexID:1261663328 https://secure.accurint.com/app/bps/main 12/12/2012 Page 3 of 3 24. MICHAEL D JOHNSON 32 1906 CHAPEL RD Jan 00-Mar 02 Gender:Male Mar xx,1980 HAMILTON OH 45013-9121 067-74-xxxx LexiD;1261663328 25. MICHAEL D JOHNSON 32 713 YORKSHIRE DR May 01-Jan 02 Gender:Male Mar xx,1980 CARLISLE PA 17013-3553 067-74-xxxx LexID:1261663328 Records: 1 to 25 of 37 Result Page: 1 2 r Your DPPA Permissible Use: Use In the Normal Course of Business Your GLBA Permissible Use:Authorized by Consumer https://secure.accurint.com/app/bps/main 12/12/2012 Michael Johnson Social Security Death Index (SSDI)Records- Social Security Death Ind... Page 1 of 3 1. Home> 2. Social Security Death Index > 3. Search Results Michael Johnson Death Records in the Social Security Death Index (SSDI) Your search for Michael Johnson did not match any items in Social Security Death Index. Suggestions • Search again using variant first names "Michael OR Mike OR Mick OR Mickey" instead of just "michael" Many first names can be presented in a wide range of forms, and searching for just one variation can exclude some valid records. To find the most results, try searching for several of them using the OR operator in the search field. • Search again without the first name "michael" Searching with only a family name should open up your search, and may even yield new family history discoveries. • Search again without last known residence requirements If you're sure your ancestor is in the Social Security Death Index but can't locate him or her, there may be a discrepancy in recorded locations. Try removing these requirements from your search. Need Help Searching Your Ancestors? Contact Us Now Toll Free 1-866-223-8535 Our family history consultants are here to help. 11am - 7pm EST Try another search! Last Name; Johnson 12 Try different name spellings Ex: Jenson, Jensen, Jens?n; Carrot, Carol, Caroll, Car* First Name I michael i? Try variations of the first name • Ex: William, Will OR Bill, Wm., W., etc. Middle Initial j? ;- Too many results? Try using a middle initial to narrow your results. Date Information http://www.genealogybank.com/gbnk/ssdi/?Iname=Johnson&fname=michael&minit=&bi... 12/12/2012 • Michael Johnson Social Security Death Index(SSDI)Records - Social Security Death Ind... Page 2 of 3 Born Between year I I and year Died Between year , and year I • Last Known Residence City County State Any • OR ZIP Code 17025 OR Non-U.S. Location Social Security Number Details State SSN Issued Social Security Number lAY Search Tips Begin Search ■ Clear Form Stay connected. Follow us! • Search All Collections Newspapers • Recent Obituaries Newspaper Archives Historical Obituaries Birth Records Marriage Records o Passenger Lists o Newspaper Articles o Legal, Probate & Court Photos &Illustrations • o http://vvww.genealogybank.com/gbnIcissdirilname=Johnson&fname—michael&minir---&bi... 12/12/2012 Michael Johnson Social Security Death Index(SSDI) Records- Social Security Death Ind... Page 3 of 3 N More o Log In Subscribe • Home • About Us Other Genealogy • Help Records • Learning Center • Store Social Security Death Index • Questions? Call 1-866-641-3297 • • Historical Books • Historical Documents African-American • Newspapers • Irish-American Newspapers • In the News • Contact.Us • Affiliates • Privacy Policy • Terms of Use • Site Map • 13loq http://www.genealogybank.com/gbnk/ssdi/?lname=Johnson&fname=mi chael&mi n it=&bi... 12/12/2012 • AFFIDAVIT OF GOOD • FAITHINVESTIGATION I 11111 1111113 lid 11111 Ell 1111 • . . . . • .. .. *45624* • • • ,File#:302-2383PA - . . Subject: Kelly Johnson • ' • Last-known Address: 211 South Enola Drive,Enola,PA 17025 . L 1 - STATE OF NEW YORK • . 4• COUNTY OF SUFFOLK ss.: Susan Farbizio,the undersigned,being duly sworn,deposes and says that I am over the age of eighteen and not a party to this action.I reside in the STATE OF NEW YORK. On 12/12/2012,I completed a good faith investigation into the whereabouts of the Kelly Johnson at the last-known/property address indicated below and the extent of the investigation and the results are as follows: Date Investigation Remarks Inquiries 12/12/2012 PROPERTY 211 South Enola Drive Enola,PA 17025 ADDRESS: INQUIRY OF LOCAL Directory Assistance: Search was unable to 12/12/2012 TELEPHONE locate a telephone listing for the subject. COMPANY: Search results show the subject resides at the 12/12/2012 INTERNET SEARCH: above stated last-known address.Results also nrovided the phone number of 717-732-2172. 12/12/2012 DEATH RECORDS: Social Security Death Index Search was unable to locate a death record for the subject. 12/12/2012 • LOCAL TAX Search was unable to confirm a mailing address •. RECORD INQUIRY: for the above stilted property address. • ' INQUIRY OF Said postal inquiry for 211 South Enola Drive' . •03/22/2013 POSTAL Enola,PA 17025,returned indicating Moved, AUTHORITY: left no forwarding address •• The information set forth in this Affidavit of Good Faith Investigation is true and correct to the best • • knowledge,information and belief. ,•Sworn to and subscribed before me on X �14 - A,✓ • N / :1 ,20_f • • Su an arbizio • ' Attorney Outsourcing Support Sery�s,Inc. I^ I Huntington Quadrangle,Suite 2514 i .-1e2-x- )`~'lfG�- ..._ac Me1vi11e,NY 11747 Notary Public, MARYANNE HANLEY \ NOTARY PUBLIC,State of New York No.01HA6108108 Oualfied in SUFFOLK Commission Expires April 12,2016 1 111111 11111 11111 11111 11111 liii viii *45624* Attorney Outsourcing Support Services,Inc. 1 Huntington Quadrangle,Suite 2SO4 Melville,NY, 11747 RETURN SERVICE REQUESTED Agency Control:45624 Date:March 12,2013 POSTMASTER Enola,PA 17025-9998 Request of change of address or box holder information needed for service of legal process Please furnish the new addressor the name and street address(if a box holder)for the following: Regarding: Kelly Johnson,211 South Enola Drive,Enola,PA,17025 The following information is provided in accordance with 38 CFR 265.6(D)(6)(II).There is no fee for providing box holder information.The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1)and(2)and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of Requester: Process Server 2. Statute that Empowers me to serve process: CPLR 308 3.Names of parties known to litigation: WELLS FARGO BANK NA vs Kelly Johnson and Michael Johnson 4.Court in which the case has been or will be heard: COURT OF COMMON PLEAS OF PENNSYLVANIA,CUMBERLAND COUNTY 5.The docket or other identifying number if one has been issued: 6.The capacity in which the individual is to be served(e.g.defendant,witness,etc): Defendant(s) Warning The submission of false information either(1)to obtain and use change of address information or box holder information for any purpose other than the service of legal process in connection with actual or prospective litigation or(2)to avoid payment of the fee for change of address information could result in criminal penalties including a fine up to$10,000 or imprisonment of not more than 5 years,or both(title 18 U.S.C. Section1001) 1 certify that the above information is true and that the address information is needed and will be used solely for service legal process irh connection with actual or prospective litigation. Signature: "' j74 Susan Farbizio,Attorney Support Services,Inc. POST OFFICE USE ONLY POSTMARK/DATE STAMP HERE ()MAIL IS DELIVERED TO ADDRESS GIVEN ()NOT KNOWN AT ADDRESS GIVEN AO CHANGE OF ADDRESS ORDER ON FILE ! ' OVED,LEFT NO FORWARDING ADDRESS J <s} ()NO SUCH ADDRESS `r/ (}DECEASED 0)MOVED,FORWARDING ADDRESS ON FILE: \ AGENCY RETURN ADDRESS: 1( 1I. /.:. Attorney Outsourcing Support Services,Inc. 1 Huntington Quadrangle,Suite 2SO4 Melville,NY 11747 This response can be faxed to: (855) 427-1281 Free People Search I WhitePages Page 1 of I WhitePages • First name KeAy „ • * Last name' Johnson • City, State or ZIP EEnola PA I ; Subr�ri Qta r� ;<� Kelly Johnson 211 S Enola Dr Enola, PA 17025-2808 Associated: Michael D Johnson Save to Mailer Claim & Edit 1� ... t i ,A 4 1` Noga�¢ l P ' fit Loading... View My Mailer © 2012 WhitePages Inc. - Privacy Policy and Terms of Use http://www.whitepages.com/name/Kelly-Johnson/Eno1a-PA/6wg4w8p 12/12/2012 Page 1 of 1 • 14 1RBsearch Person Search Results Records: 1 to 7 of 7 All Full Name Age/DOB Address Dates Phone Information 1 KELLY A JOHNSON 27 211 S ENOLA DR Jan 08•Nov 12 PENNSYLVANIA REGIONAL 182-66-xxxx 1985 ENOLA PA 17025-2808 BALLET LexID:32931747939 We Also p Property Records ❑ Email Address Found: 2. KELLY A FLOSS 27 211 S ENOLA DR Feb 08.Oct 08 182-66-xxxx 1985 ENOLA PA 17025-2808 LexID:32931747939 3. _J KELLY A JOHNSON 27 201 S PITT ST APT 12 Mar 07-Feb 08 182-66-xxxx 1985 CARLISLE PA 17013-3811 Lax ID:32931747939 4. KELLY A FLOSS 27 201 S PITT ST APT 12 Mar 07•Nov 07 182-66-xxxx 1985 CARLISLE PA 17013-3811 LexID:32931747939 5. KELLY A FLOSS 27 1365 MOUNTAIN RD Apr 03.Oct 07 717.423.5990 182-66-xxxx 1985 NEWBURG PA 17240.9132 FLUSS WILLIAM A JR LexID:32931747939 6. KELLY A JOHNSON 27 1365 MOUNTAIN RD Apr 03-Oct 07 717-423-5990 182-66-xxxx 1985 NEWBURG PA 17240-9132 FLOSS WILLIAM A JR LexID:32931747939 7. JAMEISON HALL 27 6608 GUILFORD RD Aug 09•Feb 10 Gender:Male 1985 UPPER DARBY PA 19082 182.66•xxxx 1 LexlD:154454933340 Records: 1 to 7 of 7 Your DPPA Permissible Use:Use in the Normal Course of Business Your GLBA Permissible Use:Authorized by Consumer https://secure.accurint.com/app/bps/main 12/12/2012 • Kelly Johnson Social Security Death Index (SSDI)Records- Social Security Death Index... Page 1 of 3 • 1. Home> 2. Social Security Death Index > 3. Search Results Kelly Johnson Death Records in the Social Security Death Index (SSDI) Your search for Kelly Johnson did not match any items in Social Security Death Index. Suggestions • • Search again without the first name "Kelly " Searching with only a family name should open up your search, and may even yield new family history discoveries. • • Search again without last known residence requirements If you're sure your ancestor is in the Social Security Death Index but can't locate him or her, there may be a discrepancy in recorded locations. Try removing these requirements from your search. Need Help Searching Your Ancestors? Contact Us Now Toll Free 1-866-223-8535 Our family history consultants are here to help. 11am — 7pm EST Try another search! Last Name Johnson ? Try different name spellings Ex: Jenson, Jensen, Jens?n; Carrot, Carol, Caroll, Car* First Name ' Kelly i? Try variations of the first name Ex: William, Will OR Bill, Wm., W., etc. Middle Initial . Too many results? Try using a middle initial to narrow your results. Date Information Born Between year 4 and year Died Between year i and year http://www.genealogybank.con?/gbnk/ssdi/?lname=Johnson&fname=Kelly+&minit=&bir... 12/12/2012 Kelly Johnson Social Security Death Index(SSDI)Records - Social Security Death Index... Page 2 of 3 Last Known Residence City County_._...._. rState ! ( IAny Lg OR ZIP Code • 17025 OR Non-U.S. Location Social Security Number Details State SSN Issued Social Security Number •;, Search Tips Begin Search ■ Clear Form Stay connected. Follow us! • Search All Collections Newspapers Recent Obituaries Newspaper Archives Historical Obituaries Birth Records o Marriage Records o Passenger Lists o Newspaper Articles o Legal, Probate & Court Photos & Illustrations Nfr More • o - Other Genealogy http://www.genealogybank.com/gbnk/ssdi/?lname=Johnson&fname-Kelly+-&minit=&bir... 12/12/2012 Kelly Johnson Social Security Death Index(SSDI)Records.- Social Security Death Index... Page 3 of 3 Records Log In Subscribe Social Security • Home Death Index • About Us • • Historical Books • Help • Learning Center • Historical Documents • Store African-American • Questions? Call 1-866-641-3297 • Newspapers • Irish-American Newspapers • In the News • Contact Us • Affiliates • Privacy Policy. • Terms of Use • Site Map • Bloq • http://www.genealogybank.cornlgbnk/ssdi/?lnarne=Johnson&fhaine=Kelly+&minit=&bi r... 12/12/2012 THE F1L OF lHE PRO ;t ',' 2013 APR 30 PM b: 6 CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. Cumberland County Plaintiff Court of Common Pleas V. Kelly A. Johnson and Michael D. Johnson Number 13-628 civil Defendants ORDER AND NOW, this 30*day f l� �� Y �° , 2013, the Plaintiff is granted leave to serve all process in this mortgage foreclosure action upon the Defendants,Kelly A. Johnson and Michael D. Johnson, by regular mail and by certified mail, return receipt requested, to their last known address of 211 South Enola Drive, Enola, Pennsylvania 17025, and by posting the mortgaged premises of 211 South Enola Drive, Enola, Pennsylvania 17025. BY T COURT: J. i 00 IL ED j-ICL THE ROT Ojo IA j? 2013 JUN PM 2: 35 "'11111ERLAND COUNTY PENNsYLVANIA McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE_ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ED#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,N.A. Cumberland County Plaintiff Court of Common Pleas V. Number 13-628 civil Kelly A. Johnson and Michael D. Johnson Defendants PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure in the above-captioned matter. McCABE,WEI AND ONWAY,P.C. BY: Terrence J.M%t,Esquire-uire Marc S.Weisberg,Esquire cCa Edward D.Conway,Esquire Margaret Gairo,Esquire Andrew L.Markowitz,Esquire 14 Heidi R. Spivak,Esquire Marisa J.Cohen,Esquire I Kevin T.McQuail,Esquire Christine L.Graham,Esquire ]Brian T.LaManna,Esquire Ann E. Swartz,Esquire ]Joseph F.Riga,Esquire -75�a Joseph I.Foley,Esquire o^4 */I- Attorneys for Plaintiff F0 va SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff �� .�RU\nvn~ – Jody SSmith Chief Deputy Richard VVStewart Solicitor WICE OFvRE�_mFC � — MAIA Wells,Fargo Bank, N.A. Case Number vs. | 2U13'S28 Kelly A Johnson (et ai) | SHERIFF'S RETURN OF SERVICE 06/13/2013 O8:28PM'Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the withinnamodDafendant.huwitNeUyAJohnoon. punsuantbvOrdarofCourtby^Posting''thopn*mieea located at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025-2808 with a true and correct copy according tolaw. 06/13/2013 06:28 PM Deputy Ryan Burgett, being duly sworn according bz law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Fonoc|usureupontho within named Defendant,to wit: Michael D. Johnson, pursuant to Order of Court by"Posting"the premises located at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025 with a true and correct copy according hmlaw. RYAN BURGETT, DEPUTY SHERIFF COST: $72.Q5 SO ANSWERS, 4� June 14, 2013 RbNW RANOERSDN. SHERIFF wo"unvomte Sheriff,mle"sov~= ��" . SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff it��� tt 1 4 1 i � '.� f n I y i ff „t... tro Jody S Smith L Chief Deputy ' a � 2ti i)�"1 Richard W Stewart �a� j°i` Solicitor QFP E.E OF V. ;Fa 1;1; '�B .RL' Q pNl� Wells Fargo Bank, N.A. vs. Case Number Kelly A Johnson (et al.) 2013-628 SHERIFF'S RETURN OF SERVICE 06/13/2013 06:28 PM- Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Kelly A Johnson, pursuant to Order of Court by"Posting"the premises located at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025-2808 with a true and correct copy according to law. RYAN BURGETT, DEP s 06/13/2013 06:28 PM- Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Michael D. Johnson, pursuant to Order of Court by"Posting"the premises located at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025 with a true and correct copy according to law. RYAN BURGETT, DEPUTY SHERIFF COST: $72.95 SO ANSWERS, June 14, 2013 RON&R ANDERSON, SHERIFF THE 13 al t1� ,UMBERI AND COUNTY McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET CAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID 9314675 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,N.A. Cumberland County Plaintiff Court of Common Pleas V. Number 13-628 civil Kelly A. Johnson and Michael D. Johnson Defendants AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF PHILADELPHIA The undersigned attorney being duly sworn according to law, deposes and says that the following is true and correct to the best of his/her knowledge and belief: 1. That he/she is counsel for the above-named Plaintiff, 2. That on June 13, 2013,per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant, Kelly A. Johnson and Michael D. Johnson by regular mail, certificate of mailing and certified mail,return receipt requested, addressed to his/her last-known address of 211 South Enola Drive, Enola, Pennsylvania 17025. A true and correct copy of the letter and certified receipt, is attached hereto, made a part hereof, and marked as Exhibit "A". 3. That on June 13, 2013,per the attached Court Order, Plaintiff served a true and correct copy of the Complaint in Mortgage Foreclosure upon the Defendant,Kelly A. Johnson and Michael D. Johnson,by posting the same at the mortgaged premises of 211 South Enola Drive,Enola,Pennsylvania 17025-2808. A true and correct copy of the Sheriffs Returns of Service indicating same is attached hereto, made a part hereof, and marked as Exhibit "B". ;Y: E,WEIS ND CONWAY, P.C. SWORN AND SUBSCRIBED [ nce J.McCabe,Esq. [ ]Ma . �issbberg,Esq. BEFORE ME THIS $ DAY [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,`Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. OF 2013 [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. ]-Ann E.Swartz,Esq. [ ]Joseph F.Riga,Esq. NOTARY PUBLIC Joseph I. Foley,Esq. Attorneys for Plaintiff I COMMONWEALTH 11f PENNSYLVANIA Nt3TAI IAL.. SEAL. Chelsea Anne Nixon-Notary Public City oI Philadelphis,Philadelphia County MY CNMMISSION EXPIRES JULY 21,2015 f FLED-OFFICE 03" THE F'R THONOTA Y 2013 APR 30 PH : 1 CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank,N.A. Cumberland County Plaintiff Court of Common Pleas V. Number 1.3-628 civil Kelly A. Johnson and Michael D. Johnson Defendants ORDER AND NOW,this V day cd pt jj . , 2013, the Plaintiff is granted.leave to serve all process in this mortgage foreclosure action upon the Defendants,Kelly A. Johnson and Michael D. Johnson, by regular mail and by certified mail, return receipt requested, to their last known address of 211 South Enola Drive, Enola, Pennsylvania 17025, and by posting the mortgaged premises of 211 South Enola Drive,Enola, Pennsylvania 17025. BY THE OU12T: -A) J LAW OFFICES McCABE,WEISBERG & CONWAY,P.C. SUITE 210 SUITE 1400 SUITE 303 145 HUGUENOT STREET 216 H ,AVENUE NEW ROCHELLE,NY 10801 123 SOUTH BROAD STREET WESTMONTONT N]08108 (914)-636-8900 PHILADELPHIA,PA 19109 (856)858-7080 FAX(914)636-8901 (215)790-1010 FAX(856)858-7020 FAX(215)790-1274 SUITE 202 SUITE 4021 UNIVERSITY DRIVE 30 BUXTON FARMS ROAD FAIRFAX,VA 22030 STANFORD, 06905 82 (866)656-0379 (203)99 425-1 979 FAX(301)490-1568 FAX(855)425-1 SUITE 800 June 13,2013 SUITE 130 VENUE DELAWARE CORPORATE CENTER 1 312 MARSHALL A LAUREL,ND AVENUE ONE RIGHTER PARKWAY WILMINGTON,DELAWARE 19803 (301)490-3361 (302)409-35 FAX(301)490-1568 Also servicing the District of Columbia FAX 855-425-1199 80 Kelly A. Johnson 211 South Enola Drive Enola,Pennsylvania 17025 Re: Wells Fargo Bank,N.A.v.Kelly A. Johnson and Michael D.Johnson Cumberland County;CCP; Number 13-628 civil Dear Kelly A. Johnson: Enclosed please find a true and correct copy of Complaint in Mortgage Foreclosure,along with a copy of the signed Order dated April 30,2013,the original of which has been filed against you in regard to the above- captioned matter. Very truly yours, Steven Travascio Legal Assistant for McCabe,Weisberg and Conway,P.C. SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 7013 0600 0002 2969 8603 RETURN RECEIPT REQUESTED x it A h b This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. LAW OFFICES McCABE,WEISBERG&CONWAY,P.C. SUITE 210 SUITE 1400 SUITE 303 145 HUGUENOT STREET 123 SOTJTH BROAD STREET 216 HADDON AVENUE NEW ROCHELLE,NY 10801 PHILADELPHIA,OUTH R PA 19109 WESTMONT,N7 08108 (914}636-8900 (856)858-7080 FAX(914)636-8901 (215)790-1010 FAX(856)858-7020 FAX(215)790-1274 SUITE 202 SUITE 100 4021 UNIVERSITY DRIVE 30 BUXTON FARMS ROAD FAIRFAX,VA 22030 STANFORD,CT 06905 (866)656-0379 (203)992-8200 FAX(301)490.1568 FAX(855)425-1979 SUITE 800 June 13,2013 SUITE 130 312 MARSHALL AVENUE DELAWARE CORPORATE CENTER I LAUREL,MD 20707 ONE RIGHTER PARKWAY (301)490-3361 WILMINGTON,DELAWARE 19803 FAX(301)490-1568 (302)409-3520 Also servicing the District of Columbia FAX 855-425-1980 Michael D.Johnson 211 South Enola Drive Enola,Pennsylvania 17025 Re: Wells Fargo Bank,N.A.v.Kelly A.Johnson and Michael D. Johnson Cumberland County;CCP; Number 13-628 civil Dear Michael D.Johnson: Enclosed please fmd a true and correct copy of Complaint in Mortgage Foreclosure,along with a copy of the signed Order dated April 30,2013,the original of which has been filed against you in regard to the above- captioned matter. Very truly yours, Steven Travascio Legal Assistant for McCabe,Weisberg and Conway,P.C. SENT VIA REGULAR MAIL AND CERTIFIED MAIL NUMBER 701.3 0600 0002 2969 8542 RETURN RECEIPT REQUESTED This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. KSC P4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy 4 Richard W Stewart Solicitor OFFICE OF T}-E D ERIF-- Wells Fargo Bank, N.A. Case Number vs. 2013-628 Kelly A Johnson (et al.) SHERIFF'S RETURN OF SERVICE 06/13/2013 06:28 PM- Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Kelly A Johnson, pursuant to Order of Court by"Posting"the premises located at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025-2808 with a true and correct copy according to law. RYAN BURGETT, DEPJTY------° 06/13/2013 06:28 PM-Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant,to wit: Michael D.Johnson, pursuant to Order of Court by"Posting"the premises located at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025 with a true and correct copy according to law. RYAN BURGETT, DEPUTY SHERIFF COST: $72.95 SO ANSWERS, June 14, 2013 RbNW R"ANDERSON, SHERIFF ....-xhlbit B (c)Coun-OySuite Shen'If,TelcosoR,Inc, McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 r_ j r.. ..[ �-�=1!1.,t EDWARD D. CONWAY,ESQUIRE -ID#34687 r f'" MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 3 �* i s 0 ro HEIDI R. SPIVAK,ESQUIRE-ID#74770 �` ')J MARISA J. COHEN,ESQUIRE-ID#87830 CLI U M LB E R L f;N D COUNTY KEVIN T.MCQUAIL,ESQUIRE-ID#307169 F E N N S Y OVA t'il A CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Kelly A.Johnson and Michael D.Johnson Number 13-628 civil Defendants ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants,Kelly A.Johnson and Michael D.Johnson,in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure,and assess damages as follows: Principal $ 113,000.68 Interest from 01/26/13 to 08/13/13 $ 0.00 Total $ 113,000.68 McCABE,WEISBERG AND CONWAY,P.C. BY: [ ] Terrence J.McCabe,Esq. [ arc S. Weil erg,Esq. [ ] Edward D. Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ] Joseph F.Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff AND NOW,this I day of ,2013,Judgment is entered in favor of Plaintiff,Wells Fargo Bank,N.A.,and against Defendants,Kelly A.Johnson and Michael D.Johnson, in rem only and not in personam,and damages are assessed in the amount of$113,000.68,p us interest and costs. �46-SMP rid 6'P B THE TH ARY: 1P , a �61 /� c McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Kelly A.Johnson and Michael D. Johnson Number 13-628 civil Defendants AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned,being duly sworn according to law,deposes and says that the Defendants,Kelly A.Johnson and Michael D.Johnson, are not in the Military or Naval Service of the United States or its Allies,or otherwise within the provisions of the Servicemembers Civil Relief Act,50 U.S.C.App. §501,et seq.;and that the Defendants,Kelly A. Johnson and Michael D. Johnson,are over eighteen(18)years of age, and reside as follows: Kelly A.Johnson, 211 South Enola Drive Enola,PA 17025 Michael D. Johnson, 211 South Enola Drive Enola,PA 17025 McCABE,WEISBERG A7ONWAY,P.C. SWORN AND SUBSCRIBED // BY: BEFORE ME THI ` DAY [ ] Terrence J.McCabe,Esq. Marc S. We' erg,Esq. [ ]Edward D. Conway,Esq. [ ] Margaret airo,Esq. OF W;rll [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. NOTARY PUBLIC [ ]Ann E. Swartz,Esq. [ ]Joseph F. Riga,Esq. [ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian Es Ci?l�9MGl�tWEltL:'�!G!°�r^�r,'."IYLVAP6lR► � q• NOTARIAL SEAL Attorneys for Plaintiff VICTORIA V.SI<EGAI,Notary Public City of Philadelphia,phila.County NAy Commission F.�;l!lres O03W 15.2016 Department of Defense Manpower Data Center Results as of:Aug-14-201310:01:42 SCRA 3.0 i Status Deport Pursuant to ,Servicemembers Civil Relief Act. Last Name: JOHNSON First Name: MICHAEL Middle Name: D. Active Duty Status As Of: Aug-14-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA� '. _ _ _ J No� NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA I -- NA No ++ NA This response reflects"ere the Individual left active duty status within 367 days preceding the Active Duty Status Date j 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 �4NA '� `� r; ,�No NA This response reflects whether the individual or his/her unit has received eady 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. 4 ` rra Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Ths Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to'active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: H41 E40F24049W70 Department of Defense Manpower Data Center Results as of:Aug-14-2013 10.00:07 SCRA 3.0 Status Report �,. Pursuant to Sery c+emeanbcrs Civil Relief Act Last Name: JOHNSON First Name: KELLY Middle Name: A. Active Duty Status As Of: Aug-14-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ',.� - _- _ �'7�; No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA 1 NA 'Z _11 f ".7��.v- .N._7 � -r,r 1 NA This response reflects!where the Individual left active duty status within 367 days preceding the Active duty Status Date The Member or His/Her Unit Was Noted 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 NNA �� �+: ,c. ..rr L• lz < ,! NA This response reflects whether the individual or his/her unit Aas received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 1467S022A049A40 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 KEVIN T. MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,N.A. COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Number 13-628 civil Kelly A. Johnson and Michael.D.Johnson Defendants AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANTS COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby depose and say that the last-known mailing addresses of the Defendants are: Kelly A. Johnson 211 South Enola Drive Enola,Pennsylvania 17025 Michael D.Johnson 211 South Enola Drive Enola,Pennsylvania 17025 McCABE,W ISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED BY: (// " � ��tAl �� BEFORE ME THIS DAY [ ] Terrence J.McCabe,Esq. [ Marc S, Weisberg,Esq. [ ]Edward D. Conway,Esq. [ ] Margaret Gairo,Esq. OF 13 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. I [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. EP-%,-,YLVA Ann E. Swartz,Esq. [ ] Joseph F.Riga,Esq. NOTARIAL SEAL ] Joseph L Foley,Esq. [ ] Celine P.DerKrikorian,Esq. VICTORIA V.S IECAi,Notary Pubk ttorneys for Plaintiff City of Philadsiphia,Phila.County M Commission 0 ' s OCbb�sr 95,2046 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-628 civil Kelly A. Johnson and Michael D. Johnson Defendants CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff,being duly sworn according to law,deposes and says that a letter was deposited in the United States Mail notifying the Defendants that judgment would be entered against them within ten(10)days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit"A". McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED BY: BEFORE ME THIS DAY [ ] Terrence J.McCabe,Esq. --kmarc S. Weis rg,Esq. [ ] Edward D. Conway,Esq. [ ] Margaret Gairo,Esq. OF ,2 3 [ ]Andrew L.Markowitz,Esq. [ ] Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. [ ] Brian T.LaManna,Esq. NOTARY PUBLIC [ ]Ann E. Swartz,Esq. [ ] Joseph F.Riga,Esq. Corq�.Ty of [ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. ' �"��`'�gY�-� rneys for Plaintiff NOTARIAL SEAL VICTORIA V.SHEGAI Notary p�L C C►Iy of Fhiiadelph C�isswn a,Plri a County � Cdr 95, 2016 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and correct to the best of his/her knowledge,information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. MCCABE, ISBERG AN CONWAY,P.C. BY: [ ]Terrence J.McCabe,Esq. [ arc S eisberg,Esq. [ ]Edward D. Conway,Esq. [ ] Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ]Kevin T.McQuail,Esq. [ ] Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ] Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. Attorneys for Plaintiff Wells Fargo Bank,N.A.v.Kelly A.Johnson and Michael D.Johnson Cumberland County;Number: 13-628 civil OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle,Pennsylvania 1.701.3 Curt Long Prothonotary July 26, 2013 To: Kelly A. Johnson 211 South Enola Drive Enola,Pennsylvania 17025 Wells Fargo Bank,N.A. Cumberland County VS. Court of Common Pleas Kelly A. Johnson Michael D. Johnson Number 13-628 civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO IIABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE O POR ABOGADO Y POR NO HABER RADICADO POR CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10) ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONFS A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED RECLAMOS FORMULADOS EN CONTRA sUYO, AL NO TOMAR LA AGAINSTYOU WITHOUT AHEARING AND YOU MAY LOSE YOURPROPERTY ACCION DEBIDA DENTRO DEDIEZ(10)DIAS DE LA FFCHA DE ESTA OR OTHER IMPORTANT RIGHTS. NOTIFICACION, EL TRIBUNAL PODRA, SIN 'NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU COMPARECFR USTED EN CORTE U OIR PREUBA ALGUNA;DICTAR DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH SENTENCIA EN SU CONTRA Y USTED PODRIA PERDERBIENES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTES. HIRING A LAWYER. USTED LE DEBT; TOMAR ESTE PAPEL A SU ABOGADO IF YOU CANNOT AFFORDTOHIREA LAWYER,THIS OFFICEMAYBEABLE INMEDIATAMENTF. SI USTED NO TIENE A UN ABOGADO,VA A O TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER TELEFONEA LA OFICINA EXPUSO ABAJO.ESTA OFIC[NA LO PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR CON 1NFORMA06N ACERCA DE EMPLEAR A UN ABOGADO. Cumberland County Bar Association Sl USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON Carlisle,Pennsylvania 17013 INFORMAC16NACERCADE LAS AGENCIASQUEPUEDENOPRFCERLOS (800)990-9108 SF..RVICIOS LEGALES A PERSONAS ELEGIBLES EN UN 140NOIZARIO RF.DUCIDO NI NINGUN HONORARIO. Cu rand County B r Association outh Bedford S . Carli le,Pennsyly is 17013 � lr (8999>910 '" McCABE,y.VI;ISBERG 1(7� NW C. BY; [ ]Terrence J.McCabe,E re ]Marc S.Weisberg,Esquire [ ]Edward D.Conway, s uire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L.Graham, Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [Joseph F.Riga,Esquire [ ]Joseph 1.Foley,Esquire Attorneys for Plaintiff � mce /� k�A 1121 �` � I OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle,Pennsylvania 17013 Curt Long Prothonotary July 26, 2013. To: Michael D. Johnson 211 South Enola Drive E.nola,Pennsylvania 17025 Wells Fargo Bank,N.A. Cumberland County VS. Court of Common Pleas Kelly A. Johnson Michael D. Johnson Number 1.3-628 civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORT-ANTE YOU ARE IN DEFAULT BECAUSE YOU RAVE FAILED TO ENTER A USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN(10) ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA AGAINSTYOU WITHOUTA HEARING AND YOU MAY LOSE YOUR PROPERTY ACCION DEBIDA DENTRO DE DIE7(10)DIAS DE LA FECHA DE ESTA OR OTHER IMPORTANT RIGHTS. NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 1F YOU COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA, DICTAR DO NOT HAVE A LAWYER,GO TO OR TELEPHONE 1-1-IL OFFICE SET FORTH SFNTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTES. HIRING A LAWYER. USTED LE DEBE TOMAR ESTF PAPEL A SU ABOGADO IF YOU CANNOT AFFORD TOHIREA LAWYER,THIS OFFICE MAY BEABLE'• INMEDIATAMENTE, Sl USTED NO TIENE A UN ABOGADO, VA A O TOPROVIDF YOUWITH INFORMATION ABOUT AGENCIES THAT MAY OFFER TELEFONFA LA OFICINA EXPUSO ABAJO. ESTA OFICINA Lo PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR CON 1NFORMACi6N ACERCA DE EMPLEAR A UN ABOGADO. Cumberland County Bar Association Si USTED NO PUEDF PROPORCIONAR PARA EMPLEAR UN ABOGADO, 32 South Bedford Street. ESTA OFICINA PUEDF SER CAPAZ DE PROPORCIONARLO CON Carlisle,Pennsylvania 17013 INFORMACION ACERCA DE LAS AGENCIAS QUE PUFDEN OFRFCER LOS (800)990.9108 SERVICIOS LEGALES A PERSONAS EI.FOIBLES EN UN HONORARIO RFDUCIDO NI JN6l.�HONORARIO. Cu )crland County ar Association South Bedford St eet Ca Iisl ,P nsyly i 17013 ,( ONO McCABE I ISBERG AND Y '.0 BY: [ ]Terrence J.McCabe,E 'wire [ ] Marc 8.Weisberg,Esquire [ ]Edward D.Conway squire [ ]Margaret Gairo,Esquire [ ]Andrew L..Mark witz,,Esquire [ ]I:Ieidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ].Kevin T. McQuail,Esquire [ ]Christine L.Graham,Esquire [ ].Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ Joseph F.Riga,Esquire [ ]Joseph 1.Foley,Esquire Attorneys for Plaintiff mce OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Kelly A.Johnson 211 South Enola Drive Enola,Pennsylvania 17025 Wells Fargo Bank,N.A. COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Kelly A. Johnson and Michael D.Johnson No. 13-628 civil Defendants NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGME has be enter ' he above proc a ng as indicated below. Protliono X Judgment by Default Money Judgment �C Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe Weisberg and Conway. P.C. at(215)790-1010. W , OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Michael D.Johnson 211 South Enola Drive Enola,Pennsylvania 17025 Wells Fargo Bank,N.A. COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Kelly A. Johnson and Michael D.Johnson No. 13-628 civil Defendants NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMEN as bee tered he above a ding as indicated below. Prot 0notary � Y X Judgment b Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment,please call McCabe,Weisberg and Conway, P.C. at(215)790-1010. t � IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION FILE NO.: 13-628 civil Civil Term Wells Fargo Bank,N.A. V. AMOUNT DUE: $113,000.68 M INTEREST: from 08/14/13 Kelly A. Johnson and Michael D.Johnson $2,099.54 at$18.58 -< � �' ATTY'S COMM.: <CD ^°= -C=) COSTS: TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract,or account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs upon the following described property of the defendant(s) 211 South Enola Drive Enola Pennsylvania 17025-2808 _ (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description; supply four copies of lengthy personalty list) and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of the defendant(s) described in the attached exhibit. 4 / DATE: /,✓ BY [ ]Terrence J.McCabe,Esq. [ .arc S.Weisberg,Esq. Edward D:Conway,Esq. [ ]Margaret Gairo,Esq. Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. �Dy DO LA-11 [ ]Marisa J. Cohen,Esq. [ ]Kevin T. McQuail,Esq. -a.C)s l! k [ ] Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. Ann E. Swartz,Esq. [ ]Joseph F. Riga,Esq. Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. Attorneys for Plaintiff I U ,S� ( (l Firm: MCCABE,WEISBERG AND CONWAY Address:123 S.Broad Street, Suite 1400 c�q'' Philadelphia,PA 19109 C0 Sd Attorney for:Plaintiff !�! nn Telephone: (215)790 1010 u s d 3 Supreme Court D No. LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of East Pennsboro, Cumberland County, Pennsylvania,bounded and described according to a Map showing property of Thomas L. Schert,prepared by Gerrit J. Betz Associates,Inc., dated April 5, 1976 as follows: BEGINNING at a point in the center line of South Enola Drive at the distance of 116.40 feet measured northwardly from the center line of Covert Street;thence extending south 81 degrees 45 minutes 07 seconds west, passing through and beyond a partition wall between this and premises to the north 249.20 feet to a hub in line of land now or formerly of Ronald E. and Gayle V.Berner;thence extending along said land south 06 degrees 29 minutes east, 16 feet to a hub;thence extending along land now or formerly of Clinton Orris, north 83 degrees 45 minutes east, 243.60 feet to the first mentioned point and place of BEGINNING. BEING commonly known and generally referred to as No. 21.1 South Enola Drive,Enola, Pennsylvania. BEING the same premises which DAVID BAILEY AND SUSAN A.BAILEY,HUSBAND AND WIFE by deed dated January 25,2008 and recorded January 29,2008 in the office of the Recorder in and for Cumberland County in Deed Instrument#200802855 granted and conveyed to Michael D.Johnson and Kelly A.Johnson, Husband and Wife,in fee. TAX MAP PARCEL NUMBER:09-15-1291-205 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-628 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 KELLY A.JOHNSON AND MICHAEL D.JOHNSON (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 GARNISHEES)as follows: and to notify the gamishee(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:$113,004.68 L.L.: $.50 Interest FROM 8/14/13-$2,099.54 AT$18.58 Atty's Comm: Due Prothy:$2.25 Atty Paid:$297.45 Other Costs: Plaintiff Paid: Date: August 16,2013 David D. Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name: MARC S.WEISBERG,ESQUIRE Address:MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for:PLAINTIFF Telephone:215-790-1010 Supreme Court ID No. 17616 � v McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 _ MARGARET GAIRO,ESQUIRE-ID# 34419 C-0 - ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R.SPIVAK,ESQUIRE-ID#74770 rn re; MARISA J. COHEN,ESQUIRE-ID#87830 ' "+ KEVIN T.McQUAIL,ESQUIRE-ID#307169 . c n r- CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 51 C-1 ANN E. SWARTZ,ESQUIRE-ID#201926 ;_C.) JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,N.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff V. NO: 13-628 civil Kelly A. Johnson and Michael D.Johnson Defendants AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at:211 South Enola Drive,Enola,Pennsylvania 17025-2808,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Kelly A. Johnson 211 South Enola Drive Enola,Pennsylvania 17025 2. Name and address of Defendants in the judgment: Name Address Kelly A.Johnson 211 South Enola Drive Enola,Pennsylvania 17025 Michael D. Johnson 211 South Enola Drive Enola,Pennsylvania 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address Township of East Pennsboro 98 South Enola Drive Enola,Pennsylvania 17025 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 211 South Enola Drive Enola,Pennsylvania 17025-2808 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8`h Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue,Ste.311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America c/o U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. BY: Terrence J.McCabe-,Esq. -4-gare S.W/isberg,Esq. DATE Edward D.Conway,Esq. I Margaret Gairo,Esq. Andrew L.Markowitz,Esq. ]Heidi R. Spivak,Esq. Marisa J.Cohen,Esq. I Kevin T.McQuail,Esq. Christine L.Graham,Esq. I Brian T.LaManna,Esq. Ann E.Swartz,Esq. I Joseph F.Riga,Esq. Joseph 1.Foley,Esq. Celine P.DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece nf ground with the buildings and improvements thereon situate iuthe Township of East Pennobnro Cumberland County,Pennsylvania,bounded and described according tom Map showing property of Thomas{.. 8cbert,prepared 6v Gerrit J.Betz Associates,Inc., dated April 5, 1976 as fbUovvm: BEGINNING at a point in the center line of South Enola Drive at the distance of 116.40 feet measured northwardly from the center line of Covert Street;thence extending south 81 degrees 45 minutes 07 seconds vvoot,passing through and beyond a partition wall between this and premises 1m the north 249.20 feet to a hub in line of land now or formerly of Ronald E. and Gayle V. Berner;thence extending along said land south 06 degrees 29 minutes east,'I 6 feet to a hub; thence extending along land now or formerly ofClinton Orris, north 83 degrees 45 minutes east, 243.60 feet tuthe first mentioned point and place ofBEGINNING. BEING commonly known and generally referred to as No. 211 South Enola Drive,Enola, Pennsylvania. BEING the same premises which.DAVID BAILEY AND SUSAN A.BAILEY,HUSBAND AND WIFE hy deed dated January 25,2000 and recorded January 29,2080 in the office of the Recorder ioand for Cumberland County io Deed Instrument#2OO8O2855 granted and conveyed toMichael D.Johnson and Kelly A.Johnson, Husband and Wife,in fee. TAX MAP PARCEL NUMBER: 09-15-1291-205 _ ' a McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 c_71 �P-) HEIDI R.SPIVAK,ESQUIRE-ID#74770 m a" MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T. McQUAIL,ESQUIRE-ID#307169 �> CD CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 �-- `. BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 �C-) �., JOSEPH F.RIGA,ESQUIRE-ID#57716 ,> JOSEPH I.FOLEY,ESQUIRE-ID#314675 --i �{ CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW Wells Fargo Bank,N.A. COURT OF COMMON PLEAS V. CUMBERLAND COUNTY Kelly A.Johnson and Michael D.Johnson Number 13-628 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Kelly A.Johnson Michael D. Johnson 211 South Enola Drive 211 South Enola Drive Enola,Pennsylvania 17025 Enola,Pennsylvania 17025 Your house(real estate)at 211 South Enola Drive,Enola,Pennsylvania 17025-2808 is scheduled to be sold at Sheriffs Sale on December 4,2013 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$113,000.68 obtained by Wells Fargo Bank,N.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Wells Fargo Bank,N.A.the back payments, late charges, costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) r � YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-101.0. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full'amount due on the sale. To find out if this has happened,you may call McCabe,Weisberg and Conway,P.C. at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. C. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 y LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings erected, situate in the Township of East Pennsb Of round with and improvements thereon described according o a - d Coun g Map showing property of Thomas L. �'Pennsylvania, bounded and Associates, Inc., dated April 5, 1976 as follows: Schert prepared pared by Gerrit J.Betz BEGINNING at a point in the center line of South Enola Drive at measured northwardly from the center line of Covert Street, thence extending 07 seconds west,passing through and beyond a partition the distance of 116.40 feet 249.20 feet to a hub in line of land now or formerly of Ronald south 81 degrees 45 minutes p n wall between this and premises to the north along said land south 06 degrees 29 minutes east, 16 feet to a hubathence extending V. formerly of Clinton Orris, north 2 degrees 45 minutes Gayle Berner; thence extending place formerly BEGINNING east, 243.60 feet to the first mentioned Point and BEING commonly known and generally referred to as No. 211 Pennsylvania. South Enola Drive, Enola, BEING the same premises which DAVID BAILEY AND SUSAN A.BAILEY deed dad January 25,2008 and recorded Janu County to Deed Instrument#200802855 art'29'2008 in the office of the Recorder in and l d for Cumberland Husband and Wife, in fee. IFE by granted and conveyed to Michael D.Johnson and Kelly A.Johnson, date TAX MAP PARCEL NUMBER: 09-15-1291-205 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE, ESQUIRE-ID# 16496 ? Attorneys for Plaintiff i MARC S. WEISBERG, ESQUIRE- ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO, ESQUIRE-ID# 34419 l` - PN ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 .,r .�4, ry HEIDI R. SPIVAK,ESQUIRE-ID#74770 F' r ,r'` +LV jjU T`," MARISA J. COHEN, ESQUIRE-ID# 87830 YLV,q�k 1A KEVIN T. MCQUAIL, ESQUIRE-ID# 307169 CHRISTINE L. GRAHAM,ESQUIRE- ID# 309480 BRIAN T. LAMANNA, ESQUIRE-ID# 310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F. RIGA, ESQUIRE-ID# 57716 JOSEPH L FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN, ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790-1010 Wells Fargo Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. Number 13-628 civil Kelly A.Johnson and Michael D. Johnson Defendant AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for the Plaintiff in the within matter,hereby certifies that on the 29th day of October,2013, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s)as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSC�RIIBBED McCABE,WEISBERG AND CONWAY,P.C. BEFORE ME HIS „ 'DAY BY: & C '/ [ ] Terrence J.McCabe,Esquire arc S. Weisberg,Esquire OF 2013 [ ]Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ] Kevin T.McQuail,Esquire [ ] Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire NO AR PUBLIC [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph L Foley,Esquire [ ]Celine P.DerKrikorian,Esquire Attorneys for Plaintiff McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE, ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE-ID# 17616 EDWARD D. CONWAY, ESQUIRE -ID# 34687 MARGARET GAIRO, ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T. MCQUAIL,ESQUIRE-ID# 307169 CHRISTINE L. GRAHAM,ESQUIRE-ID# 309480 BRIAN T. LAMANNA,ESQUIRE-ID# 310321 ANN E. SWARTZ,ESQUIRE-ID# 201926 JOSEPH F. RIGA, ESQUIRE-ID# 57716 JOSEPH I. FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790-1010 Wells Fargo Bank,N.A. CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. NO: 13-628 civil Kelly A.Johnson and Michael D. Johnson Defendants AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 211 South Enola Drive,Enola,Pennsylvania 17025-2808,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property is attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Kelly A. Johnson 211 South Enola Drive Enola,Pennsylvania 17025 2. Name and address of Defendants in the judgment: Name Address Kelly A. Johnson 211 South Enola Drive Enola,Pennsylvania 17025 Michael D.Johnson 211 South Enola Drive Enola,Pennsylvania 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein File#70925 Page 1 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address Township of East Pennsboro 98 South Enola Drive Enola,Pennsylvania 17025 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 211 South Enola Drive Enola,Pennsylvania 17025-2808 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8th Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales File 470925 Page 2 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America c/o U.S.Dept.of Justice,Rm 4400 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 United States of America c/o U.S.Dept.of Justice,Rm 5111 Atty General of the United States 950 Pennsylvania Avenue,NW Washington,DC 20530 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. �0 130 113 McCABE,WEISBERG AND CONWAY,P.C. DATE ; BY: [ ]Terrence J. McCabe,Esquire [ ]Marc S.Weisberg,Esquire [ ]Edward D.Conway,Esquire [ ] Margaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire [ ] Heidi R. Spivak,Esquire [ ]Marisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire [ ]Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire [ J Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire [ ]Joseph L Foley,Esquire [ ] Celine P. DerKrikorian,Esquire Attorneys for Plaintiff Re: Wells Fargo Bank,N.A. v.Kelly A.Johnson. et al. Cumberland County;Number: 13-628 civil File#70925 Page 3 MCCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID# 87830 KEVIN T.MCQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,N.A. COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY V. Kelly A.Johnson and Michael D. Johnson Number 13-628 civil Defendants DATE: October 29,2013 TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS:Kelly A.Johnson and Michael D.Johnson PROPERTY:211 South Enola Drive,Enola,Pennsylvania 17025-2808 IMPROVEMENTS:Residential Dwelling JUDGMENT AMOUNT: $113,000.68 The above-captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on December 4,2013 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013.Our records indicate that you may hold a mortgage or judgments and liens on,and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty(30)days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10)days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien,we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. r ~ • Vi•�: fA �i n'd VI w p„ �• O O 0 3y. J O p A• O n CL n W � V y""dC"bC •d '�"•C1�'T! "y';'d�7CJ►-7C 'ii"G�`�CJC'� "C�"" •'C� y7,;Cr. CD 0 Cr1�CD ❑°�o❑°n a� Oeo O-ci y -i O=� `dv �b °� ° o r"D' K `7� fD ty M ^' fj "Y n Z t fD eD Z to fD m eD 0� "! M 1C9 o A CD c >C�OaD caco � cysO� y c � '+ coc .pO� cc dcre ° � ° o, o N'-" `+ oo a� n oa va as �.b z, ara eD �,eD 0o fD eD O 74 0�n'.eD O C�n g 0 b,°oa fD �° f�D ►d��°`!o r� �i y-i - °' 5y^ zoo(A_o = c c = moo ^d c >o.d o t, �c�d�o O° °�•. 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'C ��� r• C O :y.0 .�• y 00 ft O N C' pm ° CD pCD ° eD C r+Na�eD � C �b C N.C� O < to Vi o OCD y n �> C � 0 "9 McCABE,WEISBERG AND CONWAY,P.C. �Attor,'ti�e �,fU� ?tatiff BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 f _ MARC S. WEISBERG,ESQUIRE-ID# 17616 `` ' ti°� P 2: ' EDWARD D. CONWAY,ESQUIRE -ID#34687 $ E r� MARGARET GAIRO,ESQUIRE-ID#34419 U'I3 n L M N D C G u�#1•,i, ANDREW L.MARKOWITZ,ESQUIRE-ID#28009 P ESN-Y LUA J_ ' HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T. LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L.WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,N.A. Cumberland County Court of Common Pleas Plaintiff V. Kelly A. Johnson and Michael D. Johnson Number 13-628 civil Defendants AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA :SS. COUNTY OF PHILADELPHIA The undersigned attorney, being duly sworn according to law, deposes and says that the following is true and correct to the best of his/her knowledge and belief: 1. That he/she is counsel for the above-named Plaintiff; 2. That on October 21, 2013, in accordance with the attached Court Order, Plaintiff served a true and correct copy of the Notice of Sheriff s Sale of Real Property upon the Defendant, Kelly A.Johnson and Michael D.Johnson,by regular mail,certificate of mailing and certified mail, y return receipt requested, addressed to their last-known address of 211 South Enola Drive, Enola, Pennsylvania 17025. A true and correct copy of the letter and certified receipt, is attached hereto, made a part hereof, and marked as Exhibit "A". 3. That on September 27,2013,in accordance with the attached Court Order,Plaintiff served a true and correct copy of the Notice of Sheriff's Sale of Real Property upon the Defendant, Kelly A. Johnson and Michael D. Johnson, by posting the same at the mortgaged premises of 211 South Enola Drive,Enola,Pennsylvania 17025. A true and correct copy of the Sheriff's Returns of Service indicating same is attached hereto,made a part hereof, and marked as Exhibit "B". McCABE,WEISBERG AND CONWIV, P.C. BY: �� C [ ]Terr nee J. McCabe,Esq. arc S. Weis b rg, Esq. ( ]Edward D. Conway,Esq. [ ] Margaret Gairo, l;sq. [ ]Andrew L. Markowitz,Esq. [ ]Heidi R. Spivak, Esq. [ ] Marisa J. Cohen,Esq. [ ] Christine L. Graham, Esq. [ ]Brian T.LaManna,Esq. [ )Ann E. Swartz, Esq. [ )Joseph F. Riga, Esq. ( ]Joseph I. Foley, Esq. ( ] Celine P. DerKrikorian, Esq. Attorneys for Plaintiff SWORN AND SUBSCRIBED BEFORE ME THIS d6l"DAY OF n oym t- , 2013 006ho_�') 5( Lyrt"� NOTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL. ANDREW S.HUMES,Notary Public City of Philadelphia,Phila,County My Commission Expires September 19,2017 r 0 ' n� r T '_ �''/_ 1 !14._ ;.)x... 221? AF 30 PSI I4. 1 i CUMBERLAND COUNTY PENNSYL'r'ANIA Wells Fargo Bank,N.A. Cumberland County Plaintiff Court of Common Pleas V. Number 13-628 civil Kelly A. Johnson and Michael D. Johnson Defendants 0 R 1) E R AND NOW, thiJ day id pfk-'� ' 2013, the Plaintiff is t;rantcd leave to serve all process in this mortgage foreclosure action upon the Defendants, Kelly A. .lohnson and Michael D. Johnson, by regular mail and by certified mail, return receipt requested, to their last known address of 211 South Enola Drive, Enola, Pennsylvania 17025, and by posting the mortgaged premises of 211 South Enola Drive, Enola, Pennsylvania 17025. 4 j. OURT: EXHIBIT A t fU r� m - r- _. fU Postage $ ! ru Certifiod Feu C3 Po�tRr k C3 Return Receipt Fee s - 9 (['r'ulvrsernentRequired) Jr litxa" Restricted Delivery Fee ._ _•, M (Endorsement Required) D- `fotal Postage&Feoe nl Sent Tv O SYrev Apt v,; '° - (ti yr PO flux No. - - n C;/ly,Sfote ZJP--r4�. �.'"•`� - t r c� _-.,r.�L✓�:rx- irr rr. Ir c rn d cp _ U1 Postage I� PU Corliflod Foo ru "�" -- Postmark O Ra turn Receipt f ee C3 (Endorsement Required) r-3 Restricted Delivery Fern _. (I-'ndomenn—1 Roquuod) , O .__.. _.... ... r, Taal F c stagy f Fr.rt: a r _ e �( , its - i � (}x o strdnt t -. or PU H(x No tit V Ei f F z y u rt a� w s q � o l v, 1y 4 N � `tl 7 kn O ti � Q y a U Gar ni _ ccF cn v o � V OU A U ❑ ❑ ❑ ❑ ❑ �1NW ! NW a O ti U co °n: >~ oo 4. Y J bA C% rn �,�, v M N M d n W C 00 CN C7 n EXHIBIT B SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ,��tNlt•pS�tttr�f,^^r l,;ii Jody S Smith ' Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank, N.A. Case Number vs. 2013-628 Kelly A Johnson(et al.) SHERIFF'S RETURN OF SERVICE 09/27/2013 07:00 PM-Deputy Stephen Bender, 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 211 South Enola Drive, East Pennsboro-Township, Enola, PA 17025, Cumberland County. 09/27/2013 07:00 PM-Deputy Stephen Bender, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Kelly A Johnson, pursuant to Order of Court by"Posting"the premises located at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025-2808, Cumberland County with a true and correct copy according to law. 09/27/2013 07:00 PM-Deputy Stephen Bender, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Michael D. Johnson, pursuant to Order of Court by"Posting"the premises located at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025, Cumberland County with a true and correct copy according to law. SHERIFF COST: $981.16 SO ANSWERS, October 24, 2013 RON R ANDERSON, SHERIFF "SHERIFF'S OFFICE OF CUMBERLAND COUNTY P,,'il-Vi FI tr 4. . Ronny R Anderson ifabr THE 't l IC�h iii °7 Sheriff r�ly�� Jody S Smith r` 20R JAN 23 AM Chief Deputy '� `>r '�� ''�LA�iG COUNTY Richard W Stewart Solicitor OFficE OF TRE s"Er'FF P NNSYLVAN: IA Wells Fargo Bank, N.A. Case Number vs. 2013-628 Kelly A Johnson (et al.) SHERIFF'S RETURN OF SERVICE 09/27/2013 07:00 PM -Deputy Stephen Bender, 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 211 South Enola Drive, East Pennsboro-Township, Enola, PA 17025, Cumberland County. 09/27/2013 07:00 PM -Deputy Stephen Bender, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Kelly A Johnson, pursuant to Order of Court by"Posting"the premises located at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025-2808, Cumberland County with a true and correct copy according to law. 09/27/2013 07:00 PM - Deputy Stephen Bender, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Michael D. Johnson, pursuant to Order of Court by"Posting"the premises located at 211 S. Enola Drive, East Pennsboro, Enola, PA 17025, Cumberland County with a true and correct copy according to law. 12/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania on December 04, 2013 at 10:00 AM. He sold the same for the sum of$1.00 to Attorney Terrance McCabe, on behalf of Wells Fargo Bank, N.A., being the buyer in this execution, paid to the Sheriff the sum of$ SHERIFF COST: $935.32 SO ANSWERS, January 21, 2014 RONR ANDERSON, SHERIFF -? �S pool eo- S7 L-- /9•r 644 g y2.c:2 (c)Coun ySuite Sheriff:Teleosoft,Inc. McCABE,WEISBERG AND CONWAY,P.C. BY TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID#17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T.McQUAIL,ESQUIRE-ID#307169 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 • JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,N.A. CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff v. NO: 13-628 civil Kelly A.Johnson and Michael D. Johnson Defendants AFFIDAVIT PURSUANT TO RULE 3129 The undersigned,attorney for Plaintiff in the above action,sets forth the following`information concerning the real property located at:211 South Enola Drive,Enola,Pennsylvania 17025-2808,as of the date the Praecipe for the Writ of Execution was filed.A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Kelly A. Johnson 211 South Enola Drive Enola,Pennsylvania 17025 2. Name and address of Defendants in the judgment: Name Address Kelly A. Johnson 211 South Enola Drive Enola,Pennsylvania 17025 Michael D. Johnson 211 South Enola Drive Enola,Pennsylvania 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein (/ 4. Name and address of the last recorded holder of every mortgage of record: fa Name Address _ Plaintiff herein 5. Name and address of every other person who has any record lien on the property: Name Address Township of East Pennsboro 98 South Enola Drive Enola,Pennsylvania 17025 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 211 South Enola Drive Enola,Pennsylvania 17025-2808 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O.Box 2675 Harrisburg,PA 17105 ATTN:Dan Richard Commonwealth of Pennsylvania 110 North 8th Street Inheritance Tax Office Suite#204 Philadelphia,PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department#280601 Inheritance Tax Division Harrisburg,PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O.Box 8486 Recovery Program Harrisburg,PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O.Box 281230 Harrisburg,PA 17128-1230 PA Department of Revenue PO BOX 280948 Bureau of Compliance Harrisburg PA 17128-0948 Lien Section • Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg,PA 17128-1230 Compliance ATTN: Sheriff's Sales N United States of America Internal Revenue Service •i Technical Support Group • William Green Federal Building Room 3259 600 Arch Street Philadelphia,PA 19106 Domestic Relations P.O.Box 320 Cumberland County Carlisle,PA 17013 United States of America do United States Attorney for the Middle District of PA William J.Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 ` Scranton,PA 18503 and Harrisburg Federal Building&Courthouse 228 Walnut Street, Ste.220 Harrisburg,PA 17108-1754 United States of America do U.S.Dept of Justice,Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 United States of America do U.S.Dept of Justice,Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington,DC 20530-0001 8. Name and address of Attorney of record: Name Address None I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. - Section 4904 relating to unsworn falsification to authorities. / 1 l t BY: r IA �c W 1 [ ]Terrence J. cCabe,Esq. [ arc S.W•isberg,Esq. DATE [ ] Edward D.Conway,Esq. [ ] Margaret Gairo,Esq. [ ] Andrew L.Markowitz,Esq. [ ] Heidi R.Spivak,Esq. [ ] Marisa J.Cohen,Esq. [ ] Kevin T. McQuail,Esq. [ ] Christine L. Graham,Esq. [ ] Brian T.LaManna,Esq. [ ] Ann E.Swartz,Esq. [ ] Joseph F.Riga,Esq. [ ] Joseph I.Foley,Esq. [ ] Celine P. DerKrikorian,Esq. Attorneys for Plaintiff LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of East Pennsboro, Cumberland County,Pennsylvania,bounded and described according to a Map showing property of Thomas L. Schert,prepared by Gerrit J. Betz Associates, Inc., dated April 5, 1976 as follows: BEGINNING at a point in the center line of South Enola Drive at the distance of 116.40 feet measured northwardly from the center line of Covert Street;thence extending south 81 degrees 45 minutes 07 seconds west, passing through and beyond a partition wall between this and premises to the north 249.20 feet to a hub in line of land now or formerly of Ronald E. and Gayle V. Berner;thence extending along said land south 06 degrees 29 minutes east, 16 feet to a hub; thence extending along land now or formerly of Clinton Orris, north.83 degrees 45 minutes east, 243.60 feet to the first mentioned point and place of BEGINNING. BEING commonly known and generally referred to as No. 211 South Enola Drive,Enola, Pennsylvania. BEING the same premises which DAVID BAILEY AND SUSAN A.BAILEY,HUSBAND AND WIFE by deed dated January 25,2008 and recorded January 29,2008 in the office of the Recorder in and for Cumberland County in Deed Instrument#200802855 granted and conveyed to Michael D.Johnson and Kelly A.Johnson, Husband and Wife,in fee. TAX MAP PARCEL NUMBER: 09-15-1291-205 • McCABt,WEISBERG AND CONWAY,P.C. BY: TERRENCE J. McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L. MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 KEVIN T. McQUAIL,ESQUIRE-ID#307169 CHRISTINE L. GRAHAM,ESQUIRE-ID#309480 BRIAN T.LaMANNA,ESQUIRE-ID#310321 ANN E.SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 CIVIL ACTION LAW Wells Fargo Bank,N.A. COURT OF COMMON PLEAS v. CUMBERLAND COUNTY Kelly A. Johnson and Michael D. Johnson Number 13-628 civil NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Kelly A.Johnson Michael D.Johnson 211 South Enola Drive 211 South Enola Drive Enola,Pennsylvania 17025 Enola,Pennsylvania 17025 Your house(real estate)at 211 South Enola Drive,Enola,Pennsylvania 17025-2808 is scheduled to be sold at Sheriffs Sale on December 4,2013 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square,Carlisle,Pennsylvania 17013 to enforce the court judgment of$113,000.68 obtained by Wells Fargo Bank,N.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Wells Fargo Bank,N.A.the back payments, late charges, costs,and reasonable attorney's fees due. To find out how much you must pay,you may call McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) r YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling McCabe,Weisberg and Conway,P.C.,Esquire at(215)790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened,you may call McCabe, Weisberg and Conway,P.C. at(215)790-1010. 4. If the amount due from the buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty(30)days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed schedule of distribution is wrong)are filed with the Sheriff within ten(10)days after the posting of the schedule of distribution. 7. You may also have other rights and defenses,or ways of getting your real estate back,if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 • a . LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of East Pennsboro, Cumberland County,Pennsylvania,bounded and described according to a Map showing property of Thomas L. Schert, prepared by Gerrit J.Betz Associates,Inc., dated April 5, 1976 as follows: BEGINNING at a point in the center line of South Enola Drive at the distance of 116.40 feet measured northwardly from the center line of Covert Street; thence extending south 81 degrees 45 minutes 07 seconds west, passing through and beyond a partition wall between this and premises to the north 249.20 feet to a hub in line of land now or formerly of Ronald E. and Gayle V. Berner;thence extending along said land south 06 degrees 29 minutes east, 16 feet to a hub; thence extending along land now or formerly of Clinton Orris,north 83 degrees 45 minutes east, 243.60 feet to the first mentioned point and place of BEGINNING. BEING commonly known and generally referred to as No. 211 South Enola Drive,Enola, Pennsylvania. BEING the same premises which DAVID BAILEY AND SUSAN A.BAILEY,HUSBAND AND WIFE by deed dated January 25,2008 and recorded January 29,2008 in the office of the Recorder in and for Cumberland County in Deed Instrument#200802855 granted and conveyed to Michael D.Johnson and Kelly A.Johnson, Husband and Wife,in fee. TAX MAP PARCEL NUMBER: 09-15-1291-205 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-628 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 KELLY A.JOHNSON AND MICHAEL D.JOHNSON (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: $113,000.68 L.L.: $.50 Interest FROM 8/14/13-$2,099.54 AT$18.58 Atty's Comm: Due Prothy: $2.25 Atty Paid:$297.45 Other Costs: Plaintiff Paid: Date: August 16,2013 David D. Buell,Prothonota (Seal) By: // Deputy REQUESTING PARTY: Name: MARC S.WEISBERG,ESQUIRE Address:MCCABE,WEISBERG AND CONWAY 123 S.BROAD STREET,SUITE 1400 PHILADELPHIA,PA 19109 Attorney for:PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 17616 TRUE COPY FROM RECORD 1n-Testimony whereof, I here unto set my hand and the seal of said Court at Carlisle,0 Pa` 3 This____�_day of —Pr thonota—ry gob a • On August 22, 2013 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, Known and numbered as, 211 South Enola Drive, Enola, as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: August 22, 2013 By: Real Estate Coordinator 00 :0r V b 1,p,ty d1 LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No.2013-628 Civil Term WELLS FARGO BANK,N.A. vs. KELLY A.JOHNSON, Michael D.Johnson Atty.:Terrance McCabe ALL THAT CERTAIN lot or piece of ground with the buildings and im- provements thereon erected, situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, bounded and described according to a Map showing property of Thomas L.Schert,prepared by Gerrit J.Betz Associates,Inc.,dated April 5, 1976 as follows: BEGINNING at a point in the center line of South Enola Drive at the distance of 116.40 feet measured northwardly from the center line of Covert Street;thence extending south 81 degrees 45 minutes 07 seconds west, passing through and beyond a partition wall between this and premises to the north 249.20 feet to a hub in line of land now or formerly of Ronald E. and Gayle V. Berner; thence extending along said land south 06 degrees 29 minutes east, 16 feet to a hub;thence extending along land now or formerly of Clinton Orris, north 83 degrees 45 minutes east, 243.60 feet to the first mentioned point and place of BEGINNING. BEING commonly known and generally referred to as No.211 South Enola Drive,Enola,Pennsylvania. BEING the same premises which DAVID BAILEY AND SUSAN A. BAILEY, HUSBAND AND WIFE by deed dated January 25, 2008 and recorded January 29, 2008 in the office of the Recorder in and for Cum- berland County in Deed Instrument #200802855 granted and conveyed to Michael D.Johnson and Kelly A. Johnson,Husband and Wife,in fee. TAX MAP PARCEL NUMBER:09- 15-1291-205. 68 The Patriot-News Co. • ,, 2020 Technology Pkwy Q patriot*Xcws Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 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. This ad ran on the date(s)shown below: trwe 2013-628 Civil Term 10/13/13 LLS FARGO BANK,N N . • - vs. KELLY A JOHNSON • 10/20/13 Michael D.Johnson 10/27/13 'Ariy: Terrance McCabe ALL THAT CERTAIN lot or piece of ground with the buildings and improvements - thereon erected, situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, bounded and described according to a Map showing property of Sworn to and subscribed befor-ie this 11 day of November, 2013 A.D. Thomas L. Schert, prepared by Gerrit J. Betz Associates,Inc.,dated April 5,1976 as I follows: . 1 1 al C ' I ' BEGINNING at a point in the center line of I ` _ South Enola Drive at the distance of 116.40 4' •7.41.I•ublic 1."1 feet measured northwardly from the center line of Covert Street;thence extending south j 81 degrees'45 minutes 07 seconds west, passing through and beyond a partition wall between this and premises to the north 249.20 feet to a hub in line of land now or formerly C(yMMONWEAL OF pENNSYI VANS ,of■Ronaid E.�rner,thence Notarlsl Seal extending along said land south 06 degrees Holly wEn Warfel,Notary QubliC 29 minutes east, 16 feet to a hub; thence Washington TwP.,Dauphin COUnty M Commisston Expires DeC.12,2016 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES 2013-628 Chill Term WELLS FARGO BANK,N.A. vs. KELLY A JOHNSON Michael D.Johnson 'Atty: Terrance McCabe ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, bounded and described according to a Map showing property of Thomas L. Schert, prepared by Gerrit J. Betz Associates,Inc.,dated April 5,1976 as follows: BEGINNING at a point in the center line of South Enola Drive at the distance of 116.40 feet measured northwardly from the center line of Covert Street;thence extending south 81 degrees 45 minutes 07 seconds west, passing through and beyond a partition wall between this and premises to the north 249.20 feet to a hub in line of land now or formerly of Ronald E.adds Gayle V•3erner;thence extending along said land south 06 degrees 29 minutes east, 16 feet to a hub;thence extending along land now or formerly of Clinton Orris,north 83 degrees 45 minutes east,243.60 feet to the first mentioned point and place of BEGINNING. BEING commonly known and generally referred to as No.211 South Enola Drive, Enola,Pennsylvania. BEING the same premises which DAVID 'r BAILEY AND SUSAN A. BAILEY, HUSBAND AND WIFE."by-deed dated t January 25,2008 and recorded January 29, , 2008 in the office of the Recorder in and for Cumberland County in Deed Instrument #200802855 granted and conveyed to Michael D.Johnson and Kelly A.Johnson, Husband and Wife,in fee. . TAX MAP PARCEL NUMBER: 09-15- 1291-205 • COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Wells Fargo Bank is the grantee the same having been sold to said grantee on the 4th day of December A.D., 2013, under and by virtue of a writ Execution issued on the 16th day of August, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 628, at the suit of Wells Fargo Bank N A against Kelly A & Michael D Johnson is duly recorded as Instrument Number 201401756. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this 03 day of Jcv l , A.D. ao it7 - ) G W✓Ei ; use? Recorder f Deeds Recorder of Deeds,Cumberland County,Certi*PA My Commission Expires the First Monday of Jan.2018