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HomeMy WebLinkAbout13-0683IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ~; -~ ~:~. WELLS FARGO BANK, NA, CIVIL DIVISION ~~a c:r Plaintiff, NO.: ~~ ~ /~ r cry ~ .-- VS. ~ ~ TYPE OF PLEADING ~,,~ ca Jeffrey A. Maguire; ~ --+ ,.. CIVIL ACTION -COMPLAINT rv Defendant. TO: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A DEFAULTJUDGMENT MAY BE ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3476 Stateview Blvd.. Ft. Mill, SC 29715. AND THE DEFENDANT: 420 South Frederick Street Mechanicsburg, PA 17055-6410 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 4205outh Frederick5treet. Mechanicsburg PA 17055-6410 Munici alit :Mechanicsburg ATTORNEY O PLAINTIFF ATTY FILE NO.: XFP 175473 IN MORTGAGE FORECLOSURE COUNSEL OF RECORD FOR THIS PARTY: FILED ON BEHALF OF: Wells Faro Bank, NA ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire Pa. I.D. #55650 Kimberly A. Bonner, Esquire Pa. I.D. #89705 Joel A. Ackerman, Esquire Pa I.D. #202729 Ashleigh Levy Marin, Esquire Pa I.D. #306799 Ralph M. Salvia, Esquire Pa I.D. #202946 Jaime R. Ackerman, Esquire Pa I.D. #311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckereoldber>?.com File No.: XFP-175473/mme r-, ...~ --~~ ~- ~- ;r:; -~ <~-~ (~ (3 - .i :~' - r~.• -_ ._.~ .-; ~,~~~'1G3.7S~1 Q ~u~ y~(~~ ~~- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, NO.. vs. Jeffrey A. Maguire; Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA vs. Jeffrey A. Maguire; CIVIL DIVISION Plaintiff, NO.. Defendant. AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demands establecida en las siguientes paginas, debe tomar accidn dentro de los prdximos veinte (20) dias despu~s de la notificacibn de esta Demands y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falls en tomar action como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier sums de dinero reclamada en la demands 0 cua Iquier otra reclamation o remedio solicitado por el demandante, puede ser dictado en contra Suva por la Corte. Usted puede perder dinero 0 propiedades u otros derechos importantes pars usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, NO.. vs. Jeffrey A. Maguire; Defendant. CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, NA, by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, NA, (hereinafter "plaintiff") with its place of business located at 3476 Stateview Blvd., Ft. Mill, SC 29715. 2. The Defendant, Jeffrey A. Maguire, is an individual whose last known address is 420 South Frederick Street, Mechanicsburg, PA 17055-6410. 3. Wells Fargo Bank, NA, directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, NA 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 May 1, 2009, Jeffrey A. Maguire, a married man made, executed and delivered to Wells Fargo Bank, N.A. a Mortgage in the original principal amount of $166,920.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on June 5, 2009, Instrument #200919003. 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. 6. The aforesaid Mortgage was amended and increased in principal amount of $168,848.53 pursuant to a certain Modification Agreement by and between Wells Fargo Bank, NA and Defendant, Jeffrey A. Maguire, which is unrecorded at this time. The terms of said modification set forth the interest rate at 4.250% with a new monthly payment and interest amount of $830.63 Zucker, Goldberg & Ackerman, LLC XFP-175473 062-PA-V3 commencing April 1, 2011 and continuing thereon with the due date of obligation March 1, 2041. A true and correct copy of said Modification Agreement is marked Exhibit C, attached hereto and made a part hereof. 7. Jeffrey A. Maguire, a married man is the record and real owner of the aforesaid mortgaged premises. 8. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due August 1, 2012. 9. As of 01/11/2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $ 164,995.75 Interest through 01/11/2013 $ 3,698.28 Escrow Advance $ 1,809.91 Late Charges $ 198.84 Inspection Fees $ 15.00 Total $170,717.78 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff s attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 11. This action does not come under Act 91 of 1983 because the mortgage is FHA insured. Zucker, Goldberg & Ackerman, LLC XFP-175473 062-PA-V3 12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $170,717.78 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER,-~GOLDBEfRG~p& ACKERMAN, LLC BY:~~t \~~l~U 1.~~ Dated: ~ ~~ ~ ~ ~ Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-175473/mme 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com TH-S 15 AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMAi70N OBTAINED .WILL BE USED FOIL THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC XFP-175473 062-PA-V3 EXHIBIT A 062-PA-V3 Zucker, Goldberg & Ackerman, LLC XFP-175473 NOTE ~'~iA t:ase No. Multistate ~~~. MAY 1, 2009 [Dawj 420 S FREDERICK STREET, MECHANiCSBURG, PA 17855 [Property Address) I. PARTIES "Borrower" means each person signing at the end. of this Note, and the person's successors and assigns. "'Lender" means WELLS FARGO BANK, N.A. and its successors and assigns. Z. BORRQ~'1'ER'S PRUM[SE TO 1'AY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum ofp~ HUNI3RED SIXTY-SIX THOUSAND NINE Ht3NDRAD TWENTY AND NO/100 Dollars {U.S. $ ***16fi, 920.00 ), plus intcrest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lcndcr, at the. rate ofFiVE AND ONE-SALE percent ( 5.500 %) pcryear until the full amountof principal has been paid. 3. PROMISE TU PAY S1rCURED Borrower's prdmisc to pay is secured by a mortgage, decd of trust ar similar security instrument that is dated the same date as this Note and called the "Security ]nstrument." The Security instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MAi`IiYER OF PAYMEi'~T {A) Time Borrower shall make a payment of principal and interest to Lcndcr on the first day of each month beginning on JiINE 20©9 ..Any principal and intcrest remaining on the first day of MAY , 2039 ,will be due on that date, which is called the "iVlaturity Date." (B) Place ['aymcnt shall be made at WELLS FARGO BANK, N.A. P . 0. BOX 11701, NEWARK, NJ 07101-9701 or at such place as Lender may designate in writing by naticc to Burrower. (C) Amount Each monthly payment ufprincipal and intcrest will be in the. amount of iJ.S. $ *******99.7.76 . 1'itis amount will be part of a .larger monthly payment required by the Security Instrument, that shall. be applied to principal, interest and other items in the order described in the Security Instrument. (D) A!longe to this Note for payment adjustments If an allongc providing for payment adjustments is executed by Buncawer together with this Notc, the covenants of the al longc shall be incorporated into and shall amend. and.supplement the covenants of this Note as if the allangc were a part of this Notc. (Check applicable box) ^Graduated Payment Allonge ^Growing )~quity Allonge ^4ther [specify) 5. l3URRQWER'S RICHT TQ PREPAY Borrower ha.4 the right. to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall. accept prepayment on other days providt:d that borrower pays interest on the. amount prepaid for the remainder of the month to the extent required by Lcndcr 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 Lcndcr agrees in Wrlting tQ those change. rrm~ra~etiwwsrswrrrN~rrurrr~~~~~~ FIIA Multistate Fixed Rate NOtc- ltlly5 -1R lssan VMP MORTGAGE FORMS • 1800>521JT91 ~ Pupo 1 0l 2 Initia4: 6. BURRUWER`S l~AILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received xhe full monthly payment required by the Security instrument, as dcscribcd in Paragraph 4(C) of this Notc, by the end of fifteen calendar days after the payment i 3uc, Lender may collect a late charge in the amount of E'OtJR percent (4.000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment,. then Lender may, exceptas limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the ;principal balance remaining duce and all accrued interest. Lcndcr may choose not to exercise this option: without waiving its rights in the event t~f any subscgtrcnt default. In many cirrumstanccs regulations issued by the Secretary will limit Lender's rights tU require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when-not permitted. by HUD regulations. As used in this Notc, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment pf Costs and Expenses If Lender has required immediate payment in full, as dcscribcd above, Lender may require Borrower to pay costs and expenses including reasonable and customary attomcys' fees for enforcing this Nate to the extent not prohibited by applicable law. Such fees and casts 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 Nvtc waive the rights of presentment and notice of dishonor "PresentmenC' means the right to require L,cnder 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. GlVINC OIF NOTICES Unless applicablclaw requires a different methrxl, 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 $orrowcr at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Nate will bc; given by first class matt o Lcndcr at the address stated in Paragraph 4(B) or at a different address if borrower is given a notice of that ditTercnt address. 9. UBLIGATIUNS OF PERSOVS UNl7ER THIS VOTE if more than one: person signs this Notc, each person-i fully and personally obligated to keep all of the promises made in this Notc, including the promise to pay the full amount owed. Any person who is a guarantor, surety or cndorur of this .Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Natc, is also obligated to keep all o[the promises made in this Note. Lender. may enforce its rights under this Note against each person individually or against all signatories. together. Any one person signing. this Note maybe required to pay all of the amc}unts owed under this Note. BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Notc. (Seal) (Seal) -Borrower Y A IRE .Borrower (Seal} -borrower ($cal) -lierrowcr (Seal) WITHOUT URSE -borrower PAY YO T RQER OF ~m-1R t88ort (Seal) wlT~~,~~~+{ Q~ -Borrower PA`l T4 THE (Brag -tiorrowcr (Seal) -&urawer 13AN1<, N.A. Pegs z °r z 1n ~~~~- VICE PRESIDENT 6Y. EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-175473 062-PA-V3 ' ~ °, I~GA,L DE~iCRIPTION AI.L 'I'~A,T CERTAIN puce; parcel and of land situate is the Borough of Mexltaini+cs~trg, County o~ ~umberlattd, State of Pennsylvania, more particularly bounded and described as fnllawg, to wlt: HEGINN'lN4 at a hub in SotYth Frederick Straeet, which said hub is North ninety-sight and eighty hundredths (9&.8'0) feet from the northwest corner of South Frederick Sheet and West Marble Strcet; thence along lands now or formerly of C. Schultz, South eighty (80) degrees tvrenty-two (22).trtinutes thirty (30) seconds West, a diseases of twa hundred twenty (~20). feet to a hub on the eastern line of a tvaeenty (20) foot alley; thence along the eastern line o~said alley, North t+en (l 0) degrees throe {3) minutes West, a distance of >:Ifty send forty=fouarr hundredths (~0.4~) feet to a hail; thence along !sands rww or form~xly of Mirsnlt F> Fry, North sigti~y! ~$0~} degi'ees t~jr three (S3j minutes tv~nty-(2Q) seconds East, a diet~itce oftwax-ty-flir;ee and eleven hundredths {23.Y 1) feet to a.point; thence further by earns, South nine (9) degrees six (6} minutes forty (40) seconds. East, a distance of three and eigktty-five hundredths (3.85) feet to a point; theses by saute and along a fonc~,:North tighty=~8(l} degrees thirty-two (32) nxittut~cs twenty (20) seconds East, a' distance of one hundreid seventeen and eighty-three (l 17.83} feet to a point; thettce'still ~by Dante; Norfh,;rEittc (o9j degrees fifty-flue (SS) miautes West, a dlstanae of five and ~t$~-= fs~ve hundr+xltn~ (5.55) feet to a point; tl~nce thrQUgh tha center of a frarnc partition wail of a double house and beyond, I~Iorth eighty (80) degrees flue (S) minutes East, a distartcc. afseventy-nine and fen hundredths (T9.I0) feet to a nail. in said South Frederick Street; thet-ce along said South Frederick Street, South tea{30) degrees three {3) minutes Last, a distance of fifty-two (S2) fret to a hub, the point and place of BEGINNING. I-IA'VIN.a THEREON ER:BCTE~ the southern half of a two and one-half story frame dwelling house known and.numbered as 420 South Frederick Street and a ottestory franca garage; Tlie aforesaiddescription is made in accordance with'a survay made by Jahn C, Brillbart, T~.S,, on Febsvary 26,1969. EXHIBIT C Zucker, Goldberg & Ackerman, LLC XFP-175473 062-PA-V3 ,. e Well~'Fargo Home Mortgage MAC W0152-010 220 Wildwood Parkway Birmingham. AL 35209 Tei: 877 325 4114 Toll Free LOAN MODIFICATION AGREEMENT LOAN NUMBER: PROPERTY ADDRESS 420~rick Street Mechanicsburg PA 17055 THIS LOAN MODIFICATION AGREEMENT ("Agreement"), made on January 25, 2011, by and between Jeffrey A Maguire and and (the "Borrower(s)") and Wells Fargo Bank, N A (the "Lender", together with the Borrowers}, the "Parties"). WITNESSETH WHEREAS, Borrower has requested and Lender has agreed, subject to the following terms and conditions, to a loan modification as follows: NOW THEREFORE, in consideration of the covenants hereinafter set forth and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged by the Parties, it is agreed as follows (notwithstanding anything to the contrary in the Note and Security Instrument dated 05/01/2009.) 1. BALANCE. As of January 25, 2011, the amount payable under the Note and Security Instrument (the "Unpaid Principal Balance") is U.S. $ 163,893.96. 2. EXTENSION, This Agreement hereby modifies the following terms of the Note and Security Instrument described herein above as follows: A. The current contractual due date has been extended from 10-01-10 to 04/01/2011, The first modified contractual due date is on 04/01/2011. B. The maturity date has been extended from 05-39 (month/year} to 03/01/2041. C. The amount of interest to be included (capitalized) will be U.S. $ 4,507.08. The amount of the Escrow Advance to be capitalized will be U.S. $1,272.73. The amount of Recoverable Expenses* to be capitalized will be U.S. $0.00. The modified Unpaid Principal Balance is U.S. $ 158,848.53. * Recoverable Expenses may include, but are not limited to: Title, Attorney fees/costs, BPO/Appraisal, and/or Property Preservation/ Property Inspections D. The Borrowers} promises to pay the Unpaid Principal Balance plus interest, to the order of the Lender. Interest will be charged on the Unpaid Principal Balance of U.S. $ 168,848.53. The Borrower(s) promises to make monthly payments of principal and interest of U.S. $ 830.63, at a yearly rate of 4.250, not including any escrow deposit, if applicable. If on the maturity date the Borrower(s) still owes an amount under the Note and Security Instrument, as amended by this Agreement, Borrower(s) will pay this amount in full on the maturity date. LM521/WUC/1 WNIs Fargo Home Mortgage Is a tlivlsbn o(Wells Fargo Bahr, NA. Together we'll go far :~. ~+ ~ WeUs\Fargo Home Mortgage MAC ~ 0152-010 220 Wildwood Parkway Birmingham, AL 35209 Tel: 877 325 4114 Toll Free 3. NOTE AND SECURITY INSTRUMENT. Nothing in this Agreement shall be understood or construed to be a satisfaction or release, in whole or in part of the Borrower's obligations under the Note or Security Instrument. Further, except as otherwise specifically provided in this Agreement, the Note and Security Instrument will remain unchanged, and Borrower and Lender will be bound by, and shall comply with, all of the terms and provisions thereof, as amended by this Agreement. 4. The undersigned Borrower(s) acknowledge receipt and acceptance of the Loan Modification Settlement Statement. Borrower(s) agree with the information disclosed in and understand that I/we am/are responsible for payment of any outstanding balances outlined in the Loan Modification Settlement. 5. The undersigned Borrower(s) acknowledge receipt and acceptance of the Borrower Acknowledgements, Agreements, and Disclosures Document (BRAD). 6. If included, the undersigned Borrower(s) acknowledge receipt and acceptance of the Truth in Lending statement. 7. If included, the undersigned Borrower(s) acknowledge receipt and acceptance of the Special Flood Hazard Area (SFHA). 8. That (he/she/they) (is/are) the Borrower{s) on the above-referenced Mortgage Loan serviced by Wells Fargo Bank, N A. That (he/she/they) have experienced a financial hardship or change in financial circumstances since the origination of (his/her/their) Mortgage Loan. That {he/she/they) did not intentionally or purposefully default on the Mortgage Loan in order to obtain a loan modification. LM52J./WUC/2 Welh Fargo Kant Mortgage is a division of WNis Fargo Bank, N,A Together we'll go far ' ~ '~zt, .~~ ~ Wellllf,~rgo Home Mortgage MAC W0152-010 220 Wildwood Parkway Birmingham, AL 35209 Tel: 877 325 4114 TaU Free CORRECTION AGREEMENT. The undersigned borrower(s), for and in consideration of the approval, closing and funding of this Modification, hereby grants Wells Fargo Bank, N A, as lender, limited power of attorney to correct and/or initial all typographical or clerical errors discovered in the Modification Agreement required to be signed. In the event this limited power of attorney is exercised, the undersigned will be notified and receive a copy of the document executed or initialed on their behalf. This provision may not be used to modify the interest rate, modify the term, modify the outstanding principal balance or modify the undersigned's monthly principal and interest payments as modified by this agreement. Any of these specified changes must be executed directly by the undersigned. This limited power of attorney shall automatically terminate in 120 days from the closing date of the undersigned's Modification.,~~~ (Borrower(s) initial) IN WITNESS WHEREOF, the Parties hereto have executed this Agreement as the date first above written. assessed by your mobile carrier. Da a as of this ~p day of ~P~ti1VA2`( 20~~. ey uire ture Signature By signing this Agreement I hereby consent to being contacted concerning this loan at any cellular or mobile telephone number I may have. This includes text messages and telephone calls including the use of automated dialing systems to contact my cellular or mobile telephone. Xou will not be billed by your cellular or mobile carrier for any text messages you may receive from wells Fargo, however, any calls we place to your cellular or mobile phone will incur normal airtime charges ~^~- ~1/ Wells F r Ban ,'N A Name : C. S. ViiaYashree Vice President Loan Documentation Its: LM527 WUC 3 wells Fargo Home Mortgage b a dMSign of Nhlls Fargo Bent, N,A. Together we'll go far ~ ~~ ,, ~ VERIFICATION Daniel Bullard, hereby states t the/s a is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, th the/s a is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the be his/ er information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Daniel Bullard Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 01/31/2013 086-PIS-V2 Bile # 175473 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA c ~, Wells Fargo Bank, N.A. CIVIL DIVISION ~~% C'3 ~ n Plaintiff, 0 3 ~V//~~-,~ ~ ,-: ""~~ ._.. "~ Jeffrey A. Maguire; r~ ' ~-.~ ~~ Defendant. ~' ~ ~ ?~" ~ t~n'-r'i ~~- ~ ~ ~; nL- ~.,-, I ~ ' ~ r 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. Zucker, Goldberg & Ackerman, LLC XFP-175473 IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TIDS PROGRAM IS FREE. ZUCKER, GOLDBERG & ACKERMAN, LLC By: Dated: February2013 Scott A. Di tt?rick, Esquire; A I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XFP-175473/cper 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-175473 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete• your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Is the property for sale? Realtor Name: Borrower Occupied? Mailing Address (if different): City: Phone Numbers: Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Included Taxes & Insurance: Primary Reason for Default: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: Date you closed your loan: State: Zip: Yes ^ No ^ Listing date: Price: $ Realtor Phone: Yes ^ No ^ Home: Cell: State: Office: _ Other: How long? State: Zip: Home: Office: Cell: Other: How long? Zip: Zucker, Goldberg & Ackerman, LLC XFP-175473 Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Amount owed: Automobile #2: Amount owed: Model: Model: Value: Value: Year: Year: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ^ No ^ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Email: Fax: Zucker, Goldberg & Ackerman, LLC XFP-175473 Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ^ No ^ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ^ No ^ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: Phone: I/We, ,authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. IJWe understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information to lender and lender's counsel: ~ Proof of Income ~ Past 2 bank statements ~ Proof of any expected income for the last 45 days ~ Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) ~ Listing agreement (if property is currently on the market) Zucker, Goldberg & Ackerman, LLC XFP-175473 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.. vs. Jeffrey A. Maguire; Defendant. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property, which is defendant's primary residence; 2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in acourt-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel/Appointed Legal Representative Date Signature of Defendant Signature of Defendant Date Date Zucker, Goldberg & Ackerman, LLC XFP-175473 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. Jeffrey A. Maguire; AND NOW, this day of ,20 ,the defendant/borrower in the above- captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in acourt-supervised conciliation Conference on at .M. in Cumberland County Courthouse, Carlisle, Pennsylvania. at the 1. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 2. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable CIVIL DIVISION Plaintiff, Defendant. NO.. CASE MANAGEMENT ORDER Zucker, Goldberg & Ackerman, LLC XFP-175473 resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 3. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker, Goldberg & Ackerman, LLC XFP-175473 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA t-V CIVIL DIVISION Wells Fargo Bank, N.A., �� -ti ril Plaintiff No.: 13-683-CIVIL —1 CD c'r � VS. ISSUE NUMBER: o ; CD r-r I Jeffrey A. Maguire; TYPE OF PLEADING: �G mac. Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) Mortgaged Premises: 420 South Frederick Street, Mechanicsburg, PA FILED ON BEHALF OF: 17055-6410 Wells Fargo Bank, N.A. Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER,GOLDBERG &ACKERM.AN, LLC Scott A. Dietterick, Esquire- Pa I.D.# 55650 Kimberly A. Bonner, Esquire- Pa I.D. #89705 Joel A.Ackerman, Esquire- Pa I.D.#202729 Ashleigh L. Marin, Esquire-Pa I.D.#306799 Ralph M. Salvia, Esquire- Pa I.D.#202946 Jaime R.Ackerman, Esquire- Pa I.D.#311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-175473 -eJ ��J�. Praecipe fior Entry Judm n Zucker,Goldberg&Ackerman, LLC XFP-175473 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 13-683-CIVIL vs. Jeffrey A. Maguire; Defendant. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s),for failure to file a response to Plaintiff's Complaint within the appropriate time limits from service thereof, and assess Plaintiffs damages as set forth in Complaint: Amount as set forth in Complaint $170,717.78 plus interest on the judgment amount($170,717.78)from January 11, 2013,at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 418 S. Market Street, address is: Mechanicsburg, PA 17055 ZUCKER,GOLB C ERM LC Dated: � BY: ❑ Joel A. n, quire, A I.D.#202729 Ashlei L. Marin, Esquire; PA I.D.#306799 Jai 'R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-175473 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX Email: Office @zuckergoldberg.com DAMAGES ARE HERE Y ASSESSED AS INDICATED woof Date 3 w000 Prothonotary t ' f . ti- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. ' NO.: 13-683-CIVIL Jeffrey A. Maguire; Defendant. AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. ZUCKER,GOLBERG Dated: BY: Joel A.X a n, Esquire; PA I.D.#202729 Ashleigh arin, Esquire; PA I.D.#306799 Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-175473 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908)233-1390 FAX Email: Office @zuckergoldberg.com Sworn to and subscribed before me This 3 day of Sane , 20 13 Nota u li My Commission Expires: Cheryl Debeneadto Notary Public My Comm.Expires Oct. 16,2016 ID#2280276 State of New Jersey Zucker,Goldberg&Ackerman, LLC XFP-175473 Department of Defense Manpower Data Center Results as of:May-29-2°'3'2:59:27 SCRA 3.0 Status Report Pursuant to Semcemein- hers Civil.Relief Act. Last Name: MAGUIRE First Name: JEFFREY Middle Name: A Active Duty Status As Of: May-29-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date status service Component NA NA No, NA This response reflect;the'lnciivli uail''active duty status based o'n the A""Rutty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date status Service Component Noll NA NA A "" This response reflects Writ the Individual left active duiy status with'ini 367days preceding theLActive Duty Status Date 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 I Status Service Component NA t NA he NA This response reflects whether the lndMdu;l or hWheruhil has received a—aWnefficallon 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. )uIA" k *rjq 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:http://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(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: T360Y120WOD4Q90 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-683-CIVIL Jeffrey A. Maguire; Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Jeffrey A. Maguire 418 S. Market Street, Mechanicsburg, PA 17055 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notifi d that an Order, Decree or Judgment was entered in the above captioned proceeding on 3yy\P_ 'J, and"? [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $170,717.78 u o Prothonotary Zucker,Goldberg&Ackerman, LLC XFP-175473 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 13-683-CIVIL Jeffrey A.Maguire Defendant. IMPORTANT NOTICE TO: Jeffrey A.Maguire 418 S.Market Street, Mechanicsburg, PA 17055 DATE OF NOTICE: 3/27/2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten(10)days from the date of this notice,ajudgment may be entered against you without a hearing and you may lose your property or other important rights.You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one,go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S.Bedford Street 32 S.Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 13-683-CIVIL Jeffrey A.Maguire Defendant. AVISO IMPORTANTE TO: Jeffrey A.Maguire 418 S.Market Street, Mechanicsburg, PA 17056 FECHA DEL AVISO:3127/2013 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMIAR LA ACCION REQUERIDA EN ESTE CASO. A NIENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS nv2ORTANTES. USTED DEBE LLEVAR ESTE DOCUNIENTO INNIEDIATAMINTE A SU ABOGADO. SI USTED NO TIENTE *UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABASO INDICADA PARA QUE LE INFORhIEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S.Bedford Street Carlisle,PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER,GOLDBERG &ACKERMAN BY:— Scctt A. D iefterick Scott A. Dietterick,Esquire Attorneys for Plaintiff PA 1,D. # 55650 200 Sheffield Street,Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL,POSTAGE PREPAID 175473 1. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny Sheriff Anderson <-/Sheriff :73 Jody S Smith Chief Deputy Richard W Stewart i Solicitor 0FP090FTKGWWf Wells-Fargo Bank,N.A. Case Number vs: Jeffery Maguire 2013-683 SHERIFF'S`RETURKOF SERVICE ' 02/'41201'3 07:46 PM.-' Ronny R Anderson,Sheriff;being dulyswom according to law,states he made diligent search and inquiry for the within harried Deferidant.to wit:Jaffery.Maguire,butwas unable'to locate the Defendant in his bailiwick,The Sheriff therefore retumsthe within requested Complaint in Mortgage. Foreclosure as",Not_Found"at.420S.Frederick Street,Mechanicsburg Borough,:Mechanicsburg,PA 1 17055:Residerice'is vacant a post office check provided a new address of 418 S.Market Street., 1 Mechanicsburg;PA 17055: 03/01/2013 •03:58.PM-Deputy Shawn Harrison,being duly sworn according'tolaw;served the requested Complaint In Mortgage Foreclosure by handing a true copy to a person repreXleffa4hr ti th s to be Dan Maguire,- father of defendant,who-accepted as"Adult Person in Charge"far 418 S.Markst Street,Mechanicsburg Borough,Mechanicsburg,PA 17055. ON,QEPi!i'Y I SHERIFF COST:$58.00 - SO ANSWERS, . 'March 06,2013 RONNY R ANDERSON,SHERIFF ', tc}COaripSttite'SRetiir.781msott.Inc. ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION File No. 13-683-CIVIL Wells Fargo Bank,N.A., • Amount Due $170,717.78 Plaintiff, • Interest from 01/12/2013 to date of sale $9,170.57 vs. •• • • Jeffrey A.Maguire; Costs Defendant. • • • • • TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract of account based on a confession of judgment,but if it does,it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended;and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County,for debt,interest and costs upon the following described property of the defendant(s): See Exhibit"A"attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County,for debt,interest and costs,as above,directing attachment against the above-named garnishee(s)for the following property(if real estate,supply six copies of the description;supply four copies of lengthy personality list): and all other property of the defendant(s)in the possession,custody or control of the said garnishee(s). (Indicate)Index this writ against the garnishee(s)as a lis pendens against real estate of e defendant(s)described in the attached exhibit. DATE: July 17,2013 Signature: 1111i Print Name: Scott .Di' ,Es• -fie Kimberly '. :.n -r,Esquire $ 018.SO P 0 A Joel Ackerman,Esquire 58. co CJi� / Ashleigh Levy Marin,Esquire Ralph M.Salvia,Esquire 103. '75 " Jaime R.Ackerman,Esquire-- 110.50 ` Address: Zucker,Goldberg&Ackerman,LLC 200 Sheffield Street,Suite 101 e2pf .75_ PA ATry Mountainside,NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 £- Supreme Court ID No.: 55650 89705 "I 202729 t'7'1 =01 C 306799 z . 402-:(1)-5 f t e j 202946 C=1 •50 LL rte—Z es s-r z � Q z C'3 37, . X r ; -t soBa°7 .,� � /u C; /ticker oftlberg . ,1cknnarr.C.1.C' la*Oq 774/0 XI 1?-175473 RE (,Uri+ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 13-683-CIVIL VS. :^ . Execution No.: 2 eat '' •Jeffrey A. Maguire; -a ZZ �,--11 z rez o r Defendant(s). 73 • —+e~ <C3 206 o-"r • -O 3 .tea ;' –< ca t AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 420 South Frederick Street, Mechanicsburg, PA 17055-6410. 1. Name and Address of Owner(s)or Reputed Owner(s): JEFFREY A. MAGUIRE,A MARRIED MAN 418 South Frederick Street Mechanicsburg, PA 17055 2. Name and Address of Defendant(s) in the Judgment: JEFFREY A. MAGUIRE 418 South Frederick Street Mechanicsburg, PA 17055-6410 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, N.A. Plaintiff 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff Zucker.Goldberg&Ackerman.11.(:' XI I'-175473 PORTFOLIO RECOVERY ASSOCIATES 140 Corporate Boulevard Norfolk,VA 23502 5. Name and Address of every other person who has any record lien on the property: BOROUGH OF MECHANICSBURG W.Strawberry& N. Market Street Mechanicsburg, PA 17055 CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: JEFFREY MAGUIRE 420 FREDERICK ST MECHANICSBURG, PA CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 420 South Frederick Street Mechanicsburg, PA 17055-6410 UNKNOWN SPOUSE 418 South Frederick Street Mechanicsburg, PA 17055-6410 /ticker.(,oldberg&Ackerman,I_I..(' XI P-175-173 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ZUCKER, GOLDB". &ACKERM , LLC BY: Dated: o Scott A. Die nc , Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D. #311031— Attorneys for Plaintiff XFP-175473/cal 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com E<<hlhr en.c4 1ckyr ntin I1( XI P-1'751" Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel and tract of land situate in the Borough of Mechanicsburg, County of Cumberland, State of Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a hub in South Frederick Street,which said hub is North ninety-eight and eighty hundredths(98.80) feet from the northwest corner of South Frederick Street and West Marble Street;thence along lands now or formerly of C. Schultz, South eighty (80) degrees twenty-two(22) minutes thirty(30)seconds West, a distance of two hundred twenty(220) feet to a hub on the eastern line of a twenty(20)foot alley;thence along the eastern line of said alley, North ten (10)degrees three(3) minutes West, a distance of fifty and forty-four hundredths(50.44)feet to a nail; thence along lands now or formerly of Minnie F. Fry, North eighty(80)degrees fifty-three (53) minutes twenty (20) seconds East, a distance of twenty-three and eleven hundredths(23.11)feet to a point; thence further by same,South nine (9) degrees six(6) minutes forty(40) seconds East, a distance of three and eighty-five hundredths (3.85)feet to a point;thence by same and along a fence, North eighty(80)degrees thirty-two (32) minutes twenty(20)seconds East, a distance of one hundred seventeen and eighty-three (117.83)feet to a point;thence still by same, North nine (09) degrees fifty-five (55) minutes West, a distance of five and fifty-five hundredths (5.55)feet to a point;thence through the center of a frame partition wall of a double house and beyond, North eighty(80) degrees five (5) minutes East,a distance of seventy-nine and ten hundredths(79.10)feet to a nail in said South Frederick Street;thence along said South Frederick Street, South ten (10)degrees three (3) minutes East, a distance of fifty-two (52)feet to a hub, the point and place of BEGINNING. HAVING THEREON ERECTED the southern half of a two and one-half story frame dwelling house known and numbered as 420 South Frederick Street and a one-story frame garage. HAVING thereon erected a dwelling house being known and numbered as 420 South Frederick Street, Mechanicsburg, PA, 17055-6410. BEING the same premises which Bruce Allen Homes, Inc., by Deed dated May 1,2009 and recorded June 5, 2009 in and for Cumberland County, Pennsylvania, in Deed Book Volume Instrument #200919002,granted and conveyed unto Jeffrey A. Maguire, a married man. Tax Map No.: 16-24-0787-097. Zucker,Goldberg&Ackerman, LLC XFP-175473 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION • Plaintiff, •. NO.: 13-683-CIVIL vs. • Jeffrey A. Maguire; • Defendants. • • C� o NOTICE OF SHERIFF'S SALE C3\ OF REAL PROPERTY PURSUANT TO m PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 - Jeffrey A. Maguire 418 S. Market Street Mechanicsburg, PA 17055 AND 420 South Frederick Street Mechanicsburg, PA 17055-6410 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on 3/05/2011-at 10:00am prevailing local time. 4/490/9 THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). The LOCATION of your property to be sold is: 420 South Frederick Street, Mechanicsburg, PA, 17055-6410 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 13-683-CIVIL THE NAME(S)OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Jeffrey A. Maguire Zucker,Goldberg&Ackerman, LLC XFP-175473 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff(for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty(30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square,Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights,you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone(800)990-9108 (717)249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. Zucker,Goldberg&Ackerman, LLC XFP-175473 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKER, GOLDBE - KE LLC BY: Dated: /t Scott A. Die erick, Esquire; PA I.D. #55650 I Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D.#311032L._-. Attorneys for Plaintiff XFP-175473/cal 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg&Ackerman, LLC XFP-175473 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel and tract of land situate in the Borough of Mechanicsburg, County of Cumberland, State of Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a hub in South Frederick Street, which said hub is North ninety-eight and eighty hundredths(98.80) feet from the northwest corner of South Frederick Street and West Marble Street;thence along lands now or formerly of C. Schultz,South eighty (80) degrees twenty-two (22) minutes thirty(30)seconds West,a distance of two hundred twenty(220) feet to a hub on the eastern line of a twenty(20)foot alley;thence along the eastern line of said alley, North ten (10)degrees three(3) minutes West, a distance of fifty and forty-four hundredths(50.44)feet to a nail;thence along lands now or formerly of Minnie F. Fry, North eighty(80)degrees fifty-three (53) minutes twenty (20) seconds East, a distance of twenty-three and eleven hundredths(23.11)feet to a point; thence further by same,South nine(9) degrees six(6) minutes forty(40)seconds East, a distance of three and eighty-five hundredths(3.85)feet to a point;thence by same and along a fence, North eighty(80)degrees thirty-two (32) minutes twenty(20)seconds East, a distance of one hundred seventeen and eighty-three (117.83)feet to a point;thence still by same, North nine (09) degrees fifty-five (55) minutes West, a distance of five and fifty-five hundredths (5.55)feet to a point;thence through the center of a frame partition wall of a double house and beyond, North eighty(80) degrees five(5) minutes East,a distance of seventy-nine and ten hundredths(79.10)feet to a nail in said South Frederick Street;thence along said South Frederick Street,South ten (10)degrees three(3) minutes East, a distance of fifty-two (52)feet to a hub,the point and place of BEGINNING. HAVING THEREON ERECTED the southern half of a two and one-half story frame dwelling house known and numbered as 420 South Frederick Street and a one-story frame garage. HAVING thereon erected a dwelling house being known and numbered as 420 South Frederick Street, Mechanicsburg, PA, 17055-6410. BEING the same premises which Bruce Allen Homes, Inc., by Deed dated May 1, 2009 and recorded June 5, 2009 in and for Cumberland County, Pennsylvania, in Deed Book Volume Instrument #200919002,granted and conveyed unto Jeffrey A. Maguire, a married man. Tax Map No.: 16-24-0787-097. Zucker, Goldberg&Ackerman, LLC XFP-175473 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-683 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 JEFFREY A. MAGUIRE (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: $170,717.78 L.L.: .50 Interest from 1/12/13 to Date of Sale -- $9,170.57 Atty's Comm: Due Prothy: $2.25 Atty Paid: $206.75 Other Costs: Plaintiff Paid: Date: 11/5/13 David D. Buell, Prothonota (Seal) By: d'/ ii , Deputy REQUESTING PARTY: Name:JAIME R. ACKERMAN,ESQUIRE Address: ZUCKER,GOLDBERG&ACKERMAN,LLC 200 SHEFFIELD STREET, SUITE 101 MOUNTAINSIDE,NJ 07092 Attorney for: PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No.311032 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, • NO.: 13-683-CIVIL vs. • `. -. • Execution No.: Jeffrey A. Maguire; rn �- 3 .' • • CP F' C3 Defendant(s). • rr= -;' • AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 420 South Frederick Street, Mechanicsburg, PA 17055-6410. 1. Name and Address of Owner(s) or Reputed Owner(s): JEFFREY A. MAGUIRE,A MARRIED MAN 418 South Frederick Street Mechanicsburg, PA 17055 2. Name and Address of Defendant(s) in the Judgment: JEFFREY A. MAGUIRE 418 South Frederick Street Mechanicsburg, PA 17055-6410 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, N.A. Plaintiff 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff PORTFOLIO RECOVERY ASSOCIATES 140 Corporate Boulevard Norfolk,VA 23502 5. Name and Address of every other person who has any record lien on the property: BOROUGH OF MECHANICSBURG W.Strawberry& N. Market Street Mechanicsburg, PA 17055 AND 36 W. Allen St., Mechanicsburg, PA 17055 CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: AMANDA MAGUIRE 420 Frederick St Mechanicsburg, PA 17055-6410 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 420 South Frederick Street Mechanicsburg, PA 17055-6410 UNKNOWN SPOUSE 418 South Frederick Street Mechanicsburg, PA 17055-6410 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Amended Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ZUCKER, GOLDBERG &ACKERMAN, LLC /5/9-Z\ BY:( !/�Jl i.�Z ,V Dated: . 4 Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 "Denise Carlon, Esquire; PA I.D.#317226 Attorneys for Plaintiff XFP-175473/cal 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com . • Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel and tract of land situate in the Borough of Mechanicsburg, County of Cumberland, State of Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a hub in South Frederick Street,which said hub is North ninety-eight and eighty hundredths(98.80)feet from the northwest corner of South Frederick Street and West Marble Street;thence along lands now or formerly of C. Schultz,South eighty(80) degrees twenty-two(22) minutes thirty(30) seconds West,a distance of two hundred twenty(220) feet to a hub on the eastern line of a twenty(20)foot alley; thence along the eastern line of said alley, North ten (10) degrees three (3) minutes West, a distance of fifty and forty-four hundredths(50.44)feet to a nail;thence along lands now or formerly of Minnie F. Fry, North eighty(80)degrees fifty-three (53) minutes twenty(20)seconds East, a distance of twenty-three and eleven hundredths(23.11)feet to a point; thence further by same, South nine (9)degrees six(6) minutes forty(40)seconds East, a distance of three and eighty-five hundredths (3.85) feet to a point;thence by same and along a fence, North eighty(80) degrees thirty-two (32) minutes twenty(20)seconds East, a distance of one hundred seventeen and eighty-three (117.83)feet to a point;thence still by same, North nine (09) degrees fifty-five(55) minutes West, a distance of five and fifty-five hundredths (5.55)feet to a point;thence through the center of a frame partition wall of a double house and beyond, North eighty(80)degrees five (5) minutes East,a distance of seventy-nine and ten hundredths(79.10)feet to a nail in said South Frederick Street;thence along said South Frederick Street,South ten(10)degrees three (3) minutes East, a distance of fifty-two (52)feet to a hub, the point and place of BEGINNING. HAVING THEREON ERECTED the southern half of a two and one-half story frame dwelling house known and numbered as 420 South Frederick Street and a one-story frame garage. HAVING thereon erected a dwelling house being known and numbered as 420 South Frederick Street, Mechanicsburg, PA, 17055-6410. BEING the same premises which Bruce Allen Homes, Inc., by Deed dated May 1, 2009 and recorded June 5, 2009 in and for Cumberland County, Pennsylvania, in Deed Book Volume Instrument #200919002,granted and conveyed unto Jeffrey A. Maguire, a married man. Tax Map No.: 16-24-0787-097. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, VS. CIVIL DIVISION• °A �� NO.: 13- 683- CIVIL 1 o ., 77 Jeffrey A. Maguire; TYPE OF PLEADING Defendants. Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT /OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 Ashleigh Levy Marin, Esquire- PA I.D. #306799 Ralph M. Salvia, Esquire- PA I.D. #202946 Jaime R. Ackerman, Esquire- PA I.D. #311032 Jana Fridfinnsdottir, Esquire- PA I.D. #315944 Brian Nicholas, Esquire- PA I.D. #317240 Denise Carlon, Esquire- PA I.D. #317226 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500 (908) 233 -1390 FAX office@zuckergoldberg.com File No.: XFP- 175473/mag Zucker, Goldberg & Ackerman, LLC XFP- 175473 y�. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION vs. Jeffrey A. Maguire; Plaintiff, NO.: 13- 683 -CIVIL Defendants. Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT /OWNER AND OTHER PARTIES OF INTEREST I, Margaret Agyepong, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriffs Sale of Real Property in this matter on Defendant /Owner and Other Parties of Interest as follows: 1. Defendant, Jeffrey A. Maguire, a married man, is the record owner of the real property. 2. On or about February 4, 2014, defendant Jeffrey A. Maguire, was served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland County, at the address of 418 S. Market Street, Mechanicsburg PA 17055. A true and correct copy of said Notice and Return of Service are marked Exhibit "A ", attached hereto and made a part hereof. 3. On or about February 7, 2014, Plaintiffs counsel served all other parties in interest with Plaintiff's Notice of Sheriffs Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing. True and correct copies of said Notices and Certificates of Mailing are marked Exhibit "B ", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendant /Owner and all other Parties of Zucker, Goldberg & Ackerman, LLC XFP- 175473 Interest were served with Plaintiff's Notice of Sheriff s Sale of Real Property in accordance with Pa.R.C.P. 3129.2. Dated: February n- Sworn to and subscribed before me this - day of February, 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff Notary ublic MY COMMISSION EXPIRES: PAUL C. NADRATOWSK1 Notary Public of New Jersey 113# 2407850 My Commission Expires 4/27/2016 MARGA AGYEPONG Paralegal/Legal Assistant Zucker, Goldberg & Ackerman, LLC EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP- 175473 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ov el ge-lrieht QC E OF Tr< ;mER1CF Wells Fargo Bank, N.A. vs. Jeffery Maguire Case Number 2013-683 SHERIFF'S RETURN OF SERVICE 01/06/2014 07:36 PM - Deputy Dawn Kell, 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 420 South Frederick Street, Mechanicsburg - Borough, Mechanicsburg, PA 17055, Cumberland County. 02/04/2014 07:31 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jeffery Maguire at 418 S. Markst Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. SHERIFF COST: $1,655.95 SO ANSWERS, February 28, 2014 RONNY R ANDERSON, SHERIFF (c) County Suns Sheriff, Teleosoft, Inc, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, vs. Jeffrey A. Maguire; Defendants. CIVIL DIVISION NO.: 13- 683 -CIVIL NOTICE TO LIENHOLDERS AND OTHER PARTIES IN INTEREST PURSUANT TO Pa.R.C.P. 3129(b) TO: UNKNOWN TENANT OR TENANTS 420 South Frederick Street Mechanicsburg, PA 17055 -6410 COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 AMANDA MAGUIRE 420 Frederick St Mechanicsburg, PA 17055 -6410 PORTFOLIO RECOVERY ASSOCIATES 140 Corporate Boulevard Norfolk, VA 23502 UNKNOWN SPOUSE 418 South Frederick Street Mechanicsburg, PA 17055 -6410 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept, 280601 Harrisburg, PA 17128 -0601 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 BOROUGH OF MECHANICSBURG W. Strawberry & N. Market Street Mechanicsburg, PA 17055 BOROUGH OF MECHANICSBURG 36 W. Allen St., Mechanicsburg, PA 17055 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland County, directed, there will be exposed to Public Sale in: the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 Zucker, Goldberg & Ackerman, LLC XFP- 175473 1 75473 D 1004CO2032014P 1 On 3/12/2014 at 10:OOam, the following described real estate which Jeffrey A. Maguire, a married man are the owners or reputed owners and on which you may hold a Hen or have an interest which could be affected by the sale of: 420 South Frederick Street, Mechanicsburg, PA 17055 -6410 Cumberland County (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A "). Zucker, Goldberg & Ackerman, LLC XFP- 175473 175473D1004CO2032014P2 The said Writ of Execution has been issued on a judgment in the action of Wells Fargo Bank, N.A. vs. Jeffrey A. Maguire, et al Plaintiff Defendant(s) at EX. NO. 13- 683 -CIVIL in the amount of $170717.78 plus interest and costs. Claims against property must be filed at the Office of the Sheriff before above sale date. Claims to proceeds must be made with the Office of the Sheriff before distribution. Schedule of Distribution will be filed with the Office of the Sheriff no later than thirty (30) days from the sale date. Exceptions to Distributions or a Petition to Set Aside the Sale must be filed with the Office of the Sheriff no later than ten (10) days from the date when Schedule of Distribution is filed in the Office of the Sheriff. If you have any questions or comments with regard to the Sheriff's Sale or this Notice, you should contact your attorney as soon as possible. Dated: a,l ,c5l.213 l 4 By: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottlr, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 - -Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP- 175473/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP - 175473 175473D1004CO2032014P3 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel and tract of land situate in the Borough of Mechanicsburg, County of Cumberland, State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a hub in South Frederick Street, which said hub is North ninety -eight and eighty hundredths (98.80) feet from the northwest corner of South Frederick Street and West Marble Street; thence along lands now or formerly of C. Schultz, South eighty (80) degrees twenty -two (22) minutes thirty (30) seconds West, a distance of two hundred twenty (220) feet to a hub on the eastern line of a twenty (20) foot alley; thence along the eastern line of said alley, North ten (10) degrees three (3) minutes West, a distance of fifty and forty -four hundredths (50.44) feet to a nail; thence along lands now or formerly of Minnie F. Fry, North eighty (80) degrees fifty -three (53) minutes twenty (20) seconds East, a distance of twenty -three and eleven hundredths (23.11) feet to a point; thence further by same, South nine (9) degrees six (6) minutes forty (40) seconds East, a distance of three and eighty -five hundredths (3.85) feet to a point; thence by same and along a fence, North eighty (80) degrees thirty -two (32) minutes twenty (20) seconds East, a distance of one hundred seventeen and eighty -three (117.83) feet to a point; thence still by same, North nine (09) degrees fifty -five (55) minutes West, a distance of five and fifty -five hundredths (5.55) feet to a point; thence through the center of a frame partition wall of a double house and beyond, North eighty (80) degrees five (5) minutes East, a distance of seventy-nine and ten hundredths (79.10) feet to a nail in said South Frederick Street; thence along said South Frederick Street, South ten (10) degrees three (3) minutes East, a distance of fifty -two (52) feet to a hub, the point and place of BEGINNING. HAVING THEREON ERECTED the southern half of a two and one -half story frame dwelling house known and numbered as 420 South Frederick Street and a one -story frame garage. HAVING thereon erected a dwelling house being known and numbered as 420 South Frederick Street, Mechanicsburg, PA, 17055 -6410. BEING the same premises which Bruce Allen Homes, Inc., by Deed dated May 1, 2009 and recorded June 5, 2009 in and for Cumberland County, Pennsylvania, in Deed Book Volume Instrument #200919002, granted and conveyed unto Jeffrey A. Maguire, a married man. Tax Map No.: 16 -24- 0787 -097. Zucker, Goldberg & Ackerman, LLC «Field2»- «Field I» «Field 1 »D 1004CO2/ 12/2008P4 Page 1 of 5 NOTICE TO LIENHOLDERS UNITEDSTQTES POSTAL SERVlCE6 Certificate Of Mailing This Certificate of Melling provides evidence that mall has been presented to UPS. for mailing. This form may be used for domestic and International mil, From; Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP- 175473/sde TEAM- C To: UNKNOWN TENANT OR TENANTS 420 South Frederick Street Mechanicsburg, PA 17055 -6410 County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530 -02 -000 -9065 UNITED STATES POSTAL SERVJCEe U.S POSTAGE >>PITNEY BOWES 4 = ;:k a VP ffi 92 00120° 00'01387430 FEB 07 2014 To pay fee, affix stamps or meter postage here, Postmark Here This Certificate of Mailing provides evidence that mall has been presented to USPS° for mailing. This form may be used for domestic and international mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP- 175473/sde TEAM- C Te' COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530 -02 -000 -9065 Postmark Hale U S POSTAGE» PITNEY BOWES ZIP 07092 $ 001.20° 02 1r 0001387430FE8 07 2014 Page 2 of 5 NOTICE TO LIENHOLDERS UNITED STATES Willi POSTAL SERVICE@ Certificate Of Mailing This Certificate of Melling provides evidence that mall has been presented to USPS° for mailing. This form may be used for domestic end International mail. rom' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP- 175473/sde TEAM- C T °` CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530 -02- 000 -9065 UNITED STATES railir POSTAL SERVICE@ U.S POSTAGE* PITNEY BOWES 02 °x,092 $ 001.20° 000 1 387430 FEB 07 2014 To pay fee, affix stamps or meter postage hare. Postmark Here U.S POSTAG E»» PITNEY BOWES This Certificate of Mailing provides evidence that mall hes been presented to USP5a for mailing. This form may be used for domestic and International mall. Pm"" Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP- 175473/sde TEAM- C T °` AMANDA MAGUIRE 420 Frederick St Mechanicsburg, PA 17055 -6410 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530 -02 -000 -9065 02 °7092 $ 001.200 0001387430 FEB 07 2014 Postmark Here Page 3 of 5 NOTICE TO LIENHOLDERS UNITED STATES POSTAL SERVICEe Certificate Of Mailing This Certificate of Me119 provides evidence that mall has been presented to LISPS• for mailing. This form may be used for domestic and International marl. Fr °m: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP- 175473/sde TEAM- C Tot PORTFOLIO RECOVERY ASSOCIATES 140 Corporate Boulevard Norfolk, VA 23502 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02 - 000 -9065 UNITED STATES /J POST/lLSERVICEe US POSTAGE ) » PITNEY BOWES ZIP 07092 $ 001 20° a� iri 0001387430 FEB 07 2014 To pay fee, affix stamps or meter postage here. Postmark H4re This Certificate of Melling provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and Intonational mall, Pr°m' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP- 175473/sde TEAM- C To BOROUGH OF MECHANICSBURG 36 W. Allen St., Mechanicsburg, PA 17055 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02 -000 -9065 U S POSTAGE » PITNEY eoWES ; ZIP 02 092 001 200 0001387430FEB 07 2014 Postmark Here ,+ �f c7, r :; .% W.� Page 4 of 5 NOTICE TO LIENHOLDERS UNITED STATES // POSTAL SERVICE Certificate Of Mailing This Certlfka a of Melling provides evident. that mall has been presented to LISPS• for maftng.Thlr form may be used for domestic and International mall. Fr": Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP- 175473/sde TEAM- C To BOROUGH OF MECHANICSBURG W. Strawberry & N. Market Street Mechanicsburg, PA 17055 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02- 000 -9065 • 2+ UNITED STATES AMIN POSTAL SERVICE* U S. POSTAGE )» PITNEY ROWES ;:aser,dezatiorromairor ZIP 07092 $ 001 20' 02 in 0001387430FEB 07 2G14 To pry foe, ef@t stamps or meter postage hen. Postmark Here U S POSTAGE)) PITNEY BoWES e se a„se � r 02 °f~092 $ 001.20° 0001387430FEB 07 2014 Mb Certificate of Maping provides evidence that map his been presented to USPS• for maHlrv. This form may be used for domestic and inlarnatk r al mad. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP- 175473/sde TEAM- C T °' CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Page 5 of 5 NOTICE TO LIENHOLDERS UNITED STATES I POSTAL SERVICE® Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form may be used for domestic and International mall. From Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP- 175473/sde TEAM- C lb: PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128 -0601 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530 -02 -000 -9065 UNITED STATES Eritili POST/11 SERVICE® This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. This form and International mall. From; Scott A. Dietterick, Esquire To pay fee, affix stamps or meter postage here. U S POSTAGE 001.20° c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP- 175473/sde TEAM- C T07 UNKNOWN SPOUSE 418 South Frederick Street Mechanicsburg, PA 17055 -6410 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530 -02 -000 -9065 Pbstmark Here 4 fit;; VE.5 07 2014 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY F 71�C/O 16{i.'1 FF ice. Ji i T 1 f [-PRO 11i-�1�4i 2-g Y 15 PH 12: i; CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Jeffery Maguire Case Number 2013-683 SHERIFF'S RETURN OF SERVICE 01/06/2014 07:36 PM - Deputy Dawn Kell, 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 420 South Frederick Street, Mechanicsburg - Borough, Mechanicsburg, PA 17055, Cumberland County. 02/04/2014 07:31 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jeffery Maguire at 418 S. Markst Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County. 03/12/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on March 12, 2014 at 10:00 a.m. He sold the same for the sum of $ 1.00 to Attorney Jaime Ackerman, on behalf of, Wells Fargo Bank, N.A., being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,306.57 SO ANSWERS, April 23, 2014 RONt R ANDERSON, SHERIFF (c•) CountySu: E. Sleriff. Ielaos: ft. 7 a ° o%%i = G4 mss" ->e( ,e? 305-9d)- On November 7, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 420 South Frederick Street, Mechanicsburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. (NI Date: November 7, 2013 a By: Real Estate Coordinator LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2013-683 Civil Term Wells Fargo Bank, N.A. vs. Jeffery Maguire Atty.: Jaime R. Ackerman ALL THAT CERTAIN piece, parcel and tract of land situate in the Bor- ough of Mechanicsburg, County of Cumberland, State of Pennsylvania, more particularly bounded and de- scribed as follows, to wit: BEGINNING at a hub in South Frederick Street, which said hub is North ninety-eight and eighty hun- dredths (98.80) feet from the north- west corner of South Frederick Street and West Marble Street; thence along lands now or formerly of C. Schultz, South eighty (80) degrees twenty- two (22) minutes thirty (30) seconds West, a distance of two hundred twenty (220) feet to a hub on the eastern line of a twenty (20) foot alley; thence along the eastern line of said alley, North ten (10) degrees three (3) minutes West, a distance of fifty and forty-four hundredths (50.44) feet to a nail; thence along lands now or formerly of Minnie F. Fry, North eighty (80) degrees fifty-three (53) minutes twenty (20) seconds East, a distance of twenty-three and eleven hundredths (23.11) feet to a point; thence further by same, South nine (9) degrees six (6) minutes forty (40) seconds East, a distance of three and eighty-five hundredths (3.85) feet to a point; thence by same and along a fence, North eighty (80) degrees thirty- two (32) minutes twenty (20) seconds East, a distance of one hundred seventeen and eighty-three (117.83) feet to a point; thence still by same, North nine (09) degrees fifty-five (55) minutes West, a distance of five and fifty-five hundredths (5.55) feet to a point; thence through the center of a frame partition wall of a double house and beyond, North eighty (80) degrees five (5) minutes East, a distance of seventy-nine and ten hundredths 57 (79.10) feet to a nail in said South Frederick Street; thence along said South Frederick Street, South ten (10) degrees three (3) minutes East, a distance of fifty-two (52) feet to a hub, the point and place of BEGINNING. HAVING THEREON ERECTEDthe southern half of a two and one-half story frame dwelling house known and numbered as 420 South Fred- erick Street and a one-story frame garage. HAVING thereon erected a dwell- ing house being known and num- bered as 420 South Frederick Street, Mechanicsburg, PA 17055-6410. BEING the same premises which Bruce Allen Homes, Inc., by Deed dated May 1, 2009 and recorded June 5, 2009 in and for Cumberland County, Pennsylvania, in Deed Book Volume Instrument #200919002, granted and conveyed unto Jeffrey A. Maguire, a married man. Tax Map No.: 16-24-0787-097. ti PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal. on the following dates, viz: January 24, January 31, and February 7, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, Edit SWORN TO AND SUBSCRIBED before me this 7 day of February, 2014 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot -News Co. < 12020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 e atriotXews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 13-683 Civil Term Wells Fargo Bank, N.A. Vs Jeffery Maguire Atty: Jaime R Ackerman ALL THAT CERTAIN piece, parcel and tract of land situate in the Borough of Mechanicsburg, County of Cumberland, State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a hub in South Frederick Street, which said hub is North ninety-eight and eighty hundredths (98.80) feet from the northwest corner of South Frederick Street and West Marble Street; thence along lands now or formerly of C. Schultz, South eighty (80) degrees twenty-two (22) minutes thirty (30) seconds West, a distance of two hundred twenty r f 3t to a hub on 1 the eastern line of a twenty (20) foot ' alley; thence along the eastern line of said alley, North This ad ran on the date(s) shown below: 01/19/14 01/26/14 02/02/14 Sworn to a d subs • ibed before me this 18 y of February, 2014 A.D. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington TWp., Dauphin County My Commission Expires Dec. 12 2016 MEMBER, PENNSfVAytp ASst tA--- iIbN OF NOTA 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 12th day of March A.D., 2014, under and by virtue of a writ Execution issued on the 5th day of November, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number 683, at the suit of Wells Fargo Bank N A against Jeffrey A Maguire is duly recorded as Instrument Number 201410047. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this ) 5-41) day of ftq ,A.D. a0l(1 C(Aibi v6( . t A),,-dilin DePU Recorder of Deeds, Cumberland County, Carlisle, Pa Recorder of Deeds My Commission Expires the First Monday of Jan. 2018