The URL can be used to link to this page

Home My WebLink About13-0720IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., Plaintiff, vs. Paulette Frantz; 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. CIVIL DIVISION ~., . r -,; _ ~ NO.: ~~ . ~~~ I~V! I ~ -:: ~~~ ~~~ TYPE OF PLEADING ~~ ~ rv `~;~..~,, cy -{ CIVIL ACTION - COMPLAINT ~~~ =' '== ~ , 1.; IN MORTGAGE FORECLOS URfr = ~ _~ -{ FILED ON BEHALF OF: Wells Faro Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3476 Stateview Blvd. Ft. Mill. SC 29715 AND THE DEFENDANT: 46 DREXELPLACE NEW CUMBERLAND. PA 17070-2204 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 55 Drexel Place. New Cumberland PA 17070-2204 MunicioalitV: Lower Allen ~ ~ ~ -~ ~ ATTORNEY FOR PLAINTIFF ATTY FILE NO.: XFP 170012 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 officeC«~zuckergoldbere.com File No.: XFP- 170012/ncp a~~~ 3.7s~ ~+~ ~.I:-# Gulp 31 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, 2 ~ ~ I Paulette Frantz; 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 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. Paulette Frantz; 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 action dentro de los prdximos veinte (20) dias despues de la notification 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 O VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 LAWYER REFERRAL Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. Paulette Frantz; CIVIL DIVISION Plaintiff, NO.. Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff") with its place of business located at 3476 Stateview Blvd., Ft. Mill, SC 29715. 2. The Defendant, Paulette Frantz, is an individual whose last known address is 46 DREXEL PLACE, NEW CUMBERLAND, PA 17070-2204. 3. Wells Fargo Bank, N.A., directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit A, attached hereto and made a part hereof. 4. On or about March 11, 2011, Paulette Frantz, a Single Person made, executed and delivered to Wells Fargo Bank, N.A. a Mortgage in the original principal amount of $87,620.00 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 March 14, 2011, Instrument #201108110. 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. Zucker, Goldberg & Ackerman, LLC XFP-170012 062-PA-V3 5. Plaintiff is the current mortgagee. 6. Paulette Frantz, single woman is the record and real owner of the aforesaid mortgaged premises. 7 Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due May 1, 2012. 8 As of January 02, 2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $86,356.15 Interest through 01/02/2013 $ 3,331.42 Escrow Advance $ 1,731.98 Late Charges $ 81.90 Inspection Fees $ 90.00 Total $ 91,591.45 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and 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. 9 Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 10 This action does not come under Act 91 of 1983 because the mortgage is FHA insured. 062-PA-V3 Zucker, Goldberg & Ackerman, LLC XFP-170012 11 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 $ 91,591.45 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GOLDBERG & ACKERMAN, LLC i BY: Dated: ~~~ ~ a~ 1 ~ Scot A. ietterick, 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-170012/ncp 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com THIS 1S AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION 08TA/NED WILL BE USED FOR THAT PURPOSE. 062-PA-V3 Zucker, Goldberg & Ackerman, LLC XFP-170012 EXHIBIT A 062-PA-V3 Zucker, Goldberg & Ackerman, LLC X F P-170012 NOTE ,:tt~~ cas~.o. Multistutc MARCx 11, 2011 lDa[rl 55 DREXEL PLACE, NEW CUMBERLAND, PA 17070 ~Propcrty ASdressl 1. PARTIES "I3orrowcr" means each person signing at the end of this Note, and the person's successors anti assigns. "Lender" means WELLS FARGO BANK, N.A. and its succ~s`;orr• anti assigns. 2. BORROWER'S PROA•IISF, TU PAY; INTF,REST In return fi>r a loan received from Lcndcr, Iorrower promises to pay the principal sum ofEIGHTY SEVEN THOIISAND SIX HUNDRED TWENTY AND 00/100 Dollars (11.5. $ *********87, 620.00 ), plus interest, lu the order of Le;ndcr. Interest will be charged on unpaid principal, ["rom the dolt of"disbursement of the loan proceeds by Lcndcr, al the rate ul'FIVE AND ONE-EIGHTH percent ( 5.125 °/n) per year until the lull amount of principal has been paid. 3. PRO~•tiSE 1'O PAY SF,CURED Durrowcr's promise kr pay is secured by a nutrtgagr, decd uC trust or similar security instrument that is dated the same date us this Nulc and called the "ti,:curity Inslntmcnl." The Security Instrument protects the Lcndcr Irom Ie}sses which might result il' Borrower dciaults under this Nc1tl. 4. IiIANNER OF PAYl1IEN7' (A) 'l'ime [3orrower shall make a payment of principal and interest to Lcndcr on the first clay of each month beginning on MAY OI 2011 .Any principal and interest remaining un the first day o!' APRIL 2041 ,will he due un that date, which is called the "Maturity Date." (B) Place Payment shall be made at WELLS FARGO HOME MORTGAGE, P . O. BOX 11701, NEWARK, NJ 071014701 or at such place as Lender may designate in writing by notice to [3orroa~er. (C) Amount such monthly payment of principal and interest will he in the amount of U.S. S *******477.08 .'t'his amount will be port uC a larger monthly payment required by the Security lnstnnncnt, That shall be applied to principal, interest and other items in the order ckscribcd in the Security [nstrumenl. (D) Alk-nbc to this Note fi-r payment adjustments 1C an allongc providing tier paymcnl adjustments is executed by [3ornrwcr together with this Nutc, the covenants of the allongc shall be ina[rporalctl into ant[ shall amend and supplement the covenants of this Note as if the allungc were a part of this Nutc. Check applicublc box] ^Graduatcd Payment Allonge ^Cirowing Equity Allunge ^t7lhcr ~spccify:E 5. BORROWER'S RIGII'!"l'O PRF,PAY [3urrnwcr has the right to pay the dchl evidenced by this Nine, in tvholc or in port, without charge or penalty, nn the first day oE' any nxmlh. Lcndcr shall accept prepayment nn other clays provided that burrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and pcnnitted by regulations of the Scc.retary. If Burrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly paymcnl unless Lender agrees in writing to those changes. .,,,,,,,,,,,_ .............................. ®~~R t~Ct{ pfI:~ ~tulrixlate fixed kale \ulc - 10/9* VMP MORTGAGE FORMS • (800)521-729'1 t~j Page t of 2 Initials: ti. QOIZR(riVF,R'S I'AILURE TO PAY (A) Late Charge tirr Overdue Payments If Lender has not received the full monthly payment required by the Security Irnlnunent, as described in Paragraph ~4(C) of this Note., by the end of fillccn calendar days osier the payment is clue, Lender may collect a late charge in the amount of FOUR percent (4 .000 %) of the overdue amount of each payment. (I3) Default If f3orrrnvcr drlaulls by failing to pay in full any nu~nthly paynicnl, Ihen Lender may, except as lirnilcd by regulations of the Secretary in the case of payment dclaulls, require immediate payment in full of the principal balance remaining due and all acentcd interest. Lender may choosy not to exercise this uptinn without waiving its righls in the event of any subsequent default. In many circumstances regulations issued by the Secretary will linut Lender's rights to require immediate payment in full in the case of payment defaults. 'this Note does nrn authori-re aceclrration when not permitted by IdUD regulations. As used in Ihis Notc, "Secretary" means the Secretary of Ilousing and Urban Development or his ur her designee. (C) Payment of Costs and F,xpenres If Lender has required irnmcdiale payment in lull, as describal ubcrvc, Lender may require l3orrowcr lu pay costs and expenses including rcaurnable and customary attorneys' Ices li>r enforcing Ihis Note to thr extent not prohilsited by applicable law. Such fees and costs shall bear interest Irom the date of disbursement at the same rate as the principal of Ihis Note. 7. WAVERS I3urruwer and any other pcnon who has obligations under this Notc waive the righls of presentment and notice of dishnnor. "Presentment" means the right to raluirc Lender lu demand payment of anuxrnls due. "Notice of dishonor" means the right to require Lcndcr to give notice to other persons shat amounts due have not been paid. K. (:I~'ING OF v01'ICF.S lJnlcss upplicahle law requires a diffcrcnt rncthod, any notice that must be given to 13orrowcr under this Nole will be given by dciivering it or by mailing it by tint class mail lu l3orrowcr at the prcrpcrly address above or at a diffcrcnt address if i3urnnver has given Lcndcr a notice of C3orrower's different address. My notice That mull he given Ic.r Lcndcr under Ihis Nute will he given by lirsl class mail to Lender at the address stated in Paragraph ~l(B) or at a diffcrcnt address if Borrower is given a notice of that diffcrcnt address. 9. OQLIGATTOVS OF PERSONS UNDER 1'II1S v0'1't; If more than one person signs this Note, each person is fully and pcrsnnally obligated to keep all of the promises made in Ihis Nulc, including the premise to pay the lull amcnrnt owed. Any person who is a guarantor, surety ar endorser of Ihis Note is also obligated to do Ihese shines. Any person who takes over those obligations, including the ohligations of a guarantor, surety or endorser of Ihis Nutt, is also obligated to keep all of the promises made in Ihis Note. Lender may enforce its rights under this NfNe against each pcnon individually or against all signatories together. Any one person signing this Note may be required to pay all of [he amounts awed under this Note. BY S[GNING I3ELObV, Borrower accepts and agrees to the terns and covenants contained in this Note. (tical) -(lorrower (Seal) -t1U [fUw'Cr (Seal) -[3orrou•cr (Seal) •t30f[UWCf r~ (Seal) PAULETTE FRANTZ -Borrowrr _ (Seal) -BU[rOWC[ _ (Seal) -Iiorrowcr _ (Seal} 't3orroWC[ ®®•~R ~t~ Pape2ot2 EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-170012 062-PA-V3 1~ po LEGAL DESCRIPTION File No ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, being more fully described on that certain As Built Plan of Foxlra Residential Community Village One, Phase I, Lower Allen Township, Cumberland County, Pennsylvania, as prepared by Gerrit J. Bentz Associates, Inc., Engineers and Surnyors, dated October 6, 1976, and last revised March 19, 1977, as recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on March 23, 1977, in Plan Book 26, at Page 50, which Plan is herein incorporated by reference as if hereto attached, as Unit Number SS in Building "I," descn-bed on said As Built Plan as metes and bounds, which description is likewise herein incorporated by reference. The County Parcel Number for the above-described parcel is 13-ZS-0008-002A UISS-l. FOR INFORMATIONAL PURPOSES ONLY: Premises improved with a single family frame dwelling more commonly known as 55 Drexel Place, New Cumberland, Lower Allen Township, Cumberland County, Pennsylvania. UNDER AND SUBJECT to the same reservations, conditions, restrictions, covenants, exceptions and easements as appear in prior chain of title. TOGETHER with all buildings and improvements thereon $EING the same premises which R. Thomas Kline, Sheriff of the County of Cumberland by Indenture dated 0411712009, and recorded in the Office for the Recording of Deeds, in and for the County of Cumberland, aforesaid, as Instrument ~ 200913038, granted and conveyed unto American General Consumer Discount Company, in fee. 13-25-0Q08-002A-UI-55-1 VERIFICATION Denise Goldston, hereby states that he she hs Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that he sh is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his he 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: Denise Goldston Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: O l /29/2013 086-PA-V2 File # 170012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, CIVIL DIVISION f.. ,,~ J~ -~1 ~rw~j ~ f~" f~~_: -~C~ N ~ . ~ r..: .., t_~ r~ , _... c::;--~' G~ '•' --i _ '~ '~ p ~, a .--~ W -G vs. Paulette Frantz; Defendant. NO.. 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-170012 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 Dated: February D , 2013 Scott A. ietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA t.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-170012/jab 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XFP-170012 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: Yes ^ No ^ Listing date: State: Yes ^ No ^ Home: Cell: State: Office: Other: First Mortgage Lender: Type of Loan: Loan Number: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for Default: Date you closed your loan: Included Taxes & Insurance: Is the loan in Bankruptcy? Yes ^ No ^ If yes, provide names, location of court, case number & attorney: How long? State: Zip: Home: Office: Cell: Other: How long? Zip: Price: $ Realtor Phone: Zip: Zucker, Goldberg & Ackerman, LLC XFP-170012 Assets Amount Owed: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Amount owed: Automobile #2: Amount owed: Model: Value: Model: Monthlv Income Name of Employers: 1. Value: Year: Year: 2. 3. Additional Income Description (not wages): 1• Monthly amount: 2• Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthlv Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Value: Have you been working with a Housing Counseling Agency? Yes ^ No ^ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Zucker, Goldberg & Ackerman, LLC XFP-170012 Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ^ No ^ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ^ No ^ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: Phone: I/We, ,authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with the following information to lender and lender's counsel: V Proof of Income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation (hardship letter) V Listing agreement (if property is currently on the market) Zucker, Goldberg & Ackerman, LLC XFP-170012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.. Paulette Frantz; 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-170012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. Paulette Frantz; 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 Plaintiff, Defendant. CIVIL DIVISION NO.: CASE MANAGEMENT ORDER .M. in Cumberland County Courthouse, Carlisle, Pennsylvania. at the 1. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 2. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable Zucker, Goldberg & Ackerman, LLC XFP-170012 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-170012 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 1S U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff No.: 13-720 CIVIL vs. ISSUE NUMBER: Paulette Frantz; TYPE OF PLEADING: Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) Mortgaged Premises: 55 Drexel Place, New Cumberland, PA 17070-2204 FILED ON BEHALF OF: Wells Fargo Bank, N.A. Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG &ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa I.D.# 55650 Kimberly A. Bonner, Esquire- Pa I.D. #89705 Joel A. Ackerman, Esquire- Pa I.D.#202729 Ashleigh L. Marin, Esquire-Pa I.D.#306799 Ralph M. Salvia, Esquire- Pa I.D.#202946 Jaime R.Ackerman, Esquire- Pa I.D.#311032 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-170012 c �l r=' •..a... 2 O .--- y La ---i •�-- r (,0.6(3" (3 Ck4553 )? ags) ip, 0 c c �Qc va Praecipe for Entry Judgment Zucker, Goldberg&Ackerman, LLC XFP-170012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, • • vs. NO.: 13-720 CIVIL • Paulette Frantz; •• 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 $91,591.45 plus interest on the judgment amount($91,591.45)from January 3, 2013, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 46 DREXEL PLACE address is: NEW CUMBERLAND, PA 17070-2204 ZUCKER, GOLBERG :r KERMAN, LLC Dated:)IS BY: �, �� I� 111 Joel A.Acke�� an, Esqu re; PA I.D.#202729 I n Ashleigh L. Marin, Esquire; PA I.D.#306799 Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-170012 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com DAMAGES ARE ER BY ASSESSED AS INDICATED Date F: Prothonotary • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, . vs. . NO.: 13-720 CIVIL Paulette Frantz; •• • 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 &A '''MAN, LLC/ BY: �� El Joel A.Ackerman,squir-; PA I.D.#202729 ❑ Ashleigh L. Marin, Esquire; PA I.D.#306799 Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-170012 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com Sworn to and subscribed efore me This 31 day of OCH , 20 /3 &-d- 1,c4,.-t No Publi My Commission Expires: Cheryl Debeneadto My Comm. Expires pct ary Public lD#228027616,2016 State of NOiv Jersey Zucker,Goldberg&Ackerman, LLC XFP-170012 • Department of Defense Manpower Data Center Results asof:Oct-30201306:20:03 SCRA 3.0 „ Status Report a" ' ' t,• Pursuant to Service nembers Civil Relief Act , Last Name: FRANTZ First Name: PAULETTE Middle Name: Active Duty Status As Of: Oct-30-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No_. NA This response reflects the Individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or HisMer Unit Was Notified of a Future CelWp to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA. No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,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. y)elf2,,„,,,ii, YA ,. ,,, ,I '1. t 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.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: T56AED35V093Z40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • vs. NO.: 13-720 CIVIL • • Paulette Frantz • • Defendant. • • • IMPORTANT NOTICE TO: Paulette Frantz 46 DREXEL PLACE NEW CUMBERLAND, PA 17070-2204 DATE OF NOTICE: 10/16/2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten(10)days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND& LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 13-720 CIVIL Paulette Frantz Defendant. • • • • AVISO IMPORTANTE TO: Paulette Frantz 46 DREXEL PLACE NEW CUMBERLAND, PA 17070-2204 FECHA DEL AVISO:1 0/16/2013 LISTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIIvIOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SINLLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IIvIPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO ]NMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAIO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYERREFERRAL 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: Salt A. D ietterick Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 170012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson THE Sheriff oYttrtr of coolo,rf,,4d O O ,". Jody S Smith 1013 Chief Deputy s Richard W Stewart M FRL A Solicitor CE Tt r=t. rr YI-y4C4 N T Y Wells Fargo Bank, N.A. Case Number vs. Paulette Frantz 2013-720 SHERIFF'S RETURN OF SERVICE 02/20/2013 Ronny R Anderson, Sheriff,being duly sworn according to law,states he made diligent search and inquiry for the within named Defendant to wit Paulette Frantz,but was unable to locate the Defendant in his bailiwick.The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as"Not Found"at 55 Drexel Place, Lower Allen, New Cumberland, PA 17070. Residence is vacant. 03/01/2013 08:15 PM-Deputy Shawn Harrison,being duly sworn according to law,served the r-quested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themse to be Wael Abdelmalak, husband of defendant,who accepted as"Adult Person in C g=" • •-ulette Frantz at 46 Drexel Place, Lower Allen, New Cumberland, PA 17070. ♦ �L SH '71 A:17:77*N, DEPUTY SHERIFF COST:$100.00 SO ANSWERS, March 06,2013 RONNY R ANDERSON,SHERIFF ;v ;,at;h:,.t' INFOCON Corporation Page 1 of 1 PA - CUMBERLAND ICProthonotary Dockets Filed Case No: 2013-00720 ENTER Case Type: REAL PROPERTY - MORTGAGE FOREC PAGE UP Caption: WELLS FARGO BANK NA (vs) FRANTZ PAULETTE PAGE DOWN DONE Position to Page: of EXIT Sel Date Description E-MAIL 02/12/13 COMPLAINT-MORTGAGE FORECLOSURE-BY ASHLEIGH BACK PLFF PLFF 02/12/13 NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVE ATTY FOR PLAINTIFF ATTY FOR PLAINTIFF 03/08/13 SHERIFF'S RETURN-DATED 03/01/13-COMPLAINT IN M FORECLOSURE SERVED ON DEFT AT 46 DREXEL PLACE NEI 17070 SHFF COST-$100.00 Bottom http://www.infoconcountyaccess.com/CAS_Public_Inquiries/Views/CAXPY_Views/PY... 10/14/2013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION • Plaintiff, •vs. • NO.: 13-720 CIVIL • Paulette Frantz; • • Defendant. • • NOTICE OF ORDER, DECREE OR JUDGMENT TO: Paulette Frantz 46 DREXEL PLACE NEW CUMBERLAND, PA 17070-2204 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on Nov. ! � [ J A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $91,591.45 pI costs Prothonotary Zucker,Goldberg&Ackerman, LLC XFP-170012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION File No. 13-720 CIVIL Wells Fargo Bank, N.A., Amount Due $91,591.45 Plaintiff, Interest from 01/03/2013 to date of sale $7,793.90 VS. Paulette Frantz; Costs ¢} rQ Defendant.. TO THE PROTHONOTARY OF THE SAID COURT: T9 �, C) 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 defendants) in the possession, custody or control of the said garnishee(s). cs�) - Q Sq Zucker,Goldberg&Ackerman,LLC \FP-170012 , (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: Signatur n Print NamASco'ttA. iet terick, Esquire Kimberly A. Bonner, Esquire Joel Ackerman, Esquire Ashleigh L. Marin, Esquire Ralph M. Salvia, Esquire Jaime R.Ackerman, Esquire Jana Fridfinnsdottir, Esquire Brian Nicholas, Esquire Denise Carlon, 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.: 55650 89705 202729 306799 202946 311032 315944 317240 317226 Zucker, Goldberg&Ackerman, LLC XFP-170012 a L. Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, being more fully described on that certain As Built Plan of Foxlea Residential Community Village One, Phase I, Lower Allen Township, Cumberland County, Pennsylvania, as prepared by Gerrit J. Bentz Associates, Inc., Engineers and Surveyors, dated October 6, 1976, and last revised March 19, 1977, as recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on March 23, 1977, in Plan Book 26, at Page 50, which Plan is herein incorporated by reference as if hereto attached, as Unit Number 55 in Building "I," described on said As Built Plan as metes and bounds,which description is likewise herein incorporated by reference. UNDER AND SUBJECT to the same reservations, conditions, restrictions,covenants,exceptions and easements as appear in prior chain of title. TOGETHER with all buildings and improvements thereon. HAVING thereon erected a dwelling house being known and numbered as 55 Drexel Place, New Cumberland, PA, 17070-2204. BEING the same premises which Springleaf Financial Services of Pennsylvania, formerly known as American General Consumer Discount Company, by Deed dated March 8, 2011 and recorded March 14, 2011 in and for Cumberland County, Pennsylvania as Instrument Number 201108109, granted and conveyed unto Paulette Frantz, single woman. Tax Map No.: 13-25-0008-002A-U155-1. i 4 3 I 4 1' I. Zucker,Goldberg&Ackerman, LLC I XFP-170012 i i i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. , CIVIL DIVISION r� Plaintiff, NO.: 13-720 CIVIL v �� -n c s. -M Execution No.: - Paulette Frantz; Defendant(s). .,.�,Cn A ` jr AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A., Plaintiff in the above action,sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 55 Drexel Place, New Cumberland, PA 17070-2204. 1. Name and Address of Owner(s)or Reputed Owner(s): PAULETTE FRANTZ, SINGLE WOMAN 46 Drexel Place New Cumberland, PA 17070-2204 2. Name and Address of Defendant(s) in the Judgment: PAULETTE FRANTZ 46 Drexel Place New Cumberland, PA 17070-2204 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 Zucker,Goldberg&Ackerman,LLC XFP-170012 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: FOXLEA HOMEOWNERS'ASSOCIATION 81 Drexel Place New Cumberland, PA 17070 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 55 Drexel Place New Cumberland, PA 17070-2204 UNKNOWN SPOUSE 46 DREXEL PLACE NEW CUMBERLAND, PA 17070-2204 Zucker,Goldberg&Ackerman,LLC XFP-170012 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 1 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,GOLDBERG &ACKERMAN, LLC Dated: �'" Q� �4-- B cott 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-170012/11 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoIdberg.com Zucker,Goldberg&Ackerman,LLC X.FP-170012 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, being more fully described on that certain As Built Plan of Foxlea Residential Community Village One, Phase I, Lower Allen Township, Cumberland County, Pennsylvania, as prepared by Gerrit J. Bentz Associates, Inc., Engineers and Surveyors, dated October 6, 1976, and last revised March 19, 1977, as recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania,on March 23, 1977, in Plan Book 26, at Page 50,which Plan is herein incorporated by reference as if hereto attached, as Unit Number 55 in Building"I," described on said As Built Plan as metes and bounds,which description is likewise herein incorporated by reference. UNDER AND SUBJECT to the same reservations,conditions, restrictions, covenants, exceptions and easements as appear in prior chain of title. TOGETHER with all buildings and improvements thereon. HAVING thereon erected a dwelling house being known and numbered as 55 Drexel Place, New Cumberland, PA, 17070-2204. BEING the same premises which Springleaf Financial Services of Pennsylvania,formerly known as American General Consumer Discount Company, by Deed dated March 8, 2011 and recorded March 14, 2011 in and for Cumberland County, Pennsylvania as Instrument Number 201108109, granted and conveyed unto Paulette Frantz, single woman. Tax Map No.: 13-25-0008-002A-U155-1. Zucker,Goldberg&Ackerman, LLC XFP-170012 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , " . .. Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: 13-720 CIVIL ��f .� fN Paulette Frantz; Defendant. - NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Paulette Frantz 46 Drexel Place New Cumberland, PA 17070-2204 AND 55 Drexel Place New Cumberland, PA 17070-2204 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 06/04/2014 at 10:00am prevailing Focal time. 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: 55 Drexel Place, New Cumberland, PA, 17070-2204 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 13-720 CIVIL Zucker,Goldberg&Ackerman, LLC XFP-170012 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Paulette Frantz,single woman 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-170012 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,GOLDBERG &ACKERMAN, LLC Dated: � I B C 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-170012/11 200 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-170012 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, being more fully described on that certain As Built Plan of Foxlea Residential Community Village One, Phase I, Lower Allen Township, Cumberland County, Pennsylvania, as prepared by Gerrit J. Bentz Associates, Inc., Engineers and Surveyors, dated October 6, 1976, and last revised March 19, 1977, as recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on March 23, 1977, in Plan Book 26, at Page 50, which Plan is herein incorporated by reference as if hereto attached, as Unit Number 55 in Building "I," described on said As Built Plan as metes and bounds,which description is likewise herein incorporated by reference. UNDER AND SUBJECT to the same reservations, conditions, restrictions, covenants, exceptions and easements as appear in prior chain of title. TOGETHER with all buildings and improvements thereon. HAVING thereon erected a dwelling house being known and numbered as 55 Drexel Place, New Cumberland, PA, 17070-2204. BEING the same premises which Springleaf Financial Services of Pennsylvania, formerly known as American General Consumer Discount Company, by Deed dated March 8, 2011 and recorded March 14, 2011 in and for Cumberland County, Pennsylvania as Instrument Number 201108109, granted and conveyed unto Paulette Frantz, single woman. Tax Map No.: 13-25-0008-002A-U155-1. i j i I I I. I Zucker,Goldberg&Ackerman,LLC . XFP-170012 s i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-720 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 PAULETTE FRANTZ (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: $91,591.45 L.L.: $.50 Interest from 1/3/2013 to Date of Sale -- $7,793.90 Atty's Comm: Due Prothy: $2.25 Atty Paid: $248.75 Other Costs: Plaintiff Paid: Date: 2/20/2014 David D.Buell,Prothonotary (Seal) Deputy REQUESTING PARTY: Name: DENISE CARLON,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.317226 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Paulette Frantz; Defendant. NO.: 13-720 CIVIL ca c rnci :Pm Notice of the Date of Continued Sheriff Sale r— The Sheriff Sale scheduled for June 4, 2014 at 10:00 AM in the above captioned matte Baas b,n =c) continued until September 3, 2014 at 10:00 AM. Dated: /ig[tc( BY: ZUCKER, GOLDBE , _& ACKER� LLC Scott A. ietterick, 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-170012/chr 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com .,.e'' CO Zucker, Goldberg & Ackerman, LLC X F P-170012 CD-. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. , vs. Paulette Frantz; Plaintiff, Defendant(s). . CIVIL DIVISION c� . NO.: 13-720 CIVILr --i rri r� i` . Execution No.: , 23 r" '-, r-.1 c r. c� c-7 —< t d -1 cn .1 CJ CD { r AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 2: 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 55 Drexel Place, New Cumberland, PA 17070-2204. 1. Name and Address of Owner(s) or Reputed Owner(s): PAULETTE FRANTZ, SINGLE WOMAN 46 Drexel Place New Cumberland, PA 17070-2204 2. Name and Address of Defendant(s) in the Judgment: PAULETTE FRANTZ 46 Drexel Place New Cumberland, PA 17070-2204 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 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 LOWER ALLEN TWP 1993 HUMMEL AVENUE, CAMP HILL, 17011 AND C/O BONNIE K MILLER 2233 Gettysburg RD Camp Hill PA 17011 WEST SHORE SCHOOL DISTRICT 507 Fishing Creek Rd, Lewisberry, PA 17339 AND C/O BONNIE K MILLER 2233 Gettysburg RD Camp Hill PA 17011 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: FOXLEA HOMEOWNERS' ASSOCIATION 81 Drexel Place New Cumberland, PA 17070 CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 55 Drexel Place New Cumberland, PA 17070-2204 UNKNOWN SPOUSE 46 DREXEL PLACE NEW CUMBERLAND, PA 17070-2204 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. Dated: ZUCKER, GOL18ERG & ACKERMAN, LLC BY: 1 Scott A letterick, Esq ire; PA I.D. #55650 KimbePSly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 r Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XCP-170012/nfe 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 lot or piece of ground with the buildings and improvements thereon erected, situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, being more fully described on that certain As Built Plan of Foxlea Residential Community Village One, Phase I, Lower Allen Township, Cumberland County, Pennsylvania, as prepared by Gerrit J. Bentz Associates, Inc., Engineers and Surveyors, dated October 6, 1976, and last revised March 19, 1977, as recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, on March 23, 1977, in Plan Book 26, at Page 50, which Plan is herein incorporated by reference as if hereto attached, as Unit Number 55 in Building "I," described on said As Built Plan as metes and bounds, which description is likewise herein incorporated by reference. UNDER AND SUBJECT to the same reservations, conditions, restrictions, covenants, exceptions and easements as appear in prior chain of title. TOGETHER with all buildings and improvements thereon. HAVING thereon erected a dwelling house being known and numbered as 55 Drexel Place, New Cumberland, PA, 17070-2204. BEING the same premises which Springleaf Financial Services of Pennsylvania, formerly known as American General Consumer Discount Company, by Deed dated March 8, 2011 and recorded March 14, 2011 in and for Cumberland County, Pennsylvania as Instrument Number 201108109, granted and conveyed unto Paulette Frantz, single woman. Tax Map No.: 13 -25 -0008 -002A -U155-1. C:"' J:- co :Do rn- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLIA --ori. , �-=-' — c7) -:.i CIVIL DIVISION r r-=-) ' T' U? Plaintiff, NO.: 13-720 CIVIL Wells Fargo Bank, N.A., vs. Paulette Frantz; TYPE OF PLEADING Defendant. 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 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XFP- 170012/mag Zucker, Goldberg & Ackerman, LLC XFP-170012 j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. Paulette Frantz; Plaintiff, Defendant. CIVIL DIVISION NO.: 13-720 CIVIL 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, Paulette Frantz, single woman, is the record owner of the real property. 2. On or about April 7, 2014, defendant Paulette Frantz was served with Plaintiff's 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 46 Drexel Place, New Cumberland, PA 17070-2204. 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 July 18, 2014, Plaintiffs counsel served all other parties in interest with Plaintiff's Notice of Sheriff's 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 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-170012 Interest were served with Plaintiff's Notice of Sheriffs Sale of Real Property in accordance with Pa.R.C.P. 3129.2. Dated: August 1 s , 2014 Sworn to and subscribed before me this 13 day of August, 2014 Notary P blic MY COMMISSION EXPIRES: Cheryl Debeneadto Notary Public My Comm. Expires Oct. 16, 2016 1D # 2280276 State of New Jersey ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff MARGARE GYEPONG Paraleg I/Legal Assistant Zucker, Goldberg & Ackerman, LLC XFP-170012 EXHIBITA Zucker, Goldberg & Ackerman, LLC XFP-170012 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OFTfi $i1 IFF Wells Fargo Bank, N.A. vs. Paulette Frantz Case Number 2013-720 SHERIFF'S RETURN OF SERVICE 03/27/2014 02:08 PM - Deputy Stephen Bender, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 55 Drexel Place, Lower Allen - Township, New Cumberland, PA 17070, Cumberland County. 04/07/2014 07:36 PM - Deputy Brian Grzyboski, 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: Paulette Frantz at 46 Drexel Place, Lower Allen, New Cumberland, PA 17070, Cumberland County. 05/15/2014 As directed by Jaime R Ackerman, Attorney for the Plaintiff, Sheriffs Sale Continued to 9/3/2014 SHERIFF COST: $1,390.88 SO ANSWERS, May 23, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. RONR ANDERSON, SHERIFF EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-170012 NTL Page 1 of 6 UNITED .STATES MN 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-170012/nfe 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 CI% POSTAL SERVICE® This Certificate of Melling provides evidence that mall has been presented to USPS° for mailing. T and International mall. From' Scott A. Dietterick, Esquire U.S. POSTAGE» PITNEY BOWES ZIP 0 02 tri092 $ 001.20 0001387430JUL 18 2014 To pay fee, affix stamps or mater postage here. Ptystmar c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-170012/nfe TEAM- C 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 p AL 18 2014 cm=1- U.S. POSTAGE )» PITNEY BOWES ZIP o7os�_ Z1 17 $001.20° 0001387430JUL 18 2014 NTL Page 2 of 6 �UNITED STATES 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. FfoT: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 U.S. POSTAGE» pint. EY MOS f7/22. megiamararzzoitaisoo°,0, ZIP 07092 $ 001.20 0211' 0001387430 JUL to 2014 To pay fee, affix stamps or meter postage here. 0 XFP-170012/nfe TEAM- C T°` UNKNOWN TENANT OR TENANTS 55 Drexel Place New Cumberland, PA 17070-2204 ci 1• N,1 ) r ark Here 3:8 20 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 �� UNITED STATES I! POSTAL SERVICE Thls Certificate of Mailing provides evidence that mall has been presented to USPS• for maaing and International mall. Pram: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-170012/nfe TEAM- C T LOWER ALLEN TWP 1993 HUMMEL AVENUE, CAMP HILL, 17011 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 U.S. POSTAGE» PITNEY BOWES ;70110.."7101.. 0101.4.d." ofootoomma.ww/ofirent oertoonmorimffiiior ZIP 07092 $ 00120° 02 111 0001387430 JUL. 18 20 14 NTL Page 3 of 6 ��-1 UNITED STATES POST/JL 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-170012/nfe TEAM- C T LOWER ALLEN TWP C/O BONNIE K MILLER 2233 Gettysburg RD Camp Hill PA 17011 U.S. POSTAGE >> PITNEY BOWES .1r, isarAtedtate4fttitiprecisOv lemeliamows,Ammor ZIP 07092 $ 001.20° 02 try 0001387430 JUL 18 2014 To pay fee, affix stamps or meter postage here. Postmark Here _JUL County of P.O.: CUMBERLAND P5 Form 3817, AprIl 2007 PSN 7530-02-000-9065 ir"..+ UNITED STATES Cita POST/JL SERVlCE8 This Certificate of Mailing provides evidence that mall has been presented to USPS• for mailing. Thl and International mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-170012/nfe TEAM- C T°' WEST SHORE SCHOOL DISTRICT 507 Fishing Creek Rd, Lewisberry, PA 17339 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 U.S. POSTAGE)) PITNEY BOWES (0471LAZIrwimgrammum. Inissop• ZIP 07092 $ 001.200 02 1 YP 0001387430 JUL. 18. 2014. NTL Page 4 of 6 UNITED STATES POSTAL SERVICE® Certificate Of Mailing This Certificate of Mailing provides evidence that map 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-170012/nfe TEAM- C T°` WEST SHORE SCHOOL DISTRICT C/O BONNIE K MILLER 2233 Gettysburg RD Camp Hill PA 17011 County of P.Q.: CUMBERLAND U.S. POSTAGE» PITNEY BOWES Ire ,eaerraleal.�01�a. ZIP 07092 $ 001.20° 02 1n 0001387430 JUL 18 2014 To pay fee, affix stamps or meter postage hare. Post markHef �) JUL18 Si4 PS Form 3817, April 2007 PSN 7530-02-000-9065 �UNITEDST/1TES POSTdL SERVICE® This Certificate of Mailing provides evidence that mall has been presented to USPS• fol and international mall. Frem: Scott A. Dietterick, Esquire U,S. P 'AGE* Y 9OWES c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-170012/nfe TEAM- C FOXLEA HOMEOWNERS' ASSOCIATION 81 Drexel Place New Cumberland, PA 17070 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 71P 07092 $ 001 ata° 01 ,w 0001387430 JUL 18 2014 Post arh,Httr NTL Page 5 of 6 UNITED STATES POST/1L SERVICE® Certificate Of Mailing '' U.S. POSTAGE» �NEy 80W yes. psi~�� ZIP 02 07092 $ 001.20° 1.1 00013874 30 JUL 18 2014 This Certificate of Mailing provides evidence that mall has been presented to USPS for mailing. Thls form may be used for domestic end International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-170012/nfe TEAM- C T°' CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street"t,>nl 1 PO Box 320 Carlisle, PA 17013 JUL I IL 8 &UF To pay fee, ■ffla stamps or meter postage hare. Postmark Here County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE® This Certificate of Mailing provides evidence that mall has been presented to USPS. for mailing. This form may and international mall. Fr"' Scott A. Dietterick, Esquire U.S, POSTAGE» PITNEY BOWES 4 ri wrist srw AINIONINOr ZIP 07092 $ 0101.200 02 1n 000 13 874130 JUL 18. 2014 c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-170012/nfe TEAM- C PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 0111111.41111 County of P.Q.: CUMBERLAND ry Ps Form 3817, AprII 2007 PSN 7530-02-000-9065 NTL Page 6 of 6 � �-� UNITED STATES POSTAL SERVICE® Certificate Of Mailing Fy U.S. POSTAGE» PITNEY gowEs � •�..0 t ! ..�� This Certificate of Mailing provides evidence that mag Ms been presented to USPS• for mailing. This form may be used for domestic end international mail. from: Scott A. Dietterick, Esquire c/a Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Ta: UNKNOWN SPOUSE 46 DREXEL PLACE NEW CUMBERLAND, PA 17070-2204 County of P.Q.: CUMBERLAND XFP-170012/nfe TEAM- C ZIP 07092 $ 001.20° 02 11"1 0001387430JUL 18 2014 To pay lee, affix stamps or meter postage here. PS Form 3817, AprIl 2007 PSN 7530-02-000-9065