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HomeMy WebLinkAbout13-2712 Supreme Court.of Pennsylvania X 60 Cour . Com Y n Pleas GMLCOVer Sh eet For Prothonotary Use Only: CCJ BER7LAND County Docket No: The information collected on this form is used solely court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by lcnv or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiffs Name: Wells Fargo Bank, N.A. Lead Defendant's Name: Charles R. Haines, III C T Are money damages requested ?: ❑ Yes ® No Dollar Amount Requested: within arbitration limits I (Check one) X outside arbitration limits O N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No Name of Plaintiff /Appellant's Attorney: Scott A. Dietterick, Esq. c/o Zucker, Goldberg & Ackerman, LLC A ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other S ❑ Product Liability (does not include mass tort) ❑ Employment Dispute: E ❑ Slander/Libel /Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I MASS TORT ❑ Other: O ❑ Asbestos ❑ Tobacco N ❑ Toxic Tort- DES ❑ Toxic Tort- Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste C1 Other: El Ejectment [I Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment B El Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1//2011 Zucker, Goldberg & Ackerman, LLC XFP- 177142 062 -PA -V3 : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA; WELLS FARGO BANK N.A. CIVIL DIVISION vrr� Tt /S'DO1� l� -_ C a te Plaintiff c� , NO.: r> c� ww vs. � TYPE OF PLEADING Tyh = Charles R. Haines, III; Alissa M. Haines; CIVIL ACTION - COMPLAINT --� Defendants. IN MORTGAGE FORECLOSURE TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE FILED ON BEHALF OF: ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS Wells Far Bank, N.A. FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OFTHE PLAINTIFF IS: ZUCKER GOLDBERG & ACKERMAN, LLC 3476 Stateview Blvd. Ft. Mill, SC 29715 Scott A. Dietterick, Esquire AND THE DEFENDANT: Pa. I.D. #55650 419 Eisenhower Drive Kimberly A. Bonner, Esquire Carlisle, PA 17013 -1679 Pa. I.D. #89705 Joel A. Ackerman, Esquire CERTIFICATE OF LOCATION Pa I.D. #202729 I HEREBY CERTIFY THAT THE LOCATION OF Ashleigh Levy Marin, Esquire THE REAL ESTATE AFFECTED BY HIS LIEN IS Pa I.D. #306799 419 Eisen hower Drive Carr eA 17013 -1679 Municipality: ANorthM* n Ralph M. Salvia, Esquire Pa I.D. #202946 Jaime R. Ackerman, Esquire ATTOR Y F Pa I.D. #311032 ATTY FILE NO.: XFP 177142 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500 (908) 233 -1390 FAX office(@zuckergoldberg.com File No.: XFP- 177142/rbo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.. Charles R. Haines, III; Alissa M. Haines; Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Charles R. Haines, III; Alissa M. Haines; Defendants. AVISO USTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion Como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamaci6n o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR LINO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.. Charles R. Haines, III; Alissa M. Haines; Defendants. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff ") with its place of business located at 3476 Stateview Blvd., Ft. Mill, SC 29715. 2. The Defendant, Charles R. Haines, III, is an individual whose last known address is 419 Eisenhower Drive, Carlisle, PA 17013 -1679. 3. The Defendant, Alissa M. Haines, is an individual whose last known address is 419 Eisenhower Drive, Carlisle, PA 17013 -1679. 4. Wells Fargo Bank, N.A., directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit A, attached hereto and made a part hereof. 5. On or about June 21, 2010, Charles R. Haines III and Alissa M Haines, Married made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for Walker Jackson Mortgage Corporation a Mortgage in the original principal amount of $167,741.00 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 23, 2010, Instrument #201016590. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded December 11, 2012, the mortgage was assigned to Wells Fargo Bank, NA which assignment is recorded in the Zucker, Goldberg & Ackerman, LLC 062 -PA -V3 XFP- 177142 s 5 Office of the Recorder of Deeds for Cumberland County, Instrument #201238486. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 7. Charles R. Haines III and Alissa M. Haines, husband and wife are record and real owners of the aforesaid mortgaged premises. 8. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due November 1, 2012. 9. As of 04/22/2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $ 162,476.65 Interest through 04/22/2013 $ 4,982.22 Escrow Balance ($599.70) Late Charges $ 205.92 Inspection Fees $ 60.00 Total $ 167,125.09 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 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 Defendants) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. Zucker, Goldberg & Ackerman, LLC 062 -PA -V3 XFP- 177142 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $167,125.09 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, , GOLD R & ACKE N, LLC BY: Dated: Scott rly , s eric quire; PA I.D. #55650 � C Kimb 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- 177142/rbo 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoIdberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker, Goldberg & Ackerman, LLC 062 -PA -V3 XFP 177142 EXHIBIT A Zucker, Goldberg & Ackerman, LLC 062 -PA -V3 XFP- 177142 Multistate NOTE HIA Cme No. June 21, 2010 [Date] 419 EISENHOWER DRIVE, CARLISLE, PENNSYLVANIA 17013 [Property Address] 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means Walker Jackson Mortgage Corporation and its successors and assigns. 2. BORROWER'S PROMISE TO PAY; INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of One Hundred Sixty Seven Thousand Seven Hundred Forty One and 00/100 Dollars (U. S. $ 167, 741.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender, at the rate of Five and One Half percent ( 5.500 %) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, decd of trust or similar security instrument that is dated the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A) Time Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on August 1 , 2010 . Any principal and interest remaining on the first day of July 2040 , will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at 1000 Urban Center Dr #500, BIRMINGHAM, ALABAMA 35242 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 952.42 . This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applies] to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allongc shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box) ❑Graduated Payment Allonge ❑Growing Equity Allonge ❑Other [specify) 1000026196 FHA Mullislete Fixed Hate Note 10195 V M P@ V M P1 R (0809 ) Walters Kluwer Financial Services Page 1 of 3 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent( 4.000% %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSON'S UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. 1000026196 FHA Multistate Fixed Rate Note 10195 VMP1 VMP1 R (0609) Wolters Kluwer Financial Services Page 2 of 3 BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. " e/ ->�•> z�_ (Seal) (Seal) CHARLES R RAINES III - Borrower - Borrower (Seal) (Seal) Borrower, - Borrower (Seal) (Seal) - Borrower ✓` •1 '� '�• - Borrower (Seal) (Seal) - Borrower 1 „ - Borrower 12Rt1G� "iii i 0-DII I IV; 1 'a1rt OT VA4 U7f1A G 1 ,: 7-3 VV 1r141)i2Q1`' J ,.�� 1nF1'l71 %A 1000026196 FHA Multistate FixW Rate Note 10195 VMP8 VMP 1 Wolters Kluwer Financial Services Page ge e 3 5 of of 3 Wells Fargo Bank, N.A. WITHOUT RECOURSE, PAY TO THE ORDER OF WALKER JACKSON MORTGAGE CORPORATION BY DA VS HARRIS CFOIASST TREASURER WITHOUT RECOURSE PAY TO THE ORDER OF WEl S FAR W= . ey .y. _ Scott M. Swenson Assistant Vice President EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP- 177142 062 -PA -V3 ALL THAT CERTAIN piece, parcel, or lot of land situate along Eisenhower Drive in North Middleton Township, County of Cumberland and Commonwealth of Pennsylvania, and being more fully bound and described as follows: BEGINNING at a point on the southern right -of -way line of Eisenhower Drive at the northeast corner of Lot 48; thence along said right -of -way line N 54 33' 19" E a distance of 22.00 feet to a point at the northwest comer of Lot 50; thence along said lot S 35 26'41" E' a distance of 166.21 feet to a point at the northeast comer of Lot 65; thence along said lot S 54 33 W a distance of 22.00 feet to a point at the southeast corner of Lot 48; thence along.said lot N 35 26'41" W a distance of 166.21 feet to a point, the point of BEGINNING. CONTAINING 3.657 square feet and being Lot 49 of Keystone Arms. BEING PART OF the same premises which Dickinson College, a nonprofit corporation, by Deed dated 09 -17 -04 and recorded 10 -04 -04 in the Office of the Recorder of Deeds in and for the County of Cumberland in Deed Book 265 Page 2860, granted and conveyed unto Keystone Arms Associates, LLC, a Pennsylvania limited liability company. ALSO BEING the same premises identified as Unit 49 in the Declarations of Covenants and Restrictions for Keystone Arms, a. planned community recorded in Book 725, Page 2457 as amended by a First Amendment to Declaration of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 729, Page 478 ( "Declaration "). Under and Subject to the Declaration and to all covenants, conditions, encumbrances, easements and restrictions of record. TAX MAP NO. 29 -07- 0467 -055 (20100681 a.pfd/20100681A.PFD/27) VERIFICATION Nathaniel Orendain, hereby states that he she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, tha �/e 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 o 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: Nathani renda' Title: Vice Pre ' en an Documentation Company: Wells Fargo Bank, N.A. Date: 04/26/2013 086 -PA -V2 File #: 177142 1� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION%n Plaintiff, I� �r a U °r ..... vs. C) _n Charles R. Haines, III; Alissa M. Haines; "-` t� .:=a Defendants. 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 a court - 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- 177142 IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TIDS PROGRAM IS FREE. ZUCKER, GOLDBER AC RMAN, LLC By: , Dated: Scott A. Die erick, Esquire; PA I.D. #55650 / (Oil � 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- 177142/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- 177142 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: CUSTOMER/PRIMARY Borrower name(s): Property Address: State: Zip: City: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): State: Zip: City: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? CO-BORROWER Mailing Address: State: Zip: City: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date you closed your loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Zucker, Goldberg & Ackerman, LLC XFP- 177142 Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1 : Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: 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 2nd Mortgage Utilities Car Payment(s) Condo /Neigh. Fees Auto Insurance Med. (not covered) pa Auto fuel /repairs Other prop. yment Install. Loan Payment Cable TV Child Support /Alim. Spending Money Day /Child Care /Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Zucker, Goldberg & Ackerman, LLC XFP- 177142 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): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION 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 Date Co- Borrower Signature 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- 177142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: vs. Charles R. Haines, III; Alissa M. Haines; Defendants. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property, which is defendant's primary residence; 2. Defendant has been served with a Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court - 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 Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker, Goldberg & Ackerman, LLC XFP- 177142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.. VS. Charles R. Haines, III; Alissa M. Haines; Defendants. CASE MANAGEMENT ORDER AND NOW, this day of ,20 ,the defendant /borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant /borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court - supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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- 177142 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- 177142 i 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. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith �z Cl"N.n.L 3 Chief Deputy , t r; Richard W Stewart Solicitor PENNSYLVAMA Wells Fargo Bank, N.A. Case Number vs. Charles R. Haines (et al.) 2013-2712 SHERIFF'S RETURN OF SERVICE 05/16/2013 01:39 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Alisa Haines, wife of defendant, who accepted as "Adult Person in Charge"for Charles R. Haines at 419 Eisenhower Drive, North Middleton Township, Carlisle, PA 17013. RYAN BURGETT, D 05/16/2013 01:39 PM- Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant, to wit:Alissa M. Haines at 419 Eisenhower Drive, North Middleton Township, Carlisle, PA 17013. RYAN BUR , D SHERIFF COST: $50.78 SO ANSWERS, May 17, 2013 R N R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff No.: 2013-02712 vs. ISSUE NUMBER: Charles R. Haines, Ill;Alissa M. Haines; TYPE OF PLEADING: Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) Mortgaged Premises: 419 Eisenhower Drive, Carlisle, PA 17013-1679 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-177142 C: C --I �J L)C ! con 3 cA a (Z;iV W k-ed Praecipe for Entry of Judgment Zucker,Goldberg&Ackerman, LLC XFP-177142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, • NO.: 2013-02712 vs. • Charles R. Haines, Ill; Alissa M. Haines; •• Defendants. • • • PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s),for failure to file a response to Plaintiff's Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $167,125.09 plus interest on the judgment amount($167,125.09)from April 23, 2013, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 419 Eisenhower Drive 419 Eisenhower Drive address is: Carlisle, PA 17013-1679 Carlisle, PA 17013- 1679 / ZUCK 0 BERG &AC ERMAN, LLC Dated: /OM�� //3 BY: G�]` / Joel A. e an, squire; A I.D. ❑ Ac P #202729 q , 2- Ashleigh L. Marin, Esquire; PA I.D.#306799 ❑ Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-177142 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com 7 1 DAMAGES ARE HEREBY ASSESSED AS INDICATED �t Date )0 laqi Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 2013-02712 vs. • Charles R. Haines, Ill; Alissa M. Haines; . Defendants. • • • AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. / ZUCKER,GOLBERG &ACKERMAN, LLC Dated: !0///// BY: a 4 fl4a/ 3 Jo el A.Ackerman, Esquire .D.#202729 Fr Ashleigh L. Marin, Esquire; PA I.D.#306799 ❑ Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-177142 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 it day of Oa-- , 20 13 Notary P Iic My ebieneadto Notary public My Comm. Expires Oct. 16, 2016 ID#2280276 State of New Jersey Zucker,Goldberg&Ackerman, LLC XFP-177142 Department of Defense Manpower Data Center Results as of:Ocl-10.201312:46:24 SCRA 3.0 t ia ti 4. .; Status Report Pursuant to Servicemembers Civil.Relief Act xN'�0 Last Name: HAINES First Name: ALISSA Middle Name: M Active Duty Status As Of: Oct-10-2013 Dn Active Duty at Active Doty Statue Date Active Duty Start Date Active Duty End Date Status Service Component NA NA Nu NA This response reflects the Individuals'active duty status based on the"Active Duty Status Date Lett Active Duty Within 367 Days of Active Duty Statue Date Active Duty Start Date Active Duly 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 HistHer Unit Was Notified of a Future Cai• p to Active Duty on Active Duty Status Date Order Notification Start Data Order Notification End Date r Status Service Component NA NA a Nat`_ NA This response reflects whether the Individual or his/her unit has received eariynotificatton to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL: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(RPM). 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: U5ACS2E0W05AW60 .Department of Defense Manpower Data Center Results asof:Oct-10-201312:42:32 SCRA 3.0 '1+a Status Report Pursuant to ServicentembcTs Civil Relief Act Last Name: HAINES, III First Name: CHARLES Middle Name: R Active Duty Status As Of: Oct-10-2013 On Acave Duty On Active Duty Status Dale 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 387 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 387 days preceding the Active Duty Status Date The Member or H istNer Unit Was Notified of a Future Call-Up to Active Duty o 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. yh., 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(NOAH Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: Q5SBD270L059P70 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION• Plaintiff, • • vs. NO.: 2013-02712 • Charles R. Haines, Ill;Alissa M. Haines; Defendants. • • • NOTICE OF ORDER, DECREE OR JUDGMENT TO: Charles R. Haines, III 419 Eisenhower Drive Carlisle, PA 17013-1679 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decr a or Judgment was entered in the above captioned proceeding on 10\ 5113 [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $167,125.09 us cos Prothonotary Zucker,Goldberg&Ackerman, LLC XFP-177142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • • vs. NO.: 2013-02712 • Charles R. Haines, Ill; Alissa M. Haines; . Defendants. • • • NOTICE OF ORDER, DECREE OR JUDGMENT TO: Alissa M. Haines 419 Eisenhower Drive Carlisle, PA 17013-1679 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order Decree or Judgment was entered in the above captioned proceeding on t e\ �13 [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows:$167,125.09 p us costs. .°."1) 9 Prothonotary Zucker,Goldberg&Ackerman, LLC XFP-177142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • vs. NO.: 2013-02712 • Alissa M. Haines •• Charles R. Haines, Ill • • Defendant. • • • • IMPORTANT NOTICE TO: Charles R. Haines, Ill 419 Eisenhower Drive Carlisle, PA 17013-1679 DATE OF NOTICE: 9/23/2013 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.: 2013-02712 • Alissa M. Haines Charles R. Haines, Ill • Defendant. • • AVISO IMPORTANTE TO: Charles R. Haines, Ill 419 Eisenhower Drive Carlisle, PA 17013-1679 FECHA DEL AVISO:9/23/2013 LISTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS 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 IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR LINO, VAYA 0 LLAME LA OFICINA ABAJO 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: Scdt A. D idtf-ick 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 177142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2013-02712 • • Alissa M. Haines • • Charles R. Haines, Ill • • Defendant. • • • • IMPORTANT NOTICE TO: Alissa M. Haines 419 Eisenhower Drive Carlisle, PA 17013-1679 DATE OF NOTICE: 9/23/2013 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.: 2013-02712 Alissa M. Haines Charles R. Haines, Ill • Defendant. • • AVISO IMPORTANTE TO: Alissa M. Haines 419 Eisenhower Drive Carlisle, PA 17013-1679 FECHA DEL AVISO:9/23/2013 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIIVIOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TD 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 177142 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i3O= q • ow of uurlrip,.rJ Jody S Smith n@ 3 Chief Deputy c ", r 23{3 140 API 10: 08 Richard W Stewart Solicitor or $s= PENNSYLVANIA Wells Fargo Bank, N.A. vs. Case Number Charles R. Haines(et al.) 2013-2712 SHERIFF'S RETURN OF SERVICE 05/1612013 01:39 PM-Deputy Ryan Burgett,being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Alisa Haines,wife of defendant,who accepted as "Adult Person in Charge"for Charles R. Haines at 419 Eisenhower Drive, North Middleton Township, Carlisle, PA 17013. RYAN BURGETT,DEPtf'1°t" 05/16/2013 01:39 PM-Deputy Ryan Burgett, being duly sworn according to law,served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant,to wit:Alissa M.Haines at 419 Eisenhower Drive, North Middleton Township, Carlisle, PA 17013. RYAN BU' D -1-7- *" SHERIFF COST:$50.78 SO ANSWERS, May 17,2013 RONR ANDERSON,SHERIFF ft:i titvf*.'SC 401 i:s+; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION File No. 2013-02712 Wells Fargo Bank, N.A., Amount Due $167,125.09 Plaintiff, Interest from 04/23/2013 to date of sale $11,201.39 vs. Costs Charles R. Haines, 111; Alissa M. Haines; Defendants. TO THE PROTHONOTARY OF THE SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale,contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County,for debt, interest and costs upon the following described property of the defendant(s): See Exhibit"A" attached 0 3 a o c. . _ C)"'g q :. p� Zuck ,Goldberg&Ackerman,LLC PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County,for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property(if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: r A�M3 Signature: � Print Name: Scott iet twe h ck, Esqui Fe Kimberly A. Bonner, Esquire Joel A. Ackerman, Esquire Ashleigh L. Marin, Esquire Ralph M. Salvia, Esquire Jaime R.Ackerman, Esquire Jana Fridfinnsdottir, 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 Zucker,Goldberg&Ackerman, LLC XFP-177142 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel, or lot of land situate along Eisenhower Drive in North Middleton Township, County of Cumberland and Commonwealth of Pennsylvania, and being more fully bound and described as follows: BEGINNING at a point on the southern right-of-way line of Eisenhower Drive at the northeast corner of Lot 48;thence along said right-of-way line N 54 degrees 33' 19" E a distance of 22.00 feet to a point at the northwest corner of Lot 50; thence along said lot S 35 degrees 26'41" E a distance of 166.21 feet to a point at the northeast corner of Lot 65; thence along said lot S 54 degrees 33' 19" W a distance of 22.00 feet to a point at the southeast corner of Lot 48; thence along said lot N 35 degrees 26'41" W a distance of 166.21 feet to a point,the point of BEGINNING. CONTAINING 3.657 square feet and being Lot 49 of Keystone Arms. ALSO BEING the same premises identified as Unit 49 in the Declarations of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 725, Page 2457 as amended by a First Amendment to Declaration of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 729, Page 478 ("Declaration"). Under and subject to the Declaration and to all covenants, conditions, encumbrances, easements and restrictions of record. HAVING thereon erected a dwelling house being known and numbered as 419 Eisenhower Drive, Carlisle, PA, 17013-1679. BEING the same premises which Keystone Arms Associates, LLC, a Pennsylvania limited liability company, by Deed dated June 15, 2010 and recorded June 23, 2010 in and for Cumberland County, Pennsylvania, as Instrument Number 201016589,granted and conveyed unto Charles R. Haines, III and Alissa M. Haines, husband and wife. Tax Map No.: 29-07-0467-055. Zucker, Goldberg&Ackerman, LLC XFP-177142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION C:. Plaintiff, NO.: 2013-02712 =^ vs. z c Execution No.: C ) Charles R. Haines, III; Alissa M. Haines; -< - ---. Defendant(s). p A r. 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 419 Eisenhower Drive, Carlisle, PA 17013-1679. 1. Name and Address of Owner(s) or Reputed Owner(s): CHARLES R. HAINES, III AND ALISSA M. HAINES, HUSBAND AND WIFE 419 Eisenhower Drive Carlisle, PA 17013-1679 2. Name and Address of Defendant(s) in the Judgment: CHARLES R. HAINES, III 419 Eisenhower Drive Carlisle, PA 17013-1679 ALISSA M. HAINES 419 Eisenhower Drive Carlisle, PA 17013-1679 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-177142 CITIBANK N A 701 East 601h Street N Sioux Falls, SD 57117 AND c/o Brittany Jan Suttell, Esq. Burton Neil &Associates PC 1060 Andrew Drive, Suite 170 West Chester, PA 19380 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 AND P.O. Box 2026 Flint, MI 48501-2026 AND 1901 E. Voorhees Street, Suite C Danville, IL 61834 AND 14501 George Carter Way#300 Chantilly,VA 20151 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 Zucker,Goldberg&Ackerman,LLC XFP-177142 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 419 Eisenhower Drive Carlisle, PA 17013-1679 UNKNOWN SPOUSE 419 Eisenhower Drive Carlisle, PA 17013-1679 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 KEYSTONE ARMS HOMEOWNERS ASSOCIATION c/o Boyd/Wilson Property Management, Inc. 600 Olde Hickory Road Lancaster, PA 17601 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 �� I ,3 BY: Dated: dw ] Scott A. Dietterick, Esquire; Ph 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 Attorneys for Plaintiff XFP-177142/11 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XFP-177142 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel, or lot of land situate along Eisenhower Drive in North Middleton Township, County of Cumberland and Commonwealth of Pennsylvania, and being more fully bound and described as follows: BEGINNING at a point on the southern right-of-way line of Eisenhower Drive at the northeast corner of Lot 48; thence along said right-of-way line N 54 degrees 33' 19" E a distance of 22.00 feet to a point at the northwest corner of Lot 50; thence along said lot S 35 degrees 26' 41" E a distance of 166.21 feet to a point at the northeast corner of Lot 65; thence along said lot S 54 degrees 33' 19" W a distance of 22.00 feet to a point at the southeast corner of Lot 48; thence along said lot N 35 degrees 26'41" W a distance of 166.21 feet to a point, the point of BEGINNING. CONTAINING 3.657 square feet and being Lot 49 of Keystone Arms. ALSO BEING the same premises identified as Unit 49 in the Declarations of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 725, Page 2457 as amended by a First Amendment to Declaration of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 729, Page 478 ("Declaration"). Under and subject to the Declaration and to all covenants, conditions, encumbrances, easements and restrictions of record. HAVING thereon erected a dwelling house being known and numbered as 419 Eisenhower Drive, Carlisle, PA, 17013-1679. BEING the same premises which Keystone Arms Associates, LLC, a Pennsylvania limited liability company, by Deed dated June 15, 2010 and recorded June 23, 2010 in and for Cumberland County, Pennsylvania, as Instrument Number 201016589, granted and conveyed unto Charles R. Haines, III and Alissa M. Haines, husband and wife. Tax Map No.: 29-07-0467-055. Zucker,Goldberg&Ackerman, LLC XFP-177142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2013-02712 Charles R. Haines, III; Alissa M. Haines; Defendants. ;.} r c) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO c ` PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 , t., ,.c Charles R. Haines, III 419 Eisenhower Drive Carlisle, PA 17013-1679 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 6/4/2014 at 10:00am prevailing local 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: 419 Eisenhower Drive, Carlisle, PA, 17013-1679 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 2013-02712 Zucker, Goldberg&Ackerman, LLC XFP-177142 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Charles R. Haines, III and Alissa M. Haines, husband and wife 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-177142 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 l Po I l6 BY:� 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 Attorneys for Plaintiff XFP-177142/11 200 Sheffield Street, Suite 101 Mountainside, N1 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoIdberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker,Goldberg&Ackerman, LLC XFP-177142 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel, or lot of land situate along Eisenhower Drive in North Middleton Township, County of Cumberland and Commonwealth of Pennsylvania, and being more fully bound and described as follows: BEGINNING at a point on the southern right-of-way line of Eisenhower Drive at the northeast corner of Lot 48; thence along said right-of-way line N 54 degrees 33' 19" E a distance of 22.00 feet to a point at the northwest corner of Lot S0; thence along said lot S 35 degrees 26' 41" E a distance of 166.21 feet to a point at the northeast corner of Lot 65; thence along said lot S 54 degrees 33' 19" W a distance of 22.00 feet to a point at the southeast corner of Lot 48;thence along said lot N 35 degrees 26' 41" W a distance of 166.21 feet to a.point, the point of BEGINNING. CONTAINING 3.657 square feet and being Lot 49 of Keystone Arms. ALSO BEING the same premises identified as Unit 49 in the Declarations of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 725, Page 2457 as amended by a First Amendment to Declaration of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 729, Page 478 ("Declaration"). Under and subject to the Declaration and to all covenants, conditions, encumbrances, easements and restrictions of record. HAVING thereon erected a dwelling house being known and numbered as 419 Eisenhower Drive, Carlisle, PA, 17013-1679. BEING the same premises which Keystone Arms Associates, LLC, a Pennsylvania limited liability company, by Deed dated June 15, 2010 and recorded June 23, 2010 in and for Cumberland County, Pennsylvania, as Instrument Number 201016589,granted and conveyed unto Charles R. Haines, III and Alissa M. Haines, husband and wife. Tax Map No.: 29-07-0467-OSS. Zucker,Goldberg&Ackerman, LLC XFP-177142 I WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 13-2712 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 CHARLES R.HAINES,III,ALISSA M.HAINES (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: $167,125.09 L.L.: $.50 Interest from 4/23/2013 to Date of Sale -- $11,201.39 Atty's Comm: Due Prothy: $2.25 Atty Paid: $199.53 Other Costs: Plaintiff Paid: Date:2/20/2014 f David D. Buell,Prothonota r (Sea]') By: Deputy REQUESTING PARTY: Name: ASHLEIGH L. MARIN,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.306799 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, vs. Charles R. Haines, 111; Alissa M. Haines; Defendant(s). . CIVIL DIVISION . NO.: 2013-02712 : Execution No.: AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 37() 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 419 Eisenhower Drive, Carlisle, PA 17013-1679. 1. Name and Address of Owner(s) or Reputed Owner(s): CHARLES R. HAINES, III AND ALISSA M. HAINES, HUSBAND AND WIFE 419 Eisenhower Drive Carlisle, PA 17013-1679 2. Name and Address of Defendant(s) in the Judgment: CHARLES R. HAINES, III 419 Eisenhower Drive Carlisle, PA 17013-1679 ALISSA M. HAINES 419 Eisenhower Drive Carlisle, PA 17013-1679 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 CITIBANK N A 701 East 60th Street N Sioux Falls, SD 57117 AND c/o Brittany Jan Suttell, Esq. Burton Neil & Associates PC 1060 Andrew Drive, Suite 170 West Chester, PA 19380 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 AND P.O. Box 2026 Flint, MI 48501-2026 AND 1901 E. Voorhees Street, Suite C Danville, IL 61834 AND 14501 George Carter Way #300 Chantilly, VA 20151 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION, ITS SUCCESSORS AND ASSIGNS 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 AND P.O. Box 2026 Flint, MI 48501-2026 AND 1901 E. Voorhees Street, Suite C Danville, IL 61834 AND 14501 George Carter Way #300 Chantilly, VA 20151 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 NORTH MIDDLETON AUTHORITY 10 East High St Carlisle, PA 17013 NORTH MIDDLETON TWP 2051 SPRING ROAD CARLISLE, PA 17013 AND 5 HILL DR. CARLISLE, PA 17013 ATTN ROBIN K. SOLLENBERGER CARLISLE AREA SCHOOL DISTRICT 623 W. Penn St. Carlisle, PA 17013 AND 5 HILL DR. CARLISLE, PA 17013 ATTN ROBIN K. SOLLENBERGER NORTH MIDDLETON AUTHORITY 240 CLEARWATER DRIVE CARLISLE, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 419 Eisenhower Drive Carlisle, PA 17013-1679 UNKNOWN SPOUSE 419 Eisenhower Drive Carlisle, PA 17013-1679 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 KEYSTONE ARMS HOMEOWNERS ASSOCIATION c/o Boyd/Wilson Property Management, Inc. 600 Olde Hickory Road Lancaster, PA 17601 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: BY: ZUCKER, GOLDBERG & ACK'ERMAN, LLC Scott A. Diette1ck, Esqui e; 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 XCP-177142/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 piece, parcel, or lot of land situate along Eisenhower Drive in North Middleton Township, County of Cumberland and Commonwealth of Pennsylvania, and being more fully bound and described as follows: BEGINNING at a point on the southern right-of-way line of Eisenhower Drive at the northeast corner of Lot 48; thence along said right-of-way line N 54 degrees 33' 19" E a distance of 22.00 feet to a point at the northwest corner of Lot 50; thence along said lot S 35 degrees 26' 41" E a distance of 166.21 feet to a point at the northeast corner of Lot 65; thence along said lot S 54 degrees 33' 19" W a distance of 22.00 feet to a point at the southeast corner of Lot 48; thence along said lot N 35 degrees 26' 41" W a distance of 166.21 feet to a point, the point of BEGINNING. CONTAINING 3.657 square feet and being Lot 49 of Keystone Arms. ALSO BEING the same premises identified as Unit 49 in the Declarations of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 725, Page 2457 as amended by a First Amendment to Declaration of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 729, Page 478 ("Declaration"). Under and subject to the Declaration and to all covenants, conditions, encumbrances, easements and restrictions of record. HAVING thereon erected a dwelling house being known and numbered as 419 Eisenhower Drive, Carlisle, PA, 17013-1679. BEING the same premises which Keystone Arms Associates, LLC, a Pennsylvania limited liability company, by Deed dated June 15, 2010 and recorded June 23, 2010 in and for Cumberland County, Pennsylvania, as Instrument Number 201016589, granted and conveyed unto Charles R. Haines, III and Alissa M. Haines, husband and wife. Tax Map No.: 29-07-0467-055. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, NO.: 2013-02712 vs. MOTION FOR ALTERNATE SERVICE Charles R. Haines, III; Alissa M. Haines; ON DEFENDANT PURSUANT TO Defendant(s). Pa.R.C.P. 430 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- 177142/jf < ) ,, r cam. I rnT� - i- C/)( rso c_, CL✓ =-:'� CD - Zucker,Goldberg&Ackerman,LLC XFP-177142 . . 7. An Internet person locator search provided no alternative address for Defendant(s). 8. Plaintiff conducted an investigation to determine the whereabouts of Defendant(s), Charles R. Haines, Ill but all sources indicated no alternative address other than that of the last known address being 419 Eisenhower Drive, Carlisle, PA 17013-1679. An affidavit of Plaintiffs counsel regarding the investigation taken to determine the whereabouts of Defendant is marked Exhibit "D", attached hereto and made a part hereof. 9. Consequently, Plaintiff has continued the Sheriff Sale scheduled for June 4, 2014 to in order to provide sufficient time to obtain alternate service of Defendant(s), Charles R. Haines, Ill. 10. Defendant(s) Charles R. Haines, Ill Defendant(s) cannot be located, therefore no concurrence was obtained. 10. There has been no other motion filed in this case. WHEREFORE, Plaintiff respectfully requests that this Honorable Court permit Plaintiff to serve Defendant(s), Charles R. Haines, Ill, with the Notice of Sheriff Sale, by instructing the Cumberland County Sheriff's Office to POST a copy of same on the Mortgaged Premises, being 419 Eisenhower Drive, Carlisle PA 17013-1679, and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 419 Eisenhower Drive, Carlisle, PA 17013-1679 and to 26 RUNYON DRTRENTON, NJ 08610-4133 with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 3129.2 and 430. ZUCKER GOLDBERG &ACKER A, LLC Dated: June 1 2014 S k, BY: AIAZIAgLIA 14/0 ) i cl n Al ir, 6 cot A. Dietterick, Esquire; PA I ID.#55650 I •erly 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 File No.: XFP-177142 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com EXHIBIT A . ' � .N|S|�|A: Em:F F'S OFFICE OF CUMBERLAND B ERLAND ~OUNTY Ronny R Anderson Sheriffi � �`"�«, 'JodyS Smith Chief Deputy Richa� VS�va� Solicitor mF.CewFTHE SHERIFF VeUoFoqgoBank. Case Nunbmrmy. 2013-2712ChadeoR. Heinos SHERIFF'S RETURN OF SERVICE 03C25/2014 05:44 PM -Deputy Ryan Burgett, 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 419 Eisenhower Drive, North Middleton -Township, Carlisle, PA 17013, Cumberland County. 03/31/2014 03:33 PM-Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Alissa M. Haines, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and DeonhpUon, in the above titled action, as"Not Found"at 419 Eisenhower Drive, Carlisle, PA 17013, defendant moved and did not leave a forwarding address. 03/31/2014 03:33 PM-Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Charles R. Haines, Ill , but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 419 Eisenhower Drive, Carlisle, PA 17013, defendant moved and did not leave a forwarding address. SHERIFF COST: $1,418.41 SO ANSWERS, . �r May2014 ^R> 23, �ON... RANDERGON. SHERIFF w»oun*Suit"Sheriff,��oft,Inc. EXHIBIT B y lkA .ar. ; . ?;:f11'. S y� 4 1.:`;.r"'''',V,':,,, Mt ;did r',\a. t, 4 a N + 1 i‘ ' ,, , . -0....,..-...... ,'-At,,.,,.•.,-. % 2"t ^` 4 =0 � "fir .•ij ., - - .:._ . . , a • s.' S a `s aN y" :::r A 5 i. }p N 6 `M t N ig •g .t --•O F n 4� ;5 ,1 16 SNS% i 6 -.Q } r G kl," 7 ' may® tu LL 1 N _ cad r,;-1�': ' ;'•'• H r0. S v c �* ,,, . f a "s : r ti_ ,-� , ♦' .. . yra.ey, 4..1N; ti T a 3 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • NO.: 2013-02712 V5, Charles R. Haines, III;Alissa M. Haines; Defendants. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO pENNSYLVANJA RULE OF CIVIL PROCEDURE 3129 Charles R. Haines, Ill 419 Eisenhower Drive Carlisle, PA 17013-1679 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 6/4/2014 at 10:00am prevailing local 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"Al., The LOCATION of your property to be sold is: 419 Eisenhower Drive,Carlisle, PA, 17013-1679 The JUDGMENT under or pursuant to which your property is being sold is docketed to; No.2013-02712 Zucker,Goldberg&Ackerman,LLC XFP-177142 THE NAME(S)OF THE OWNER(S)OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Charles R.Haines,III and Alissa M.Haines,husband and wife 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 I A NOTICE 0 THE TIME AND PLACE OF THE SALE *F YOUR PROP RTY,,,, 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 sHouj_p TAKE THIS PAPERTO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOWTQ FIND OUT WHERE YOU CAN GET FRU 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-177142 • • • 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 (/6\0 L.5 BY _______- Scott Scott A. Dietterick,Esquire; PALI).#55650 Kimberly A. Banner, Esquire; PA LD.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Mann, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D. #202946 Jaime R.Ackerman, Esquire; PALE).#311032 Jana Frldfinnsdottir, Esquire; PA I.D.#315944 Attorneys for Plaintiff XFP-177142/1I 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-177142 ' . Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel, or lot of land situate along Eisenhower Drive in NorthiddIeton Township, County of Cumberland and Commonwealth of Pennsylvania, and being more fully bound and described as follows: BEGINNING at a point on the southern right-of-way line of Eisenhower Drive at the northeast corner of Lot 48; thence along said right-of-way line N 54 degrees 33' I9" E a distance of 22.00 feet to a point at the northwest corner of Lot 50; thence along said lot S 35 degrees 26'41" E a distance of 166.21 feet to a point at the northeast corner of Lot 65; thence along said lot S 54 degrees 33' 19"Wadistance of Z2.00feet tuapoint at the southeast corner of Lot 48;thence along said lot N 35 degrees 26'41" W a distance of 166.21 feet to apoint,the point of BEGINNING. CONTAINING 3.657 square feet and being Lot 49 of Keystone Arms. ALSO BEING the same premises identified as Unit 49 in the Declaationsf Covent nd Restrictions for Keystone Arms, a planned community recorded in Book 725, Page 2457 as amended by a First Amendment to Declaration of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 729, Page 478 ("Declaration"). Under and subject to the Declaration and to all covenants, conditions,encumbrances, easements and restrictions of record. HAVING thereon erected a dwelling house being known and numbered as 419 Eisenhower Drive, Carlisle, PA, 17013-1679. BEING the same premises which Keystone Arms Associates, LLC,a Pennsylvania limited liability company, by Deed dated June 15, 2010 and recorded June 23, 2010 in and for Cumberland County, Pennsylvania, as Instrument Number 201016589,granted and conveyed unto Charles R. Haines, III and Alissa M. Haines, husband and wife. Tax Map No.: 29-07-0467-055. ~ Zucker,Goldberg&Ackerman,LIC v�_a xFP'177142 ; ~~~ ~ , .. . EXHIBIT C o cPs, 14, . -4 7 t13 tt 0 N 0 tEl tr C ...a Tr 0 /3 9) $ 3. "•• 13 CD ".1 tO t31 CP CP is- ••• tr tX) t.) .173 4.1 0 ' ;4 • ) So 41 •4 t .... 0 r ..i . t .. i 3 t.1 itt tt, ? . • 0 ••'::.: .::-. .-----.. _..... ''''.' - z,, ,.,... .,,,..._.......,,, ..._...._..................___,.,_......2..1...:....,... . ;: • . . . .0 .r....... ...----.........." CI TR 'A°I 01 IS .0''•••'---" ..,... 13 rn 73•S Tr •Z.C.0)•1'..... re) ...--................ .---,,..... ••a‘ AVP r tr .............................,-;4.0_.„..- •••• i 0. .... ..*:. .11, ''."--.•.------- ......* .... • -i..%.•.•..• ‘.31 ''''..--..--••••"—..„...- Trk z.0 02.-.^. a ........„..... --_,.• f- -:--- ...--- -----_-- .... - - N ,.....-•-'—......,..,...•-•--........„.,,,,,...1..•i....'...... 7:0, 0 ... ...- 12. ... ..• ... ta •"*".../........ . .0 ....... ---"--' • r 7.1 ...- ..- - - tr i 0 '''', ..-- -.. . ‘,...., 4. .. ..r.. V -.• ..- 'a ...1..00 ....0 ... , \ • " ... \. 'a -11 -5) (1) ...k 0 0 ..... '. • .... ...••• . ....••• :,...7. ., ,.... . 0 % ....%• , . t;..• 0 V ,• tr,.••• ' " 7. 11.• ..-••• • 14, St. t!, .. ...-"'"' .• '' .... 1N .....-• , t..Y3., \'"'' * ....t. -.. ... • . ....," ....• ... • , .........„ .. •.::: • • '..:.k cp ... .. ,,., ., .".:" --• .3;:"., ; . - .. -v., v. • 40.. T. • . --- . . ______ __ : . 4 ,4,-, , .,. . . \ t ______________----:-.----- , , _,,i, _ ....„ .„ ...., ......, A .....'°....,,...-!--."--- (11 0 Or/0°e o,s * ....,„.. , A 2'r) ' •' 1 % 0 443 Ili: -a---,...--- -07 %. •(...0'' tt% 111". .--_..:.: .1% ..... "I% I 0 13 3 0 • 0 •:..." a-----„,...0,0*.= to _.._ . •_... — In- ... _. ul..... .____,.. 0 0 (.; t a-0.-------- to • '4to to ' 9 , 2 :74 ' . 1 ti A % : r r•••, U.I A •. g ;, yt . .. . ..,.:r. .. A , ir 0 -4. ,, 7- .., tr % si ... 1, 1 . to ...-. .st -, 12 A3 1 A " V Ir tU S!, %.: CI' ,........ . . .. . 1 EXHIBIT D . ' UN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 2013-02712 Charles R. Haines, III; Alissa M. Haines Defendants. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Jana Fridfinnsdottir, Esquire, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and says that Plaintiff, or counsel for Plaintiff, conducted an investigation to determine the whereabouts of Defendant(s), which included, but was not limited to searches of the following records: (X) Records of the U.S. Postmaster (X) Internet Person Locator Records (X) Credit Report Agency. (X) Telephone Directory (X) Records of the County Recorder of Deeds and Prothonotary Finally, Affidavit deposes and says that if Defendant(s) is/are not located at the address uncovered by this investigation,the whereabouts of Defendant(s) is/are unknown to Plaintiff. ZUCKER,GO : &ACKERMAN, 1.1LC By: • , NAIVY0‘ , Dated: June 2014 Jana Fridfinns•ottir, fsq., PA. ID#315944 Atty File No.: XFP-177142 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908)233-1390 FAX COMMONWEALTH OF PENNSYLVANIA Sworn to and subscribed before me this NOTARIAL SEAL KATHERINE N MILLER day of Z.Un ,2014. Notary Public UPPER ALLEN TWP, CUMBERLAND COUNTY 4 . My Commission Expires May 7.2017 Notary Public My Commission Expires: • Page 1 of 2 GI' LexisNexis. ( Accurine for Collections Person Search Results Records:1 to 5 of 5 Search Terms Used - SSN: 4.11.11111 All Full Name SSN Address Phone Next Steps i• R CHARLES 326 RUNYON DR 609-888-0667-EDT R H CHARLES JR TRENTON NJ 08610.4133 Aug 13-Mar 14 CHARLES HAINES Dec 1999-Feb 2014 '�Active Phone CHARLES R HAINES #4/ Probable current address HAINES C CHARLES R HAINES III DOB:1982 Age:32 Gender:Male 'View Sources(-4) 0 Setup Alert We Also Found: ❑ Phones Plus ❑ Property Records ❑ Email Address 2• R CHARLES 3 419 EISENHOWER DR 717-856-5132-EDT R CHARLES III CARLISLE PA 17013.1679 May 13-Jun 13 CHARLES HAINES Jun 2010.Dec 2013 Possible Cell Phone CHARLES R HAINES CHARLES R HAINES CHARLES R HAINES 3 717-743-7373-EDT CHARLES R HAINES III Jan 13 DOB:1982 Possible Cell Phone Age:32 CHARLES HAINES Gender:Male "View Sources(-6) tSetup Alert 3. R CHARLES 3 30 SUMMERFIELD DR 717-440-4609-EDT R CHARLES III 111111MCARLISLE PA 17015-6931 May 12-Aug 12 CHARLES R HAINES 3 Mar 2009-Aug 2010 Possible Cell Phone CHARLES R HAINES III CHARLIE HAINES DOB:1982 Age:32 Gender:Male "View Sources(-4) c Setup Alert 4• R CHARLES 330 SUMMER LN CHARLES R HAINES MECHANICSBURG PA 17050-4147 CHARLES R HAINES III Mar 2009-Jul 2009 DOB:1982 Age:32 Gender:Male 'View Sources(-4) Setup Alert 5. R CHARLES 3 4610 BRIAN RD 717-856-5132-EDT R CHARLES III MECHANICSBURG PA 17050-4612 Mar 07-Jan 09 CHARLES R HAINES 3 Sep 2004.Oct 2008 Possible Cell Phone CHARLES R HAINES III CHARLES HAINES DOB:1982 717-816-6275-EDT Age:32 Mar 07-Aug 11 Gender:Male Possible Cell Phone 'View Sources(-4) CHARLES HAINES ]:{ Setup Alert 717-413-1559-EDT Sep 13 Possible Cell Phone CHARLES HAINES Records:1 to 5 of 5 Your DPPA Permissible Use:Civil,Criminal,Administrative or Arbitral Proceedings https://secure.accurint.com/app/bps/misc 3/13/2014 Page 2 of 2 Your GLBA Permissible Use:Legal Compliance Copyright©2014 LexisNexis.All rights Reserved. Terms&Conditions I Privacy&Security https://secure.accurint.com/app/bps/misc 3/13/2014 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.:2013-02712 vs. Charles R.Maines, HI;Alissa M.Haines; •• Defendants. Notice of the Date of Continued Sheriff Sale , - The Sheriff Sale scheduled for June 4,2014 at 10:00 AM in the above captioned matter hasbeen continued until August 6, 2014 at 10:00 AM. ZUCKER, GOLDBERG & •. RMAN LLC rBY: Dated'.f �i Scott A. Diette ck,Esquire; PA I.D. #55650 fV,'o ( 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 n- lana Frldfinnsdottir,Esquire;PA LD.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-177142/chr 200 Sheffield Street,Suite 101 Mountainside, Ni 07092 (908) 233-8500;(908) 233-1390 FAX Email; Office@zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XFP-177142 vl IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 2013-02712 vs. Charles R. Haines, Ill; Alissa M. Haines; Defendants. ORDER OF COURT AND NOW,this 2 S. day of , 2014, upon consideration of Plaintiff's Motion for Alternate Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Notice of Sheriff Sale on Defendant(s), Charles R. Haines, III, by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 419 Eisenhower Drive, Carlisle PA 17013-1679, and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 419 Eisenhower Drive, Carlisle, PA 17013-1679 and to 26 RUNYON DR,TRENTON, NJ 08610-4133 with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 3129.2 and 430. BY THE COURT: -sGs J. copy rte., ( � N A411/ is ck do141z `/ s py IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2013-02712 Charles R. Haines, Ill; Alissa M. Haines; - CD, Defendants. -m �- ca -n c_ rn; r'rr; C ' cam -‹ )' --1 --+ -11 PRAECIPE TO REINSTATE COMPLAINT v� = ziri F9_ c TO THE PROTHONOTARY: Please mark the Complaint in Mortgage Foreclosure filed at the above -captioned term and number reinstated. Dated: (Li OW' II.--7SpdaH� By: ZUC,'R,J QLDERG & ACKERMAN, LLC Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XFP-177142/jbenn 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com e)/(A4 &)q3q Z-41- 3US'to • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Charles R. Haines, III; Alissa M. Haines; Defendants. NO.: 2013-02712 Notice of the Date of Continued Sheriff Sale r.- —ts The Sheriff Sale scheduled for August 6, 2014 at 10:00 AM in the above captioned matter has been continued until October 1, 2014 at 10:00 AM. BY: Dated: July 31, 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC Christina Covert, Legal Assistant File No.: XFP-177142 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff No.: 2013-02712 vs. Charles R. Haines, III; Alissa M. Haines; 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. 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 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- 177142/nfe CO Zucker, Goldberg & Ackerman, LLC XFP-177142 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, vs. Charles R. Haines111; Alissa M. Haines; Defendants. CIVIL DIVISION NO.: 2013'03712 Pa.R.C.P. RULE AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST 1, Nixon Feliz, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Welis Fargo Bank, N.A., being duiy sworn according to iaw 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 lnterest as follows: I. Defendant(s) Charles R. Haines, Ill and Alissa M. Haines, husband and wife, is/are the record owners of the real property. 2. Pursuant to the Order of Court dated June 25, 2014, the Sheriff of Cumberland County posted Plaintiff's Notice of Sheriffs Sale, at the address of the mortgaged premises, being 419 Eisenhower Drive, Cariisie, PA 17013-1679, on or about August 6, 2014. A true and correct copy of said Order of Court and Proof of Posting are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about July 3, 2014, defendant Alissa M. Haines was served with Plaintiffs Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberiand County, at the address of 6 Buchannon Drive, Apt 105, Carlisle, PA 17013. A true and correct copy of said Notice and Return of Service are marked Exhibit "B", attached hereto and made a part hereof. 4. Pursuant to the Order of Court dated June 25, 2014, Plaintiff s counsel served Defendant Charles R. Haines, III with Plaintiffs Notice of Sheriff's Sale, via Certified Mail no signature required and via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing, at the addresses of 419 Eisenhower Drive, Carlisle, PA l7O13'1679and 26Runyon Dr,Trenton, NJOB61O'4133,onmrabout July 14,3O14. True and correct copies of said Notices and Proofs of Mailing are marked Exhibit "C", attached hereto and made a part hereof, Zucker, Goldberg & Ackerman, LLC 5. On or about May 5, 2014, Plaintiffs counseserved alt other parties in interest with Plaintiff's Notice of Sherifrs 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 "D", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendants/Owners and all other Parties of Interest were served with Plaintiffs Notice of Sheriff's Sate of Real Property in accordance with Pa.R.C.P. 3129.2. ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff Dated: September /IZ� Sworn to and subscribed before me This day of. �6--./oo^~2014 - ubJk MY COMMISSION EXPIRES: Paralegal/Legal Assistant JANELL �?��r ��e �— '�U�U�OFNEWJE0SEY ID # 2364963 My Commission Expires 10/1J/20Y7 Zucker, Goldberg & Ackerman, LLC EXHIBIT A Zucker, Goldberg & Ackerman, LLC XFP-177142 Haines; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Charles R. Haines, III; Alissa M. Defendants. NO.: 2013-02712 ORDER OF COURT AND NOW, this .,2 stay of ."LLJ�3., , 2014, upon consideration of Plaintiffs Motion for Alternate Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Notice of Sheriff Sale on Defendant(s), Charles R. Haines, III, byinstructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 419 Eisenhower Drive, Carlisle PA 17013-1679, and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 419 Eisenhower Drive, Carlisle, PA 17013-1679 and to 26 RUNYON DR, TRENTON, NJ 08610-4133 with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 3129.2 and 430. BY THE COURT: Ronny R Anderson Sheriff Jody S Smith Chief Depu Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF TI4E smv.rIFF Wells Fargo BankN.A. vs. Charles R. Haines, Ill (et al.) Case Number 2013-2712 SHERIFF'S RETURN OF SERVICE 03/25/2014 05:44 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Wr, Notice and Descrand Sale Handbill in the above titled action, upon the prody|000hedst419 Eisenhower Drive, North Middleton - Township, Carlisle, PA 17013, Cumberland County. 03/31/2014 03:33 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Alissa M. Haines, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 419 Eisenhower Drive, Carlisle, PA 17013, defendant moved and did not leave a forwarding address, 03/31/2014 03:33 PM - Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Charles R. Haines, Ill , but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at419Eisenhower Drive, Carlisle, PA17O13. defendant moved arid did not leave a forwarding address. 06/03/2014 As directed by Jaime R Ackerman, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/6/2014 0703/2014 03:05 PM - Deputy Dawn Kell, 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: Alissa M. Haines at 6 Buchannon Drive, Apt 105, Carlisle, PA 17013, Cumberland County. 08/01/2014 As directed by Jaime R Ackerman, Attorney for the P|ointiff, Sheriffs Sale Continued to 10/1/2014 0806/2014 03:28 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Charles R. Haines, 01, pursuant to Order of Court by "Posting" the premises located at 419 Eisenhower Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. SHERIFF COST: $1,47719 SO ANSWERS, September 22, 2014 RONNYRANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc, EXHIBIT B Zucker, Goldberg & Ackerman, LLC XFP-177142 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY �cultor OFFICE OF :FRE ERERIFF Wells Fargo BankN.A. vs. Charles R. Haines, Ill (et al.) Case Number 2013-2712 SHERIFF'S RETURN OF SERVICE 03Q5/2014 05:44 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by posting true copy of the requested Real Estate Writ, Notice and Dand Sale Handbill in the above titled action, upon the property located at 419 Eisenhower Drive, North Middleton - Township, Carlisle, PA 17013, Cumberland County. 03/31/3014 03:33 PM - Ronny R. Anderson, Sheriff, being duly sworn according to lawstates that he made a diligent search and inquiry for the within named Defendant, to wit: Alissa M. Haines, but was unable to locate the Defendant in his bailiwick, He therefore returns the wthin Real Estate Writ, Notice and Deochption, in the above titled action, as "Not Found" at 419 Eisenhower Drive, Carlisle, PA 17013, defendant moved and did not leave a forwarding address. 03/31/2014 03:33 PM - Ronny R. Anderson, Sheriff, being duly sworn according to Iaw, states that he made a diligent search and ini for the within named Defendant, to wit: Charles R. Haines, 111 , but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 419 Eisenhower Drive, Carlisle, PA 17013, defendant moved and did not leave a forwarding address. 08/03/2014 As directed by Jaime R Ackerman, Attorney for the Plaintiff, Sheriffs Sale Continued to 8/6/2014 07/03/2014 03:05 PM - Deputy Dawn Kell, 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: Alissa M. Haines at 6 Buchannon Drive, Apt 105, Carlisle, PA 17013, Cumberland County. 08/01/2014 As directed by Jaime R Ackermar, Attorney for the Plaintiff, Sheriffs Sale Continued to 10/1/2014 08/06/2014 03:28 PM - Deputy Dawn Kell, being duly sworn according to law, served the reted Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Charles R. Haines, Ill, pursuant to Order of Court by "Posting" the premises located at 419 Eisenhower Drive, North Middleton Township, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. SHERIFF COST: $1,477.19 SO ANSWERS, September 22, 2014 RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft, Inc. EXHIBIT C Zucker, Goldberg & Ackerman, LLC XFP-177142 Zucker, Gbeep PO Box 219 a Ackerman, U.c iainside, NJ 070924219 uj/hij1/iL/lijIiII/i///i// r iill Charles ltrtrIrltllirrrltrlllrrl 2ii40T14102 R Haines, 1I1 rlrr4rltllltltlrl►rllll0140 26 Runyon Dr Trenton, NJ 08610.4133 PANOS8 Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, vs. Charles R. Haines, 111; Allssa M. Haines; Defendants. Charles R. Haines, III 419 Eisenhower Drive Carlisle, PA 17013-1679 And 26 Runyon Dr Trenton, Ni 08610-4133 TAKE NOTICE: CIVIL DIVISION NO.: 2013-02712 AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF gyiL PROPEDUR6 129 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 October 1, 2014, at 10:OOam prevailing local 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: 419 Eisenhower Drive, Carlisle, PA, 17013-1679 The JUDGMENT under or pursuant to which your property 15 being sold is docketed to: No. 2013-02712 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Charles R. Haines, III; Alissa M. Haines 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, S. _N!TICE OF TH ,TIN) P1.A! E O ESHE-SALE:OF YC1.LI.R.: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.'('HI p PER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE ET FORTH BELOW. TO FIND OUT WHERE,YQU,CAN ET 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 Sheriffs 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 Sheriffs Deed Is delivered. 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. Dated: July ZUCKER GOLDBERG & ACKERMAN, LLC , 2014 BY: Scott A. Dietterlck, Esquire; A I,D, #55650 Kimberly A. Bonner, Esquire; PAID. #89705 Joel A. Ackerman, Esquire; PA 1.0. #202729 Ashleigh Levy Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA1.D. #311032 Jana Fridfinnsdottlr, 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 File No.: XFP-177142 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA ORDER OF COURT Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel, or lot of land situate along Eisenhower Drive in North Middleton Township, County of Cumberland and Commonwealth of Pennsylvania, and being more fully bound and described as follows: BEGINNING at a point on the southern right-of-way line of Eisenhower Drive at the northeast corner of Lot 48; thence along said right-of-way line N 54 degrees 33' 19" E a distance of 22.00 feet to a point at the northwest corner of Lot 50; thence along said lot S 35 degrees 26' 41" E a distance of 166.21 feet to a point at the northeast corner of Lot 65; thence along said lot S 54 degrees 33' 19" W a distance of 22.00 feet to a point at the southeast corner of Lot 48; thence along said lot N 35 degrees 26' 41" W a distance of 166.21 feet to a point, the point of BEGINNING. CONTAINING 3.657 square feet and being Lot 49 of Keystone Arms. ALSO BEING the same premises identified as Unit 49 in the Declarations of Covenants and Restrictions for Keystone Arms, a planned community recorded In Book 725, Page 2457 as amended by a First Amendment to Declaration of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 729, Page 478 ("Declaration"), Under and subject to the Declaration and to all covenants, conditions, encumbrances, easements and restrictions of record. HAVING thereon erected a dwelling house being known and numbered as 419 Eisenhower Drive, Carlisle, PA, 17013-1679. BEING the same premises which Keystone Arms Associates, LLC, a Pennsylvania limited liability company, by Deed dated June 15, 2010 and recorded June 23, 2010 in and for Cumberland County, Pennsylvania, as Instrument Number 201016589, granted and conveyed unto Charles R. Haines, III and Alissa M. Haines, husband and wife. Tax Map No.: 29-07-0467-055. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaitf vs. Charles R. Haines, Ill; Alissa M. Defendants. NO.: 2013-02712 ORDER OF COURT AND NOW, this .Zoay of JLI i , 2014, upon consideration of Plaintiff's Motion for Alternate. Service, It is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Notice of Sheriff Sale on Defendant(s), Charles R. Haines, III, by instructing the Sheriff of Cumberland County to POST.a copy of same on the Mortgaged Premises, being 419 Eisenhower Drive, Carlisle PA 17013-1679, and by mailing a copy via Certified Mail, no signature required and First Class U.S. Mail,, Postage Prepaid to 419 Eisenhower Drive, Carlisle, PA 17013-1679 and to 26 RUNYON DR, TRENTON, NJ 08610-4133 with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 31292 and:430. BY THE COURT: Zucker, Goldberg & Ackerman, LLC PO Box 1219 Mountainside, NJ 07092-1219 111111\11\11 „ 20140714-102 sillillulrli�HI II11n„1In'Ilu,l�luI,iIIj9I'il�IIIIIhuih Charles R. Haines, IN 419 EISENHOWER DR CARLISLE, PA 17013-1679 PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. Plaintiff, vs. Charles R. Haines, III; Alissa M. Haines; Defendants. Charles R. Haines, Ili 419 Eisenhower Drive Carlisle, PA 17013-1679 And 26 Runyon Dr Trenton, NJ 08610-4133 TAKE NOTICE:: CIVIL DIVISION NO,: 2013-02712 AMENDED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO P N LVANIARU EOF i 'R• Es R That the Sheriff's Sale of Real Property (Real Estate) will be held at Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on October 1, 2014, at time, THE PROPERTY TO BE 5OLD is delineated in detail in a legal description of the measured boundaries of the property, together with a brief mention other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 419 Eisenhower Drive, Carlisle, PA, 17013-1679 the Cumberland County 10:OOam prevailing local consisting of a statement of the buildings and any The JUDGMENT under or pursuant to which your property Is being sold is docketed to: No. 2013-02712 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Charles R. Haines, III; Alissa M. Haines 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, T,Hj.S PAP.ER.J.S.A N 1T. l OF THE .TVE AND PLACE OF THE §ALE :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. Y OULD TAKE HIS PER T • YOUR. LAWYER AT ONC 6• T s OR ' H •. .0 .FICE ORTH BELOW.TO FIND OUT HER Y 0 P E 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 Sheriffs 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. 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 +1, 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. Dated: July q , 2014 ZUCKER GOLDBERG & ACKERMAN, LLC BY: tr4:. 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.Q. #202946 Jaime R. Ackerman, Esquire; PA1.D. #311032 Jana Fridfinnsdottir, Esquire; PA LD. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA LD. #317226 200 Sheffield Street, Suite 101 Mountainside, Ni 07092 File No.: XFP-177142 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA ORDER OF COURT Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel, or lot of land situate along Eisenhower Drive in North Middleton Township, County of Cumberland and Commonwealth of Pennsylvania, and being more fully bound and described as follows: BEGINNING at a point on the southern right-of-way line of Eisenhower Drive at the northeast corner of Lot 48; thence along said right-of-way line N 54 degrees 33' 19" E a distance of 22.00 feet to a point at the northwest corner of Lot 50; thence along said lot S 35 degrees 26' 41" E a distance of 166.21 feet to a point at the northeast corner of Lot 65; thence along said lot S 54 degrees 33' 19" W a distance of 22.00 feet to a point at the southeast corner of Lot 48; thence along said lot N 35 degrees 26' 41" W a distance of 166.21 feet to a point, the point of BEGINNING. CONTAINING 3.657 square feet and being Lot 49 of Keystone Arms. ALSO BEING the same premises identified as Unit 49 in the Declarations of Covenants and Restrictions for Keystone Arms, a planned community recorded In Book 725, Page 2457 as amended by a First Amendment to Declaration of Covenants and Restrictions for Keystone Arms, a planned community recorded in Book 729, Page 478 ("Declaration"), Under and subject to the Declaration and to all covenants, conditions, encumbrances, easements and restrictions of record. HAVING thereon erected a dwelling house being known and numbered as 419 Eisenhower Drive, Carlisle, PA, 17013-1679. BEING the same premises which Keystone Arms Associates, LLC, a Pennsylvania limited liability company, by Deed dated June 15, 2010 and recorded June 23, 2010 in and for Cumberland County, Pennsylvania, as Instrument Number 201016589, granted and conveyed unto Charles R. Haines, Ili and Alissa M. Haines, husband and wife. Tax Map No.: 29-07-0467-055. Haines; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A, CIVIL DIVISION Pl iiti Iff; VS. Charles R. Haines, III; Alissa M. Defendants. ORDER OF COURT AND NOW, this .2S ay of J..t.A;><+,,_,., NO.: 201342712 , 2014, upon consideration of Plaintiffs Motion for Alternate.Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Notice of Sheriff Sale on Defendant(s); Charles R. Haines, Iii, by instructing the Sheriff of Cumberland County to POST.a copy of same on the Mortgaged Premises, being 419 Eisenhower Drive, Carlisle PA 17013-1679, and by mailing a copy via Certified Mail, no signature required and First Class U.S. Malt,. Postage Prepaid 10419 Eisenhower Drive, Carlisle; PA 17013-1679 and to 26 RUNYON DR, TRENTON, NJ 08610-4133 with said service being valid and complete upon such posting and mailing in accordance- With ccordancewith Pa.R.C.P. 31292 and:430. BY THE COURT: NOS AMENDED OC CERT SENT UNITED STATES POSTAL SERVICE Certificate 0 Mailing '. U.S.POSTAGE»PRnler s L 1. �"rtr ZIP 0.7092 $ 0020 02 1 to 0001387430 JUL 14 21014 To pay fee, affix stamps or meter Postalehere. This Certificate of Mailing provides evidence that map has bean presented to USPS* for mailing. This form may be used for domestic and International mall. H0m' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 T°t Charles R. Haines, III 419 Eisenhower Drive Carlisle, PA 17013-1679 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES COSTAL SERVICE Certificate Of Mailing This Certificate of Ma Ping provides evidence that mall has been presents and international mail. From; Scott A. Dietterick, Esquire ng. This form may be used for domestk c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/wn TEAM- C T°t Charles R. Haines, 111 26 Runyon Dr Trenton, NJ 08610-4133 County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 ►ioe Vi lnrocbLecloo0 mt. Lo Z60L0 dIZ o0Ze1a00 $ J S3MaljaNild «3OV1SOd sS'fl To pay fee, affix stamps or meter Postage here. Page 1 of 1 EXHIBIT D Zucker, Goldberg & Ackerman, LC XFP-177142 NTL Page 1 of 12 UNITED STATES POSTAL SERVICE Certificate 0 Mailing This Certificate of Melling provides evidence that matt 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, Ni 07092 XFP-177142/nfe TEAM- C --",.111111111111111iing0 CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 County of P.O.: CUMBERLAND PS Form 3817, AprIl 2007 P5N 7530-02-000-9065 r, UNITED STATES POSTAL SERVICE 11•11111111MMIO "meow Imo" Amor ZIP 07092 $ 001.200 021r 0001387430 MAY 05 2014 To pay fee effle ;tamps or meter postale here. Postmark Here Certificate Of Mailing Thls Certificate of MaMne provides evidence that mall hes 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-177142/nfe TEAM- C To' 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 OZ SO AM0CPC8 CI 000 00Z.100 $ AA' LO Z6OLO clIZ 1,10) 4=4Trafil .011 To pay fee, affix damps or meter postai, here. rk Here NTL Page 2 of 12 UNITED STATES POSTAL SERVICE Certificate 0 Mailing U.S. POSTAGE» PIT1cY eawEs This Certificate of Mailing provides evidence that mall has bun presented to USPS for mailing. This form may be used for do MI slit and International moi. F"int Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 °' UNKNOWN TENANT OR TENANTS 419 Eisenhower Drive Carlisle, PA 17013-1679 XFP-177142/nfe TEAM- C ZIP 07092 $ 001.200 02 1P 0001387430 MAY 05 2014 To pay fee, affix stamps or meter portage here. Postmark MAY 0 5 20iii County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 .UNITED STATES Mifill POSTAL SERVECEm 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 and International mall. Fromr Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman LC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C T°` CITIBANK N A 701 East 60th Street N Sioux Falls, SD 57117 County of P.O.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 6101, 50 / W0CPL8£1 00Zii ci $ Z6OL araarerr.x+'r�ll�� carw(Tla ARfJ1ld C(IC)VI SOd'SYl To pay fee, affix stamps or meter postage here., Postmark Here NTL Page 3 of 12 UNITED STATES POSTAL SERVICE Certificate Of Mailing U.S. fAOE}af This Grllikate of Melling provides evidence that mall hu been presented to USPS' for moiling. 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 °' CITIBANK N A c/o Brittany Jan Suttell, Esq. Burton Neil & Associates PC 1060 Andrew Drive, Suite 170 West Chester, PA 19380 ZIP 07092 $ YV 1eienO 02 111 00013 87430 MAY 05 2014 To pay fee, affix stamps or mater pottage here. County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 r, UNITEDSTIITES POSTAL SERVICE Certificate Of Mailing TMs Certificate of hiding provides evidence that mall has been presented to USPS' for matling, This form may be used for domestic and International meg, t;°mt Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C To: NORTH MIDDLETON AUTHORITY 240 CLEARWATER DRIVE CARLISLE, PA 17013 County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9055 1102 SO AYW0£4LOC40O0 o0Z'I'OQ . Z6ai.n ii .imeesar•.�.�a. AillerenanirOrifirran�".=r 1 a� A ikf «Rf)krl.SOd s n To pup he, alfbr stamps or meta portage here. Pox NTL Page 4 of 12 UNITED STATES POSTAL SERVICE Certificate 0 Mailing This Certificate of Meiling provides evidence that melt has been presented to USPS for maillr4. 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-177142/nfe TEAM- C U.S. POSTAGE* PITNEY BOWES orti.arae i .P./r= ram' ZIP 07092 $ 001.200 02 114 00013874.30 MAY 05 2014 To pay fee, 'lifts stamps or meta postage hare. T°' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION, ITS SUCCESSORS AND ASSIGNS 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE Certificate Of Mailing TMs Cartiflate of Mailing provides evidence that mall has been presented to UPS* for malting. This form may be used for domeatk and Intematlonal map. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C Tc" MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION, ITS SUCCESSORS AND ASSIGNS P.O. Box 2026 Flint, MI 48501-2026 County of P.Q.: CUMBERLAND 1,$ For PIOZ SO AYW0£t'LB£t000 00Z-1,00 $ Zso`LLO dI S3MOB A3Nlad «3JV1SOd 's71 PSN 7530-02-000-9065 Postmark Here To pay Is, affix stamps ormeter pastae hen. Postmark Here NTL Page 5 of 12 or, UNITED STATES POSTAL SERVICE® U.S. POSTAGE* PITNEY BOWES ZIP 0.7092 $ 001.200 02 111 Certificate 000 1387430 MAY 05 2014 Mailing This Certificate of MaU9 provides evidence that mall has been prarented to USPS' for malUna. This 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-177142/nfe TEAM- C TO` MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION, ITS SUCCESSORS AND ASSIGNS 1901 E. Voorhees Street, Suite C Danville, IL 61834 County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 r UNITED STATES POST/1LSERVKE® Certificate Of Mailing To pay fee, of l x Ramps or meter postage hare, This Certificate of Melling provides evidence that mall has been presented to end Intemettonal malt. From: Scott A. Dietterick, Esquire . Thi form may ba ured for domestic c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C To: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION, ITS SUCCESSORS AND ASSIGNS 14501 George Carter Way #300 Chantilly, VA 20151 County of P.Q.: CUMBERLAND tit0Z SO AVWO£ 00Z'1.00 $ .rAy �YaaaWlaaaa� fleelartle J S3M00 X3e111d «3V.I SOd s rl 007 PSN 7530-02-000-9065 ostmark Here To pay fee, affix stamps or meter postage here. Postm NTL Page 6 of 12 UNITED STATES POSTAL SERVICE Certificate Of Mailing U.S. POSTAGE) PITNEY Bowes This Certificate of Mang provides evidence that ma, has been presented to USW for mailing. This form may bo used for domestic and Imernetlonel mail, From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C ZIP 0.7092 $ 001.200 02 1,1 000138.74.30 MAY 05 2014 To pay fee, affix stamps or mater putage here, To: KEYSTONE ARMS HOMEOWNERS ASSOCIATION PaztmancHere c/o Boyd/Wilson Property Management, Inc. 600 Olde Hickory Road Lancaster, PA 17601 County of P.Q.: CUMBERLAND PS Form 3817, AprII 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE!, Certificate Of Mailing This Certificate of Mailing provides evidence that TO heti boon presented to USPSo for milling. Mb form may be used for dome' tic and Internotlonel moil, Frain: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C Tet CARLISLE AREA SCHOOL DISTRICT 5 HILL DR. CARLISLE, PA 17013 ATTN ROBIN K. SOLLENBERGER County of P.Q.: CUMBERLAND To per foe, effbt stamps or meter postage here. PS Form 3817, AprII 2007 PSN 7530.02-000-9065 ►'IOZ S0 A VIN0€tL 00Z100 $ ZOO20 d12 +e+aArtimoweas S3M08A3NLki«39VLSOd r► • Postmark Here NTL Page 7 of 12 UNITED STATES // POSTAL SERVICE Certificate 0 Mailing U.S. POSTAGE) PITNEY BOWES This Certificate of Mailing provides evidence that mall has been presented to USPS' for mailing. Thh form may M used for dameslk and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C Ta' CARLISLE AREA SCH 623 W. Penn St. Carlisle, PA 17013 OL D STR ZIP 07092 $ 001 e20© 02 tri 0001387430 MAY 05 2014 To pay fee, affix stamps or meter postage here. Postmark Here County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9055 UNITED STATES POSTAL SERV10E6 Certificate Of Mailing This Certfflcate of MuUing provides evidence that mall has bean pniented to USPS' for mailing. This form may be used for dome ilk and International mail. From Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C To: NORTH MIDDLETON TWP 5 HILL DR. CARLISLE, PA 17013 ATTN ROBIN K. SOLLENBERGER County of P.Q.: CUMBERLAND 010;~ SO AYV9 0 00Z°I►0O $ Z8OL de.......r..�e. 411111110. S dE<3DVIS d *ST) PS Form 3817, April 2007 PSN 7530-02.000-9065 NJ To pay fee, affix stamp or meterposgp here. NTLPage 8of12 UNITED STATES POSTAL SERVICE* Certificate Of Mailing ` U.S.# OSTAGE»,IPITNEY COWES tw ' •.a..a..wr ---rev ZIP 07092 $ 001 20 ° 02 1rt 0001387430MAY 05 2014 This Certificate of Mailing provides evidence that mail hes been presented to USPS' for mailing. This form maybe used for domestic and International mall. "fl" Scott A, Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 MatinraIrra te; NJ -0092. To pay lea, affix stamps or meter pastas. hare. XFP-177142/nfe TEAM- C To' NORTH MIDDLETON TWP 2051 SPRING ROAD CARLISLE, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 �� UNITED STATES I/ POSTAL SERVICE* Certificate Of Mailing This Certificate of Meiling provides evidence that melt hes been presented to USPS' for malting, This form may be used for domestk and Unemotional mall. Fr°"" Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C T°t NORTH MIDDLETON AUTHORITY 10 East High St , Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, AprIl 2007 PSN 7530-02-000-9065 vto: S0 AVIN OCI-Lin 1.000 00Z.[.00 $ Z60L0 M Z Postmark Here To pay fee, affix stamps or meter postop hen. Postmark Here NTL Page 9 of 12 „r„+ UNITED STATES MIN POST/JL SERVICED Certificate 0 Mailing Thb Certlfkate of Mal/Ing provider evidence that mall has been presented to USPS for mailing. ThIt 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-177142jnfe TEAM- C T°' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION 14501 George Carter Way #300 Chantilly, VA 20151 U.S. POSTAGE» Paw( emu ZIP 07092 C 001200 02 1V 0001387430 MAY 05 2014 To pay fee, affix stamps or meter portage here. County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POST/1L SERVICEm Certificate Of Mailing This Certificate of Mallin provides evidence that mall has been presented to and International mall. From; Scott A. Dietterick, Esquire PS° for milling. This form may be used for domestic c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C T°' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION 1901 E. Voorhees Street, Suite C Danville, IL 61834 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 171-0Z 90 AVIA OCt'L9Et000 00Z. 400 $ ?sono aizo Postmark Here To pay fee, affix stamps or meter postage hers. Postmark Here NTL Page 10 of 12 UNITED STATES POSTAL SERVICE Certificate 0 Mailing This Certificate of Mailing provides evidence that mall hu been presented to USPS* for mailing. This form may be used for domestic and International mall. Front Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C U.S. POSTAGE »» FrTP€Y Bows ZIP02 007092 $ 001.200 0001387430 MAY 05 2014 To pay fee, Ott stamps or meter postage hen. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION P.O. Box 2026 Flint, MI 48501-2026 County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE Certificate Of Mailing TMs Certificate of Ma Moo provides evidence flit mall has been presented to USPS* for mating. Tho form mey be used for domestic end intemetional mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C T0: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WALKER JACKSON MORTGAGE CORPORATION 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 County of P.O.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 PIOZ SQ AVM O£6L8£t000 00Z. 100 $ Z60L0 dIZZ 4=i��ws i 7 SgAi06A3NLd39V1SOd'S71 Postmark Here To pay fie, aftbt stamps or meter postage here. Postmark Here NTL Page 11 of 12 �UNITEDST4TES POSTAL SERVICE Certificate Of Mailing This Cartiflwte of Mailing provides evidence that mall has been presented to USPS* for mailing. Thls form may be used for domestic and international mall, From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C U.S. POSTAGE )»PITNEY BOWES 44/e7-11111w=rememmw ZIP 07092 $ 001.200 02 114 00013874.30 MAY 05 2014 To pay fee, affix stamps or meter postage here. TO: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 Postmark Here County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 '"'� UNITED STATES POSTAL SERVICE. Certificate Of Mailing nes Certificate of Meiling provides evidence that mall has been presented to USPS* for mailing. Thlo form may be used for domestic and International malt. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XFP-177142/nfe TEAM- C tit 0Z 90 AYW0 0O 1.00 $ To: 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 £961000 Mt ZO OLO dl2 SMO53MCM A3NLki <39VISOd S -n To pay fee, affix stamps ormeter postage here. Postmark Here NTL Page 12 of 12 UNITED STATES Erdal POSTAL SERVICEs Certificate 0 Mailing This Certificate of Mailing provides evidence that mall has been presented to USW for mailing. This form may be used for domestk and International mall. Fr"rn Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, Ni 07092 XFP-177142/nfe TEAM- C U.S. POSTAG E >> PITNEY BOWES kr1711wp, ZIP 07092 $ 001.200 02 1 V1 0001387430 MAY 05 2014 To pay fee, affix damps or miter postage here. lb' UNKNOWN SPOUSE 419 Eisenhower Drive Carlisle, PA 17013-1679 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 Postmark Here