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HomeMy WebLinkAbout13-3451 Supreme Court of Pennsylvania Cougt4Gammon Pleas Ci vil;Cover,Sheet For Prothonotary Use Only: CUMBERLAND.,--,,'' County Docket No: .. _Sup � The information collected on this form is used solely for court administration put-poses. This form does not supplement or replace the filing and service of pleadings or other papers as required by Imi,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: Mark A. Stoner C T Are money damages requested?: ❑Yes ® No Dollar Amount Requested: within arbitration limits I {Check one} X outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDI 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 r_1 Product Liability(does not include $ mass tart) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I MASS TORT ❑ Other: O El Asbestos ❑ Tobacco N ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste [:1 Ejectment Other: El Common Law/Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus B ❑ 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-179372 062-PA-V3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., CIVIL DIVISION Plaintiff, NO.:J) - 3ySI vil VS. TYPE OF PLEADING Mark A. Stoner; CIVIL ACTION -COMPLAINT Defendant. IN MORTGAGE FORECLOSURE TO: DEFENDANT FILED ON BEHALF OF: YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY(20)DAYS Wells Fargo Bank, N.A. FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAYBE 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 ' `a 408 North Filbert Street ' �~ Kimberly A. Bonner, Esquire --u �. F.r;_.-! Mechanicsburg,PA 17055-3329 Pa. I.D.#89705 Joel A. Ackerman, Esquire Wit'-" ` Pa I.D.#202729 —� -� CERTIFICATE OF LOCATION „ICJ ss I HEREBY CERTIFY THAT THE LOCATION OF Ashleigh Levy Marin, Esquire -.P- THE REAL ESTATE AFFEC eD.BYTHIS LIEN IS. Pa I.D.#306799 Z C:3 r 408 North Filbert Street',Mechanicsburg PA 17055-3329 .75 Ralph M.Salvia, Esquire p -r'. Municipality: Mech4'n'iicsbufg >� Pa I.D.#202946 !/ Jaime R.Ackerman, Esquire ATTORNEY FOI(d?WNTIFF Pa I.D.#311032 ATTY Fill NO XFP 179372 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office @zuckergoldberg.com File No.: XFP- 179372/rbo Q � & 3. �5L a c 1 V41 a qlgs7 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 DEBTOR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY(30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT. TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Mark A. Stoner; Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND& LAWYER REFERRAL SERVICE NOTICE TO DEFEND , LAWYER REFERRAL Cumberland County Bar Association 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.. Mark A. Stoner; Defendant. AVISO LISTED 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. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PLIEDE PAGAR UNO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND& LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association 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.. Mark A.Stoner; Defendant. CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg&Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff") with its place of business located at 3476 Stateview Blvd., Ft. Mill, SC 29715. 2. The Defendant, Mark A. Stoner, is an individual whose last known address is 408 North Filbert Street, Mechanicsburg, PA 17055-3329. 3. Wells Fargo Bank, N.A., directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit A. attached hereto and made a part hereof. 4. On or about April 9, 2003, Mark A. Stoner, a single man made, executed and delivered to Coastal Capital Corp. D/B/A The Mortgage Shop a Mortgage in the original principal amount of$91,259.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on April 16, 2003, in Mortgage Book\Volume 1806, Page 672. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. Zucker,Goldberg&Ackerman, LLC XFP-179372 062-PA-V3 5. By Assignment of Mortgage recorded November 16, 2004, the mortgage was assigned to Washington Mutual Bank, FA which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County in Assignment Book 713, Page 435. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Plaintiff is the current Mortgagee. By further Assignment of Mortgage recorded January 18, 2007,the mortgage was assigned to Wells Fargo Bank, NA, which assignment is recorded in the Office of the Register of Deeds for Cumberland County in Assignment Book 733, Page 3180. 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. Mark A. Stoner, a single man is the record and real owner of the aforesaid mortgaged premises. 8. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due December 1, 2012. 9. As of 06/03/2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $77,266.65 Interest through 06/03/2013 $ 2,729.71 Escrow Balance $ (108.72) Suspense Balance ($ 2.06) Late Charges $ 173.06 Inspection Fees $ 30.00 Total $80,088.64 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. Zucker,Goldberg&Ackerman, LLC XFP-179372 062-PA-V3 10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 11. This action does not come under Act 91 of 1983 because the mortgage is FHA insured. 12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding,this action is in no way an attempt to re-establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of$ 80,088.64 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, GOLDB- G &ACKERMA'N, LLC BY: Dated: /n Scott A. Die`tterick,Esquire; PA I.D.#55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 ! Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M.Salvia, Esquire; PA I.D. #202946 Jaime R.Ackerman, Esquire; PA I.D. #311032.-- Attorneys for Plaintiff XFP-179372/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 XFP-179372 062-PA-V3 EXHIBIT A Zucker,Goldberg&Ackerman, LLC XFP-179372 062-PA-V3 _ I PHOTE araraa Mw Wtacm NOTE Gsa NtNUR: - i APRIL 9, 2003 14ECHANICSBURG PENNSYLVANIA [Date] [City] / [State] 408 NORTH FILBERT STREET MECHANICSBURG, PA 17055 J [Property Address] 1. PARTIES "Borrower"means each person signing at the end of this Note,and the person's successors and assigns. "Lender" means COASTAL CAPITAL CORP. D/B/A THE MORTGAGE SHOP 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 stmt of NINETY—ONE THOUSAND TWO HUNDRED FIFTY—NINE AND 00/100 Dollars(U.S.S 91,259.00 ), plus interest, to the order of Lender. Interest will be charged on unpaid principal,from the date of disbursement of the loan proceeds by Lender,at the rate of SIX pe=nt( 6.000 %)per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage,deed of trust or similar security 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 1ST day of each month beginning on JUNE, 2003 .Any principal and interest remaining on the IST day of MAY, 2033 ,will be due on that date,which is called the maturity date, I (B) Plate Payment shall be modest 220 PONTE VEDRA PARK DRIVE #200 PONTE VEDRA BEACH, rL 32082 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.S 547.14 This amtwnt will be pan of a larger monthly payment required by the Security Instrument,that shall be applied to principal,interest and other items in the order described in the Security Instrument. I (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 allonge 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] El Graduated Payment Allonge 0 Growing Equity Allonge Q Other[Specify] 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. I t1000RAi Page 1 of) FHA Muatuste Flied Rue Note—61% DOMWFAe.VTX 11/15/2001 I 5. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Paymeau 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 tray collect a late charge in the annum of EXM percent( 4.000 °A)of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any momNy 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 i*terest.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[,enders rights to require immediate payment in Rill in the case of payment delhu►ts.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 Develojiment or his or her designee. i (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 attorney's fees for enforcing this Note to the extent not prohibited by applicable low. Such fees and costs shall beat 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 trail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrowers different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B)or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this 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 wider this Note. txtnTrrAr oaCvrr�a.vrx 31/08/2001 Page 2 of J FHA Mafdane Fixed tare Note—6196 i e i BY SIGNING BELOW,Borrower accepts and agrees to the terms and covenants contained in this Note. -w"4' ' - C/9-ems BORROWER — MRRK A. STONER DATE — WITHOUT RECOURSE W�� B�F�VK,fiA ODASTAL CAPITAL CORP. D T !nOE) Pay to te order of i� Assistant ice President �� FA t000n � N i = A� Page 3 or3 FHA Mrldxtate Fixed Rate Note—61% ppeureax.v�s iiioaixoot i I' e EXHIBIT B Zucker,Goldberg&Ackerman, LLC XFP-179372 062-PA-V3 legal, description ALL THAT CERTAIN piece ox. parcel of land, situate in the Borough of Mechanicsburg, Cumberland. County, Pennsylvania, more particularly bounded and described according to a survey of D. R. Raffensperger, dated August 10, 1953, as follows: BEGINNING at .a point on the eastern line of Filbert Street, 252 feet North .of the northeast corner of the intersection of Filbert and Portland Streets, also at the dividing line between Lot No. 's 5 and 6, Block ,bu , on the hereinafter mentioned plan of lots; thence North 21 degrees 40 minutes West along the eastern line of Filbert Street 52 .29 feet to a point on the line of lands now or formerly of Raymond W. White; thence North 43 degrees 1 minute East, 137,78 feet to a point; thence alone the eastern line of Lot No. 6,, Block "D", South 21 degreez 40 minutes East, 111,21 feet .to .a point at the dividing line between Lot go. 'a 5, and 6., Block "D", on said Plan; thence along: same, South 68 degrees' 20 minutes: West,. 124.55 feet. to a point, being the Place of BEGINNING. BEING Lot No. 6, Block ''D" Plan of White Acres, said Plan being reoordjd in Plan Book 6, Page 14., Cumberland County records. HAVING THEREON erected a one-story brick and block dwelling house known as No. 408, Filbert Street, Mechanicsburg, PA 17055. BEING THE SAML PRSMISES which Russell L. . Rhoads and Brenda L. Rhoads, his wi.f'e, by. their peed dated May 23, 1990 and recorded on May 25, 1.990 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Boole O, Volume 34, Page 912, granted and conveyed. unto Mark A. Stoner, a single man. T Ccrtrt`y fills to be recorded lta C11n1ber1and C'otjnty PA ,Recorder Of Deeds Bit 1. 80'6 PG 0.680 VERIFICATION Darren Britt, hereby states that0she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., Plaintiff in this matter,that&he 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 ofQher 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. C)CAV -- Name: Darren Britt Title:Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 06/06/2013 086-PA-V2 File# 179372 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, S NO.. � ow I VS. t �— 3y Mark A.Stoner; Cf Defendant. r) ~; -t3 03 <_ ryl:= PRAECIPE FOR ENTRY OF APPEARANCE © To the Prothonotary/Clerk of said Court: C,--R Please enter my appearance on behalf of Wells Fargo Bank, N.A.. i rs Papers may be served at the address set forth below. j I xv, Attorney for Party Named Above 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 ti Zucker,Goldberg&Ackerman, LLC 200 Sheffield Street,Suite 101, Mountainside, NJ 07092 Ph: 908-233-8500; Fax:9083.3-8500 OK- Date: June �j ,2013 Signature: (/% � '- v v4,11- -- v PRAECIPE FOR WITHDRAWAL O\APEARANCE WITHOUT LEAVE OF URT Rule 1012 b 2 i To the Prothonotary/Clerk of said Court: Please withdraw the appearance on be If of Wells F go Bank, N.A.. has entered his/he p arance for the aforementioned party. I hereby certify that this change of attorneys s n intended to, nor will it, delay this proceeding to the best of my knowledge, information and be 'X. Date: ignature: Print Name: Zucker,Goldberg&Ackerman, LLC XFP-179372 Jun 19 2013 1 : 53PM ZGF1 9086547861 p. 2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank N.A. CIVIL DIVISION VS. NO.: 2013-03451 NOTICE"OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been se d with a foreclosure complaint that could cause you to lose your home. if you own and live h the residential property which Is the subject of this foreclosure action,you may be able to participate In a court-supervlsed conciliation conference In an effort to resolve this matter with your lender. If you do not have lawyer,you must take the following steps to be eligible for a conciliation conference. First, within t venty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 24 3-9400 extension 2S10 or (800) 822-5289 extension 2510 and request appointment of a legal rel resentative at no charge to you. Once you have been appointed a legal representative, you must p mptly meet with that legal representative within twenty (20) days of the appointment date. During I�Iat meeting, you must provide the legal representative with all requested financial information so tM a loan resolution proposal can be prepared on your behalf. if you and your legal representative com Jete a financial worksheet In the format attached hereto, the legal representative will prepare land file a Request for Conciliation Conference with the Court,which must be filed with the Court within s,Ixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation cofference, Is scheduled, you will have an opportunity to meet with a representative of your leniler in an attempt to work out reasonable arrangements with your tender before the mortgage foreclosure suit pn)ceeds forward. Zucker,Goldberg&Ackerman,LLC r Jun 19 2013 1 : 53PM ZGA 9086547861 P. 3 If you are represen'ed by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation inference. it is not necessary for you to contact MldPenn Legal Service for the appointment of a legal tepresentative. However, you must provide your lawyer with all requested financial Information so tha 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 Co 'ference with the Court, which must be filed with the Court within sixty(60) days of the service upon yo of the foreclosure complaint. if you do so and a conciliation conference Is scheduled, you will have a ;opportunity to meet with a representative of your lender in an attempt to work out reasonable arran ements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE.TIDS PRO TRAM IS FREE. ZUCKER,GOLDBERG &ACKERMAN, LLC Dated: June 19,2013 Scott A. Dletterick, Esquire; PA I.D.#55650 Kimberly A. Bonner, Esquire;- PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashlelgh L.Marin, Esquire; PA I.D.11306799 Ralph M.Salvia,Esquire; PA I.D.#202946 Jaime R.Ackerman,Esquire; PA I.D.#311032 Attorneys for Plaintiff XFP-179372/emed 200 Sheffield Street,Suite 101 Mountalnslde, NJ 07092 (908)233-8500;{908}233-1390 FAX Email: Office@zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XFP-179372 Jun 19 2013 1 : 53PM ZGR 9086547861 p. 4 Cumberland County Residential Mortgage Foreclosure Diversion Program FInOMC131 Worksheet Date: Cumberland County Court oi Com onPleasDocket# 12013-03451 BORROWER REQUEST FOR �ARDSHIIP ASSISTANCE To complete-your request f�r hardship assistance,your lender must consider your circumstances to determine possible options Nihlle working with your Please provide the following Information to the best of your knowledge-, CUSTOM FR/PRI MARY APPLICANT Borrower name(s); Property Address: City: State: Zip: is the property for sale? Yes No Fj Listing date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes No F1 Mailing Address(if different): _ City: State- Zip: Phone Numbers: Home: Office: Cell; Other: Ernall: #of people In household: How long? Mailing Address, City: State: Zip: Phone Numbers: Home: Office: Cell Other: Email: #of people In household: How long? Y FINANCIAL INFORMATION First Mortgage Lender: Type of Loan; Loon Number: Date you closed your loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments A Mount: $ Included Taxes&Insurance: Date of Last Payment: Prl,Mary Relson for Defa Is the loan in Bankruptcy? Yes [] No if yes, provide names, locat on of court, case number&attorney: Zucker,Goldberg&Ackerman,LLC XFP-179372 Jun 19 2013 1 : 53PM ZGR 9086547861 p. 5 Assets mount Owed: value: Home: $ S Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile tt1: Model: Year: Amount owed: Value: Ault mobile tt2: Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Descripti bn (not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please bnly 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 Auto fuel/repairs Other prop. payment Install. Loan Payment Cable N Child Support/Allm. Spending Money Da /Child Care/Tult. I Other Expenses Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working wi0i a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the fo lowing Information: Counseling Agency: Counselor: Phone (Office); Fax: Email: Zucker,Goldberg&Ackerman,LLC j XFP-179372 Jun 19 2013 1 : 53PM ZGA 9086547861 p. 6 Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)assistance? Yes E] No If yes, please indicate the st tus of the application: Have you had any prior neg !tlatlons with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please Indicate the st tus 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/s rvicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We unijerstand 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 docum ;nt along wll:h the following information to lender and lender's counsel: Proof of Income y Past 2 bank statern nts V Proof of any expec od income for the last 45 days y Copy of current utll ty bill V Letter explaining re son for delinquency and any supporting documentation (hardship letter) V Listing agreement property In currently on the market) Zucker,Goldberg&Ackerman,LLC XFP-179372 Jun 19 2013 1 : 53PM ZGIa 908G5478G1 p. 7 IN THE COURT OF(COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: 2013-03451 vs. Mark A. Stoner; Defendant. !REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Ad Inistrative Order dated February 28, 2012 governing the Cumberland County Residential Mortga i 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 actt n; 1. Defendant lives Feen the subject real property,which is defendant's primary residence; 2. Defendant has served) with a "Notice of Residential Mortgage Foreclosure Diversion Program" and taken all of the steps required in that Notice to be eligible to participate in a court-supervl ed conciliation conference. The undersigned v 'rlfies 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 Counsei/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date sucker,Goldberg&Ackerman,LLC XFP-179372 Jun 19 2013 1 : 53PM 2GA 9086547861 p. 8 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wefts Fargo Bank, N.A, CIVIL DIVISION Plaintiff, No.: 2013-03451 VS. Mark A.Stoner; Defendant. CASE MANAGEMENT ORDER AND NOW,this day of ,2t} ,the defendant/borrower in the above- captioned residential mortg ige foreclosure action having filed a Request for Conciliation Conference verifying that the defendani lborrower has compiled with the Administrative Rule requirements for the scheduling of a Conciliationanference, It is hereby ORDERED AND DECREED that. 1. The parties and the Ir counsel ar,_directed to participate In a court-supervised conclilation Conference on I at M. in at the Cumberland Count Courthouse,Carlisle,Pennsylvania, 1. At least twenty-on (21)days prior to the date of the Conciliation Conference,the defendant/borrow r must serve!upon the plaintiff/lender and its counsel a copy of the "Cumberland Couni V Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2)which has Deen completed by the defendant/borrower. Upon agreement of the parties In writing or at the iscretlon of the Court,the Conciliation Conference ordered may be rescheduled to a la r date and/or the date upon which service of the completed Form 2 Is to be made may be exte I ed,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 wr ting 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/bor wer and counsel for the parties must attend the Conciliation Conference In person and an aut prized representative of the plaintlff lend er 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-179372 Jun 19 2013 1 : 53PM ZGA 9086547861 p. 9 resolution,and cour set for the plalntiff/lender must discuss resolution proposals with the authorized represen ative in advance of the Conciliation Conference. If the duly authorized representative of th plaintiff/lender Is not available by telephone during the Conciliation Conference,the Co ;rt will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plalntiff/lender at the rescheduled Conciliation Conference. 3. At the Conciliation c.onference,the parties and their counsel shall be prepared to discuss and explore all avallable resolution options which shall Include:bringing the mortgage current through a reinstate ent; paying off the mortgage;proposing a forbearance agreement or repayment plan to `ring the account current over time;agreeing to tender a monetary payment and to vacate In th ;near future In exchange for not contesting the matter;offering the lender a deed In lieu of fore losure;entering Into a loan modification or a reverse mortgage;paying the mortgage default o ,er sixty months; and the Institution of bankruptcy proceedings. 4. All proceedings In this matter are stayed pending the completion of the scheduled concillatlon conference, BY THE COURT, J. Zucker,Goldberg&Ackerman,LLC XFP-179372 SHERIFF'S OFFICE OF CUMBERLAND COUNTY C�4 C•: —n, Ronny R Anderson C= Sheriff = 65 Jody S Smith Chief Deputy tl�r C� Richard W Stewart 0FRCE C�FTt',E$K-E-OFF —0 Solicitor = =C:) r-0 Wells Fargo Bank, N.A. Case Number vs. Mark A Stoner 2013-3451 SHERIFF'S RETURN OF SERVICE 06/2412013 03:57 PM-Deputy Jason Kinsler, 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: Mark A Stoner at 408 N. Filbert Street, Mechanicsburg Borough, Mechanicsburg, PA 17055. ,ASON KINSLER, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, June 25, 2013 RON R ANDERSON, SHERIFF (r-)Coun.tySufte Sheriff,Tefeosot,Inc. WELLS FARGO BANK, N.A. , IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS . CIVIL ACTION- LAW NO. 13-3451 CIVIL MARK A. STONER, Defendant CIVIL ACTION- MORTGAGE FORECLOSURE PRAECIPE FOR ENTRY OF APPEARANCE TO THE .PROTHONOTARY: Please enter my appearance as attorney for and on behalf of #' Mark A. Stoner, the Defendant in the within action. Date: 2013 Marlin R. McCa eb Attorney I .D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, Pennsylvania 17055 (717) 691-7770 Attorney for DefendantoY rT" ryl r- -u ;, c C o c LAW OFFICES MARLIN R. McCALEB WELLS FARGO BANK, N.A. , IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs . CIVIL ACTION- LAW NO. 13-3451 CIVIL MARK A. - STONER, Defendant CIVIL ACTION- MORTGAGE FORECLOSURE ANSWER 1 . Admitted. Admitted. c,a (n I .�CD 3 . e') I Admitted. ' -• � '{'' 4 . Admitted. 5 . Admitted. 6 . Admitted. LAW OFFICES MARLIN R. McCALEB t° s 7 . Admitted. 8 . Admitted. 9 . After reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments of Paragraph 9 as to the amounts owed and the same therefore are deemed denied and proof thereof is demanded. 10 . Admitted. 11 . Specifically Denied. The averments of Paragraph 11 are conclusions of law to which no responsive of pleading is required. 12 . Specifically Denied. The averments of Paragraph 12 are conclusions of law to which no responsive of pleading is required. LAW OFFICES MARLIN R. McCALEB —2— i Wherefore, Defendant demands Judgement be entered into his favor and against the Plaintiff herein. Date : r r!� � 2013 Marlin R. cCaleb Attorney I .D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, Pennsylvania 17055 (717) 691-7770 Fax (717) 691-77772 Attorney for Plaintiffs LAW OFFICES MARLIN R. McCALEB —3— VERIFICATION MARK A. STONER, Defendant in the foregoing Answer, hereby verifies that the statements made in said Answer are true and correct to the best of his knowledge, information and belief . I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. , Section 4904, relating to unsworn falsification to authorities . Date : ` Z2 2013 M rk A. Stoner LAW OFFICES MARLIN R. MCCALEB -4- T CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the within Answer was served upon the Plaintiff herein, or their attorney, on July 23, 2013, by depositing same in the mail at the United States Post Office at Mechanicsburg, Pennsylvania, postage prepaid, properly addressed as follows : Scott A. Diett.erick, Esquire Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, New Jersey 07092 Marlin R. McCaleb LAW OFFICES MARLIN R. McCALEB .� 1L MOTH` V 5'"i 2;513 AUG -5 PH l 14 WELLS FARGO BANK, N.A. , IN T t kJ�T� 11 l.. QN PLEAS OF Plaintiff CUMBEIR'+ � PENNSYLVANIA VS. CIVIL ACTION- LAW NO. 13-3451 CIVIL MARK A. STONER, Defendant CIVIL ACTION- MORTGAGE FORECLOSURE 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 known and numbered as 408 North Filbert Street, Borough of Mechanicsburg, Cumberland County, Pennsylvania 17055 . 2 . Defendant lives in the subject real property, which is Defendant' s primary residence . 3 . 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 and is represented therein by the undersigned counsel . 4 . No Judge has been previously involved in this matter. 5 . The undersigned hereby respectfully requests that your LAW OFFICES MARLIN R. McCALEB Honorable Court schedule a Conciliation Conference herein, to I be attended by Defendant and his counsel and Plaintiff and its counsel . The undersigned verifies that the statements made herein i are true and correct . I understand that false statements are i made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. M k A. Stoner, Defendant Date: , 2013 Marlin R. McCaleb Attorney I .D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, PA 17055 (717) 691-7770 FAX: (717) 691-7772 Attorney for Defendant LAW OFFICES MARLIN R. McCALEB —2— WELLS FARGO BANK, N.A. , IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs . CIVIL ACTION- ,LAW ;rM NO. 13-3451 CIVIL %j G' ; - r x;= MARK A. STONER, .�s3> Defendant CIVIL ACTION- MORTGAGE--- RECLCWSURE CASE MANAGEMENT ORDER AND NOW, this day of 2013 , 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 ajj-,y"/,dA p�(e 2013 , at 3() M. in GQ�*R��No. at the Cumberland County Court House, Carlisle, Pennsylvania; 2 . At least twenty-one (21) days prior to the date of the Conciliation Conference, the Defendant/Borrower must serve upon the Plaintiff/Lender or 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 LAW OFFICES at the discretion of the Court, the Conciliation Conference MARLIN R. McCALEB 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. 3 . 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 resolution, and counsel for the Plaintiff/Lender must discuss the resolution proposals with that 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. 4 . At the Conciliation Conference, the parties and their LAW OFFICES MARLIN R. McCALEB —2— counsel shall be prepared to discuss and explore all available resolution options which shall include : bringing the mortgage to 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 . 5 . All proceedings in this matter are stayed pending the completion of the scheduled Conciliation Conference . BY THE COURT: J. LL "�f M . Ac�" LAW OFFICES MARLIN R. McCALEB —3— i 2d 13 AU WELLS FARGO BANK, N.A. , IN TH �. QU TnA ,�%14,MQN PLEAS OF Plaintiff CUMB&"'14 IANIAPENNSYLVANIA VS . CIVIL ACTION- LAW NO. 13-3451 CIVIL MARK A. STONER, Defendant CIVIL ACTION- MORTGAGE FORECLOSURE 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 known and numbered as 408 North Filbert Street, Borough of Mechanicsburg, Cumberland County, Pennsylvania 17055 . 2 . Defendant lives in the subject real property, which is Defendant' s primary residence . 3 . 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 and is represented therein by the undersigned counsel . 4 . No Judge has been previously involved in this matter. 5 . The undersigned hereby respectfully requests that your LAW OFFICES MARLIN R. McCALEB Honorable Court schedule a Conciliation Conference herein, to i be attended by Defendant and his counsel and Plaintiff and its counsel . 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 unsworn falsification to authorities . Mq&k A. Stoner, Defendant Date : 5� 2013 *lei Marlin R. McCaleb Attorney I .D. No. 06353 219 East Main Street P.O. Box 230 Mechanicsburg, PA 17055 (717) 691-7770 FAX: (717) 691-7772 Attorney for Defendant i LAW OFFICES MARLIN R. McCALEB _2_ WELLS FARGO BANK,N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 13-3451 CIVIL MARK A. STONER, Defendant MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE Present at a conciliation conference held September 26, 2013,were Ralph Salvia, Esquire, attorney for the plaintiff, and Marlin McCaleb, Esquire, attorney for the defendant. The homeowner has recently submitted documents to the bank for its review. Additional time is necessary and a continued conciliation conference will be set by order of even date herewith. ORDER AND NOW, this 2 G - day of September, 2013, continued conciliation conference is set for Friday,November 22, 2013, at 1:30 p.m. in Chambers of the undersigned. BY THE COURT, r� Kevin . Hess, P. J. Ralph Salvia, Esquire P. O. Box 650 Msrs Hershey,PA 17033 =7Q-- c--3 t For the Plaintiff ?" ` { Marlin R. McCaleb, Esquire ' 219 East Main Street a- r�3 :,Q P. O. Box 230 Mechanicsburg, PA 17050-0230 :rlm Co n2�� L WELLS FARGO BANK,N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 13-3451 CIVIL MARK A. STONER, Defendant MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this y day of December, 2013, the conciliation conference scheduled for November 22, 2013, is continued to Friday, January 24, 2014, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, Al Kevi . Hess, P. J. Ralph Salvia, Esquire P. O. Box 650 Hershey, PA 17033 For the Plaintiff Marlin R. McCaleb, Esquire 219 East Main Street P. O. Box 230 Mechanicsburg, PA 17050-0230 r Am M MM �z-. �c C) WELLS FARGO BANK,N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION—LAW : NO. 13-3451 CIVIL MARK A. STONER, Defendant : MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 3b` day of January, 2014, the conciliation conference scheduled for January 24, 2014, is continued to Wednesday, April 16, 2014, at 3:00 p.m. in Chambers of the undersigned. BY THE COURT, /4 / Kevi I . Hess, P. J. .. Ralph Salvia, Esquire P. O. Box 650 Hershey, PA 17033 For the Plaintiff Marlin R. McCaleb, Esquire 219 East Main Street P. O. Box 230 Mechanicsburg, PA 17050-0230 C, c - :rim m _s -r Cert.es 1)'1 .tt.c.ri., .0., �w C)" Vac,'/r ; • WELLS FARGO BANK, N.A., Plaintiff vs. MARK A. STONER, Defendant • IN THE COURT OF COMMON PLEAS OF • • CUMBERLAND COUNTY, PENNSYLVANIA • : CIVIL ACTION — LAW : NO. 13-3451 CIVIL : MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this /1..' day of April, 2014, at the request of counsel, the conciliation conference scheduled for April 16, 2014, is continued to Friday, June 20, 2014, at 2:00 p.m. in Chambers of the undersigned. Ralph Salvia, Esquire P. 0. Box 650 Hershey, PA 17033 For the Plaintiff /Marlin R. McCaleb, Esquire 219 East Main Street P. 0. Box 230 Mechanicsburg, PA 17050-0230 /Janene Rimolo Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street Mountainside, NJ 07092 :rim BY THE COURT, WELLS FARGO BANK, N.A., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION — LAW : NO. 13-3451 CIVIL MARK A. STONER, Defendant : MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this /8 day of June, 2014, at the request of counsel, the conciliation conference scheduled for June 20, 2014, is continued to Friday, August 29, 2014, at 1:30 p.m. in Chambers of the undersigned. BY THE COURT, Kevi ► A. Hess, P. Ralph Salvia, Esquire P. O. Box 650 Hershey, PA 17033 For the Plaintiff arlin R. McCaleb, Esquire 219 East Main Street P. O. Box 230 Mechanicsburg, PA 17050-0230 For the Defendant Janene Rimolo • Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street Mountainside, NJ 07092 :rlm COp Oalick LoPePY WELLS FARGO BANK,N.A., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION—LAW NO. 13-3451 CIVIL MARK A. STONER, Defendant MORTGAGE FORECLOSURE IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this Z 9 •day of August, 2014, at the request of counsel, the conciliation conference scheduled for August 29, 2014, is continued generally. BY THE COURT, Kevin ess, P. J. alph Salvia, Esquire P. O. Box 650 Hershey, PA 17033 For the Plaintiff Marlin R. McCaleb, Esquire 219 East Main Street P. O. Box 230 Mechanicsburg, PA 17050-0230 For the Defendant ./Janene Rimolo m f �_ Zucker, Goldberg & Ackerman, LLC Cf) 200 Sheffield Street - c Mountainside,NJ 07092 y z c:, c:.. CD Am � LL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSMAWIA Wells Fargo Bank, N.A. • CIVIL DIVISION ``A Plaintiff, r, NO.: 2013-03451 vs. (. ... • Mark A. Stoner; •• Defendant. • • PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Please mark the case filed at the above-captioned term and number SETTLED, DISCONTINUED and ENDED,without prejudice. Respectfully Submitted: ZUCKER, GOLDBERG &ACK j- AN, LLC i / f BY: Scott A. Dietter' k, 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 Roger Fay, Esquire; PA I.D.#315987 Attorneys for Plaintiff XFP-179372/dcr 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX