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Home My WebLink About13-3610 Supreme Courtof. Pennsylvania Cour f CommonTleas ,'�. For Prothonotary Use Only: r �ivillcovef, Sheet CUMBERti NM. County Docket No: SrI The information collected on this form is used solely for court administration purposes. This form does not supplement or replace 1hefiling and service of leadin s or other papers as required by law or rules of court. S Commencement of Action: ❑O Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: WELLS FARGO BANK, N.A. Lead Defendant's Name: ANITA F. SHEAFFER A/K/A ANITA T SHEAFFER A /K/A ANITA FAYE SHEAFFER I Are money damages requested? ❑ Yes ❑x No Dollar Amount Requested: ❑ within arbitration limits Q (Check one) outside arbitration limits N Is this a Class Action Suit? ❑ Yes 9 No Is this an MDJ Appeal? ❑ Yes ❑x No A Name of Plaintiff /Appellant's Attorney: Jonathan Lobb. Esg., Id. No.312174 Phelan Hallinan LLP ❑ 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 ❑ Product Liability (does not S include mass tort) ❑ Employment Dispute: ❑ Slander /Libel/ Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: T I MASS TORT ❑ Other: O ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration B ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations Z Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto • Dental ❑ Partition ❑ Replevin • Legal ❑ Quiet Title ❑ Other: • Medical ❑ Other: ❑ Other Professional: Pa.R.C.P. 205.5 Updated 0110112011 CONbERLA1 -,11D COUNTY PENNs YLVANIA PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD CIVIL DIVISION FORT MILL, SC 29715 Plaintiff, NO.: VS. ANITA F. SHEAFFER A /K/A ANITA SHEAFFER A/K/A ANITA FAYE SHEAFFER 18 HAMILTON ROAD BOILING SPRINGS, PA 17007 -9762 BENJAMIN M. SHEAFFER A/K/A BENJAMIN SHEAFFER A /K/A BENJAMIN MICHAEL SHEAFFER 110 S EARL STREET SHIPPENSBURG, PA 17257 -1802 Defendants. CIVIL ACTION — COMPLAINT IN MORTGAGE FORECLOSURE And now comes WELLS FARGO BANK, N.A., by its attorneys, Phelan Hallinan, LL and files this Complaint in Mortgage Foreclosure as follows: aUa s103.%pJ alb J 062 -PA -V3 --T1 as a c� 1. The Plaintiff is WELLS FARGO BANK, N.A., 3476 STATEVIEW BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff'). 2. The Defendant ANITA F. SHEAFFER A/K/A ANITA SHEAFFER A /K/A ANITA FAYE SHEAFFER is an individual whose last known address is 18 HAMILTON ROAD, BOILING SPRINGS, PA 17007 -9762. 3. The Defendant BENJAMIN M. SHEAFFER A/K/A BENJAMIN SHEAFFER A/K/A BENJAMIN MICHAEL SHEAFFER is an individual whose last known address is 110 S EARL STREET, SHIPPENSBURG, PA 17257 -1802. 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 23, 2010, ANITA F. SHEAFFER and BENJAMIN M. SHEAFFER made, executed and delivered to WELLS FARGO BANK, N.A. a Mortgage in the original principal amount of $131,991.00 on the premises described in the legal description marked Exhibit "B ", attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 201018214. 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. 7. ANITA F. SHEAFFER A /K/A ANITA SHEAFFER A /K/A ANITA FAYE SHEAFFER and BENJAMIN M. SHEAFFER A/K/A BENJAMIN SHEAFFER A/K/A BENJAMIN MICHAEL SHEAFFER are record and real owners of the aforesaid mortgaged premises. 062 -PA -V3 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 January 1, 2013. 9. As of 06/12/2013, the amount due and owing Plaintiff on the mortgage is as follows: Principal Balance $126,350.41 Interest $3,349.15 12/01/2012 through 06/12/2013 Late Charges $113.88 Property Inspections $15.00 Suspense Balance $(700.00) Escrow Balance $(327.54) TOTAL $128,800.90 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above - captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 11. This action does not come under Act 91 of 1983 because the mortgage is FHA - insured. 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 062 -PA -V3 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 $128,800.90, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. �P 113 By: Date: � Jo than Lobb, Esq., Id. No.312174 Attorney for Plaintiff 062 -PA -V3 Exhibit "A" Multistate NOTE JUNE 23, 2010 [t}J fCI 18 HAMILTON ROAD, BOILING SPRINGS, PA 17007 [Property Address] 1. PARTIES "Borrower" means each person signing at the end of (his Note, and the person's successors and assigns. "Lender" means WELLS FARGO BANK, N.A. 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 ofONE HUNDRED THIRTY ONE THOUSAND NINE HUNDRED NINETY ONE AND 00 /100 Dollars (U.S. $ * * * * * ** *131 991.00 ), plus interest, to the order of Lender. Inlcrest will be charged on unpaid principal, from the dale of disbursement of the .loan proceeds by Lender, at the rate of FIVE percent( 5.000 ° /„) 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, 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 tosses 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 01 , 2010 . Any principal and interest remaining on the first day of JULY 2040 , will be due on that dale, which is called the "Maturity Dale." . (B) Place Payment shall be made at WELLS FARGO HOME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ * * * * ** *708.56 This amount will he part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument_ (D) 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] OGraduated Payment Allonge ❑Growing Equity Allonge Other (specify] 5. BORROWER'S RIGHT TO PREPAY Borrower has the right (o pay the debt evidenced by this Note, in whole or in part, without charge or penally, on (he 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 monthl s Lender agrees in writing to those changes. FIIA Multistate Flied Rate Note • 10/95 l y�• -1R (9Ei01) VMP MORTGAGE FORMS - (1100)521 -7291 Page 1 of 2 Initials: 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 fitieen 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 fill 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. R. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will he 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 differcnt 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 u 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, surely or endorser of this Note is also obligated to do these things. Any person who lakes 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 [his 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. BY SIGNING BELOW, Borrower accepts and agrees to the terns and covenants contained in this Note. (Seal) 'h7 (Seal) - Borrower 13EN77IZ S FER - Borrower (Seal) (Seal) - Borrower ANITA F SHEAFFER - Borrower (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) - Borrower - 13orrower �® -1 R tseor l Pogo 2 or 2 Exhibit "B" LEGAL DESCRIPTION ALL THAT CERTAIN parcel of land situated in township of South Middleton being known as all that certain tract of land situate in South Middleton township, Cumberland county, Pennsylvania, bounded and described in accordance with a survey by G. J. Betz, R.S., dated November 11, 1970 as follows, to -wit: BEGINNING at a bolt set on the legal right -of -way line of Hamilton road (T -670) the dividing line between lots 1 and 2 on the hereinafter mentioned plan of lots; thence by said division line, south 85 degrees 42 minutes 17 seconds east, 133.51 feet to a bolt set on lot 1 on the hereinafter mentioned plan of lots; thence by said lot 1, south 06 degrees 30 minutes 29 seconds west, 80.00 feet to a bolt set at the corner of lands now or formerly of Wayne W. Yohe; thence by said lands south 76 degrees 08 minutes 40 seconds west, 140.00 feet to a bolt set; thence continuing south 84 degrees 11 minutes 40 seconds west, 8.50 feet to a bolt set; thence continuing north 86 degrees 39 minutes 33 seconds west, 24.19 feet to a bolt set on the legal right -of -way line of Hamilton road (T -670); thence along Hamilton road by a curve extending to the right with a radius of 291.50 feet, an arc length of 131.39 feet to bolt set, the place of beginning. APN #: 40 -28- 2098 -020A PROPERTY ADDRESS: 18 HAMILTON ROAD, BOILING SPRINGS, PA 17007 -9762 PARCEL #40 -28- 2098 -020A File #: 323622 VERIFICATION Steve DeFurio, hereby states tha e/ he is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, tha he/ 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 of is 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: Steve DeFu io Title: Vice President Loan Documentation Company: Wells Fargo Bank N.A. Date: 06/14/2013 086 -PA -V2 File # 323622 FORM 1 r IN THE COURT OF COMMON PLEAS c WELLS FARGO BANK, N.A. OF CUMBERLAND COUNTY, PENN,,!1'L NIA! Plaintiff(s) {" 4, -1 vs.r? ANITA F. SHEAFFER A /K/A ANITA SHEAFFER A /K/A ANITA FAYE SHEAFFER BENJAMIN M. SHEAFFER A /K/A BENJAMIN = — - r' SHEAFFER A /K/A BENJAMIN MICHAEL �' '.' C SHEAFFER Defendant(s) �" V Civil 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 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 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 arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: 3 �f 1 Date nathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff f FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: CUSTOM ER/PRI MARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? CO-BORROWER Mailing Address: City: State: Zip: 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 ❑ r If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net 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 Mortizaae Food 2 nd Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care /Tuft. I 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: a Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and 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 counseling 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: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 323622 SHERIFF'S OFFICE OF CUMBERLAND COUNTY C:; � Ronny R Anderson =Lk- UH f L 1 .t__ Sheriff _i HE r ROT j'�ON10 ��,.� �;�k�atitn xr1 � Jody S Smith 2 0113 JUL 29 AM 9: 56 Chief Deputy M e: �, Richard W Stewart f39iER A ga (✓ It' Solicitor OfNOE')FTP_ISIiERIFF PENNSYLVANIA Wells Fargo Bank, N.A. Case Number vs. 2013-3610 Anita F Sheaffer(et al.) SHERIFF'S RETURN OF SERVICE 06/27/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Benjamin M Sheaffer, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 18 Hamilton Road, South Middleton, Boiling Springs, PA 17007. Deputies were advised by the defendant's wife that the defendant moved to 110 S. Earl Street, Shippensburg, PA 17257. 06/27/2013 06:40 PM- Deputy Tim Black, 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:Anita F Sheaffer at 18 Hamilton Road, South Middleton, Boiling Springs, PA 170077..' TIM BLACK, DEPUTY 07/16/2013 04:43 PM - Deputy Jamie DiMartle, 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 Anita Gipe, Girlfriend, who accepted as"Adult Person in Charge"for Benjamin M Sheaffer at 110 S. Earl Street, Shippensburg, PA 17257. tyIE DIM , DEPUTY SHERIFF COST: $105.98 SO ANSWERS, July 26, 2013 RbNW R ANDERSON, SHERIFF c CountySuite Shoriff,Teleosoff.Inc. }h PaRO1 HONOT;Ar,.`l 2013 OCT —2 AM 10: 10 CUMBERLAND COUNTY Phelan Hallinan,LLP PFNNSYLMANIA Attorney For Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 WELLS FARGO BANK,N.A. : Court of Common Pleas Plaintiff . Civil Division vs . CUMBERLAND County ANITA F.SHEAFFER A/K/A ANITA SI-IEAFFER : No. 13-3610-CIVIL A/K/A ANITA FAYE SHEAFFER BENJAMIN M.SHEAFFER A/K/A BENJAMIN SHEAFFER A/K/A BENJAMIN MICHAEL SHEAFFER Defendant PRAECIPE TO THE PROTHONOTARY: ® Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ❑Please mark the above referenced case Settled,Discontinued and Ended. n Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. I Please mark the in rem judgment Satisfied and the action Discontinued and Ended. Please Vacate the Judgment entered. Date: f/303 N,LLP By: IrACIV Jo ,/ �el Kolesnik,Esq.,Id.No.308877 / Attorney for Plaintiff PH#817380 Phelan Hallinan,LLP Attorney for Plaintiff 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 WELLS FARGO BANK,N.A. Court of Common Pleas Plaintiff Civil Division v. CUMBERLAND County ANITA F. SHEAFFER No. 13-3610-CIVIL A/K/A ANITA SHEAFFER A/K/A ANITA FAYE SHEAFFER BENJAMIN M. SHEAFFER A/K/A BENJAMIN SHEAFFER A/K/A BENJAMIN MICHAEL SHEAFFER Defendant PH#817380 CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiff's Praecipe was served by regular mail to the person(s) on the date listed below: ANITA F. SI IEAFFER A/K/A ANITA SHEAFFER A/K/A ANITA FAYE SHEAFFER 18 HAMILTON ROAD BOILING SPRINGS,PA 17007-9762 BENJAMIN M.SHEAFFER A/K/A BENJAMIN SHEAFFER A/K/A BENJAMIN MICHAEL SHEAFFER 110 S EARL STREET SHIPPENSBURG, PA 17257-1802 Date: T/3iA3 PHE • 'ALLINAN, LLP By. 40 J. n • ichael Kolesnik,Esq.,Id.No.308877 Attorney for Plaintiff