The URL can be used to link to this page

Home My WebLink About13-3824 Supreme Court.of Pennsylvania Cout,&'o'f Comriion Pleas r iv ' For Prothono Use On Civil:Cove,r, Sheet >� On CUM � County Docket No: BERLAND F . The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition El Transfer from Another Jurisdiction El Declaration of Taking E C Lead Plaintiffs Name: Wells Fargo Bank, N.A. Lead Defendant's Name: Melissa R. Roberts 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 MDJAppeal? ❑ 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 A9ass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ F1 Board of Assessment Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance El Premises Liability El Dept. of Transportation ❑ Statutory Appeal: Other S ❑ Product Liability (does not include mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination F Other: ❑ Employment Dispute: Other C El Zoning Board T ❑ Other: I MASS TORT ❑ Other: O ❑ Asbestos ❑ Tobacco N ❑ Toxic Tort- DES ❑ Toxic Tort Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Other: ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment B ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non- Domestic Relations PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ E] Replevin Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1//2011 Zucker, Goldberg & Ackerman, LLC XCP- 153798 062 -PA -V3 c , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., CIVIL DIVISION l Plaintiff, NO.: , — q -,,�d o�' VS. TYPE OF PLEADING Melissa R. Roberts; CIVIL ACTION - COMPLAINT Defendant. IN MORTGAGE FORECLOSURE TO: DEFENDANT YOU ARE HEREBY NOTIFIED TO PLEAD TO THE FILED ON BEHALF OF: ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS Wells Fargo 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 OF THE PLAINTIFF IS: ZUCKER GOLDBERG & ACKERMAN, LLC 3476 Stateview Blvd. Ft. Mill, SC 29715 Scott A. Dietterick, Esquire AND THE DEFENDANT: Pa. I.D. #55650 22 Umberto Avenue Kimberly A. Bonner, Esquire New Cumberland, PA 17070 -0262 Pa. I.D. #89705> T' Joel A. Ackerman, Esquire Pa I.D. #202729 CERTIFICATE OF LOCATION 2 7j- 1— 7,�.� I HEREBY CERTIFY THAT THE LOCATION OF Ashleigh Levy Marin, Esquire Cf) THE REAL ESTATE AFFECTED BY THIS LIEN IS Pa I.D. #306799 1620 Valley Road, Mechanicsburg PA 17055 -4854 .< C3 Municipality: Lower Allen Ralph M. Salvia, Esquire Pa I.D. #202946 c: C f'•i Jaime R. Ackerman, Esquire r " j ATTORNEY FOR PLAINTIFF Pa I.D. #311032 -< ATTY FILE NO.: XCP 153798 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500 (908) 233 -1390 FAX office@zuckgfpoldberg.com File No.: XCP- 153798/rbo s �qo *7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.. Melissa R. Roberts; 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.. Melissa R. Roberts; Defendant. 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. Listed 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.: Melissa R. Roberts; 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, Melissa R. Roberts, is an individual whose last known address is 22 Umberto Avenue, New Cumberland, PA 17070 -0262. 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 November 20, 2009, Melissa Roberts, A Single Person made, executed and delivered to Wells Fargo Bank, N.A. a Mortgage in the original principal amount of $115,204.00 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 December 2, 2009, Instrument #200940052. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 5. Plaintiff is the current mortgagee. 6. Melissa R. Roberts, a single woman is the record and real owner of the aforesaid mortgaged premises. 7. Defendants .are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due April 1, 2011. Zucker, Goldberg & Ackerman, LLC XCP- 153798 062 -PA -V3 8. As of 06/19/2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $ 113,075.24 Interest through 06/19/2013 $ 13,974.69 Escrow Advance $ 3,175.63 Late Charges $ 438.60 Inspection Fees $ 135.00 Total $ 130,799.16 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 Plaintiffs attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above - captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and /or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 10. This 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 XCP- 153798 062 -PA -V3 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $130,799.16 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER, GOLDBERG & ACKERMAN, LLC w BY: Dated: � a pt, Scot A. ietteric , squire, A I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XCP- 153798/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 USE FOR THAT PURPOS Zucker, Goldberg & Ackerman, LLC 062 - - XCP- 153798 EXHIBIT A Zucker, Goldberg & Ackerman, LLC 062 -PA -V3 XCP- 153798 NOTE, NOVEMBER 20, 2009 CAMP HILL [ c i ty] f rate] [arty] [Sta 1620 VALLEY RD, MECHANICSBURG, PA 17055 [Properly Address] I. BORROWER'S PROMISE TO PAY In keturn for a loan that I have received, I promise to pay U.S_ $ --***115,204. 00 (this amount is called "Principal "), plus interest, to the order of the Lender. The Lender is WELLS FARGO BANK, N.A- I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 5.375 %_ - The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the FIRST day of each month beginning onJANUARY 01, 2010 I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on DECEMBER 01, 2039 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly paymentsatWELLS FARGO HOME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ * ** *645.11 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." Whcn I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note_ I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal. that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Molder agrees in writing to those changes. a ers Kluwer mama ervices MULTISTATE FIXED RATE NOTE • Single Family - Fannie Mae /Freddie Mac UNIFORM INSTRUMENT ' r ��/j Form 3200 1101 MP O /�VMPSN ( 1 0 N MFL 3200 (CNOT) Rev 3/2009 Initials: / / Page age 1 0 0 o f 3 S. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then. (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (h) any sums already collected from me which exceeded permitted limits will he refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me- If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is titre, I will pay a late charge to the Note ]-folder. The amount of the charge will be 4.000 % of my overdue payment_of principal and interest. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default.. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that it I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not - been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by ine for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will' be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER TIIIS 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. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I 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 the Note Holder to demand payment of amounts due. "Notice of Dishonor "' means the right to require the Note I-folder to give notice to other persons that amounts due have not been paid. MULTISTATE FIXED RATE NOTE - Single Family - Fannie Mae/Freddie Mac UNIFORM INSTRUMENT 1/Ot 32 Form 00 VMP ® Fo �VMP5N 0003.00 Wolters Kluwer Flnanclal Services Initials: page of 3 11). UNIFORM SECURED NOTE This Note is a unifonn instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument "), dated the same date as this Note, protects the Note Holder from possible losses which-might result if I do.not keep the promises which I make in this Note. Tliat Security Instnimcnt describes how and under what conditions I may be required to make immediate payment in fill of all amounts I owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any, Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. (Seal) (Seal) MELISSA ROBERTS - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) Borrower - Borrower (Seal) (Seal) - Borrower - Borrower WITHOUT RECOURSE PAY TO THE ORDER OF WEL FAR00•131ANK, N.A. [Sign Original Only] BY NJ— '__... In M. M-116, Vlre PFes1def+ MULTISTATE FIXED RATE NOTE - Single Family - re Mae Fannie Mae/Freddie M UNIFORM INSTRUMENT - Fonn 3200 BIOS VMP5N (0803).00 Wolters Kluwer financial Services Page 3 or 3 EXHIBIT B Zucker, Goldberg & Ackerman, LLC XCP- 153798 062 -PA -V3 G i C F Exhibit A Legal Description 1620 Valley Rd. Mechanicsburg, PA 17055 E. Parcel No,:13 -26- 0251 -018 ALL THAT CERTAIN lot ofground situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, bounded and described according to a Plan as surveyed by William E, Sees, Jr., registered surveyor, dated April 3, 1953 as follows to wit: BEOINNiNG at a stake on the South side of a public road, now known as Valley Road, at lands now or formerly of Samuel[. Ritter; thence along said lands of Ritter, South 12 degrees 55 minutes East, one hundred eighteen and three- tenths (1 18.3) feet to a stake, said stake being twelve (12) feet, more or less, from The Yellow Breeches Creek thence along said Creek, South 59 degrees 45 minutes West, fifty and seven - tenths (50,7) feet to a stake at lands now or formerly of Mark 3. Lehmer and Helen F. Lehmer, his wife, North 10 degrees 55 minutes West, one hundred thirty- fourand eight- tenths (134.8) feet to a stake, at the South side of the aforementioned public road, now known as Valley Road; thence along said road, North 78 degrees 45 minutes East, forty -five and six - tenths (45.6) feet to a. stake, the place of BEGINNING VERIFICATION Nathaniel Orendain, hereby states tha he/ he is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that e/ 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 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: Nathaniel nd 'n Title: Vice Pres'd t oan Documentation Company: Wells Fargo Bank, N.A. Date: 06/24/2013 086 -PA -V2 File #: 153798 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION f.« Plaintiff, 112 _W� VS. NO.. l�� -rz Melissa R. Roberts; Defendant. t z 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 XCP- 153798 IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. TIDS PROGRAM IS FREE. ZUCKER, GOLDBERG & ACKERMAN, LLC By: Dated: June , 2013 Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Attorneys for Plaintiff XCP- 153798/ns 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XCP- 153798 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: CLISTOMER/PRI 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 ❑ If yes, provide names, location of court, case number & attorney: Zucker, Goldberg & Ackerman, LLC XCP- 153798 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 2 " Mortgage Utilities Car Payment(s) Condo /Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. payment Install. Loan Payment Cable TV Child Support /Alim. Spending Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Zucker, Goldberg & Ackerman, LLC XCP- 153798 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 tender 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 XCP- 153798 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Melissa R. Roberts; Defendant. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property, which is defendant's primary residence; 2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in 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 XCP- 153798 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Melissa R. Roberts; Defendant. 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 XCP- 153798 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 XCP- 153798 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 `Z)� Sheriff Jody S Smith �111 Chief Deputy3 Richard W Stewart Solicitor OFPCE OF T Z SRERIFF ._c Wells Fargo Bank, N.A. vs. Case Number Melissa R Roberts 2013-3824 SHERIFF'S RETURN OF SERVICE 07/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Melissa R Roberts, 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 1620 Valley Road, Lower Allen, Mechanicsburg, PA 17055. Residence is vacant. 07/22/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Melissa R Roberts, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 08/01/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of York County upon Melissa R Roberts, personally, at The York County Sheriffs Office, 45 North George Street, York PA 17401. Richard P. Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $53.00 SO ANSWERS, August 13, 2013 RONNY R ANDERSON, SHERIFF )ci CountySuite Sheriff,TeleosoR,Inc. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerfeber PETER J.MANGAN,ESQ. Sheriff Solicitor Reuben B Zeager y, Operations Richard E Rice,11 Chief Deputy, Chief Deputy,Administration WELLS FARGO BANK, N.A vs. Case Number MELISSA R. ROBERTS 13-3824 CIVIL SHERIFF'S RETURN OF SERVICE 08/01/2013 10:44 AM-SERVED THE REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE(CIMF) BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT,TO WIT: MELISSA R. ROBERTS AT THE YORK COUNTY SHERIFFS OFFICE, 45 NORTH GEORGE STREET, YORK, PA 17401. ASHLEY DdKLEY, DEPUTY SHERIFF COST $45.60 so RS, August 07,2013 RICHARD P KEMERLEBER, SHERIFF COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sheila E."Cook,=NotaryPubllc City of York,York County MY Commission b,1,2017 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES ------------------- ------------ ------ ------------- ---------------------------------------------------------- NOTARY Affirmed and subscribed to before me this 7TH day of AUGUST 2013 (c)CountySuite Sheriff,Teleosoft,Inc, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff No.: 13-384 IO vs. ISSUE NUMBER: Melissa R. Roberts; TYPE OF PLEADING: Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) Mortgaged Premises: 1620 Valley Road, Mechanicsburg, PA 17055-4854 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.: XCP-153798 �-rq C ) (Jr) - N :70't © - -) G C rT", < C-71 N % s hi 1 tot S () 11 0.A\ce.. NeC.■ Praecipe for Entry of Judgment Zucker,Goldberg&Ackerman, LLC XCP-153798 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, • • NO.: 13-3834 vs. • Melissa R. Roberts; •• Defendant. • • • PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s),for failure to file a response to Plaintiffs Complaint within the appropriate time limits from service thereof, and assess Plaintiffs damages as set forth in Complaint: Amount as set forth in Complaint $130,799.16 plus interest on the judgment amount($130,799.16)from June 20, 2013, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 22 Umberto Avenue 1620 Valley Road, address is: New Cumberland, PA Mechanicsburg, PA 17070-0262 17055-4854 ZUCKER, GOLBE' :�: K •MAN,,e Dated: BY: ��_�� /0 / ❑ Joel A.A5, .n, 'squire; I.D.#202729 � Ashleig' L. Marin, Esquire; PA I.D.#306799 Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XCP-153798 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com DAMAGES ARE HEREBY ASSESSED AS INDICATED Date oP l3 a <. Protho IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, • NO.: 13-38$4 vs. • Melissa R. Roberts; • Defendant. • • • AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. -- ZUCKER, GOLBER = - E' A Dated: BY: �L�� /0/ Joel A.Ac ,rman, Esquire; P I.D.#202729 /� Ashleigh L. Marin, Esquire; PA I.D.#306799 .pVJaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XCP-153798 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 p?...day of D G - , 20 13 -- Nota !slit My Commission Expires: poly Apbaneadto Notary Public RfiIilmi• ►�Flres Oct.16,2016 11 2260276 atAte 0 New Jersey Zucker,Goldberg&Ackerman, LLC XCP-153798 Results as of:Oct-21-2013 06:25:20 Department of Defense Manpower Data Center SCRA 3.0 ®F •: '';", Status Report ' ` Pursuit to Sery remembers Civil Relief Act Last Name: ROBERTS First Name: MELISSA Middle Name: R Active Duty Status As Of: Oct-21-2013 On Active Duty lift Active Duty Status Data Active Duty start Data Active Duty End Data Status Service Component NA NA "t`ta -.. NA This response reflects the Individuals'active duty status based on the Active Duty Status Date Left Active Dutywiihln 367 Days of Actve Duty Status Date Active Duty Start Date Active Duty End Date Status SeMce Component NA Rm^NA No NA y; r'. This response reflects where the individual left active duty S ttta tNBtin 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Cast-Up to Active Duly on Active Duty Statue Date Order Notification Start Date Order Noti icatton 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. )1/fit:tilt A r F,,,_... Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 • The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: C5RFT332L030120 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, • • • vs. NO.: 13-3814 • Melissa R. Roberts; • Defendant. • • • • NOTICE OF ORDER, DECREE OR JUDGMENT TO: Melissa R. Roberts 22 Umberto Avenue New Cumberland, PA 17070-0262 And 1620 Valley Road, Mechanicsburg, PA 17055-4854 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, ecrep or Judgment was entered in the above captioned r, proceeding on lay-(!I/3 [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $130,799.16 plus cc Oyer a vP�tSthonotary Zucker,Goldberg&Ackerman, LLC XCP-153798 Zucker,Goldberg&Ackerman, LLC XCP-153798 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • vs. NO.: 13-3834 • • Melissa R. Roberts • • Defendant. • • • • • IMPORTANT NOTICE TO: Melissa R. Roberts 22 Umberto Avenue New Cumberland, PA 17070-0262 DATE OF NOTICE: 10/2/2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten(10)days from the date of this notice,a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S.Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION • Plaintiff, • vs. • NO.: 13-3834 • Melissa R. Roberts • Defendant. • • • AVISO IMPORTANTE TO: Melissa R. Roberts 22 Umberto Avenue New Cumberland, PA 17070-0262 FECHA DEL AVISO:10/2/2013 LISTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERJDA EN ESTE CASO. A MENOS QUE LISTED TOME ACCION DENTRO DE LOS PROMOS 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 &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER,GOLDBERG &ACKERMAN BY: Scott A. D ietteridc Scott A. Dietterick,Esquire Attorneys for Plaintiff PA I.D. # 55650 200 Sheffield Street, Suite 301 P.D. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 153798 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • vs. NO.: 13-3834 • • Melissa R. Roberts • • Defendant. • • • • • IMPORTANT NOTICE TO: Melissa R. Roberts 1620 Valley Road, Mechanicsburg, PA 17055-4854 DATE OF NOTICE: 10/2/2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten(10)days from the date of this notice,a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND& LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 13-3834 Melissa R. Roberts • Defendant. • • • • • AVISO IMPORTANTE TO: Melissa R. Roberts 1620 Valley Road, Mechanicsburg, PA 17055-4854 FECHA DEL AVISO:10/2/2013 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIVIOS 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 OFIC1NA 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: 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 153798 SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber �� ' v�� PETER J.MANGAN oES 531 Q.ci ter. Reuben B Zeager _ Richard E Rice, II Chief Deputy, Operations " R Chief Deputy,Administration WELLS FARGO BANK, N.A Case Number vs. MELISSA R. ROBERTS 13-3824 CIVIL SHERIFF'S RETURN OF SERVICE 08/01/2013 10:44 AM-SERVED THE REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE(CIMF) BY "PERSONALLY"HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT,TO WIT: MELISSA R. ROBERTS AT THE YORK COUNTY SHERIFF'S OFFICE,45 NORTH GEORGE STREET,YORK, PA 17401. ASHLEY DdLEY, DEPUTY SHERIFF COST: $45.60 SO z RS, 4 August 07,2013 RICHARD P KE;ER EB R, SHERIFF COMM_ ONWEALTH 4F PENNSYLVANIA Notarial Seal Sheila E.Cook,Notary Public City of York,York County My Commission •lres Feb.1 2017 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES NOTARY Affirmed and subscribed to before me this 7TH day of AUGUST 2013 'f 41-e7 (C)GoantySato Sheriff,?eleosort.Inc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Wells Fargo Bank, N.A., vs. Melissa R. Roberts; Plaintiff, Defendant. TO THE PROTHONOTARY OF THE SAID COURT: File No. 13-3824 Amount Due $130,799.16 Interest from 06/21/2013 to date of sale $11,409.57 Costs CZ rW� c�v ' _W — C'. c_ —r The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). Zucker, Goldberg & Ackerman, LLC XCP-153798 (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: (0110/ 14 Signature: CAI Ai L. Print Name: Scott A. Dietterick, Esquire; P .D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Address: Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 a$ • 5a- Po Ani 53. oo CBF 1153:75 " I(n.5o " c90 - PO Air/ 50 L•L &t X 711 of -300533 QE 606+4z.uS Zucker, Goldberg & Ackerman, LLC XFP-153798 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., Plaintiff, vs. Melissa R. Roberts; Defendant(s). CIVIL DIVISION NO.: 13-3824 Execution No.: 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 1620 Valley Road, Mechanicsburg, PA 17055-4854. 1. Name and Address of Owner(s) or Reputed Owner(s): MELISSA R. ROBERTS, A SINGLE WOMAN 22 Umberto Avenue New Cumberland, PA 17070-0262 AND 1620 Valley Road, Mechanicsburg, PA 17055-4854 2. Name and Address of Defendant(s) in the Judgment: MELISSA R. ROBERTS 22 Umberto Avenue New Cumberland, PA 17070-0262 AND 1620 Valley Road, Mechanicsburg, PA 17055-4854 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, N.A. Plaintiff 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, N.A. Plaintiff Zucker, Goldberg & Ackerman, LLC XCP-153798 5. Name and Address of every other person who has any record lien on the property: LOWER ALLEN TWP 1993 Hummel Avenue, Camp Hill, 17011 AND C/O BONNIE K. MILLER 2233 Gettysburg Rd Camp Hill PA 17011 WEST SHORE SCHOOL DISTRICT 507 Fishing Creek Road P.O. Box 803, New Cumberland, Pennsylvania 17070-0803 AND C/O BONNIE K. MILLER 2233 Gettysburg Rd Camp Hill PA 17011 CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 PRIVATE PA AMERICAN 800 W Hersheypark Dr Hershey, PA 17033 LOWER ALLEN TWP AUTH 120 Limekiln Road New Cumberland, PA 17070 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 Zucker, Goldberg & Ackerman, LLC XCP-153798 UNKNOWN TENANT OR TENANTS 1620 Valley Road Mechanicsburg, PA 17055-4854 UNKNOWN SPOUSE 22 Umberto Avenue New Cumberland, PA 17070-0262 AND 1620 Valley Road, Mechanicsburg, PA 17055-4854 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: (af I, ZUCKER, GOLDBERG & ACKERMAN, LLC BY: ahra, 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 XCP-153798/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XCP-153798 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. Melissa R. Roberts; Plaintiff, Defendant. CIVIL DIVISION NO.: 13-3824 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 MELISSA R. ROBERTS 1620 Valley Road, Mechanicsburg, PA 17055-4854 AND 22 Umberto Avenue New Cumberland, PA 17070-0262 TAKE NOTICE: rri { r C,0 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 December 3, 2014 at 11: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: 1620 Valley Road, Mechanicsburg, PA, 17055-4854 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 13-3824 Zucker, Goldberg & Ackerman, LLC XCP-153798 THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Melissa R. Roberts, a single woman A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. Zucker, Goldberg & Ackerman, LLC XCP-153798 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 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: Lp (Cf ( 14 ZUCKER, GOLDBERG & ACKERMAN, LLC BY: moi - 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 XCP-153798/sde 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 XCP-153798 Exhibit "A" LEGAL DESCRIPTI.ON ALL THAT CERTAIN lot of ground situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, bounded and described according to a Plan as surveyed by William E. Sees, Jr., registered surveyor, dated April 3, 1953 as follows to wit: BEGINNING at a stake on the South side of a public road, now known as Valley Road, at lands now or formerly of Samuel I. Ritter; thence along said lands of Ritter, South 12 degrees 55 minutes East, one hundred eighteen and three -tenths (I 18.3) feet to a stake, said stake being twelve (I 2) feet, more or less, from the Yellow Breeches Creek thence along said Creek, South 59 degrees 45 minutes West, fifty and seven -tenths (50.7) feet to a stake at lands now or formerly of Mark 3. Lehmer and Helen F. Lehmer, his wife, North 10 degrees 55 minutes West, one hundred thirty-four and eight -tenths (134.8) feet to a stake, at the South side of the aforementioned public road, now known as Valley Road; thence along said road, North 78 degrees 45 minutes East, forty-five and six -tenths (45.6) feet to a stake, the place of BEGINNING. HAVING thereon erected a dwelling house being known and numbered as 1620 Valley Road, Mechanicsburg, PA, 17055-4854. BEING the same premises which Timothy F. Straub and Marisa A. Straub, his wife, and Calvin W. Williams, a single man, by Deed dated October 16, 2009 and recorded December 2, 2009 in and for Cumberland County, Pennsylvania, in Deed Book Volume , Page Instrument #200940051, granted and conveyed unto Melissa R. Roberts, a single woman. Tax Map No.: 26-0251-0018-0000000-13. Zucker, Goldberg & Ackerman, LLC XCP-153798 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net WELLS FARGO BANK, N.A. Vs. MELISSA R. ROBERTS WRIT OF EXECUTION NO 13-3824 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $130,799.16 L.L.: $ .50 Interest from 6/21/13 to date of sale -- $11,409.57 Atty's Comm: Due Prothy: $2.25 Atty Paid: $201.75 Other Costs: Plaintiff Paid: Date: 7/16/14 (Seal) David D. Buell, Prothonota 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., vs. Melissa R. Roberts; Plaintiff, Defendant. CIVIL DIVISION NO.: 13-3824 TYPE OF PLEADING w-. Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: Wells Fargo Bank, N.A. COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 Ashleigh Levy Marin, Esquire -PA I.D. #306799 Ralph M. Salvia, Esquire- PA I.D. #202946 Jaime R. Ackerman, Esquire- PA I.D. #311032 Jana Fridfinnsdottir, Esquire- PA I.D. #315944 Brian Nicholas, Esquire- PA I.D. #317240 Denise Carlon, Esquire- PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XCP- 153798/mag Zucker, Goldberg & Ackerman, LLC XCP-153798 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. vs. Melissa R. Roberts; Plaintiff, Defendant. CIVIL DIVISION NO.: 13-3824 Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Margaret Agyepong, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, N.A., being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriff's Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Melissa R. Roberts, a single woman, is the record owner of the real property. 2. On or about October 27, 2014, defendant Melissa R. Roberts was served with Plaintiff's Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, personally by the Sheriff of Cumberland County, at the address of 22 Umberto Avenue, New Cumberland, PA 17070-0262. A true and correct copy of said Notice and Return of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about October 14, 2014, Plaintiffs counsel served all other parties in interest with Plaintiffs Notice of Sheriff's Sale according to Plaintiff's Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing. True and correct copies of said Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of Zucker, Goldberg & Ackerman, LLC XCP-153798 Interest were served with Plaintiffs Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P. 3129.2. Dated: November 5 , 2014 Sworn to and subscribed before me this C day of ov- mber, 2014 y Public MY COMMISSION EXPIRES: ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff MARGARET YEPONG Para leg Legal Assistant JANELL URLIN NOTARY PUBLIC OF NEW JERSEY ID # 2364963 My Commission Expires 10117/2017 Zucker, Goldberg & Ackerman, LLC XCP-153798 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XCP-153798 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY oty Qt Ctnrtb OFFICE OF ME $!i£RIFF Wells Fargo Bank, N.A. vs. Melissa R Roberts Case Number 2013-3824 SHERIFF'S RETURN OF SERVICE 07/24/2014 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: Melissa R. Roberts, but was unable to locate the Defendant in his bailiwick. He therefore deputized the Sheriff of York County to serve the within Real Estate Writ, Notice and Description, in the above titled action, according to law. 09/29/2014 02:06 PM - Deputy Shawn Gutshall, 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 1620 Valley Road, Lower Allen - Township, Mechanicsburg, PA 17055, Cumberland County. 10/27/2014 The requested Real Estate Writ, Notice and Description, in the above titled action, served by the Sheriff of York County upon Melissa R. Roberts, personally, at 22 Umberto Avenue, New Cumberland, PA 17070 on 10/16/14 at 1653 hrs. So Answers: Tyler Stepanchick, Sheriff. SHERIFF COST: $986.54 SO ANSWERS, October 27, 2014 c) ountySu: e Srierit', Telex Qtt, inN' RSON, SHERIFF ONZ(NDER Zucker, Goldberg & Ackerman, LLC XCP-153798 Page 1 of 7 NOTICE TO LIENHOLDERS UNITED STATES POST/]L SERVICE Certificate 0 Mailing This Certificate of Mailing provides evidence that mail has been presented to USPS• for mailing. This form may be used for domestic and International mall From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-153798/sde TEAM- C T°' UNKNOWN TENANT OR TENANTS 1620 Valley Road Mechanicsburg, PA 17055-4854 U.S. POSTAGE »RTNEYRf) Es ZIP 07092 $ O07e200 02 1r1 0001396603 OCT 14 2014 To pay fee, affix stamps or meter postage here. Postmark Here County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE Certificate Of Mailing This Cartlfkate o1 Malting provides evidence that mall has been presented to USP5• for mailing. This form may be used for domestic a,4 International mag.. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-153798/sde TEAM!C COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 1710r t'1 ,.10E0906£1 000 MI, Z0 QOZ. OO $ �60L0 dIT .d+rr.�tgww+rs� ' w .- - To pay fee, affix stamps or meter postage here. Fos Page 2 of 7 NOTICE TO LIENHOLDERS UNITED STATES POSTAL SERVICE® 4 Certificate Of Mailing This Certificate of Mailing provides evidence that mail has been presented to USPS• for mailing. This form may be used for domestic and International mail. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Tet CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 XCP-153798/sde TEAM- C U.S POSTAGE ») PITNEY BOWES tit, •=111111imor .n ZIP n7092 $ 001.200 02 in 0001396603 OCT 14 20t4 To pay fee, affix stamps or meter postage here. County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTM 5E1mc Certificate Of Mailing .. - To pay fee, affix stamps or meter postage here. This Certificate of Mailing provides evidence that mail has been presented to USPS for mailing. This form may be used for domestic and International mail. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-153798/sde TEAM- C Tet UNKNOWN SPOUSE 1620 Valley Road, Mechanicsburg, PA 17055-4854 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 V4OZ vt .L00 S0996C 1000 ML ZO 00Z. 100 $ Z60/0 dIZ al...w./1=`16.01 53M09 A3N.Ud «3OVISOd'S'n Postmark Here Page 3 of 7 NOTICE TO LIENHOLDERS UNITED ST/1TE5 POSTAL SERVICE. Certificate 0 Mailing U.S, POSTAGE» PITNEY BOWES This Certificate of Mailing provides evidence that mail has been presented to USPS' for and international mall. °ram' Scott A. Dietterick, Esquire iling, This form may be used for domestic c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-153798/sde TEAM- C To' PRIVATE PA AMERICAN 800 W Hersheypark Dr Hershey, PA 17033 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 unnrEQsrnrEs CM POSTAL SERVICE' Certificate Of Mailing This Certificate of MaNing provides evidence that mall has been presented to USW for mailing. This form may be used for domestic and international mall. Fr"' Scott A. Dietterick, Esquire c/o Zucker, Goldber Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-153798/sde TEAM- C To' LOWER ALLEN TWP AUTH 120 Limekiln Road New Cumberland, PA 17070 County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 TIM 1't 10P609966t000 AOZ1.00 $ Z6040 dIZ =0"..=:•sviz—d- samai A3N,jj 30v190d,s'n ZIP 07092 $ 001.200 02 VI 00013966030CT 14 2014 To pay fee, affix stamps or meter postage here. Postmark Here To pay fee, affix stamps or meter paataga here. Page 4 of 7 NOTICE TO LIENHOLDERS pUNITED ST/]TES POSTAL SERVICE® Certificate 0 Mailing U.S. POSTAGE» PITNEY EIGWES This Certificate of Mailing provides evidence that mail has been presented to USPS for mailing. This form may be used for domestic and international mail. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-153798/sde TEAM- C Tet WEST SHORE SCHOOL DISTRICT C/O BONNIE K. MILLER 2233 Gettysburg Rd Camp Hill PA 17011 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES Min P05TJ11SER17ICE@ Certificate Of Mailing ZIP 07092 $ 001.200 02 1l'4 0001396603OCT 14 2014 To pay fee, affix stamps or meter postage here. This Certificate of Meiling provides evidence that mall has been presented to USPS* for mailing. This form may be used for domestic and international mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-153798/sde TEAM- C Te' WEST SHORE SCHOOL DISTRICT 507 Fishing Creek Road P.O. Box 803, New Cumberland, Pennsylvania 17070-0803 Postmark Here County of P.O.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 010Z 41 1008099601000 MI ZO Z60L0 dr?. 00Z" COO $ S.714°9 Ak41.1d «39'L To pay fee, affix stamps or meter postage here. Postmark Here Page 5 of 7 NOTICE TO LIENHOLDERS UNITED STATES � .."*„1:11 POSTAL SERVICE® Certificate 0 Mailing U.S. POSTAGE» PITNEY BOWES This Certificate of Mailing provides evidence that mail has been presented to USPS* for mailing. This form may be used for domestic and International mall. From' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-153798/sde TEAM- C T°' LOWER ALLEN TWP C/O BONNIE K. MILLER 2233 Gettysburg Rd Camp Hill PA 17011 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ,UNITED,STATES POSTAL SERVICEt sme%►""ea e mineneueir 0a 04/092 $ 001 200 0001396603 OCT 14 2014 To pay fee, affix stamps or meter postage here. Postmark Here Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS* for mailing. This form may be used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-153798/sde TEAM- C T°t LOWER ALLEN TWP 1993 Hummel Avenue, Camp Hill, 17011 County of P.Q.: CUMBERLAND PS Form 3817, AprII 2007 PSN 7530-02-000-9065 41.0Z 4t 190E0996E 000 Mt ZO 0Or1000 $ Z60L0 dIZ y S3M08A3N1Id<<3OVISOd Sfl To pay fee, affix stamps or meter postage here, Postmark Here Page 6 of 7 NOTICE TO LIENHOLDERS PUNITE”) STATES -11 F'OSTAL SERVICE Certificate 0 Mailing This Certificate of Milling provides evidence that mall has been presented to USP • for mailing. This form may be used for domestic and international mall. Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, Ni 07092 XCP-153798/sde TEAM- C 70; CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES POSTAL SERVICE@ Certificate Of Mailing This Certificate of Mailing provides evidence that mill his been presented to UPS• for mailing. This form may be used for domestic and International mall. rmnu Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, Ni 07092 XCP-153798/sde TEAM- C T°' PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 County of P.Q.: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 41.04 C0996 El, 000 ZO 00Z 1,00 $ 514°11A1NildC 35)V.1.90d-sn U.S. POSTAGE* PITNEY BOWES k'Lr'— wffilftimmer ZIP 07092 $ 001 20° 02 111 000 1396603 OCT 14 2014 To pay fee, affix stamps or meter postage here. Postmark Here To pay fee, affix stamps or meter postage here. Pcistmark fin Page 7 of 7 NOTICE TO LIENHOLDERS UNITED STATES Cali POSTAL SERI/lCE8 Certificate 0 Mailing This Certificate of Mailing provides evidence that mail has been presented to USW for mailing, This form may be used for domestic and International mail. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XCP-153798/sde TEAM- C T°' UNKNOWN SPOUSE 22 Umberto Avenue New Cumberland, PA 17070-0262 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 4100 41 100£0996£I000 o0Z-1000 $ x6010 dIZ r..:-�.=..1imisor.ammondieG 111)$ S3MMB A3Nlld «3Ot/LSOeJ 's"n ZIP 07092 $ 001.20° 02 111 0001396603 OCT 11 2014 To pay fee, ON stamps or meter postage here, Postmark Here