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Home My WebLink About13-3957 Supreme Court -of Pennsylvania Cour 1of C�mon Pleas rt'Y . CiV11'COVer, Sleet For Prothonotary Use Only: 6ND [ County Docket No: CUMBE 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 lmv or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiffs Name: Wells Fargo Bank, N.A. Lead Defendant's Name: Wayne Morris C T Are money damages requested ?: ❑ Yes ® No Dollar Amount Requested: within arbitration limits I (Check one) X outside arbitration limits O N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No Name of Plaintiff /Appellant's Attorney: Scott A. Dietterick, Esq. c/o Zucker, Goldberg & Ackerman, LLC A ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution [] Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not include S mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I MASS TORT ❑ Other: O C Asbestos ❑ Tobacco N ❑ Toxic Tort- DES ❑ Toxic Tort- Implant REAL PROPERTY MISCELLANEOUS El Toxic Waste ❑ Other: ❑Ejectment ❑Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment B ❑ Ground Rent F1 mandamus Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABLITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1//2011 Zucker, Goldberg & Ackerman, LLC XVP- 175897 062 -PA -V3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., CIVIL DIVISION Plaintiff, NO.: VS. TYPE OF PLEADING Wayne Morris; CIVIL ACTION - COMPLAINT Defendant. IN MORTGAGE FORECLOSURE TO: DEFENDANT FILED ON BEHALF OF: YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS Wells Fargo Bank, N.A. FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OFTHE PLAINTIFF IS: Z GOLDBERG & ACKERMAN, LLC 3476 Stateview Blvd. Ft. Mill, SC 29715 Scott A. Dietterick, Esquire AND THE DEFENDANT: Pa. I.D. #55650 4833 Brian Road Kimberly A. Bonner, Esquire Mechanicsburg, PA 17050 -3014 Pa. I.D. #89705 Joel A. Ackerman, Esquire C - - Pa I.D. #202729 C: CERTIFICATE OF LOCATION Ashleigh Lev Marin, ES Uire J -0 _ —Z I HEREBY CERTIFY THAT THE LOCATION OF g Y q zizl I =T1 i THE REAL ESTATE AFFECTED B THIS LIEN IS Pa I.D. #306799 4833 Brian Road MechaniWurR PA 17050-3014 Cn Municipality: Ham de Ralph M. Salvia, Esquire s CYam Pa I.D. #202946 Jaime R. Ackerman, Esquires CD i ATTORNE F PLAINTIFF Pa I .D. #311032 : ATTY Fl E NO.: XVP 175897 200 Sheffield Street, Suite 101 : f Mountainside, NJ 07092 (908) 233 -8500 (908) 233 -1390 FAX office @zuckergoIdberg.com File No.: XVP- 175897/mme S C/G Aso J� a old g s0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.. VS. Wayne Morris; 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, NO.: VS. Wayne Morris; 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. Usted puede perder dinero o propiedades u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PLIEDE 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, NO.. VS. Wayne Morris; 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, Wayne Morris, is an individual whose last known address is 4833 Brian Road, Mechanicsburg, PA 17050 - 3014. 3. Wells Fargo Bank, N.A., directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit A, attached hereto and made a part hereof. 4. On or about March 10, 2009, Wayne Morris, a single man made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for Franklin American Mortgage Company a Mortgage in the original principal amount of $171,551.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on March 25, 2009, Instrument #200909028. 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. By Assignment of Mortgage recorded November 7, 2012, the mortgage was assigned to Wells Fargo Bank NA which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument #201234522. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. Zucker, Goldberg & Ackerman, LLC XVP- 175897 062 -PA -V3 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of ,public record. 6. Wayne Morris, single individual 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 September 1, 2012. 8. As of 06/21/2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $ 162,933.12 Interest through 06/21/2013 $ 7,958.83 Escrow Advance $ 560.91 Late Charges $ 459.48 Inspection Fees $ 170.00 Total $ 172,082.34 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 XVP- 175897 062 -PA -V3 1 . WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $172,082.34 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, GOLDBER ACK RM , LLC BY: Dated: � Scott A. Aetterick, 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 XVP- 175897/mme 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (9p8) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WI LL BE USED FO TH PURPOSE. Zucker, Goldberg & Ackerman, LLC XVP- 175897 062 -PA -V3 EXHIBIT A 1 Zucker, Goldberg & Ackerman, LLC XVP- 175897 062 -PA -V3 -,Now MORRIS Loan NumL_ -.— — Case N MIN / NOTE NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUT THE APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. MARCH 10, 2009 CAMP HILL , PENNSYLVANIA [Date] [City] [Stale] 4833 BRIAN ROAD, MECHANICSBURG, PENNSYLVANIA 17050 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ 171,551.00 (this amount is called "Principal "), plus interest, to the order of the Lender. The Lender is FRANKLIN AMERICAN MORTGAGE COMPANY 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 5.500 %. 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. MULTISTATE FIXED RATE NOTE -- Single Family -Famile Mae /Freddie Mae UNIFORM INSTRUrvMNT Form 3200 1 /01 AMENDED FOR VA (page l of 0 pages) GV1238.HP I will make my monthly payment on the 1ST day of each month beginning on MAY 1, 2009 . I will make these payments every month until 1 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 APRIL 1, 2039 I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." 1 will make my monthly payments at 501 CORPORATE CENTRE DRIVE, SUITE 400, FRANKLIN, TENNESSEE 37067 or at a different place if requited by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ 974.05 4. BORROWER'S RIGHT TO PREPAY The Borrower shall have the right to prepay at any time, without premium or fee, the entire indebtedness or any part thereof not less than the amount of one installment, or $100, whichever is less. Any Prepayment -in -full of the indebtedness shall be credited on the date received, and no interest may be charged thereafter. Any partial Prepayment made on other than an installment due date need not be credited until the next following installment due date or 30 days after such Prepayment, whichever is earlier. The Note Holder and the Borrower may agree at any time that any Prepayment not previously applied in satisfaction of matured installments shall be reapplied for the purpose of curing or preventing any subsequent default. 5. 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 (b) any sums already collected from me which exceeded permitted limits will be 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 FIFTEEN calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 4.00% of my overdue payment. 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 if 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 1 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 me 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 [nail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. MULTI T FE FIXED RATE NOTE.-Single Family- -Femde Mac /Freddie Mae UMFOR10 INSTRUMENT /G 2 of 4 001/0 GV 123a.HP 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 THIS NOTE If more than one person signs this Note, each person is hilly 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 Holder to give notice to other persons that amounts due have not been paid. 10. ALLONGE TO THIS NOTE If an allonge providing for payment adjustments or for any other supplemental information is executed by the 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] • Graduated Payment Allonge • Other: [specify] 11. UNIFORM SECURED NOTE This Note is a uniform 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. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: Regulations (38 C.F.R. Part 36) issued under the Department of Veterans Affairs ( "VA ") Guaranteed Loan Authority (38 U.S.C. Chapter 37) and in effect on the date of loan closing shall govern the rights, duties and liabilities of the parties to this loan and any provisions of this Note which are inconsistent with such regulations are hereby amended and supplemented to conform thereto. MULTISTATE FIXED RATE NOTE -- Single Family-- Fannle Mae /Freddie Mac UNIFORM INSTRUMENT Form 3200 1/01 AMENDED FOR VA (page 3 of pager) OV 1238.HP i WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED (Seal) (Seal) WAYNE MO S - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower [Sign Original Only] WITHOUT RECOURSE PAY TO THE ORDER OF / PAY TO THE ORDER OF Wells Fargo Bank, PI.A. Wells Fargo Bank, N.A. WITHOUT RECOURSE FRANK IN AMERICA MOR(_L 1TGAAG�IE COMPANY By William R. Martin Vlce President Beznita J. Hill Sr. P. MULTISTATE FIXED RATE NOTE — Single Family.- Fannie Mae/Freddle Mae UNIFORM INSTRUMENT (pa Fo 4 32 pages 1 AM FOR VA GV I238.HP EXHIBIT B Zucker, Goldberg & Ackerman, LLC XVP- 175897 062 -PA -V3 EXHIBIT "A" ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows, to wit: BEGINNING at a point on the northern line of Donald Road, since renamed Brian Road, at the division line between Lots Nos. 2 and 3, Block "E" on the hereinafter mentioned Plan of Lots; thence northwardly along said dividing line, 120 feet to a point; thence North 84 degrees 32 minutes East, 68 feet to a point at the .dividing line between Lots Nos. 3 and 4, Block "E" on said Plan; thence southwardly along same, 122.51 feet to a point on the northerly line of Donald Road, since renamed Brian Road; thence westwardly along same, 68.05 feet to a point, the place of BEGINNING. BEING Lot No. 3, Block "E" on Plan No. 3 of Del -Brook Manor, said Plan recorded in Plan Book 8, Page 11, Cumberland County records. HAVING THEREON ERECTED a brick and frame ranch dwelling. BEING THE SAME PREMISES which Linda J. Davis, single individual, by Deed dated October 15, 2007 and recorded October 17, 2007 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, at Instrument No. 200739739, granted and conveyed unto Wayne Morris, single individual. i IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: CIO �_ ,l Wayne Morris; Defendant. M cn ma G CD -0 O NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE > DIVERSION PROGRAM p 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 fo rwa rd. Zucker, Goldberg & Ackerman, LLC XVP- 175897 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 & AC AN, LLC By: Dated: July, 2013 Scott A. Dietter' k, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R, Ackerman, Esquire; PA I.D. #311032, Attorneys for Plaintiff XVP- 175897/ns 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XVP- 175897 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 XVP- 175897 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. I Spending Money Day /Child Care /Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Zucker, Goldberg & Ackerman, LLC XVP- 175897 Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I /We, , authorize the above named to use /refer this information to my lender / servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /We understand that I /we am /are under no obligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: V Proof of Income V Past 2 bank statements J 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 XVP- 175897 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.. VS. Wayne Morris; 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 XVP- 175897 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.: VS. Wayne Morris; 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 XVP- 175897 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 XVP- 175897 + n 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 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: Natha Title: Vice P oc umentation Company: W, N.A. Date: 06/27/2013 File #: 175897 086 -PA -V2 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-0 r FIC Sheriff - 1Pr i Pi'c� l II0I� �tit�if Jody S Smith i JUL 19 PM Chief Deputy Richard W Stewart . COUNTY solicitor �` PENNSYLVANIA Wells Fargo Bank, N.A. Case Number vs. Wayne Morris 2013-3957 SHERIFF'S RETURN OF SERVICE 07/12/2013 03:45 PM-Deputy Amanda Cobaugh, being duly swom according to law, served the requested Complaint& Notice by"personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Wayne Morris at 4833 Brian Road, Hampden Township, Mechanicsburg, PA 17050, A ANDA COBAUGH, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, ;i July 15,2013 RbNW R ANDERSON, SHERIFF (c)CountySuite Sheriff,Teleosoit,Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff No.: 2013-03957 vs. ISSUE NUMBER: Wayne Morris; TYPE OF PLEADING: Defendant(s). PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) Mortgaged Premises: 4833 Brian Road, Mechanicsburg, PA 17050-3014 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 2, `T1 Mountainside, NJ 07092 row c (908) 233-8500 File No.: XVP-175897 = x- o _o := > ° ---+ �.- 1;1 t S.9d a 14. CAL a31 Praecipe for Entry of Judgment Zucker, Goldberg&Ackerman, LLC Nochu XVP-175V7 (c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • vs. NO.: 2013-03957 • Wayne Morris; 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 Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $172,082.34 plus interest on the judgment amount($172,082.34)from June 22, 2013, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 4833 Brian Road address is: Mechanicsburg, PA 17050- 3014 ZUCKER, GOLBERG &ACKERMAN, LLC Dated: 60 /3 BY: I A ,i a l Joe A.Ac erman, Esquire; •A I.D.#202729 V Ashleigh L. Marin, Esquire; PA I.D.#306799 Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XVP-175897 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 3•14Arm.i. C3 ttft, eP Date b Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • vs. NO.: 2013-03957 Wayne Morris; • 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. / ZUC ER, GOLBERG &ACK,ERMAN, LLC Dated: `ol/a! t. BY: I_• hi IL/ la I Joe A A ckerman, Esquire; PA I.D.#202729 rq Ashleigh L. Marin, Esquire; PA I.D.#306799 Jaime R.Ackerman, Esquire; PA I.D.#311032 Attorneys for Plaintiff XVP-175897 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 Z. day of 0C4-- , 20 /3 Notary Pu y`is My Commission Expires: Cheryl rebeneadto Notary Public StateExpires Oct. 16,2016 of NeW0276 Jersey Zucker,Goldberg&Ackerman, LLC XVP-175897 Results as of:Sep-30-20t3 10:58:27 Department of Defense Manpower Data Center SCRA 3.0 .ia6`f. '`" ; Status Report Pursuant to Servicemembers Civil Relief Act Last Name: MORRIS First Name: WAYNE Middle Name: Active Duty Status As Of: Sep-30-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA"4/ :L, _ _. —.,,G NA o� This response reflect the intlivlduals'active duty status based orithe Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA 1 Nor NA This response reflects where the IndMdual left active duty status within 367 days preceding the Active Duty Status Data .\ ! I The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component•NA '.NA _ r;No J NA This response reflects whether the individual or his/her unit has received early notification to report for active duty I, 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. Yhat yA. _ _ 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: 040484FCP01A920 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • NO.: 2013-03957 vs. • Wayne Morris; Defendant. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Wayne Morris 4833 Brian Road Mechanicsburg, PA 17050-3014 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, De ree or Judgment was entered in the above captioned proceeding on t v/`1/.3 [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows:$172,082.34 plus cos Zucker,Goldberg&Ackerman, LLC XVP-175897 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, • vs. NO.: 2013-03957 • Wayne Morris • Defendant. •• • • IMPORTANT NOTICE TO: Wayne Morris 4833 Brian Road Mechanicsburg, PA 17050-3014 DATE OF NOTICE: 8/20/2013 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you.Unless you act within Ten(10)days from the date of this notice,a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 • • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 2013-03957 Wayne Morris • Defendant. • • • • AVISO IMPORTANTE TO: Wayne Morris 4833 Brian Road Mechanicsburg, PA 17050-3014 FECHA DEL AVIS0:8/20/2013 USTED ESTA EN REBELDIA PORQUE HA FALLAD O DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A Iv1ENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIIMIOS 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 INivIEDLATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICJNA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE T O 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 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 175897 _..---....■•■•••■••11111111111111111.11 . . SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FLED-OFFICE Sheriff \or of<woof, Cr THE PROTHONOTARY Jody S Smith 4foill Chief Deputy 7013 JUL 19 PH 3: 0 1 Richard W Stewart CUMBERLAND COUNTY Solicitor °MICE OC TKE PENNSYLVANIA Wells Fargo Bank, N.A. v Case Number 2013-3957 s. Wayne Morris SHERIFF'S RETURN OF SERVICE 07/12/2013 03:45 PM-Deputy Amanda Cobaugh,being duly sworn according to law,served the requested Complaint&Notice by"personally"handing a true copy to a person representing themselves to be the Defendant,to wit:Wayne Morris at 4833 Brian Road, Hampden Township, Mechanicsburg,PA 17050. " ILAPA •4 tjtis # A ANDA COBAUGH,DUTY SHERIFF COST: $39.30 SO ANSWERS, g July 15,2013 RONNY R ANDERSON,SHERIFF • (clCaontySuite SbaMt.Teleosolt Ina 1111.111111111111111111"r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. • CIVIL DIVISION Plaintiff, • NO.: 2013-03957 vs. ;: Wayne Morris; • • Defendant. , c� • • c PRAECIPE TO SATISFY JUDGMENT -' TO THE PROTHONOTARY: Please mark the judgment filed at the above-captioned term and number satisfied without prejudice. Respectfully submitted: ZUCKER, GOLDBERG ERMAN, LLC By: AL."' Dated: December 2, 2013 Scott A. Die er ' Esquire`PA I.D. #55650 Kimberly A. Banner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D. #311032--- Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Attorneys for Plaintiff XVP-175897/dcr 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com 004 9,scpa C 61P297 ()1 .38 ra Zucker,Goldberg&Ackerman,LLC XVP-175897