HomeMy WebLinkAbout13-4369 Supreme Cour.-t.of Pennsylvania
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COUrOI CYPleas For Prothonotary Use Only:
Civil�CoveA� Sheet ry rib S
CUMBE)AND1 X r C o unty Docket No: rq
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The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court.
S Commencement of Action:
D Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiff s Name: WELLS FARGO BANK, N.A. Lead Defendant's Name: MASOOD AHMED
T
I Are money damages requested? El Yes OD No Dollar Amount Requested: El within arbitration limits
0 (Check one) ❑x outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ❑x No Is this an MDJ Appeal? ❑ Yes 0 No
A Name of Plaintiff/Appellant's Attorney: Melissa J. Cantwell Esq. , Id. No.308912, Phelan Hallinan, LLP
❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
• Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
• Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
• Nuisance ❑ Dept. of Transportation
• Premises Liability ❑ Statutory Appeal: Other
• Product Liability (does not
S include mass tort) ❑ Employment Dispute:
• Slander/Libel/ Defamation Discrimination
E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board
C ❑ Other:
T
I MASS TORT ❑ Other:
0 ❑ Asbestos
N ❑ Tobacco
• Toxic Tort - DES
• Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
❑ Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration
B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
® Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑ Other:
❑ Other:
❑ Medical
❑ Other Professional:
Pa.R.C.P, 205.5 Updated 01101/2011
PR 0
rUMBERLAND CoLq,jp
P DghjS`(LVAN1A
PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF
Melissa J. Cantwell, Esq., Id. No.308912
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Melissa.Cantwell@phelanhallinan.com
215 -563 -7000
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.
3476 STATEVIEW BOULEVARD CIVIL DIVISION
FORT MILL, SC 29715
Plaintiff, NO.: , �f vy & 9 1 U/
vs.
MASOOD AHMED
GUL BUSHRA
67 JOHNS DRIVE
ENOLA, PA 17025 -2694
Defendants.
CIVIL ACTION — COMPLAINT IN MORTGAGE FORECLOSURE
And now comes WELLS FARGO BANK, N.A., by its attorneys, Phelan Hallinan, LLP
and files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is WELLS FARGO BANK, N.A., 3476 STATEVIE S-
BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff').
Q a
062-PA-V3
2. The Defendants, MASOOD AHMED and GUL BUSHRA, are individuals whose
last known address are 67 JOHNS DRIVE, ENOLA, PA 17025 -2694.
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 30, 2010, MASOOD AHMED and GUL BUSHRA made,
executed and delivered to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS
NOMINEE FOR ALLIED MORTGAGE GROUP, INC., A PENNSYLVANIA BANKING
CORPORATION a Mortgage in the original principal amount of $138,218.00 on the premises
described in the legal description marked Exhibit "B ", attached hereto and made a part hereof.
Said Mortgage being recorded in the Office of the Recorder of CUMBERLAND County in
Instrument No. 201036743. 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 23, 2011, the mortgage was assigned to WELLS FARGO BANK, NA which
Assignment is recorded in the Office of the Recorder of CUMBERLAND County in Instrument
No. 201132691. The Assignment is a matter of public record and is incorporated herein by
reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its
obligation to attach documents to pleadings if those documents are of public record.
6. MASOOD AHMED and GUL BUSHRA are record and real owners 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 February 1, 2013.
062 -PA -V3
8. As of 07/16/2013, the amount due and owing Plaintiff on the mortgage is as
follows:
Principal Balance $137,251.54
Interest 01/01/2013 through 07/16/2013 $ 3,249.17
Late Charges $ 234.15
Escrow Deficit $ 194.80
TOTAL $140,929.66
plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania
Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including
escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file
a motion in the above - captioned action to add such additional sums authorized under the
Mortgage and Pennsylvania Law to the above amount due and owing when incurred.
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 action does not come under Act 91 of 1983 because the mortgage is FHA -
insured.
11. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff
is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to
do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of
personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish
such liability.
062 -PA -V3
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the
amount due of $140,929.66, with interest thereon plus additional costs (including additional
escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the
mortgaged premises.
By:
Date: Melissa J. Cantwell, Esq., I . No.308912
Attorney for Plaintiff
062 -PA -V3
Exhibit "A"
T
r •`
MIN: Loan Number:
NOTE
FHA Case No.
NOVEMBER 30, 2010 BALA CYNWYD PENNSYLVANIA
(Date] [Cityl (Slate]
67 JOHNS DRIVE, ENOLA, PENNSYLVANIA 17025
Properly Addressl
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns.
"Lender" means ALLIED MORTGAGE GROUP, INC, A PENNSYLVANIA BANKING
CORPORATION and its successors and assigns.
2. BORROWER'S PROMISE TO PAY: INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of
ONE HUNDRED THIRTY -EIGHT THOUSAND TWO HUNDRED EIGHTEEN AND
00/100 Dollars (U.S. $ 138, 218.00 ),
plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of
the loan proceeds by Lender, at the rate of FOUR AND 5 0 0 / 10 0 0 percent
( 4 . 5 0 0 per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated
the same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from
losses which might result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on theist day of each month beginning
on JANUARY 1, 2011 . Any principal and interest remaining on the 1st day of
DECEMBER, 2040 , will be due on that date, which is called the "Maturity Date."
(B) Place
Payment shall be made at 7 BALA AVE., STE 108, BALA CYNWYD,
PENNSYLVANIA 19004
or at such other place
as Lender may designate in writing by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. $ 7 0 0 . 3 3
This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to
principal, interest and other items in the order described in the Security Instrument.
(D) Allonge to this Note for Payment Adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants
of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge
were a part of this Note.
MULTISTATE - FHA FIXED RATE NOTE DocMagic0 oD 800- 649•+362
USFHA.NTE 09!25109 Page 1 of 3 www.docmagic.com
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I
(Check applicable box.)
❑ Growing Equity Allonge
❑ Graduated Payment Allonge
0 Other [specify]:
5. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty,
on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest
on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations
of the Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount
of the monthly payment unless Lender agrees in writing to those changes.
6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument, as described in
Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late
charge in the amount of FOUR AND 0 0 0 / 10 0 0 percent( 4.000 %)
of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by
regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance
remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in
the event of any subsequent default. In many circumstances, regulations issued by the Secretary will limit Lender's
rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration
when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and
Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs
and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited
by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the
principal of this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the rights of presentment and notice
of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of
Dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid.
-. 8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note
will be given by delivering it or by mailing it by first class mail to Borrower at the Property Address above or at a
different address if Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by delivering it or by mailing it by first
class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of
that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises
made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or
endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including
the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in
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this Note. Lender may enforce its rights under this Note against each person individually or against all signatories
together. Any one person signing this Note may be required to pay all of the amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note.
Pv L a yn_ - 4 Sea l )
(Sea )
SOOD ARMED - Borrower - Borrower
(Seal) (Seal)
- Borrower - Borrower
(Seal) (Seal)
- Borrower - Borrower
` WITHOUT RECUURSE
WELLS FARGO BALK, NA PAY TO THE ORDER OF 1_ /
PAY TO THE ORDER OF WELO FARGO PANK. N.A. Yom'
WITHOUT RECOURSE
AWED MORTGAGE GROUP, INC. By
Scott M. Swanson
Assistant -ice President
[Sign Original Only]
SHANTAN OY CHOWDHURX PRESSDJif
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Exhibit "B"
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in the township of East Pennsboro, county
of Cumberland and commonwealth of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on the eastern right -of -way line of Johns drive, at the westernmost
comer of lot no 215 on the hereinafter described final subdivision plan; thence along the western
line of said lot no, 215, south 41 degrees 37 minutes 47 seconds east, a distance of 155.04 feet to
a point on the northern line of lot no. 27, Penn Hills; thence along the northern line of said lot no.
27, south 81 degrees 35 minutes 00 seconds west, a distance of 23.91 feet to a point at the
easternmost corner of lot no. 217 on the hereinafter described final subdivision plan; thence
along the eastern line of said lot no. 217, north 41 degrees 37 minutes 47 seconds west, a
distance of 146.61 feet to a point on the eastern right -of -way line of Johns drive; thence along the
eastern right -of -way line of Johns drive by a curve to the left having a radius of 150.00 feet, an
arc length of 20.55 feet to a point at the westernmost corner of lot no. 215 on the hereinafter
described final subdivision plan, the point and place of beginning.
Parcel ID: 001 -15 -1288 -358
Commonly known as 67 Johns Drive, Enola, PA 17025
However, by showing this address no additional coverage is provided
PROPERTY ADDRESS: 67 JOHNS DRIVE, ENOLA, PA 17025 -2694
PARCEL #09 -15- 1288-358.
File #f: 818147
VERIFICATION
Leola McCray, hereby states that he /Q is Vice President Loan Documentation,
of WELLS FARGO BANK, N.A., plaintiff in this matter, that he/Q 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 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: Leola McCray
Title: Vice President Loan Documentation
Company: Wells Fargo Bank, N.A.
Date: 07/18/2013
File #818147
086 -PA -V2
FORM 1
IN THE COURT OF COMMON PLEAS
WELLS FARGO BANK, N.A. OF CUMBERLAND COUNTY, PENNVLV" NIA
Plaintiff(s) "'
vs. r C
MASOOD AHMED
GUL BUSHRA �✓ ymcivil Defendant(s)
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSAJR=E
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference.
First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400
extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you.
Once you have been appointed a legal representative, you must promptly meet with that legal representative within
twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all
requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal
representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the
service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your
lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a
conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal
representative. However, you must provide your lawyer with all requested financial information so that a loan resolution
proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached
hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed
within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable
arguments with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
jU L 2 5 2013 L'_
Date Melissa J. Cantwell, Esq., Id. No.308912
Attorney for Plaintiff
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to determine
possible options while working with your counseling agency. Please provide the following information to
the best of your knowledge:
APPLICANT CUSTOM ER/PRI MARY
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:
Primga Reason for Default:
Is the loan in Bankruptcy? Yes Q No ❑
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount owed: Value:
Automobile #2 : Model: Year:
Amount owed: Value:
Other transportation (automobiles boats, motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
I . Monthly Gross Monthly Net
2. Monthly Gross Monthly Net
3. Monthly Gross Monthly Net
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2n Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. not covered
Auto fuel/repairs Other prop. payment
Install. Loan Payment Cable TV
Child Su ort/Alim. — Spending Mone
Da /Child Care /Tuft. 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:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)
assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender and lender's loan servicing
company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTHORIZATION
I/We, , authorize the above named
to use /refer this information to my lender /servicer for the sole purpose of evaluating my
financial situation for possible mortgage options. I/We understand that I/we am /are under no obligation to
use the counseling services provided by the above named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and lender's
counsel:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation (hardship
letter)
6. Listing agreement (if property is currently on the market)
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so, the case may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249 -3166
(800) 990 -9108
File #: 818147
Wells Fargo Bank,N.A. : IN THE COURT OF COMMON PLEAS
3476 Stateview Boulevard : CUMBERLAND COUNTY,
Fort Mill, SC 29715 : PENNSYLVANIA C_>
Plaintiff c t
•-a z ZZ
rn Co
V. : Docket No. 13-4369 C„
r-� tV
Masood Ahmed ; ,�"�° -e+
Gul Bushra of r
67 Johns Drive : CIVIL ACTION- —r r•
Enola, PA 17025 : MORTGAGE FORECLOSURE
Defendants
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 2012, governing the
Cumberland County Residential Mortgage Foreclosure Diversions program, the undersigned
hereby certifies as follows:
1. Defendant is owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a"Notice of Residential Mortgage Foreclosure
Diversion Program" and has taken all of the steps required in that Notice to be
eligible to participate in a court-supervised conciliation conference.
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 N.C.S. §4904 relating to
unsworn falsification to authorities.
�. �S�ZZf ZCa
W re of Defendant's Counsel/Ap rated Date
Legal-Representative
41.�-V;) D /a,
Signature of Defendant _ Date
Wells Fargo Bank,N.A. : IN THE COURT OF COMMON PLEAS
3476 Stateview Boulevard : CUMBERLAND COUNTY,
Fort Mill, SC 29715 : PENNSYLVANIA
Plaintiff
V. : Docket No. 13-4369
Masood Ahmed
Gul Bushra :
67 Johns Drive : CIVIL ACTION-
Enola, PA 17025 : MORTGAGE FORECLOSURE
Defendants
CERTIFICATE OF SERVICE
I, Jaime M. Haley, Esquire, of MidPenn Legal Services, attorney for the Defendant, Gul
Bushra,hereby certify that I am serving a copy of the Praecipe for Entry of Appearance and
Request for Conciliation Conference on the Plaintiff, through their attorney, on the following
date and in the manner indicated below:
U.S. First Class Mail, Postage Pre-Paid
Melissa J. Cantwell,Esq.
Phelan Hallinan, LLP
1-617 JFK Boulevard, Suite 1400
One Penn Center
Philadelphia,PA 19103
MIDPENN LEGAL SERVICES
DATE: c
Jaime M. Haley, Esquire
Attorney for Defendant
Supreme Ct. ID #205255
401 E. Louther Street, Ste 103
Carlisle, PA 17013
(717)243-9400
Wells Fargo Bank,N.A. : IN THE COURT OF COMMON PLEAS
3476 Stateview Boulevard : CUMBERLAND COUNTY,
Fort Mill,.SC 29715 : PENNSYLVANIA
Plaintiff o
V. : Docket No. 13-4369 a�� c aw
�r- N _rT�
Masood Ahmed '��'
Gul Bushra Z:-
67 Johns Drive : CIVIL ACTION-
Enola, PA 17025 : MORTGAGE FORECLOSLM'E
Defendants
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of MidPenn Legal Services on behalf of the Defendant, Gul
Bushra, in the above matter,representing the Defendant in the Cumberland County Residential
Mortgage Foreclosure Diversion Program.
Respectfully Submitted,
MIDPENN LEGAL SERVICES
DATE:
Jaime M. Haley, Esquire
Attorney for Defendant
Supreme Ct. ID #205255
401 E.. Louther Street, Ste 103
Carlisle, PA 1701.3
(717)243-9400
SHERIFF'S OFFICE OF CUMBERLAND COUNTY"
Ronny RAndereon --- OF
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Jody SSmith ���� ��
Chief Deputy �0�� ��� �� �on'�� ��.
Richard WStevvart ' ~�
Solicitor o��mrnsMR� °°' b&
PENN
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Wells Fargo Bank, N.A.' Case Number
vs� |
2O13'43GS
�asood Ahmed�teOj |
SHERIFF'S RETURN OF SERVICE 08/01/2013 06:22pM-Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally"handing a true copy hn o person representing themselves to be the Defendant, to wit: Gut E
BushroatG7 John's Drive, East Pennebono. Eno}n. R4i702S.
AMANDA Cvo°uGn. ucrv/ y /
��
|
08102/2018 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
`
for the within named Defendant to wit: Masood Ahmed, but was unable to locate the Defendant in the
Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Dauphin, Pennsylvania toserve the within
Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure
according holaw.
08/12/2013 09:17 AM-The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint
in Mortgage Foreclosure served by the Sheriff of Dauphin County upon Masood Ahmed, personally, at
152 Lincoln Ave, Harrisburg, PA 17111. Jack Lotwick, Sheriff, Return of Service attached to and made
part of the within record.
SHERIFF COST: $69.86 SO ANSWERS,
August 20. 2013 RONNY R/\NOER8ON. SHERIFF
(c)CounlySuite Sheriff,Teleosoftl,Inc.
Wells Fargo Bank,N.A. IN THE COURT OF COMMON PLEAS
3476 Stateview Boulevard CUMBERLAND COUNTY,
Fort Mill, SC 29715 PENNSYLVANIA
Plaintiff
V. Docket No. 13-4369
G'> ritl
CZ)
Masood Ahmed 00
Gul Bushra r C:)
67 Johns Drive : CIVIL ACTION-
—r-
Enola,PA 17025 : MORTGAGE FORECLOSUR7':;r_
Defendants
CASE MANAGEMENT ORDER
AND NOW,this,27 4 day of &7vZt,2013, the defendantiborrower in the above-
captioned residential mortgage foreclosure action having filed a Request for Conciliation
Conference verifying that the defendantiborrower 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
—A— a - -b
conciliation Conference on /0, d613 at ,A ; o in
(,q41Xk1Atjo at the Cumberland County Courthouse, Carlisle,
Pennsylvania.
2. At least twenty-one(21) days prior to the date of the Conciliation Conference,the
defendant/borrower must serve upon the Plaintiff/lender 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
v
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 and may be extended. Upon notice to
the Court of the defendant/borrower's failure to serve the completed Form 2 with the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender 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.
4. 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 reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
_14
J.
DISTRIBUTION:
aime M.Haley,Esquire
MidPenn Legal Services
401 E. Louther Street, Ste 103
Carlisle,PA 17013
For the Defendants
,,-4elissa J. Cantwell,Esq.
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center
Philadelphia,PA 19103
For the Plaintiff
1"es /)&tL
WELLS FARGO BANK, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANli
1-fl
vs. : CIVIL ACTION—LAW - .7
NO. 13-4369 CIVIL ---
MASOOD AHMED and ~<
GUL BUSHRA, • 1 :
Defendants • y -
IN RE: CONCILIATION CONFERENCE
Present at a conciliation conference held October 10, 2013, were D. Troy Sellars,
Esquire, attorney for the plaintiff; Jaime M. Haley, Esquire, attorney for the defendant, Gul
Bushra; and Ms. Bushra.
It appears that any sort of loan modification will be difficult to accomplish as the note is
in the name of Ms. Bushra's estranged husband, Masood Ahmed. Mr. Ahmed appears not to be
cooperating with efforts to save the home from foreclosure.
Notwithstanding, we will continue the conciliation conference for a period of
approximately forty-five (45) days. In that interim, the plaintiff will provide a reinstatement
quote to the defendant. A further reason for the continuance is to give Ms. Bushra the
opportunity to speak with an attorney concerning her divorce. If the mortgage cannot be
reinstated, the strong likelihood is that this will be removed from the conciliation program.
ORDER
AND NOW, this /0 *. day of October, 2013, continued conciliation conference is
set for Friday,November 22, 2013, at 2:15 p.m. in Chambers of the undersigned.
BY THE COURT,
A 4,4
Kevin A Hess, P.J.
Troy Sellars, Esquire
For the Plaintiff
aime M. Haley, Esquire
For the Defendant
:rlm
040 I.�.S ritl�.16.) ��1t3
WELLS FARGO BANK, • IN THE COURT OF COMMON PLEAS OF
Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA
•
vs. • CIVIL ACTION—LAW
•
NO. 13-4369 CIVIL
MASOOD AHMED and •
GUL BUSHRA, •
Defendants •
IN RE: CONCILIATION CONFERENCE
ORDER
AND NOW, this 224 day of November, 2013, this matter is removed from the
Cumberland County Mortgage Foreclosure Diversionary Program and the stay entered in this
matter is vacated. The plaintiff may proceed in this mortgage foreclosure action pursuant to rule.
BY THE COURT,
. 4
Kevi, A . Hess, P.J.
✓ Joseph P. Schalk, Esquire
For the Plaintiff
V Jaime M. Haley, Esquire z! c :`
For the Defendant cc c, na c'
-`cam
r
:rlm �-_,
a { :iz i F.��13v fiJ�t:•11` i
PHELAN HALLINAN, LLP L0,,14 FEB _6 Ali 10, 22 Attorney for Plaintiff
Jonathan Lobb, Esq., Id. No.3121 4
1617 .1FK Boulevard. Suite 1400UNBERLANu COUNTY
One Penn Center Plaza PENNSYLVANIA
Philadelphia, PA 19103
Jonathan.Lobb a phelanhallinan.com
215-563-7000
WELLS FARGO BANK, N.A. CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
vs.
: CIVIL DIVISION
MASOOD AHMED
GUL BUSHRA : No. 13-4369 CIVIL
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned attorney hereby verifies that he/she is the attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge
of the following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act,
as amended.
(b) that defendant MASOOD AHMED is over 18 years of age and has last
known addresses at 152 LINCOLN AVENUE, HARRISBURG, PA 17111-4154 and 67 JOHNS
DRIVE, ENOLA, PA 17025-2694.
(c) that defendant GUL BUSHRA is over 18 years of age and resides at 67
JOHNS DRIVE, ENOLA, PA 17025-2694.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date 2 /4 V
P an Hallinan, LLP
Jonathan Lobb, Esq., Id. No.312174
Attorney for Plaintiff
PHELAN HALLINAN, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza, Philadelphia, PA 19103
215-563-7000
818147
ti Department of Defense Manpower Data Center Results as of Feb-05-201406:1533 AM
•
SCRA 3.0
,A 7,
.ff ;
•, Pursuant to Senticernerttbers Civil Relief Act
Last Name: AHMED
First Name: MASOOD
Middle Name:
Active Duty Status As Of: Feb-05-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA :No NA
This response reelects the individuals'active duty status based on the 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 No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
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 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.
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
- , Department of Defense Manpower Data Center Results as of:Feb-05-2014 06:15:35 AM
SCRA 3.0
a t---a t
,� � tip`
a„ 'e, Status Report
g . ',...::_i, ' Pursuant to Servic ,em,� Civil Relief Act
Last Name: BUSHRA
First Name: GUL
Middle Name:
Active Duty Status As Of: Feb-05-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date ! Status Service Component
NA NA No NA
This response reflects the individuals active duty status based on the Active Duty Status Date
Left Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
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 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.
t
yit
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
SAY Tf106I1.i• ,
PHELAN HALLINAN, LLP �n FEB t� Attorney for Plaintiff
Adam H. Davis, Esq., Id. No.203034 VIII:
1617 JFK Boulevard, Suite 1400 C M'ERL.AN0 COUNTY
One Penn Center Plaza PENNSYLVANIA
Philadelphia,PA 19103
Adam.Davis@PhelanHallinan.com
215-563-7000
WELLS FARGO BANK,N.A. : CUMBERLAND COUNTY
vs. : COURT OF COMMON PLEAS
MASOOD AHMED : CIVIL DIVISION
GUL BUSHRA
: No. 13-4369 CIVIL
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against MASOOD AHMED and
GUL BUSHRA, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20
days from service thereof and for foreclosure and sale of the mortgaged premises, and assess
Plaintiff's damages as follows:
As set forth in Complaint $140,929.66
TOTAL $140,929.66
I hereby certify that (1) the Defendants' last known addresses are 152 LINCOLN
AVENUE, HARRISBURG, PA 17111-4154 and 67 JOHNS DRIVE, ENOLA, PA 17025-2694,
and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1.
Date 2/ r//,
Adam H. Davis, Esq., Id. No.203034
Attorney fpr Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
M� �t f
DATE: og 1LSJ
PH#818147 PROTHONOTARY CO
44 I
818147
--p4'ajiL133
PHELAN HALLINAN, LLP Attorney for Plaintiff
Adam H. Davis, Esq., Id. No.203034
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
Adam.Davis@PhelanHallinan.com
215-563-7000
WELLS FARGO BANK, N.A. : CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
vs.
: CIVIL DIVISION
MASOOD AHMED
GUL BUSHRA : No. 13-4369 CIVIL
AFFIDAVIT OF NON-MILITARY SERVICE
The undersigned attorney hereby verifies that he/she is the attorney for the
Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge
of the following facts, to wit:
(a) that the defendant(s) is/are not in the Military or Naval Service of the United
States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act,
as amended.
(b) that defendant MASOOD AHMED is over 18 years of age and has last
known addresses at 152 LINCOLN AVENUE, HARRISBURG, PA 17111-4154 and 67 JOHNS
DRIVE, ENOLA, PA 17025-2694.
(c) that defendant GUL BUSHRA is over 18 years of age and resides at 67
JOHNS DRIVE, ENOLA, PA 17025-2694.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date /77/i?
Phelan Hallinan, LLP
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
PHELAN HALLINAN, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza, Philadelphia, PA 19103
215-563-7000
818147
Deportment of Defense Manpower Data Center Results as of:Feb-07-20141213.15 AM
SCRA 3.0
4 �r' Status
g MN 6�•• R L.�+t
Pursuant to Serviceitienibers Civil Relief Act
Last Name: BUSHRA
First Name: GUL
Middle Name:
Active Duty Status As Of: Feb-07-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date' Statue Service Component
NA
NA _.No NA
This response reflects the individuals'active duty status based on the Active Duty,Status Date
Left Active Duty.Within 367 Days of Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Setvice Component
NA NA No NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
The Member or 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 No NA
This response reflects whether the individual or his/her uhit has received early notifrcabon 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.
s
Y) Yil itf::4.0i44"•r r1 ar•
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
Department of Defense Manpower Data Center Results as of:Feb-07-2014 1213:13 AM
SCRA 3.0
r a
_
Status Report
Pursuant to Servicemenibers Civvil.Relief Act
Last Name: AHMED
First Name: MASOOD
Middle Name:
Active Duty Status As Of: Feb-07-2014
On Active Duty On Active Duty Status Date
Active Duty Start Date Active Duty End Date Status Service Component'..
NA NA Na NA
This response reflects the Individuals'active,duty status based on the 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 No NA
This response reflects where the individual left actve duly status within 367'>days preceding the Active Duty Status Date
The Member or His/tier Unit¢Vas Notified of a Future Catl-Up t6.Active Duty on Active Duty Status Date
Order Notfication Start:Date Order Notification End Date Status Service Component
NA NA No NA
This response reflects whether the indviduat or his/her umt 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.
Y)111:t4filit, )144 '
Mary M.Snavely-Dixon,Director
Department of Defense-Manpower Data Center
4800 Mark Center Drive,Suite 04E25
Arlington,VA 22350
(Rule of Civil Procedure No. 236) - Revised
WELLS FARGO BANK, N.A. : CUMBERLAND COUNTY
vs. : COURT OF COMMON PLEAS
MASOOD AHMED
GUL BUSHRA : CIVIL DIVISION
: No. 13-4369 CIVIL
Notice is given that a Judgment in the above captioned matter has been entered
against you on � l� 11
3v,,,rJ44
By:
If you have any questions concerning this matter please contact:
Phelan Hallinan, LLP
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND
ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU
HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND
SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT
ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
818147
WELLS FARGO BANK,N.A, COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v.
MASOOD AHMED NO. 13-4369 CIVIL
GUL BUSHRA
Defendant(s) CUMBERLAND COUNTY
TO: MASOOD AHMED
152 LINCOLN AVENUE
HARRISBURG,PA 17111-4154
DATE OF NOTICE: /
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
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 AGAINST YOU. UNLESS YOU
ACT WITHIN TEN 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary CUMBERLAND COUNTY BAR
Cumberland County Courthouse ASSOCIATION
1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE
Carlisle,PA 17013 2 LIBERTY AVENUE
(717)240-6195 CARLISLE,PA 17013
(717)249-3166
. P
By: _
Emily M.Phelan,Esq.,Id.No.315250
Attorney for Plaintiff
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
PH#818147
WELLS FARGO BANK,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v.
MASOOD AHMED NO. 13-4369 CIVIL
GUL BUSHRA
Defendant(s) CUMBERLAND COUNTY
TO: MASOOD AHMED
67 JOHNS DRIVE
ENOLA,PA 17025-2694
DATE OF NOTICE: 1{r /17:5/41(
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
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 AGAINST YOU. UNLESS YOU
ACT WITHIN TEN 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary CUMBERLAND COUNTY BAR
Cumberland County Courthouse ASSOCIATION
1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE
Carlisle,PA 17013 2 LIBERTY AVENUE
(717)240-6195 CARLISLE,PA 17013
(717)249-3166
By:
Entl y M.Phelan,Esq., Id.No.315250
Attorney for Plaintiff
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
PH#818147
WELLS FARGO BANK,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v.
MASOOD AHMED NO. 13-4369 CIVIL
GUL BUSHRA
Defendant(s) CUMBERLAND COUNTY
TO: GUL BUSHRA
67 JOHNS DRIVE
ENOLA,PA 17025-2694
DATE OF NOTICE: /
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
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 AGAINST YOU. UNLESS YOU
ACT WITHIN TEN 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary CUMBERLAND COUNTY BAR
Cumberland County Courthouse ASSOCIATION
1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE
Carlisle,PA 17013 2 LIBERTY AVENUE
(717)240-6195 CARLISLE,PA 17013
(717)249-3166
By: A/.
mat y 4.Phelan,Esq.,Id.No.315250
Attorney for Plaintiff
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
PH#818147
WELLS FARGO BANK,N.A. COURT OF COMMON PLEAS
Plaintiff CIVIL DIVISION
v.
MASOOD AHMED NO. 13-4369 CIVIL
GUL BUSHRA
Defendant(s) CUMBERLAND COUNTY
TO: GUL BUSHRA
CIO JAMIE M.HALEY,ESQUIRE
401 EAST LOUTHER STREET,SUITE 103
CARLISLE,PA 17013 /
DATE OF NOTICE: ( Z-3 f
THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE
IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO
HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT
PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY,
THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN
ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST
PROPERTY.
IMPORTANT NOTICE
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 AGAINST YOU. UNLESS YOU
ACT WITHIN TEN 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE
CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
Office of the Prothonotary CUMBERLAND COUNTY BAR
Cumberland County Courthouse ASSOCIATION
1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE
Carlisle,PA 17013 2 LIBERTY AVENUE
(717)240-6195 CARLISLE,PA 17013
17)249-3_166
By:
Emily M. Phelan,Esq., Id.No.315250
Attorney for Plaintiff
Phelan Hallinan,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
WELLS FARGO BANK,N.A. • COURT OF COMMON PLEAS
•
Plaintiff
• CIVIL DIVISION
v.
. NO.: 13-4369 CIVIL
MASOOD AHMED
GUL BUSHRA •
Defendant(s) CUMBERLAND COUNTY
To the Prothonotary:
Issue writ of execution in the above matter:
Amount Due $140,929.66
Interest from 02/11/2014 to Date of Sale $2,641.38
($23.17 per diem)
TOTAL $143,571.04
f'V el/
Phelan Hallinan,LLP
Adam H. Davis,Esq.,Id.No.203034
Attorney for Plaintiff
Note: Please attach description of property.
PH#818147
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ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro,
County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows,
to wit:
BEGINNING at a point on the eastern right-of-way line of Johns Drive, at the westernmost
corner of Lot No. 215 on the hereinafter described Final Subdivision Plan; thence along the
western line of said Lot No. 215, South 41 degrees 37 minutes 47 seconds East, a distance of
155.04 feet to a point on the northern line of Lot No. 27, Penn Hills; thence along the northern
line of said Lot No. 27, South 81 degrees 35 minutes 00 seconds West, a distance of 23.91 feet to
a point at the easternmost corner of Lot No. 217 on the hereinafter described Final Subdivision
Plan; thence along the eastern line of said Lot No. 217, North 41 degrees 37 minutes 47 seconds
West, a distance of 146.61 feet to a point on the eastern right-of-way line of Johns Drive; thence
along the eastern right-of-way line of Johns Drive by a curve to the left having a radius of 150.00
feet, an arc length of 20.55 feet to a point at the westernmost corner of Lot No. 215 on the
hereinafter described Final Subdivision Plan, the point and place of BEGINNING.
CONTAINING 3,012.00 square feet, more or less.
BEING Lot No. 216, Final Subdivision Plan of Laurel Hills North, Phase 5, dated June 5, 2001,
last revised July 12, 2001, recorded in the Office of the Recorder of Deeds of Cumberland
County, Pennsylvania, in Plan Book 83, Page 113.
BEING improved with a townhouse dwelling.
SUBJECT TO an Easement for utility installation and maintenance which is reserved on all lots
and such other easements, as may be shown in recorded documents, granted to Public Utility
Companies for utility purposes. Electric service will be supplied only from the underground
distribution system in accordance with then current PP&L Company Tariff provisions.
UNDER AND SUBJECT, NEVERTHELESS to restrictions, easements, set-back lines and
conditions as now appear of record including, but not limited to, Declaration of Covenants and
Restrictions applicable to Final Subdivision Plan for Laurel Hills North, Phase 5, East Pennsboro
Township, Cumberland County, Pennsylvania, dated September 14, 2001, and recorded in the
Office of the Recorder of Deeds of Cumberland County, in Miscellaneous Book 681, Page 601.
FURTHER UNDER AND SUBJECT to a thirty foot drainage easement, and ten foot pedestrian
easement, across the southern portion of the premises, as shown on the above-referenced Final
Subdivision Plan.
TITLE TO SAID PREMISES IS VESTED IN Masood Ahmed and Gul Bushra, h/w, by Deed from
Laurel Hills Development Corporation, a Pennsylvania Corporation, dated 10/29/2004, recorded
11/02/2004 in Book 266, Page 135_
PREMISES BEING: 67 JOHNS DRIVE,FNOLA, PA 17025-2694
PARCEL NO. 09-15-1288-358.
PHELAN HALLINAN, LLP L., k Attorneys for Plaintiff
Adam H. Davis, Esq., Id. No.203034 ' I ' H° 'l
1617 JFK Boulevard, Suite 1400 #
One Penn Center Plaza '
Philadelphia, PA 19103 l MBERLAND COUNTY
Adam.Davis @PhelanHallinan.com PENNSYLVANIA
215-563-7000
WELLS FARGO BANK, N.A. : COURT OF COMMON PLEAS
Plaintiff
: CIVIL DIVISION
v.
: NO.: 13-4369 CIVIL
MASOOD AHMED
GUL BUSHRA
Defendant(s) : CUMBERLAND COUNTY
CERTIFICATION
The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned
matter and that the premises are not subject to the provisions of Act 91 because:
(X) the mortgage is an FHA Mortgage
( ) the premises is non-owner occupied
( ) the premises is vacant
( ) Act 91 procedures have been fulfilled
( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943
This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to
authorities.
By:
Phelan Hallinan,LLP
Adam H. Davis,Esq.,Id.No.203034
Attorney for Plaintiff
WELLS FARGO BANK,N.A. • ik COURT OF COMMON PLEAS
Plaintiff F CIVIL DIVISION
v. .,. , 'BER AyiLi COUrd 1 NO.: 13-4369 CIVIL•
MASOOD AHMEDEt ?SYLDAy 1A
GUL BUSHRA
Defendant(s) CUMBERLAND COUNTY
AFFIDAVIT PURSUANT TO RULE 3129.1
WELLS FARGO BANK,N.A.,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe
for the Writ of Execution was filed,the following information concerning the real property located at 67 JOHNS DRIVE,ENOLA,PA
17025-2694.
1. Name and address of Owner(s)or reputed Owner(s):
Name Address(if address cannot be reasonably ascertained,
please so indicate)
MASOOD AHMED 152 LINCOLN AVENUE
HARRISBURG,PA 17111-4154
GUL BUSHRA 67 JOHNS DRIVE
ENOLA,PA 17025-2694
2. Name and address of Defendant(s)in the judgment:
Name Address(if address cannot be reasonably
ascertained,please so indicate)
MASOOD AHMED 152 LINCOLN AVENUE
HARRISBURG,PA 17111-4154
GUL BUSHRA 67 JOHNS DRIVE
ENOLA,PA 17025-2694
3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold:
Name Address(if address cannot be
reasonably ascertained,please indicate)
None.
4. Name and address of last recorded holder of every mortgage of record:
Name Address(if address cannot be
reasonably ascertained, please indicate)
None.
5. Name and address of every other person who has any record lien on the property:
Name Address(if address cannot be
reasonably ascertained, please indicate)
None.
PH# 818147
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.
Name Address(if address cannot be
reasonably ascertained,please indicate)
LAUREL HILLS NORTH 216 TORY CIRCLE
ENOLA,PA 17025
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:
Name Address(if address cannot be
reasonably ascertained,please indicate)
TENANT/OCCUPANT 67 JOHNS DRIVE
ENOLA,PA 17025-2694
MASOOD AHMED 4701 NORTH FRONT STREET
C/O TIMOTHY J.O'CONNELL,ESQUIRE HARRISBURG,PA 17110
DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET
CUMBERLAND COUNTY CARLISLE,PA 17013
COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675
DEPARTMENT OF WELFARE HARRISBURG,PA 17105
INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704
PITTSBURGH,PA 15222
U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220
U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754
DISTRICT OF PA HARRISBURG,PA 17108-1754
FEDERAL BUILDING
GUL BUSHRA 401 EAST LOUTHER STREET
C/O JAMIE M.HALEY,ESQUIRE SUITE 103
CARLISLE,PA 17013
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities.
Date: 2,/7//f By: C �4i ,>4■efti+
Phelan Hallinan,LLP
Adam H. Davis,Esq.,Id.No.203034
Attorney for Plaintiff
PHELAN HALLINAN,LLP
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza, Philadelphia,PA 19103
215-563-7000
PH # 818147
WELLS FARGO BANK, N.A. : COURT OF COMMON PLEAS
Plaintiff : CIVIL DIVISION
vs. : NO.: 13-4369 CIVIL
MASOOD AHMED
GUL BUSHRA : CUMBERLAND COUNTY
Defendant(s) :
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
""D ' rr
TO: MASOOD AHMED GUL BUSHRA ...<7.> c = m,-
152 LINCOLN AVENUE 67 JOHNS DRIVE a f;'-
HARRISBURG PA 17111-4154 ENOLA,PA 17025-2694 e-)
**THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION Olt-TAMED
WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY',
THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY
ENFORCEMENT OF A LIEN AGAINST PROPERTY.**
Your house (real estate) at 67 JOHNS DRIVE,ENOLA,PA 17025-2694 is scheduled to be sold at the
Sheriff's Sale on 06/04/2014 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street,
Carlisle,PA 17013 to enforce the court judgment of$140,929.66 obtained by WELLS FARGO BANK,N.A.
(the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in
compliance with Pa.R.C.P. Rule 3129.3.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff's Sale, you must take immediate action:
1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and
reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment,
if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause.
You may also be able to stop the sale through other legal proceedings.
You may need an attorney to assert your rights. The sooner you contact one, the more chance you will
have of stopping the sale. (See notice on page two on how to obtain an attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the
price bid by calling 215-563-7000.
2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared
to the value of your property.
3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this
has happened, you may call 215-563-7000.
4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if
the sale never happened.
5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff
gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of
distribution of the money bid for your house will be prepared by the Sheriff not later than thirty(30) days after
the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his
office. This schedule will state who will be receiving that money. The money will be paid out in accordance
with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff
within ten (10) days after the filing of the proposed schedule.
7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately
after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW
TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
(800) 990-9108
SHORT DESCRIPTION
By virtue of a Writ of Execution No. 13-4369 CIVIL
WELLS FARGO BANK, N.A.
v.
MASOOD AHMED
GUL BUSHRA
owner(s) of property situate in EAST PENNSBORO TOWNSHIP, CUMBERLAND County,
Pennsylvania, being
67 JOHNS DRIVE,ENOLA, PA 17025-2694
Parcel No. 09-15-1288-358.
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
Judgment Amount: $140,929.66
Attorneys for Plaintiff
Phelan Hallinan, LLP
-
ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro,
County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows,
to wit:
BEGINNING at a point on the eastern right-of-way line of Johns Drive, at the westernmost
corner of Lot No. 215 on the hereinafter described Final Subdivision Plan; thence along the
western line of said Lot No. 215, South 41 degrees 37 minutes 47 seconds East, a distance of
155.04 feet to a point on the northern line of Lot No. 27, Penn Hills; thence along the northern
line of said Lot No. 27, South 81 degrees 35 minutes 00 seconds West, a distance of 23.91 feet to
a point at the easternmost corner of Lot No. 217 on the hereinafter described Final Subdivision
Plan; thence along the eastern line of said Lot No. 217, North 41 degrees 37 minutes 47 seconds
West, a distance of 146.61 feet to a point on the eastern right-of-way line of Johns Drive; thence
along the eastern right-of-way line of Johns Drive by a curve to the left having a radius of 150.00
feet, an arc length of 20.55 feet to a point at the westernmost corner of Lot No. 215 on the
hereinafter described Final Subdivision Plan, the point and place of BEGINNING.
CONTAINING 3,012.00 square feet, more or less.
BEING Lot No. 216, Final Subdivision Plan of Laurel Hills North, Phase 5, dated June 5, 2001,
last revised July 12, 2001, recorded in the Office of the Recorder of Deeds of Cumberland
County, Pennsylvania, in Plan Book 83, Page 113.
BEING improved with a townhouse dwelling.
SUBJECT TO an Easement for utility installation and maintenance which is reserved on all lots
and such other easements, as may be shown in recorded documents, granted to Public Utility
Companies for utility purposes. Electric service will be supplied only from the underground
distribution system in accordance with then current PP&L Company Tariff provisions.
UNDER AND SUBJECT, NEVERTHELESS to restrictions, easements, set-back lines and
conditions as now appear of record including, but not limited to, Declaration of Covenants and
Restrictions applicable to Final Subdivision Plan for Laurel Hills North, Phase 5, East Pennsboro
Township, Cumberland County, Pennsylvania, dated September 14, 2001, and recorded in the
Office of the Recorder of Deeds of Cumberland County, in Miscellaneous Book 681, Page 601.
FURTHER UNDER AND SUBJECT to a thirty foot drainage easement, and ten foot pedestrian
easement, across the southern portion of the premises, as shown on the above-referenced Final
Subdivision Plan.
TITLE TO SAID PREMISES IS VESTED IN Masood Ahmed and Gul Bushra,h/w, by Deed from
Laurel Hills Development Corporation, a Pennsylvania Corporation,dated 10/29/2004, recorded
11/02/2004 in Book 266, Page 135.
PREMISES BEING: 67 JOHNS DRIVE,ENOLA,PA 17025-2694
PARCEL NO. 09-15-1288-358.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 13-4369 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WELLS FARGO BANK,N.A.,Plaintiff(s)
From MASOOD AHMED,GUL BUSHRA
(1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEE(S)as follows:
and to notify the garnishee(s)that: (a)an attachment has been issued;(b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant
(s)or otherwise disposing thereof;
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $140,929.66 L.L.: $.50
Interest FROM 2/11/2014 TO DATE OF SALE($23.17 PER DIEM)-$2,641.38
Atty's Comm: Due Prothy: $2.25
Atty Paid: $218.70 Other Costs:
Plaintiff Paid:
Date: 2/10/14 a
%�k L
Davis D. el , Pr.thonotary
(Seal) By:
Deputy
REQUESTING PARTY:
Name: ADAM H. DAVIS,ESQUIRE
Address: PHELAN HALLINAN,LLP
1617 JFK BLVD.,SUITE 1400
ONE PENN CENTER
PHILADELPHIA,PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No.203034
•
AFFIDAVIT OF SERVICE
PLAINTIFF CUMBERLAND COUNTY
WELLS FARGO BANK, N.A.
DEFENDANT
MASOOD MEWED
GUL BUSHRA
SERVE MASOOD AHMED AT:
152 LINCOLN AVENUE
HARRISBURG, PA 17111-4154
PH # 818147
SERVICE TEAM/ lxh
COURT NO.: 13-4369 CI
TYPE OF ACTION
XX Notice of Sheriff's Sale
SALE DATE: June 4, 2014
**DIVORCED- One cannot accept service for the other**
SERVED
i-veci, and made known tp
Aida...P . M., at ASO D th
MED. Defendant oil the day of
ciock , t
4.47 14, in the manner described bel
Defendant personally served.
Adult family member with whom Defendant(s) reside(s).
Relationship is
Adult in charge of Defendant's residence who refused to give name or relationship.
Manager/Clerk of place of lodging in which Defendant(s) reside(s).
Agent or person in charge of Defendant's office or usual place of business.
an officer of said Defendant's company.
Other:
Description: Age Height SIM 1 Weight /4/1— Rac Sex Other
‘o- , a competent adult, hereby verify that I personally handed a true and correct copy of the
N tice of Sheriffs Salein the manner as set forth herein, issued in the captioned case on the date and at the address
indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to
unsworn falsification to authorities.
DATE:2– Si/
NAIM/0
PRINTED NAMEC. 4-4J/.49 / A/A*25
TITLE:
NOT SERVED
On the day of . 20 , at o'clock . M., I, , a competent adult hereby
state thETZTendant NOT FOUND because:
Vacant _ Does Not Exist _ Moved /Does Not Reside Not Vacant)
V No Answer on --0--/ ti at rk, at
Service Refused
Other:
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
BY:
PRINTED NAME:
ATTORNEY FOR PLAINTIFF
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
(215) 563-7000
Phelan Hallinan, LLP
Adam H. Davis, Esq., Id. No.203034
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Adam.Davis@PhelanHallinan.com
215-563-7000
WELLS FARGO BANK, N.A.
Plaintiff
v.
MASOOD AHMED
GUL BUSHRA
2Thi Arr; 1 M {0: i
Ot!MDE'RLANDCMTPANEY FOR PLAINTIFF
PLIINSYLVANIA
Court of Common Pleas
Civil Division
CUMBERLAND County
No.: 13-4369 CIVIL
Defendants
PLAINTIFF'S MOTION TO REASSESS DAMAGES
Plaintiff, by its Attorneys, Phelan Hallinan, LLP, moves the Court to direct the
Prothonotary to amend the judgment in this matter, and in support thereof avers the following:
1. Plaintiff commenced this foreclosure action by filing a Complaint on July 26, 2013,
2. Judgment was entered on February 10, 2014 in the amount of $140,929.66. A
true and correct copy of the praecipe for judgment is attached hereto, made part hereof, and
marked as Exhibit "A".
3. Pursuant to Pennsylvania Rule of Civil Procedure 1037(b)(1), a default judgment
containing a dollar amount must be entered for the amount claimed in the complaint and any item
which can be calculated from the complaint, i.e. bringing the interest current. However, new items
cannot be added at the time of entry of the judgment.
4. The Property is listed for Sheriffs Sale on June 4, 2014.
818147
5. Additional sums have been incurred or expended on Defendants' behalf since the
Complaint was filed and Defendants have been given credit for any payments that have been made
since the judgment. The amount of damages should now read as follows:
Principal Balance
Interest Through March 11, 2014
Late Charges
Legal fees
Cost of Suit and Title
Property Inspections
Mortgage Insurance Premium/ Private Mortgage Insurance
Escrow Deficit
$137,251.54
$7,506.00
$234.15
$1,550.00
$967.61
$75.00
$289.74
$2,676.70
TOTAL $150,550.74
6. The judgment formerly entered is insufficient to satisfy the amounts due on the
Mortgage.
7. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to
inclusion of the figures set forth above in the amount of judgment against the Defendants.
8. Plaintiff's foreclosure judgment is in rem only and does not include personal
liability, as addressed in Plaintiff's attached brief.
9. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of
its proposed Motion to Reassess Damages and Order to the Defendant on April 10, 2014 and
requested the Defendants' Concurrence. Plaintiff did not receive any response from the Defendants.
A true and correct copy of Plaintiff's letter pursuant to Local Rule 208.3(9) and certification of
mailing are attached hereto, made part hereof, and marked as Exhibit `B ".
10. No judge has previously entered a ruling in this case.
818147
WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the
judgment as ,requested., .
DATE:
Phelan Hallinan, LLP
V By
Adarn H. Davis, Esquire. �.
ATTORNEY FOR PLAINTIFF
.;1
818147
Phelan Hallinan, LLP
Adam H. Davis, Esq., Id. No.203034
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Adam.Davis@PhelanHallinan.com
215-563-7000
WELLS FARGO BANK, N.A.
Plaintiff
v.
MASOOD AHMED
GUL BUSHRA
Defendants
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CUMBERLAND County
No.: 13-4369 CIVIL
MEMORANDUM OF LAW IN SUPPORT OF
PLAINTIFF'S MOTION TO REASSESS DAMAGES
1. BACKGROUND OF CASE
MASOOD AHMED executed a Promissory Note agreeing to pay principal, interest, late
charges, real estate taxes, hazard insurance premiums, and mortgage insurance premiums as
these sums became due. Plaintiffs Note was secured by a Mortgage on the Property located at
67 JOHNS DRIVE, ENOLA, PA 17025-2694. The Mortgage indicates that in the event of a
default in the mortgage, Plaintiff may advance any necessary sums, including taxes, insurance,
and other items, in order to protect the security of the Mortgage.
In the instant case, Defendants defaulted under the Mortgage by failing to tender numerous,
promised monthly mortgage payments. Accordingly, after it was clear that the default would not be
cured, Plaintiff commenced the instant mortgage foreclosure action. Judgment was subsequently
entered by the Court, and the Property is currently scheduled for Sheriffs Sale.
818147
Because of the excessive period of time between the initiation of the mortgage foreclosure
action, the entry of judgment and the Sheriffs Sale date, damages as previously assessed are
outdated and need to be adjusted to include current interest, real estate taxes, insurance premiums,
costs of collection, and other expenses which Plaintiff has been obligated to pay under the Mortgage
in order to protect its interests. It is also appropriate to give Defendants credit for monthly
payments tendered through bankruptcy, if any.
II. LEGAL ARGUMENT TO AMEND PLAINTIFF'S IN REM JUDGMENT
It is settled law in Pennsylvania that the Court may exercise its equitable powers to control
the enforcement of a judgment and to grant any relief until that judgment is satisfied. 20 P.L.E.,
Judgments § 191. Stephenson v. Butts, 187 Pa.Super. 55, 59, 142 A.2d 319, 321 (1958). Chase
Home Mortgage Corporation of the Southwest v. Good, 537 A.2d 22, 24 (Pa.Super. 1988). The
Pennsylvania Superior Court has repeatedly cited the right of a foreclosing creditor to amend its
judgment prior to the Sheriffs sale. Nationsbanc Mortgage Corp. v. Grillo, 827 A.2d 489
(Pa.Super. 2003). Morgan Guaranty Trust Co. of N.Y. v. Mowl, 705 A.2d 923 (Pa. Super. 1998).
Union National Bank of Pittsburgh v. Ciongoli, 407 Pa.Super. 171, 595 A.2d 179 (1991).
The Supreme Court of Pennsylvania recognized in Landau v. Western Pa. Nat. Bank, 445
Pa. 117, 282 A.2d 335 (1971), that the debt owed on a Mortgage is subject to change and, in fact,
can be expected to change from day to day because the bank must advance sums in order to protect
its collateral. Because a Mortgage lien is not extinguished until the debt is paid, Plaintiff must
protect its collateral up until the date of sale. Beckman v. Altoona Trust Co., 332 Pa. 545, 2 A.2d
826 (1939). Because a judgment in mortgage foreclosure is strictly in rem, it is critical that the
judgment reflect those amounts expended by the Plaintiff in protecting the property. Meco Reality
818147
Company v. Burns, 414 Pa. 495, 200 A.2d 335 (1971). Plaintiff submits that if it goes to sale
without the requested amended judgment, and if there is competitive bidding for the Property,
Plaintiff will suffer a significant loss in that it would not be able to recoup monies it advanced to
protect its interests. Conversely, amending the in rem judgment will not be detrimental to
Defendants as it imputes no personal liability.
In B.C.Y. v. Bukovich, the Pennsylvania Superior Court reiterated its long standing rule that
a Court has the inherent power to correct a judgment to conform to the facts of a case. 257 Pa.
Super. 157, 390 A.2d 276 (1978). In the within case, the amount of the original judgment does not
adequately reflect the additional sums due on the Mortgage due to Defendants' failure to tender
payments during the foreclosure proceeding and the advances made by the mortgage company. The
Mortgage plainly requires the mortgagors to tender to the mortgagee monthly payments of principal
and interest until the Promissory Note accompanying the Mortgage is paid in full. The mortgagors
are also required to remit to the mortgagee sufficient sums to pay monthly mortgage insurance
premiums, fire insurance premiums, taxes and other assessments relating to the Property. The
mortgagor s have breached the terms of the Mortgage, and Plaintiff has been forced to incur
significant unjust financial losses on this loan.
III. THE FORECLOSURE JUDGMENT IS IN REM ONLY
The within case is a mortgage foreclosure action, the sole purpose of which is to take the
mortgaged property to Sheriffs Sale. Pennsylvania law makes clear that an action in mortgage
foreclosure is strictly in rem and does not include any personal liability. Newtown Village
Partnership v. Kimmel, 424 Pa. Super 53, 55, 621 A.2d 1036, 1037 (1993). Signal Consumer
818147
Discount Company v. Babuscio, 257 Pa. Super 101, 109, 390 A.2d 266, 270 (1978). Pennsylvania
Rule of Civil Procedure 1141(a).
However, Pennsylvania law requires that the foreclosure action demand judgment for the
amount due. Pa.R.C.P. 1147(6). The purpose of the dollar amount in the in rem judgment is for
bidding at the Sheriffs Sale. In the event that a third party real estate speculator were to bid on the
mortgaged property at the Sheriffs Sale and become the successful purchaser, Plaintiff would
receive the amount of the in rem judgment from the Sheriff.
IV. INTEREST
The Mortgage clearly requires that the Defendants shall promptly pay when due the
principal and interest due on the outstanding debt. In addition, the Note specifies the rate of interest
to be charged until the debt is paid in full or otherwise satisfied. Specifically, interest from 30 days
prior to the date of default through the date of the impending Sheriff's sale has been requested.
V. TAXES AND INSURANCE
If Plaintiff had not advanced monies for taxes and insurance throughout the foreclosure
proceeding, Plaintiff would have risked loss of its collateral. If the Property were sold at a tax sale,
Plaintiffs interest very well may be divested, and Plaintiff would sustain a complete loss on the
outstanding balance due on the loan. If the Property were damaged in a fire, Plaintiff would not be
able to obtain insurance proceeds to restore the Property if it did not pay the insurance premiums.
Most importantly, the Mortgage specifically provides that the mortgagee may advance the
monies for taxes and insurance and charge these payments against the escrow account. Plaintiff is
simply seeking to have the Court enforce the terms of the Mortgage.
818147
VI. ATTORNEY'S FEES
The Plaintiffs foreclosure fees are very modest. They cover all of the legal work done
throughout the course of the foreclosure action to date, including reviewing the Act 6 or Act 91
letters, loan documents, account records, title reports and supporting documents, preparing and
reviewing the mortgage foreclosure complaint, filing and service of the complaint, Rule 237.1
Notice, Department of Defense search, entry of judgment, the writ of execution process, lien
holder notices, and all of the other legal work that goes into handling the mortgage foreclosure
lawsuit.
The Mortgage specifically provides for Plaintiff's recovery of its attorney fees. The
amount of attorney's fees requested in the Motion to Reassess Damages is in accordance with the
loan documents and Pennsylvania law. Pennsylvania Courts have long and repeatedly concluded
that a request of five percent of the outstanding principal balance is reasonable and enforceable as
an attorney's fee. Robinson v. Loomis, 51 Pa. 78 (1865); First Federal Savings and Loan
Association v. Street Road Shopping Center, 68 D &C 2d 751, 755 (1974).
In Federal Land Bank of Baltimore v. Fetner, the Superior Court held that an attorney's fee
of ten percent of the original mortgage amount is not unconscionable. 410 A.2d 344 (Pa. Super.
1979). The Superior Court cited Fetner in confirming that an attorney's fee of ten percent included
in the judgment in mortgage foreclosure action was reasonable. Citicorp v. Morrisville Hampton
Realty, 662 A.2d 1120 (Pa. Super. 1995). Plaintiffs legal fees are not a percentage but are
significantly less than what is permitted by Pennsylvania law.
818147
VII. COST OF SUIT AND TITLE
Pursuant to the terms of the mortgage, Plaintiff is entitled to recover all expenses incurred in
the foreclosure action. The amount claimed for the costs of suit and title are the expenses Plaintiff
paid to date as a result of the mortgage default.
The title report is necessary to determine the record owners of the property, as Pa.R.C.P.
1144 requires all record owners to be named as Defendants in the foreclosure action. It is also
necessary to determine whether there are any prior liens to be cleared, so that the Sheriff's sale
purchaser acquires clear title to the property. It is necessary to determine if there are IRS liens
on the property, whether the Defendants are divorced (which could affect service of the
complaint), and numerous other legal issues. The title bringdown is necessary to identify any
new liens on the property or new owners between the time of filing and complaint and the writ
date.
The Freedom of Information Act inquiries and the investigation into Defendants'
whereabouts are necessary to effectively attempt personal service of the complaint and notice of
sale on the Defendant. The notice of sale and Rule 3129 notice are required by Pa.R.C.P.3129.1
and 3129.2 to notify all lienholders, owners, and interested persons of the Sheriffs sale date, as
their interests will be divested by the Sheriff's sale.
Accordingly, the modest sums Plaintiff has incurred for the costs of suit and title were
necessary pursuant to Pennsylvania law. The amounts were reasonable and actually incurred.
The mortgage and Pennsylvania law permit Plaintiff to recover these sums through its
foreclosure action. As the foreclosure action is in rem only, Plaintiff recovers its judgment from
the sale of the property, not out of the Defendant's pockets. Plaintiff should recover the costs of
suit and title in their entirety, which will not cause harm to the Defendants.
818147
VIII. PROPERTY INSPECTIONS AND PRESERVATION
The terms of the mortgage provide for property inspections and property preservation
charges. The lender or its agent may make reasonable inspections of the property pursuant to the
terms of the mortgage. When a borrower defaults under the terms of the mortgage, the lender
may do, or pay for, whatever is reasonable to protect its interest in the collateral, including
property maintenance. Any amounts disbursed by the lender for property inspections and
preservation become additional debt of the borrower secured by the mortgage. The lender may
charge the borrower for services performed in connection with the default, for the purpose of
protecting the lender's interest in the property, including property inspections and valuation
costs.
When a loan is in default, the lender's risk increases. Mortgage companies typically have
a vendor visit the premises to determine if any windows need to be boarded up, if the property is
vacant, if the grass needs to be cut, or the snow shoveled. If the property inspection reveals any
problems at the mortgaged premises, then the mortgage company may proceed to take whatever
steps are necessary to secure the collateral, such as boarding windows, winterizing, removing
hazards or debris, etc. The mortgage company generally pays a vendor to handle these tasks,
which are referred to in the industry as "property preservation ". These services avoid code
violations and avoid the property becoming an eyesore in the neighborhood. Property
preservation helps maintain property values in the neighborhood.
Accordingly, line items included in Motions to Reassess Damages for property
inspections and property preservation represent amounts which the mortgage company has paid
out of its pocket to preserve its collateral, consistent with the terms of the mortgage contract.
Since the terms of the mortgage provide that such expenses by the mortgage company become
818147
part of the borrower's debt secured by the mortgage, those expenses are properly included in the
Plaintiff's Motion to Reassess Damages.
IX. CONCLUSION
Therefore, Plaintiff respectfully submits that if the enforcement of its rights is delayed by
legal proceedings, and such delays require the mortgagee to expend additional sums provided for by
the Mortgage, then the expenses necessarily become part of the mortgagee's lien and should be
included in the judgment.
Plaintiff respectfully requests that this Honorable Court grant its Motion to Reassess
Damages. Plaintiff submits that it has acted in good faith in maintaining the Property in accordance
with the Mortgage, and has relied on terms of the Mortgage with the understanding that it would
recover the monies it expended to protect its collateral.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the
judgment as requested.
DATE: qj%D` /"7
By
Phelan Hallinan, LLP
Adam H. Davis, Esquire
Attorney for Plaintiff
818147
Exhibit "A"
PILED-OFFICE
Or i HE PROTHONOTARY
, LL QQ ff yy FF
Adam PHELAN H. Davis, Esq., HALLIN AN Id. No23�3 RM 1�' 8
1617 JFK Boulevard, Suite BERLANO COUNTY
One Penn Center Plaza PENNS YLYANIA
Philadelphia, PA 19103
Adam.Davis@PhelanHallinan.com
215 -563 -7000
Attorney for Plaintiff
WELLS FARGO BANK, N.A. : CUMBERLAND COUNTY
vs. o fi000 URT OF COMMON PLEAS
MASOOD AHMED p 1eY c, ?OS8 Re: CIVIL DIVISION
GUL BUSHRA
: No. 13 -4369 CIVIL
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Go104
Kindly enter judgment in fa ]�,,�� d against MASOOD AHMED and
GUL BUSHRA, Defendant(s) for ail a�wer to Plaintiff's Complaint within 20
days from service thereof and for foreclosure and sale of the mortgaged premises, and assess
Plaintiff's damages as follows:
As set forth in Complaint
TOTAL
$140,929.66
$140,929.66
1 hcrcby co.tlfy drat (1) the Defendants fast Kn w .i; flosses are i z L1NUULN
AVENUE, HARRISBURG, PA 17111 -41 . �,• ,t '41 *RIVE, ENOLA, PA 17025 -2694,
and (2) that notice has been given in accor�y: `''�'' ' ' :� • .C.P 237.1.
Date 217//0
r / /0
Adam H. Davis, Esq., Id. No.203034
AttornPtfor Plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE:
PH4t818147
Et
PROTHONOTARY
818147
Exhibit _"B"
PHELAN HALLINAN, LLP
1617 John F. Kennedy Boulevard
Suite 1400
Philadelphia, PA 19103
(215) 563-7000
FAX#: (215) 563-3459
Phelan Ha 'limn, LLP
2014
JAMIE M. M. HALEY
401 EAST LOUTHER STREET, SUITE 103
CARLISLE, PA 17013
MASOOD AHMED
152 LINCOLN AVENUE
HARRISBURG, PA 17111-4154
Representing Lenders in
Pennsylvania
RE: WELLS FARGO BANK, N.A. v. MASOOD AHMED and GUL BUSHRA
Premises Address: 67 JOHNS DRIVE ENOLA, PA 17025
CUMBERLAND County CCP, No. 13-4369 CIVIL
Dear Defendants,
Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages
and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your
concurrence with the requested relief that is, increasing the amount of the judgment. Please
respond to me within 5 days, by April eith, 2014
Should you have further questions or concerns, please do not hesitate to contact me.
Otherwise, please be guided accordingly.
Very truly yours,
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
Enclosure
818147
Name and Phelan Hallinan, LLP
Address 1617 JFK Boulevard,
Of Sender One Penn Center Plaza
Philadelphia, PA 19103 ASZ
$rite 140
Line Article Number Name of Addressee, S reet, an fl Post 011ice Address
TENANT/OCCUPANT
67 JOHNS DRIVE
ENOLA, PA 17025 -2094
Postage
S0.47
2
MASOOD AHMED
152 LINCOLN AVENUE
HARRISBURG, PA 11111 -4154
MASOOD AHMED
MASOOD AHMED
GUL BUSHRA
67 JOHNS DRIVE
ENOLA, PA 17025 -264
50.47
50.47
4
JAMIE M. HALEY
401 EAST LOUTHER STREET
SUITE 103
CARLISLE, PA 17013.
50.47
RE: MASOOD AHMED (CUMBERLAND) PH # 818147/1200 Page 1 of 1
51.88
Total Number of
Pisa Listed by Snobs
Total Numhn of Pieces
Reeeieed et Rot Office
Form 3877 Facsi
The foil declaration of valve is-required on ail domestic sod rtacrnaiosal registered nail. The maim
for the tvarntnrcdm of avoepothble docvrrrau ender Expreu Mil decumcnl irconetravion insure per
piece abject 3o • limit of $300,000 pa oearnarce. The maximum bdemaiiy payable on i?yias M 43 merehandise 6 3300.
The maximum indemnity payable is 525.000 r revived mail, scat with odd iestuance. SeeDomesX Mel Mewl
R900 5913 and 5911 toe (imitations of corv;'e.
81812
J
Phelan Hallinan, LLP
Adam H. Davis, Esq., Id. No.203034
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Adam.Davis@PhelanHallinan.com
215-563-7000
WELLS FARGO BANK, N.A.
Plaintiff
v.
MASOOD AHMED
GUL BUSHRA
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CUMBERLAND County
No.: 13-4369 CIVIL
Defendants
CERTIFICATION OF SERVICE
I hereby certify that true and correct copies of Plaintiffs Motion to Reassess Damages,
and Brief in Support thereof, were sent to the following individuals on the date indicated below.
JAMIE M. HALEY, ESQUIRE
401 EAST LOUTHER STREET, SUITE 103
CARLISLE, PA 17013
MASOOD AHMED
152 LINCOLN AVENUE
HARRISBURG, PA 17111-4154
DATE: cr77e9t/767` By:
MASOOD AHMED
67 JOHNS DRIVE
ENOLA, PA 17025-2694
Phelan Hallinan, LLP
Adam H. Davis, Esquire
ATTORNEY FOR PLAINTIFF
818147
PLAINTIFF
WELLS FARGO BANK, N.A.
DEFENDANT
MASOOD AHMED
GUL BUSHRA
AFFIDAVIT OF SERVICE
CUMBERLAND COUNTY
PH # 818147
SERVICE TEAM/ Ixh
COURT NO.: 13-4369 CIVIL
SERVE GUL BUSHRA AT:
67 JOHNS DRIVE
ENOLA, PA 17025 -2694
**DIVORCED- One cannot accept service for the other**
SERVED
Served and made known to GUL BUSHRA, Defendant on the J day of M M Cl/ , 20 14 , at
6.: o 0, o'clock. M., at b 7 JB4N5 Da I d E, E44 6 4A r A 4 in the manner described below
j[ Defendant personally served.
Adult family member with whom Defendant(s) reside(s).
Relationship is
_ Adult in charge of Defendant's residence who refused to give name or relationship.
_ Manager/ Clerk of place of lodging in which Defendant(s) reside(s).
_ Agent or person in charge of Defendant's office or usual place of business.
an officer of said Defendant's company.
TYPE OF ACTION
XX Notice of Sheriff's Sale
SALE DATE: June 4, 2014
Other:
iAN F Other
Description: Age 30 s Height 5 4 ' Weight 130 Race �koP�lS'ex
1, Ronald Moll , a competent adult, hereby verify that I personally handed a true and correct copy of the
Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address
indicated above. I understand that this statement is made subject to t)Le penalties of 18 Pa. C.S. Sec. 4904 relating to
unworn falsification to authorities.
DATE 3 IeZ ( NAME: 61/1A&
PRINTED NAME: Ronald. MOIL
Process Server
TITLE:
On the day of 20 at
state thatleFet NOT FOUND because:
NOT SERVED
o'clock _. M., I, , a competent adult hereby
_ Vacant _ Does Not Exist _ Moved _ Does Not Reside (Not Vacant)
_ No Answer on at at
Service Refused
Other:
I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
BY:
PRINTED NAME:
ATTORNEY FOR PLAINTIFF
Phelan HaDinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
(215) 563 -7000
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
WELLS FARGO BANK, N.A.
Plaintiff
v.
MASOOD AHMED
GUL BUSHRA
AND NOW, this
Defendants
Court of Common Pleas
Civil Division
CUMBERLAND County
No.: 13-4369 CIVIL
RULE
/1- day of 4,49/ 2014, a Rule is entered upon the Defendants
to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess
Damages.
Defendants shall have twenty (20) days from the date of this Order to file a response to
Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a
Motion to Make Rule Absolute and no hearing will be scheduled on this matter.
BY TH COURT
818147
Adam H. Davis, Esq., Id. No.203034
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
TEL: (215) 563-7000
FAX: (215) 563-3459
JAMIE M. HALEY
401 EAST LOUTHER STREET, SUITE 103
CARLISLE, PA 17013
MASOOD AHMED
152 LINCOLN AVENUE
HARRISBURG, PA 17111-4154
MASOOD AHMED
67 JOHNS DRIVE
ENOLA, PA 17025-2694
818147
/
Phelan Hallinan, LLP 2C
Adam H. Davis, Esq., Id. No.203034 J 2� i 10; ATTORNEY FOR PLAINTIFF
1617 JFK Boulevard, Suite 1400 CUMBERLAND C
One Penn Center Plaza PENNS Y�-Y CO J
Philadelphia, PA 19103
Adam.Davis @PhelanHallinan.com
215 -563 -7000
WELLS FARGO BANK, N.A.
Plaintiff
vs.
MASOOD AHMED
GUL BUSHRA
Court of Common Pleas
Civil Division
CUMBERLAND County
No.: 13 -4369 CIVIL
Defendants
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's April 14, 2014 Rule directing
the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be
granted was served upon the following individuals on the date indicated below.
JAMIE M. HALEY, ESQUIRE
401 EAST LOUTHER STREET, SUITE 103
CARLISLE, PA 17013
MASOOD AHMED
152 LINCOLN AVENUE
HARRISBURG, PA 17111 -4154
DATE: c-ffi
MASOOD AHMED
67 JOHNS DRIVE
ENOLA, PA 17025 -2694
Phelan Hallinan, LLP
By:
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
818147
Phelan Hallinan, LLP P i 0,/id
, ' rCOUNT
Jonathan Lobb, Esq., Id:No.312174781G F1A'Y -9 Aiv / :
ATTORNEY FOR PLAINTIFF
i : 04
1617 JFK Boulevard, Suite 1400 ,
0
One Penn Center Plaza ru°iBERL AND
Philadelphia, PA 19103 PENNSYLVANIA
Jonathan.Lobb@phelanhallinan.com
215-563-7000
WELLS FARGO BANK, NA.
Plaintiff
vs.
MASOOD AHMED
GUL BUSHRA
Defendants
-• Court of Common Pleas
Civil Division
CUMBERLAND County
No.: 13-4369 CIVIL
MOTION TO MAKE RULE ABSOLUTE
WELLS FARGO BANK, N.A., by and through its attorney, hereby petitions this
Honorable Court to make Rule to Show Cause absolute in the above -captioned action, and in
support thereof avers as follows:
1. A Motion to Reassess Damages was filed with the Court on April 11, 2014.
2. A Rule was issued by the Honorable Judge Kevin A. Hess on or about April 14,
2014 directing the Defendants to show cause by May, 4, 2014 why the Motion to Reassess
Damages should not be granted. A true and correct copy of the Rule is attached hereto, made
part hereof, and marked Exhibit A.
3. The Rule to Show Cause was timely served upon all parties on April 21, 2014 in
accordance with the applicable rules of civil procedure. A true and correct copy of the
Certificate of Service is attached hereto, made part hereof, and marked Exhibit B.
4. Defendants failed to respond or otherwise plead by the Rule Returnable date of
May 4, 2014.
818147
. TW lei, •
WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show
Cause absolute and grant Plaintiff's Motion to Reassess Damages.
DATE: S 1 g /% r By:
Phelan Hallinan, LLP
Jo an Lobb, Esq., Id. No.312174
A orney for Plaintiff
818147
Exhibit "A"
818147
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
PENNSYLVANIA
WELLS FARGO BANK, N.A.
Plaintiff
V.
MASOOD AHMED
GUL BUSHRA
AND NOW, this
Defendants
•
Court of Common Pleas
Civil Division•
CUMBERLAND County
No.: 13-4369 CIVIL
day 20.14, a Rule is entered upon the Defendants
to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess
Damages.
Defendants shall have twenty (20) days from the date of this Order to file a response to
Plaintiffs Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a
Motion to Make Rule Absolute and no hearing will be scheduled on this matter.
BY T COURT
818147
Adam H. Davis, Esq., Id. No.203034
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103
TEL: (215) 563-7000
FAX: (215) 563-3459
JAMIE M. HALEY
401 EAST LOUTHER STREET, SUITE 103
CARLISLE, PA 17013
MASOOD AHMED
152 LINCOLN AVENUE
HARRISBURG, PA 17111-4154
MASOOD AHMED
67 JOHNS DRIVE
ENOLA, PA 17025-2694
818147
Exhibit "B"
818147
Phelan Hallinan, LLP
Adam H. Davis, Esq., Id. No.203034
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Adam.Davis@PhelanHallinan.com
215-563-7000
WELLS FARGO BANK, N.A.
Plaintiff
vs.
MASOOD AHMED
GUL BUSHRA
Defendants
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CUMBERLAND County
No.: 13-4369 CIVIL
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the Court's April 14, 2014 Rule directing
the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be
granted was served upon the following individuals on the date indicated below.
JAMIE M. HALEY, ESQUIRE
401 EAST LOUTHER STREET, SUITE 103
CARLISLE, PA 17013
MASOOD AHMED
152 LINCOLN AVENUE
HARRISBURG, PA 17111-4154
DATE: efil (77(1C
By:
MASOOD AHMED
67 JOHNS DRIVE
ENOLA, PA 17025-2694
Phelan Hallinan, LLP
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
818147
Phelan Hallinan, LLP
Jonathan Lobb, Esq., Id. No.312174
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Jonathan.Lobb@phelanhallinan.com
215-563-7000
WELLS FARGO BANK, N.A.
Plaintiff
vs.
MASOOD AHMED
GUL BUSHRA
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
CUMBERLAND County
No.: 13-4369 CIVIL
Defendants
CERTIFICATION OF SERVICE
I hereby certify that true and correct copies of Plaintiffs Motion to Make Rule Absolute
was served upon the following individuals on the date indicated below.
JAMIE M. HALEY, ESQUIRE
401 EAST LOUTHER STREET, SUITE 103
CARLISLE, PA 17013
MASOOD AHMED
152 LINCOLN AVENUE
HARRISBURG, PA 17111-4154
DATE: /6hv
MASOOD AHMED
67 JOHNS DRIVE
ENOLA, PA 17025-2694
Phelan Hallinan, LLP
By: %✓T/
Josr:"an Lobb, Esq., Id. No.312174
Attorney for Plaintiff
818147
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A. Court of Common Pleas
Plaintiff
Civil Division
vs.
CUMBERLAND CounKT c-,
MASOOD AHMED -,X .r- -t
GUL BUSHRA No.: 13-4369 CIVIL M
=n r- —� .:'
Defendants rte- co
>cp
,,-T,
li- c)
ORDER ;, c -- c ---,r
AND NOW, this ,34 day of rkuki , 2014, upon consideration of Plaint's f
Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered
upon Defendants shall be and is hereby made absolute and Plaintiff's Motion to Reassess
Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED
to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows:
Principal Balance
Interest Through March 11, 2014
Late Charges
Legal fees
Cost of Suit and Title
Property Inspections
Mortgage Insurance Premium/ Private Mortgage Insurance
Escrow Deficit
$137,251.54
$7,506.00
$234.15
$1,550.00
$967.61
$75.00
$289.74
$2,676.70
TOTAL $150,550.74
Plus interest at six percent per annum.
Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above
figure.
818147
N
PHELAN HALLINAN, LLP
Adam H. Davis, Esq., Id. No.203034
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
Adam.Davis@PhelanHallinan.com
215-563-7000
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.
Plaintiff,
v.
MASOOD AHMED
GUL BUSHRA
Defendant(s)
CUMBERLAND COUNTY
•
COURT OF COMMON PLEAS
CIVIL DIVISION
. No.: 13-4369 CIVIL
AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2
COMMONWEALTH OF PENNSYLVANIA )
PHILADELPHIA COUNTY ) SS:
As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders
and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of
the persons or parties named, at that address, set forth on the Affidavit and as amended if
applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return
Receipt stamped by the U.S. Postal Service is attached hereto Exhibit "A".
Date: 5/< ?M
IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not
be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale
must be postponed or stayed in the event that a representative of the plaintiff is not present
at the sale.
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
PH # 818147
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Phelan Hallinan, LLP
ini. 1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103 AZK/CET - 06/04/2014 SALE
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Article Number
Name of Addressee, Street, and Post Office Address
Postagew
****
TENANT/OCCUPANT
67 JOHNS DRIVE i
ENOLA, PA 17025-2694
50.45
****
LAUREL HILLS NORTH
its
216 TORY CIRCLE
ENOLA, PA 17025
50.45 (4
****
MASOOD AHMED C/O TIMOTHY J. O'CONNELL, ESQUIRE
4701 NORTH FRONT STREETS
HARRISBURG, PA 17110
50.45 '.1
****
Domestic Relations of
Cumberland County %
13 North Hanover Street•
Carlisle, PA 17013
50.45
****
Commonwealth of Pennsylvania
Department of Welfare r
P.O. Box 2675
Harrisburg, PA 17105
50.45
l
{
****
Internal Revenue Service Advisory
1000 Liberty Avenue Room 704 ,
Pittsburgh, PA 15222
50.45
****
U.S. Department of Justice
U.S. Attorney for the Middle District of PA
Federal Building
228 Walnut Street, Suite 220 '
PO Boz 11754
Harrisburg, PA 17108-1754
50.45
'
****
GUL BUSHRA CIO JAMIE M. HALEY, ESQUIRE
401 EAST LOUTHER STREET
SUITE 103 al
CARLISLE, PA 17013
50.45
Number of
s Listed by Sender
1
i
Total Number of Pieces
Received at Post Office
Postmaster, Per (Name of
Receiving Employee)
The full declaration of value is required on all domestic and international registered mail. The maximum indemnity payable
for the reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is $50,000 per
piece subject to a limit of SS00,000 per occurrence. The maximum indemnity payable on Express Mail merchandise is S OO.
The maximum indemnity payable is'S2S,000 for registered mail, sent with optional insurance. See Domestic Mail Manual
R900 S913 and S921 fir limitations of coverage.
im 3877 Facsimile
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
C ; .- THE PROTHONOTARY
Z I II AUC -5 PH 2: 03
OFFICE OFT. CUMBERLAND COUNTY
PENNSYLVANIA
Wells Fargo Bank, N.A.
vs. Case Number
Masood Ahmed (et al.) 2013-4369
SHERIFF'S RETURN OF SERVICE
03/28/2014 03:46 PM - Deputy Ryan Burgett, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 67 Johns Drive, East Pennsboro - Township, Enola, PA
17025, Cumberland County.
03/28/2014 03:46 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, by making known its contents and at the same
time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Gul
E Bushra at 67 John's Drive, East Pennsboro, Enola, PA 17025, Cumberland County.
06/04/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse 1 Courthouse Square Carlisle Pa, 17013 at 1000 am on June 4, 2014.
He sold the same for the sum of $1.00 to Attorney Joseph Schalk, on behalf of, Wells Fargo Bank, N.A.,
being the buyer in this execution, paid to the Sheriff the sum of
SHERIFF COST: $817.54 SO ANSWERS,
July 11, 2014 RONNY R ANDERSON, SHERIFF
,C) C ount,ysu: e
en
On March 3, 2014 the Sheriff levied upon the
defendant's interest in the real property situated in
-East Pennsboro Township, Cumberland County, PA,
CZ Known and numbered as 67 Johns Drive,
U . -.
L.; Enola, as Exhibit "A" filed with this
L cc,
Writ and by this Reference incorporated herein.
Date: March 3, 2014
By:
Real Estate Coordinator
LXIII 16 CUMBERLAND LAW JOURNAL 04/18/14
Writ No. 2013-4369 Civil Term
Wells Fargo Bank, N.A.
vs.
Masood Ahmed
Gul E. Bushra
Atty.: Joseph Schalk
By virtue of a Writ of Execution
No. 13-4369 CIVIL, WELLS FARGO
BANK, N.A. v. MASOOD AHMED
GULBUSHRA owner(s) of property
situate in EAST PENNSBORO TOWN-
SHIP, CUMBERLAND County, Penn-
sylvania, being 67 JOHNS DRIVE,
ENOLA, PA 17025-2694.
Parcel No. 09-15-1288-358.
Improvements thereon: RESIDEN-
TIAL DWELLING.
Judgment Amount: $140,929.66.
21
1
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA :
: ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
April 18, April 25 and May 2, 2014
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
Lisa Marie Coyne Editor
SWORN TO AND SUBSCRIBED before me this
da of May, 2014
Notary
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BORO.. CUMBERLAND CNTY
My Commission Expires Apr 2e. 2011
lZhe Patriot -News Co.
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE
PA 17013
be atriotJews
Now you know
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday
Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317.
PUBLICATION COPY
2013-4369 Civil Term
Wells Fargo Bank, N.A.
Vs
Masood Ahmed
Gul E Bushra
Atty: Joseph Schalk
By virtue of a Writ of Execution No.
13-4369 CIVIL .
WXLLS FARGO BANK, N.A.
v.
MASOOD AHMED
GULBUSHRA
owner(s) of property situate in
EAST PENNSBORO TOWNSHIP, i
CUMBERLAND County,
Pennsylvania, being 67 JOHNS
DRIVE, ENOLA, PA 17025-2694.
Parcel No. 09-15-1288-358.
(Acreage or street address)
Improvements thereon:
RESIDENTIAL DWELLING
Judgment Amount: $140,929.66
This ad ran on the date(s) shown below:
04/13/14
04/20/14
04/27/14
Sworn
subscribed before me
4 • D
U • IC
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Holly Lynn Warfel, Notary Public
Washington Twp., Dauphin County
My Commission Expires Dec. 12, 2016
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
} SS:
I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the
Sheriff's Deed in which Wells Fargo Bank N A is the grantee the same having been sold to said grantee
on the 4th day of June A.D., 2014, under and by virtue of a writ Execution issued on the 10th day of
February, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2013 Number
4369, at the suit of Wells Fargo Bank N A against Masood Ahmed & Gul Bushra is duly recorded as
Instrument Number 201417328.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office thisJ41 day of
A U@US+ , A.D. 00 (LI
)1)CW-eta •().-ezaio-Y7, D6lati
Recorder of
Recorder of Deeds, Cumberland County, Carlisle,°PA
My Commission Expires the First Monday of Jan. 2018
ee s