HomeMy WebLinkAbout13-4980 Supreme Court of Pennsylvania
4
Cou of�iion , Pleas
(.3ivil;.Coverr,'beet For Prothonotary Use Only:
'�� I�,.(�! -fit W '
CUMBERLA r County Docket No:
��.
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S ® Complaint ❑ Writ of Summons ❑ Petition
❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
E Lead Plaintiffs Name: Wells Fargo Bank, N.A. Lead Defendant's Name: Peter J. Hoffman
C
T Are money damages requested ?: ❑ Yes ® No Dollar Amount Requested: within arbitration limits
I (Check one)
X outside arbitration limits
O
N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeaP ❑ Yes ® No
Name of Plaintiff /Appellant's Attorney: Scott A. Dietterick, Esq. c/o Zucker, Goldberg & Ackerman, LLC
A ❑ Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
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Updated 1/1//2011
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
062 -PA -V3
y Y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A., CIVIL DIVISION
p F-
Plaintiff, NO.. t/ n�
r ,
TYPE OF PLEADING s= %°'''
Peter J. Hoffman; Donna B. Hoffman;
CIVIL ACTION - COMPLAINT
Defendants. IN MORTGAGE FORECLOSURE
TO: DEFENDANTS FILED ON BEHALF OF:
YOU ARE HEREBY NOTIFIED TO PLEAD TO THE
ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS Wells Fargo Bank, N.A.
FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE
ENTERED AGAINSTYOU. COUNSEL OF RECORD FOR THIS PARTY:
I HEREBY CERTIFY THAT THE ADDRESS
OFTHE PLAINTIFF IS: ZUCKER GOLDBERG & ACKERMAN, LLC
3476 Stateview Blvd.
Ft. Mill, SC 29715
Scott A. Dietterick, Esquire
AND THE DEFENDANT: Pa. I.D. #55650
550 Saint Johns Drive Kimberly A. Bonner, Esquire
Camp Hill, PA 17011 -1332 Pa. I.D. #89705
Joel A. Ackerman, Esquire
Pa I.D. #202729
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF Ashleigh Levy Marin, Esquire
THE REAL ESTATE AFFECTED BY THIS LIEN IS Pa I.D. #306799
550 Saint Johns Drive, Camp Hill PA 17011 -1332 Ralph M. Salvia, Esquire
Municipality: Ham den
Pa I.D. #202946
(I W(IA Jaime R. Ackerman, Esquire
ATTORNEY70R PLAINTIFF Pa I.D. #311032
ATTY FILE NO.: XFP 167098 -R1 200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233 -8500
(908) 233 -1390 FAX
office @zuckergoldberg.com
File No.: XFP- 167098- R1 /rbo
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
NO..
vs.
Peter J. Hoffman; Donna B. Hoffman;
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the following pages,
you must take action within twenty (20) days after this complaint and notice are served, by entering a
written appearance personally or by attorney and filing in writing with the court your defenses or
objections to the claims set forth against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the court without further notice
for any money claimed in the complaint or for any other claim or relief requested by the plaintiff.
You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO
YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990 -9108 Phone (800) 990 -9108
(717) 249 -3166 (717) 249 -3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
NO..
VS.
Peter J. Hoffman; Donna B. Hoffman;
Defendants.
AVISO
USTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de la demanda establecida en
las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la
notificaci6n de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una
comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas
establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe
anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de
dinero reclamada en la demanda 0 cua Iquier otra reclamaci6n o remedio solicitado por el
demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o
propiedades u otros derechos importantes para usted.
USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI LISTED NO TIENE UN
ABOGADO 0 NO PUEDE PAGAR LINO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR
DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL.
NOTICE TO DEFEND & LAWYER REFERRAL SERVICE
NOTICE TO DEFEND LAWYER REFERRAL
Cumberland County Bar Association Cumberland County Bar Association
32 S. Bedford Street 32 S. Bedford Street
Carlisle, PA 17013 Carlisle, PA 17013
Phone (800) 990 -9108 Phone (800) 990 -9108
(717) 249 -3166 (717) 249 -3166
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
NO..
VS.
Peter J. Hoffman; Donna B. Hoffman;
Defendants.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg & Ackerman, LLC,
and files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is Wells Fargo Bank, N.A., (hereinafter "plaintiff ") with its place of
business located at 3476 Stateview Blvd., Ft. Mill, SC 29715.
2. The Defendant, Peter J. Hoffman, is an individual whose last known address.is 550
Saint Johns Drive, Camp Hill, PA 17011 -1332.
3. The Defendant, Donna B. Hoffman, is an individual whose last known address is 550
Saint Johns Drive, Camp Hill, PA 17011 -1332.
4. Wells Fargo Bank, N.A., directly or through an agent, has possession of the
Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the
Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked
Exhibit A, attached hereto and made a part hereof.
5. On or about April 9, 2008, Peter J. Hoffman'and Donna B. Hoffman made, executed
and delivered to Mortgage Electronic Registration Systems, Inc., as nominee for Lend America, a New
York Corporation a Mortgage in the original principal amount of $187,500.00 on the premises
described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said
mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on May 13,
2008, Instrument #200815694. The mortgage is a matter of public record and is incorporated herein
by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation
to attach documents to pleadings if those documents are of public record.
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
062 -PA -V3
6. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded May 9,
2011, the mortgage was assigned to Wells Fargo Bank, N.A. which assignment is recorded in the
Office of the Recorder of Deeds for Cumberland County, Instrument #201113349. The Assignment is
a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P.
1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those
documents are of public record.
7. The aforesaid Note and Mortgage was amended by a certain Loan Modification
Agreement. A true and correct copy of said Modification Agreement is marked Exhibit C, attached
hereto and made a part hereof.
8. Peter J. Hoffman and Donna B. Hoffman, his wife are the record and real owners of
the aforesaid mortgaged premises.
9. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the monthly installments of principal and interest due January 1, 2013.
10. As of 07/19/2013 the amount due and owing Plaintiff by Defendants) is as follows:
Principal $211,089.72
Interest through 07/19/2013 $ 5,174.86
Escrow Advance $ 284.31
Late Charges $ 213.48
Inspection Fees $ 30.00
Total $ 216,792.37
plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law,
actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow
advances) and Plaintiffs attorneys' fees and expenses. Plaintiff reserves the right to file a motion in
the above - captioned action to add such additional sums authorized under the Mortgage and
Pennsylvania Law to the above amount due and owing when incurred.
11. 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).
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
062 -PA -V3
12. This action does not come under Act 91 of 1983 because the mortgage is FHA
insured.
13. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is
not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in
a separate legal action if such right exists. If Defendant(s) have received a discharge of personal
liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount
due of $ 216,792.37 with interest thereon plus additional costs (including additional escrow
advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged
premises.
ZUCKER, GOLDBERG & ACKERIVAN, LLC
BY: (I A M &
Dated: , Scott A. Dietterick, Esquire; PA I.D. #55650
u Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP- 167098- R1 /rbo
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233 -8500; (908) 233 -1390 FAX
Email: Office @zuckergoldberg.com
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED
WILL BE USED FOR THAT PURPOSE.
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
062 -PA -V3
EXHIBIT A
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
062 -PA -V3
it CERTI I D T E COPY
BY
..o..a Loan Number:
MIN:
NOTE
I FHA CASE NO.
441- 8253469/703
APRIL 9, 2008
IDatel
550 SAINT JOHNS DRIVE, CAMP HILL, PENNSYLVANIA 17011
[Property Addressl
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means
LEND AMERICA
` and its successors and assigns.
2. BORIROWER'SPROMISE TO PAY; INTEREST
In return for a loan received from Lender. Borrower promises to pay the principal Bunt of ONE HUNDRED llars
EIGHTY —SEVEN THOUSAND FIVE HUNDRED AND 00 /100
(U.S.$ 187, 500.00 ) , plus interest, to the order of Lender. Interest will be charged on unpaid principal,
from the'date of disbursement of the loan proceeds by Lender, at the rate of SIX AND 125/1000
1 percent ( 6.12 5 %) 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.
if
4. MANNER OF PAYMENT
(A) :j Time
Borrower shall make a payment of principal and interest t A Lender cipal t nd interest remaining remaining on the he firsts day of
on JUNE, 2008
MAY, ' 2038' will be due on (hat date, which is called the "Maturity Date."
(B) ;`: Place MELVILLE, NEW YORK 11747
Payment shall be made at 201 OLD COUNTRY. ROAD,
i
or at such other place as Lender may designate in writing by notice to Borrower.
(C) , Amount 39 27
Each monthly payment of principal and interest will be in the amount of U.S. $ 1, 1.
This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal,
Interest' j`d other items in the order described in the Security Instrumeni.
(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 all be incorporated Into and shall amend and supplement the covenants of this Note as if the allonge were a part
of this Ntile. (Check applicable box.)
�) 0 Growing Equity Allonge, Graduated Payment Allonge
i ❑ 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
by Lender and permitted by regulations of the Secretary.- If Borrower
for the remainder of the month to the extent required
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:
MULTISTATE•FI(A RXFD RATE NO (dam
(NO) 649AM2
DaumeM S ` �ms I I l �lll I�l��lll IIII) Illl IIIIII IIII IIII) 111 IIIII�I IIII IIII) VIII �l� Illlll VIII lull VIII VIII VIII VIII ����� NIII (IIII Illl IIII {
l.�
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
of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in [he amou t %)
FOUR H AND 000 /1000
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. Sucli fees and casts 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 Ihar amounts due have not been paid.
g. GIVINGOF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note willbe 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 first class mail to Lender at the address stated
in Paragri ph 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 mout owed. Any person who is a guarantor, surety Che en ono of
of to
Note i also obligated to I things. Any Person
guarantor, surety or endorser of ( r of his.Note, is also obligated to keep a ll of the promises made in this Note. Lender may
enforce its rights under this Note against each person individually or against all signatories together. Any one person signing
this Note may be required to pay all of the amounts owed under this Note.
I
t
BY SI G BELOW, Borrower accepts and agrees to the terms and covenants contained in pages 1 and 2 of this Note.
(Seal)
(Seal) - Borrower
PETER, ' HOFFMAN Borrower
i t (Seal)
(Seal) -Borrower
- Borrower
�j (Seal)
(Seat)
-Borrower
- Borrower
I
t ,
PAY TO THE ORDER OF
(! REC IC 8
1 A
{I A
VICE PRESIDENT
I
MU1.714rATE -FHA FIX M RATE NOTE. (6196) Page 2 of 2
����
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(Page 20 of 42)
Bar-24 -2006 10 :42ta Fror T-532 P.0OV024 F-636
J
ALLONGE
(
This Allongo Is aid and made a part of that ,certain promissory note dated
04/14/1003, together with all reaewaia, extensions and modiScatton% if any, cm=d
and given by I'J HOML4N ASSOC1AT1l~4, INC. in the odginal amount Of
514,000.00. It is to be read tngetber with and is hereby incorporated by ret'eronee in the
attached insmMont and G an tweval Part therWE
Pay to the order of NC TWO, L.P., ae is; where is; with aU fl au and without
raxurse ad without a� to mentadw or war andes of any kind, whether express or
implied, oral or wdttenj except as provided in Atuole VII of tb d oertaia lroan Sale
Agreement dated Novem 15, 2005.
Effective as of thb 15th day of November 2005. i
BANK OF Ab11irRI" N.A. gUCCiLSSOR TO
n3i i NATiONAL RANK
Name
Title; Vice Piselderd
32
FCFfO31t0! `
i '
EXHIBIT B
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
062 -PA -V3
First American Tltie Insurance Company
Schedule C Description
i
I Title Number VN664MPA Page 1
i
ALL THAT CERTAIN LOT OF LAND SITUATE IN HAMPDEN TOWNSHIP,
i CUMBERLAND. COUNTY, PENNSYLVANIA, MORE PARTICULARLY
BOUNDED AND DESCRIBED. AS FOLLOWS;
BEGINNING AT A POINT ON THE WESTERN LINE OF POINT RIDGE DRIVE
SHOWN ON THE HEREINAFTER MENTIONED PLAN OF LOTS, ON THE
i DIVIDING LINE BETWEEN LOTS NOS. 34 AND 35 ON SAID PLAN, SAID
}JOINT OF BEGINNING BEING 370 FEET MEASURED NORTHWARDLY
ALONG THE WESTERN LINE OF SAID STREET FROM THE INTERSECTION.
i OF THE NORTHERN LINE OF WEST LAUER LANE AND THE WESTERN
�! LINE OF POINT RIDGE DRIVE AS SHOWN ON SAID PLAN; THENCE IN A
WEST15RLY DIRECTION ALONG SAID DIVIDING LINE BETWEEN LOTS NOS.
34 AND 36., 145.6 FEET TO A POINT; THENCE IN A NORTHWESTERLY
DIRECTION ALONG THE DIVIDING LINE BETWEEN LOTS NOS. 29 AND 35'
AN D 28 AND 35, 92.4 FEET TO A POINT; THENCE IN AN EASTERLY
DIRECTION ALONG THE DIVIDING LINE BETWEEN LOTS NOS. 35 AND 36,
154.8 FEET TO THE WESTERN LINE OF POINT RIDGE DRIVE; THENCE IN A
SOUTHERLY DIRECTION ALONG THE WESTERN LINE OF POINT RIDGE
DRIVE ON A CURVE TO.THE :RIGHT, HAVING A RADIUS OF 1880.08 FEET,
100 FEET TO THE PLACE OF BEGINNING.
BEING LOT'NO. 35 AS SHOWN ON PLAN OF LOTS, SECTION 1, POINT
RIDGE FARM,, HAMPDEN TOWNSHIP; CUMBERLAND COUNTY,
PENNSYLVANIA, SAID PLAN BEING RECORDED IN PLAN BOOK 8, PAGE 2,
CUMBERLAND COUNTY RECORDS.
PARCEL NO, 10-19-1598-070
BEING THE SAME PREMISES WHICH CIARA JANE GOODWIN, BY DEED
DATED 11 -08 -85 AND RECORDED 11- 1.3 -85 IN THE OFFICE OF THE
RECORD OF DEEDS IN AN.D FOR THE COUNTY OF CUMBERLAND IN
RECORD BOOK 0 -31 PAGE 1097, GRANTED AND CONVEYED UNTO
PETER J. HOFFMiAN AND DONNA B. HOFFMAN, HUSBAND AND WIFE.
EXHIBIT C
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
062 -PA -V3
Wells Fargo Home Mortgage
-✓ MAC W0152.010
• , 220 Wildwood Parkway
Birmingham, AL 35209
Tel: 877 3254114 Toll Free
LOAN MODIFICATION AGREEMENT
LOAN NUMBER: 1
PROPERTY ADDRESS 550 Saint Johns Drive
Camp Hill PA 17011
THIS LOAN MODIFICATION AGREEMENT ( "Agreement "), made on
June 29, 2011, by and between Peter J Hoffman and
and ( the 11 Borrower (s) ") •and
Wells Fargo Bank, N.a. (the "Lender ",
together with the Borrower(s), the "Parties ").
WITNESSETH
WHEREAS, Borrower has requested and Lender has agreed, subject to the
following terms and conditions, to a loan modification as follows:
NOW'THEREFORE, in consideration of the covenants hereinafter set forth
and for other good and valuable consideration, the receipt and
sufficiency of which are hereby acknowledged by the Parties, it is agreed
as follows (notwithstanding anything to the contrary in the Note and
Security Instrument dated 04/09/2008.)
1. BALANCE. As of June 29, 2011, the amount payable under the Note
and Security Instrument (the "Unpaid Principal Balance ") is U.S.
$ 197,980.35.
2. EXTENSION. This Agreement hereby modifies the following terms of the
Note and Security Instrument described herein above as follows:
A. The current contractual due date has been extended from 04 -01 -11
to 09/01/2011. The first modified contractual due date is on
09/01/2011.
B. The maturity date has been extended from 09 -40 (month /year) to
08/01/2041.
C. The amount of interest to be included (capitalized) will be U.S.
$ 3,918.35.
The amount of the Escrow Advance to be capitalized will be U.S. $1,649.84.
The amount of Recoverable Expenses* to be capitalized will be
U.S. $0.00.,
The modified Unpaid Principal Balance is U.S. $ 203,548,54.
* Recoverable Expenses may include, but are not limited to: Title,
Attorney fees /costs, BPO /Appraisal, and /or Property Preservation/
Property Inspections
D. The Borrower(s) promises to pay the Unpaid Principal Balance plus
interest, to the order of the Lender. Interest will be charged on the
Unpaid Principal Balance of U.S. $ 203,548.54. The Borrower(s) promises
to make monthly payments of principal and interest of U.S. $ 1,046.52,
at a yearly rate of 4,6251, not including any escrow deposit, if
applicable. If on the maturity date the Borrower(s) still owes an amount
under the Note and Security Instrument, as amended by this Agreement,
Borrower(s) will pay this amount in full on the maturity date.
LM521 /WUC /1
Together we'll go far
Wells Fargo Home Mortgage is a division of Wells Fargo Bank, N.A. NMLSR ID 399801 __ _ • _ _. .. .._. ._.. _.. . _...._.._
Wells Fargo Home Mortgage
~' MAC W0152 -010
220 Wildwood Parkway
Birmingham, AL 35209
Tel: 877 325 4114 Toll Free
E. Borrowe•r that certain amounts owed will not be capitalized,
waived, or addressed as part of this Agreement, and will remain owed
until paid. These amounts owed are referenced in the Cover Letter to
this Agreement,••which is incorporated herein, and are to be paid with
the return of this executed Agreement. If these amounts owed are not
paid with-the return of this executed Agreement, then Lender may deem
this Agreement void.
3. NOTE AND SECURITY INSTRUMENT. Nothing in this Agreement shall be
understood or construed to be a satisfaction or release, in whole or in
part of the Borrower-s obligations under the Note or Security Instrument.
Further, except,as otherwise specifically provided in this Agreement, the
Note and Security "Instrument will remain unchanged, and Borrower and
Lender will bek:bound by, and shall comply with, all of the terms and
provisions thereof, as amended by this Agreement.
4, The undersigned Borrower(s) acknowledge receipt and acceptance of the
Loan Modification Settlement Statement. Borrower(s) agree with the
information disclosed in and understand that I /we am /are responsible for
r, payment of _ any outstanding balances outlined in the Loan Modification
1K ' =
Settlement.
The undersigned Borrower(s) acknowledge receipt and acceptance of the
Borrower Acknowledgements, Agreements, and Disclosures Document (BARD).
6. If included, the.undersigned Borrower(s) acknowledge receipt and
acceptance of the Truth in Lending statement.
�::•. 7.. If included, the undersigned Borrower(s) acknowledge receipt and
acceptance of the 1 - Family Modification Agreement Rider Assignment
of Rents.
8. If included, the undersigned Borrower(s) acknowledge receipt and
acceptance of the Special Flood Hazard Area (SFHA).
9. This Agreement is conditioned upon the receipt of the 1 -4 Family
Modification Agreement Rider Assignment of Rents, if included, specified
in the attached cover letter, which is incorporated herein by reference.
10. That (he /she /they) (is /are) the Borrower(s) on the above - referenced
Mortgage Loan serviced by Wells Fargo Bank, N.a.
That (he /she /they) have experienced a financial hardship or. change in
financial circumstances since the origination of (his/her/their)
Mortgage Loan.
That .(he /she / they} did not intentionally or purposefully default on the
Mortgage Loan in order to obtain a loan modification.
LM521 /WUC /2
Together we'll go far
Wells Fargo Home Mortgage Is a division of Wells Fargo Bank, N.A. NMLSR ID 399801
Wells Fargo Home Mortgage
MAC W0152.010
220 W ildwood Parkway
Birmingham, AL 35209
Tel: 877 325 4114 Toll Free
CORRECTION AGREEMENT, The undersigned borrower(s), for and in
consideration of the approval, closing and funding of this
Modification, hereby grants Wells Fargo Bank, N.a. , as
lender, limited power of attorney correct and /or initial all
typographical or clerical errors discovered in the Modification
Agreement required to be signed. In the event this limited power of
attorney is exercised, the undersigned will be notified and receive
a copy of the document executed or initialed on their behalf. This
provision may not be used to modify the interest rate, modify the
term, modify the outstanding principal balance or modify the
undersigned's monthly principal and interest payments as modified by
this Agreement.;Any of these specified changes must be executed
directly by the undersigned. This limited power of attorney shall
. .automatically terminate in 120 d ys from the closing date of the
undersigned's Modification. (Borrower(s) initial)
IN WITNESS WHEREOF, the Parties hereto have executed this Agreement as
the date' f-irst.above written.
By signing.this Agreement I hereby consent to being contacted concerning
this loan at any cellular or mobile telephone number I may have. This
includes text messages and telephone calls including the use of
automated dialing systems to contact.my cellular or mobile telephone.
You will not be billed by your cellular or mobile carrier for any text
messages you may receive from Wells Fargo, however, any calls we place
to your cellular or mobile phone will- incur normal airtime charges
assessed by your mobile carrier.
Date as of this day of �v 20
Peter offman
Signatu e Signature
Wells.Fargo Bank, N.a.
Name: Sarah Witte
Vice P resident loan Documentation
Its: _
LM527 /WUC /3 ,
Together we'll go far
Wells Fargo Home Mortgage is a division of Wells Fargo Bank, N.A. NMLSR ID 399801
e
VERIFICATION
Linwood Williams, hereby states tha he she is Vice President Loan
Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that &she 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&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.
1..J
Name: Linwood Williams
Title: Vice President Loan Documentation
Company: Wells Fargo Bank, N.A.
Date: 07/30/2013
086 -PA -V2 File# 167098 -R 1
,
UN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
� NC).:
VS. . ' c` �� -n
Peter J. Hoffman; Donna B. Hoffman;
Defendants.
cz `
c�
�� re
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
if you own and live in the residential property which is the subject of this foreclosure action, you
may be able to participate in a court-supervised conciliation conference in an effort to resolve this
matter with your lender.
If you dm not have alawyer, you must take the following steps tmbe eligible for aconciliation
conference. First, within twenty (30) days of your receipt of this notice, you must contact K4idPenn
Legal Services at (717) 243'9400 extension 3510 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 (30) days of the
appointment date. During that meeting, you must provide the legal representative with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. If you and your
legal representative complete a financial worksheet in the format attached hereto, the legal
representative will prepare and file a Request for Conciliation Conference with the Court, which must be
filed with the Court within sixty /60\ days of the service upon you of the foreclosure complaint. if you do
so and a conciliation conference is scheduled, you will have an opportunity 10 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 fo|\mxvlmg steps to be
eligible for a conciliation conference. It is not necessary for you to contact K4idPenn Legal Service for
the appointment ofa legal representative. However, you must provide your lawyer with all requested
financial information so that a loan resolution proposal can be prepared on your behalf. if you and your
lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60)
days of the service upon you of the foreclosure complaint. if you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to
work out reasonable arrangements with your lender before the nnmr18aQe foreclosure suit proceeds
forxvard.
Zucker, Goldberg & Ackerman, LLC
XFP'167098'R1
• .x
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED
BY THIS NOTICE. TIDS PROGRAM IS FREE.
ZUCKER, GOLDBERG & ACKERMAN, LLC
By: 9�m QR
Dated: August , 2013 Scott A. Dietterick, Esquire; PA I.D. # 5650
Kimberly A. Bonner, Esquire; PA I.D. #89705
Joel A. Ackerman, Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D. #306799
Ralph M. Salvia, Esquire; PA I.D. #202946
Jaime R. Ackerman, Esquire; PA I.D. #311032
Attorneys for Plaintiff
XFP- 167098 -R1 /emed
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233 -8500; (908) 233 -1390 FAX
Email: Office @zuckergoldberg.com
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date:
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete• your request for hardship assistance, your lender must consider your circumstances to
determine possible options while working with your
Please provide the following information to the best of your knowledge:
CUSTOM ER/PRI MARY APPLICANT
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
CO-BORROWER
Mailing Address:
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date you closed your loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ No ❑
If yes, provide names, location of court, case number & attorney:
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
Assets Amount Owed Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1 : Model: Year:
Amount owed: Value:
Automobile #2 : Model: Year:
Amount owed: Value:
Monthly Income
Name of Employers:
1.
2.
3.
Additional Income Description (not wages):
1. Monthly amount:
2. Monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 " Mortgage Utilities
Car Payment(s) Condo /Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel /repairs Other prop. payment
Install. Loan Payment Cable TV
Child Support /Alim. Spending Money
Day /Child Care /Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
Email:
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes ❑ No ❑
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender or lender's loan servicing
company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
AUTHORIZATION
I /We, , authorize the above named to use /refer this
information to my lender /servicer for the sole purpose of evaluating my financial situation for possible
mortgage options. I /We understand that I /we am /are under no obligation to use the services provided
by the above named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and lender's counsel:
V Proof of Income
V Past 2 bank statements
V Proof of any expected income for the last 45 days
V Copy of current utility bill
V Letter explaining reason for delinquency and any supporting documentation (hardship letter)
V Listing agreement (if property is currently on the market)
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
NO..
VS.
Peter J. Hoffman; Donna B. Hoffman;
Defendants.
REQUEST FOR CONCILIATION CONFERENCE
Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies
as follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
1. Defendant lives in the subject real property, which is defendant's primary residence;
2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion
Program" and has taken all of the steps required in that Notice to be eligible to participate in
a court - supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I understand
that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn
falsification to authorities.
Signature of Defendant's Counsel /Appointed Date
Legal Representative
Signature of Defendant Date
Signature of Defendant Date
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
NO..
VS.
Peter J. Hoffman; Donna B. Hoffman;
Defendants.
CASE MANAGEMENT ORDER
AND NOW, this day of ,20 ,the defendant /borrower in the above -
captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference
verifying that the defendant /borrower has complied with the Administrative Rule requirements for the
scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court- supervised conciliation
Conference on at M. in at the
Cumberland County Courthouse, Carlisle, Pennsylvania.
1. At least twenty -one (21) days prior to the date of the Conciliation Conference, the
defendant /borrower must serve upon the plaintiff /lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet"
(Form 2) which has been completed by the defendant /borrower. Upon agreement of the parties
in writing or at the discretion of the Court, the Conciliation Conference ordered may be
rescheduled to a later date and /or the date upon which service of the completed Form 2 is to be
made may be extended. Upon notice to the Court of the defendant /borrower's failure to serve
the completed Form 2 within the time frame set forth herein or such other date as agreed upon
by the parties in writing or ordered by the Court, the case shall be removed from the
Conciliation Conference schedule and the temporary stay of proceedings shall be terminated.
2. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in
person and an authorized representative of the plaintiff /lender must either attend the
Conciliation Conference in person or be available by telephone during the course of the
Conciliation Conference. The representative of the plaintiff /lender who participates in the
Conciliation Conference must possess the actual authority to reach a mutually acceptable
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
resolution, and counsel for the plaintiff /lender must discuss resolution proposals with the
authorized representative in advance of the Conciliation Conference. If the duly authorized
representative of the plaintiff /lender is not available by telephone during the Conciliation
Conference, the Court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff /lender at the rescheduled
Conciliation Conference.
3. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and
explore all available resolution options which shall include: bringing the mortgage current
through a reinstatement; paying off the mortgage; proposing a forbearance agreement or
repayment plan to bring the account current over time; agreeing to tender a monetary payment
and to vacate in the near future in exchange for not contesting the matter; offering the lender a
deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the
mortgage default over sixty months; and the institution of bankruptcy proceedings.
4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation
conference.
BY THE COURT,
J.
Zucker, Goldberg & Ackerman, LLC
XFP- 167098 -R1
IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT:
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977),
DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF
DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING,
COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION
THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN
THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S)
THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE.
THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD
FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH
THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION
WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO
REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30)
DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE
DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD
THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR
EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE
REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE
CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT.
IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO
COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A. CIVIL DIVISION
Plaintiff,
NO.: 2013-04980
VS. w
Peter J. Hoffman; Donna B. Hoffman; %ro 01
N� N
Defendants.
<� 7v► Cs—r's
7;'n
-C
PRAECIPE TO SETTLE, DISCONTINUE AND END
TO THE PROTHONOTARY:
Please mark the case filed at the above-captioned term and number SETTLED, DISCONTINUED
and ENDED,without prejudice.
Respectfully bmitte
ZUCKER, GOLD
LLC
BY:
Scott A. Diet n k, uire; A .#55650
Kimberly A.r, on er, Esquire; PA I.D.#89705
Joel A.Ackeaa , Esquire; PA I.D. #202729
Ashleigh L. Marin, Esquire; PA I.D.#306799
Ralph M. Salvia, Esquire; PA I.D.#202946
Jaime R.Ackerman, Esquire; PA I.D.#311032
Attorneys for Plaintiff
XFP-167098/efl
200 Sheffield Street, Suite 101
Mountainside, NJ 07092
(908) 233-8500; (908) 233-1390 FAX
LEONARD B.ZUCKER ZUCKER, GOLDBERG & ACKERMAN, LLC FOUNDED IN 1923
OIELACK RMAN ACKERMAN ATTORNEYS AT LAW AS ZUCKER&GOLDBERG
FRANCES GAMBARDELLA MAURICE J.ZUCKER 119218�1979
BRIAN C.NICHOLAS 0 200 SHEFFIELD STREET-SUITE 101 LOUIS D.GOLDBERG 1919671 SCOTT A. P.O.BOX 1024 LEONARD H.GOLDBRG 1929-1979
KIMBERLY A-BO NER BENJAMIN WEISS 1949-1981
KIMBERLY A.BONNER Y MOUNTAINSIDE,N1 07092-0024
STEVEN D.KROL
CHRISTOPHER G.FORD TELEPHONE:908-233-8500
DENISE CARLON A
CHRISTINE E.POTTER FACSIMILE:908-233-1390
Pennsylvania Office:
RYAN S.MAIL E-MAIL:office @zuckergoldberg.com P.O.Box 650
STEPHANIE WOLCHOK Hershey,PA 17033
ASHLEIGH LEVY MARIN£
DOUGLAS J.McDONOUGH For payoff/reinstatement figures
TIMOTHY J.ZIEGLER Please send your request to:zuckergoldberg.com/pr
RALPH M.SALVIA Y ' ALSO MEMBER OF NY,PA AND CA BAR
ROBERT D.BAILEY ♦ALSO MEMBER OF NY, PA AND ME BAR
JAIME R.ACKERMAN♦ REPLY TO NEW JERSEY ADDRESS 0 ALSO MEMBER OFNYAND ME BAR
RACHEL G.PACKER# A ALSO MEMBER OFNYBAR
KACIE W*BROWN E ALSO MEMBER OF PA BAR
MONIKA S.PUNDALIK # ALSO MEMBER OFNYANDDCBAR
TODD MARKS A Y MEMBER OF PA BAR ONLY
TIMOTHY D.KUHLS A
XFP-167098 August 27, 2013
Cumberland County Prothonotary
Cumberland County Courthouse
Carlisle, PA 17013-3387
Re: Wells Fargo Bank, N.A.
vs. Peter J. Hoffman and Donna B. Hoffman, his wife
Property Address: 550 Saint Johns Drive
Camp Hill, PA 17011-1332
Docket No.: 2013-04980
Dear Sir/Madam:
Enclosed for filing please find an original and one copy of a Praecipe to Settle, Discontinue and End.
Please file the original,immediately upon receipt and return the extra copy of the face page,time-
stamped, in the self-addressed stamped envelope provided.
Should you have any questions,please feel free to contact Ellen Flanagan of our office at 908-233-8500
ext. 166.
Very Truly Yours,
ZUCKER, GOLDBERG&ACKERMAN, LLC
BY:
Ellen Flanagan, Legal Assistant
200 Sheffield Street,Suite 101
Mountainside, NJ 07092
Email: Office @zuckergoldberg.com
File No.: XFP-167098
(908)233-8500;(908) 233-1390 FAX
efl
enclosures