HomeMy WebLinkAbout13-5465 Supreme Court:of__Pennsylvania
Cour Comm of Commo Pleas
For Prothonotary Use Only:
ivil;Cover,h'eet
CU MBE County Docket No:
The information collected on this forin is used solely for court administration purposes. This form does not
su lenient or replace thefiling and service ofpleadings or other a ers as required by law or rules of court.
S Commencement of Action:
❑O Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiff's Name: WELLS FARGO BANK, N.A. Lead Defendant's Name: ANTHONY M. FERRETTI
T
I Are money damages requested? El Yes Z No Dollar Amount Requested: 171 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: Jonathan Lobb, Esq., Id. No.312174, Phelan Hallinan, LLP
❑ Checic here if you have no attorney (are a Self - Represented [Pro Sel 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 A4ass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
❑ Premises Liability ❑ Statutory Appeal: Other
❑ Product Liability (does not
S include mass tort) ❑ Employment Dispute:
❑ Slander/Libel/ Defamation Discrimination
E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board
C ❑ Other:
T
I MASS TORT ❑ Other:
O ❑ Asbestos
N ❑ Tobacco
❑ Toxic Tort - DES
• Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS
• Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration
$ ❑ 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:
• Medical ❑ Other:
❑ Other Professional:
Pa.R.C.P. 205.5 Updated 01/01/2011
I. P° THE PRDI ikl0pi0 f AR
2013 SEP 17 AM 10: 17
CUMBERLAND COUNTY
PENNSYLVANIA
PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF
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
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.
3476 STATEVIEW BOULEVARD CIVIL DIVISION
FORT MILL, SC 29715
Plaintiff, NO.:
vs.
ANTHONY M. FERRETTI
908 SIXTEENTH STREET
NEW CUMBERLAND, PA 17070 -1518
Defendant.
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 STATEVIEW
BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff'). 6)
062 -PA -V3 C, —J+ 1 30(oO
2. The Defendant, ANTHONY M. FERRETTI, is an individual whose last known
address is 908 SIXTEENTH STREET, NEW CUMBERLAND, PA 17070 -1518.
3. WELLS FARGO BANK, N.A., directly or through an agent, has possession of
the Promissory Note. WELLS FARGO BANK, N.A. is either the original payee of the
Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said
Promissory Note is marked Exhibit "A ", attached hereto and made a part hereof.
4. On or about March 27, 2009, ANTHONY M. FERRETTI made, executed and
delivered to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE
FOR FULTON BANK a Mortgage in the original principal amount of $162,011.00 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. 200909831. 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 April 4,
2013, the mortgage was assigned to WELLS FARGO BANK, N.A. which Assignment is
recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 201310740.
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. ANTHONY M. FERRETTI is record and real owner of the aforesaid mortgaged
premises.
7. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the monthly installments of principal and interest due May 1, 2013.
062 -PA -V3
8. As of 09/05/2013, the amount due and owing Plaintiff on the mortgage is as
follows:
Principal Balance $ 161,191.93
Interest 04/01/2013 through 09/05/2013 $ 3,188.00
Late Charges $ 906.64
Escrow Deficit $ 1;343.59
Suspense Balance $ (1,118.18)
TOTAL $ 165,511.98
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 $165,511.98 , with interest thereon plus additional costs (including additional
escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the
mortgaged premises.
B k j
Date: Gt �( JQffathan Lobb, Esq., Id. No.312174
Attorney for Plaintiff
062 -PA -V3
Exhibit "A"
t
Multistate
NOTE use 0.
March 27, 2009
(Date)
908 SIXTEENTH STREET
NEW CUMBERLAND, PA 17070
(Property Address]
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means
PULTON BANK
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 Sixty Two
Thousand Eleven And Zero /100
Dollars (U.S. $ 162, 011.00 }, 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 Five
percent( 5.000 o va) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is scoured by a mortgage, decd of trust or similar security instrument that is dated the same date
as this Note and called the "Security Instrument." The Security Instrument protects the Lender from 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 the first day of each month beginning on
May 01 , 2009 . Any principal and interest remaining on the first day of April ,
2039 , will be due on that date, which is called the "Maturity Date."
(B) Place
Payment shall be made at ONE PENN SQUARE, LANCASTER, PA 17602
or at such place as Lender may designate in writing
by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. $ 869.71 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 allongc shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of
this Note. [Check applicable box]
❑Graduated Payment Allonge ❑Growing Equity Allonge ❑Other [specify]
FRA H. iistele Flxed Rate Note
VMP ryg VMPf R (0809)
Wolters Kluw at Financial Services Page t of 3
S. 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 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 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 this Note. Lender may enforce its rights under this
ANTHONY M. FERRETTI iignatorles to; uired to
�M xed Rate Note
VMP ® VIVIZA8081 9
Wolters Kluwer Financial Services Pepe 2 of
BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note.
42 (Seal)
(Sea!)
HONY M. FERRETTI - Borrower - Borrower
(Seal) (Seal)
- Borrower - Borrower
(Seal) (Seal)
- Borrower - Borrower
(Seal) (Seal)
- Borrower - Borrower
F`ay to the order of
WELLS s FAMO L'AM N.a.
;L , p
Bank �
wet our Iarc-nt,c�ri
AY HE
WE R 01j.'..
'•'.• '+
U Y
s u
Assis nt Vice Ntesrdont
WITHOUT RECpiRSE
PAY TO T:1C O ER OF
isY WEt. FARGt? t�q� r� q
i
Scolt to. Hanson
Assisfani Vice President
".."Wed Rate Mote -
yMp ® VMPt R (0809)
Wolters Kluwer Financial Services Page 3 o1 3
Exhibit "B"
LEGAL DESCRIPTION
ALL THAT CERTAIN tract of land, with improvements thereon found, situate in the Borough
of New Cumberland, County of Cumberland, and Commonwealth of Pennslyvania, being more
particularly bounded and described as follows, to wit:
BEGINNING at a point on the southern line of Sixteenth Street on the dividing line between
Lots No. 15 and 16 on the hereinafter mentioned plan of lots; thence in a southerly direction
along said dividing line 250 feet to a twenty (20) foot alley; thence in an easterly direction by the
line of said alley 45 feet to a point; thence in a northerly direction along a line parallel with said
dividing line between Lots No. 15 and 16 250 feet to Sixteenth Street; thence in a westerly
direction along the southern line of Sixteenth Street 45 feet to the point or place of
BEGINNING.
BEING part of Lot No. 15 on the plan of lots as laid out by Elmer E. Zimmerman, recorded in
the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book
2, at Page 20, and being known and numbered as 908 Sixteenth Street, New Cumberland,
Pennsylvania 17070.
PROPERTY ADDRESS: 908 SIXTEENTH STREET, NEW CUMBERLAND, PA 17070-
1518
PARCEL #26 -24- 0809 -004.
File M 929893
VERIFICATION
Darren Britt, hereby states thate she is Wells Fargo Bank, N.A. of WELLS FARGO
BANK, N.A., plaintiff in this matter, that he 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 is her 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: Darren Britt
Title: Vice President Loan Documentation
Company: Wells Fargo Bank, N.A.
Date: 09/10/2013
086 -PA -V2 File # 929893
FORM 1
IN THE COURT OF COMMON PICAS,.,
WELLS FARGO BANK, N.A. OF CUMBERLAND COUNTY, PENNSVIA ._.
Plaintiff s) -0 "' --n
M CD ct3
VS. �--
k
ANTHONY M. FERRETTI
Defendant(s)
C__
NOTICE OF RESIDENTIAL MORTGAGE FORECLO JRE
DIVERSION PROGRAM t
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:
Date Ak_ -
onathan Lobb, Esq., Id.
No.312174
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:
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:
Assets Amount Owed Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #1: Model: Year:
Amount owed: Value:
Automobile #2 : Model: Year:
Amount owed: Value:
Other transportation (automobiles, boats, motorcycles): Model:
Year: Amount owed: Value
Monthly Income
Name of Employers:
1. Monthly Gross Monthly Net
2. Monthly Gross Monthly Net
3. Monthly Gross Monthly Net
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mortgage Food
2 n 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 #: 929893
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson .± n-oF F ICEr
Sheriff r1a = � � e� �.� ,r;
Jody S Smith ', � 5 P T.Chief Deputy P
Richard W Stewart � ';
Solicitor OFS�CEOrTkzSRERfF=
Wells Fargo Bank
vs. Case Number
Anthony M. Ferretti 2013-5465
SHERIFF'S RETURN OF SERVICE
09/23/2013 03:44 PM- Deputy Stephen Bender, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be Heather Dobson, girlfriend, who accepted as
"Adult Person in Charge"for Anthony M. Ferretti at 908 16th Street, New Cumberland Borough, New
Cumberland, PA 17070.
STEPHEN MENDER, DEPUTY
SHERIFF COST: $47.21 SO ANSWERS,
September 24, 2013 RONNY R ANDERSON, SHERIFF
(c)Couniy8uite Sheriff,Teleosoft,Inc.
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
ILION°
201 La APR 28 1W 9:57
CUIV3ERL NO COUNTY
PENNSYLVANIA
Attorney For Plaintiff
WELLS FARGO BANK, N.A.
Plaintiff
V.
ANTHONY M. FERRETTI
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 13-5465-CIVIL
PRAECIPE
TO THE PROTHONOTARY:
E] Please withdraw the complaint and mark the action Discontinued and Ended without prejudice.
• Please mark the above referenced case Settled, Discontinued and Ended.
E Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
E Please mark the in rem judgment Satisfied and the action Discgp ued and Ended.
111 Please V cate he Judgment entered.
Date: eY
PH # 929893
PHELA HA LIN
By:
Joseph A. Dessoye, Esq., IL No.200479
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
Attorney For Plaintiff
WELLS FARGO BANK, N.A.
Plaintiff
V.
ANTHONY M. FERRETTI
Defendant(s)
Court of Conunon Pleas
Civil Division
CUMBERLAND County
No. 13-5465-CIVIL
CERTIFICATION OF SERVICE
I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by
regular mail to the person(s) on the date listed below:
ANTHONY M. PERREI1I
908 SIXTEENTH STREET
NEW CUMB , PA 17070-1518
Date:
PHELA
By:
Joseph A P e, Esq., Id. No.200479
Attorney for Plaintiff