HomeMy WebLinkAbout13-5466 Supreme Court of Pennsylvania
Cour, =of Common Pleas
. a� . r • For Prothonotary Use Only:
Civl I'Cov Sheet
CUM Di ffi County Docket No: ,
J
The information collected on this form is used solely for court administration put poses. This form does not
supplement or replace the filing and service o pleadin s or other papers as re q uired b), laws 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: CASEY L. SIPE
T
j Are money damages requested? El Yes 9 No Dollar Amount Requested: ❑ within arbitration limits
0 (Check one) outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ❑x No Ts this an MDJ Appeal? ❑ Yes ❑x 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:
• Medical ❑ Other:
❑ Other Professional:
Pa.R.C.P. 205.5 Updated 01/01/2011
3 SEP TA f? y
7 � . 24
�IS
S CON T
YLVg Y
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 2
Plaintiff, NO.:
vs.
CASEY L. SIPE
320 GLENDALE DRIVE
SHIREMANSTOWN, PA 17011 -6513
KATELIN E. SIPE
320 GLENDALE DRIVE
SHIREMANSTOWN, PA 17011 -6513
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:
ffi lW
062 -PA -V3
1. The Plaintiff is WELLS FARGO BANK, N.A., 3476 STATEVIEW
BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff').
2. The Defendants, CASEY L. SIPE and KATELIN E. SIPE, are individuals whose
last known address are 320 GLENDALE DRIVE, SHIREMANSTOWN, PA 17011 -6513.
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 January 20, 2012, CASEY L. SIPE and KATELIN E. SIPE made,
executed and delivered to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS
NOMINEE FOR FIRST CHOICE BANK a Mortgage in the original principal amount of
$182,177.00 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. 201204713. 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 June 19,
2012, 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. 201218231.
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. CASEY L. SIPE and KATELIN E. SIPE 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 April 1, 2013.
062 -PA -V3
8. As of 09/06/2013, the amount due and owing Plaintiff on the mortgage is as
follows:
Principal Balance $178,619.65
Interest from 03/01/2013 to 09/06/2013 $3,555.55
Late Charges $166.11
Suspense Balance $(115.76)
Escrow Deficit $2,648.94
TOTAL $184,874.49
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.
062 -PA -V3
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.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for
the amount due of $184,874.49, 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., No.308912
Attorney for Plaintiff
062 -PA -V3
Exhibit "A"
ORIGINAL.
Multistate NOTE
January 20, 2012
320 Glendale Drive
Shiremanstown, PENNSYLVANIA 17011
(Property Address)
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns.
"Lender" means FIRST CHOICE 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 EIGHTY -TWO
THOUSAND ONE HUNDRED SEVENTY -SEVEN AND NO /100 Dollars (U.S. $182,177.00), 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 THREE AND
SEVEN EIGHTHS percent (3.875 %) 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 the 1st day of each month beginning on March I, 2012.
Any principal and interest remaining on the 1st day of February, 2042, will be due on that date, which is called the "Maturity Date."
(B) Place
Payment shall be made at
FIRST CHOICE BANK
500 CAMPUS DRIVE, SUITE 102
MORGANVILLE, NEW JERSEY 07751
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. $856.66.
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.
FHA Multistate Fixed Rate Note - 110195)
VMPAR (0210).02
Page 1 of 3
Borrowers) Initials
n ,
(D) Allonge to this Note for payment adjustments
(fan 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. (Check
applicable box)
❑ Graduated Payment Allonge ❑ Growing Equity Allonge ❑ 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 percent
(4.000 %) of the overdue amount of each payment.
(B) Default
]f Borrower defaults by failing to pay in full any monthly payment, them 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 ofdisbursement 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.
I 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 Borrowers 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.
FHA Multistate Fixed Rate Note - (10/85)
VMP-1 R torn m
IDs, IM Page 2 of 3
Borrower(s) Initials
I
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. My 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 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 SIGXN0 BELOW, Borrower accepts and agrees to the terns and covenants contained in this Note.
4 'r. L 4 e (Seal)
Ca ipe - Borrower - Borrower
FHA Multistate Fixed Rate Note -(10195)
VMP -1R piol.oz
(DS, Im Page 3 of 3
I
Allonge To Promissory Note
FOR PURPOSES OF FURTHER ENDORSEMNT OF THE FOLLOWING DESCRIBED NOTE, THIS
ALLONGE IS AFFIXED AND BECOMES A PERMANENT PART OF SAID NOTE.
This 24th Day of January, 2012
Note Date: 1/20/2012
Original Loan Amount: $182,177 ORIG
Interest Rate: 3.875%
Maturity Date: 2/1/2042
Borrower(s) Names(s): Casey L. Sipe
Property Address: 320 Glendale Drive, Shiremanstown, PA 17011
Pay to the Order of: Wells Fargo Bank, N.A.
�^ Without Recourse
FIRST CHOICE BANK
Signature of Duly Authorized Officer
Joseph Baio
Typed Name of Signatory
Title of Signatory: SVP — Capital Markets
Pay to the Order of
Without ecourse
Wells Fargo Bank, NA
M ary -Seamans
Vice President
Exhibit "B"
LEGAL DESCRIPTION
ALL THAT, CERTAIN piece or parcel of land situate in the Township of Lower Allen, County
of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on the southern line of Glendale Drive, said point being at the dividing
line between Lots Nos. 3 and 4 on the hereinafter mentioned Plan of Lots; thence along the
southern line of Glendale Drive, north 66 degrees 36 minutes East, ninety (90) feet to a point at
the dividing line between Lots Nos. 4 and 5 on said Plan; thence along said dividing line, South
23 degrees 24 minutes East, one hundred fifteen (115) feet to a point; thence South 66 degrees 36
minutes West, ninety (90) feet to a point at the dividing line between Lots Nos. 3 and 4 on said
Plan; thence along said dividing line, North 23 degrees 24 minutes West, one hundred fifteen
(115) feet to a point on the southern line of Glendale Drive, the place of BEGINNING.
BEING Lot No. 4, Block 'O' on Plan No. 2 of the Shireman Manor Extension, said Plan being
recorded in the Cumberland County Recorder's Office in Plan Book 16, Page 35.
Together with all and singular the buildings and improvements, ways, streets, alleys, driveways,
passages, waters, water - courses, rights liberties, privileges, hereditaments and appurtenances,
whatsoever unto the hereby granted premises belonging, or in any wise appertaining, and the
reversions and remainders, rents, issues, and profits therefore; and all the estate, right, title,
interest property, claim and demand whatsoever of them, the said Grantor(s), as well at law as in
equity, of, in, and to the same.
Parcel Id #: 48 -24- 0795 -033
Filet 927435
For title see deed recorded in Cumberland County September 2, 2009 at Instrument # 200930823
PROPERTY ADDRESS: 320_ GLENDALE DRIVE, SHIREMANSTOWN, PA 17011 -6513
PARCEL #48 -24- 0795 -033
File #: 927435
VERIFICATION
Darren 011am, hereby states that hg /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 o hi /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 011am
Title: Vice President Loan Documentation
Company: Wells Fargo Bank, N.A.
Date: 09/10/2013
086 -PA -V2 File #:927435
FORM 1
IN THE COURT OF COMMON PLEAS
WELLS FARGO BANK, N.A. OF CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
C .
M
CASEY L. SIPE '
KATELIN E. SIPE /„ te r — ._
Defendant (s) /// "` -��� ivil
NOTICE OF RESIDENTIAL MORTGAGE FORECI U3� 3E �#
DIVERSION PROGRAM «Y
-r
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:
SEP 16 2013
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:
ER/PRIMARY CUSTOM
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?
INFORMATION FINANCIAL
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" 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 #: 927435
SHERIFF'S OFFICE OF CUMBERLAND COUNTY '
Ronny RAnderson
Sheriff -
xm»�' - - �F Tu�---
Jody SGmdh � ~m� ^ ./� PMO[H0NOTARv
Chief Deputy
�D/� ��� �� �� �~ � |
R/chmrdVVStema� ^°'° °+/ �w . ', �. � .
Solicitor OFFICE OrTiha.ewsn/pp
PUMBERLAND COUNTY
PENNSYLVANIA
Wells Fargo Bank, N.A.
vs. Case Number
Casey Lee Sipe(et oi) | 3013'5466
SHERIFF'S RETURN OF SERVICE
09C23/2013 OG:O7PM ' Deputy Stephen Bender, being duly sworn according bu law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by
"personally"handing a true copy to a person representing themselves to be the Defendant, to wit: Casey
Lee Sipe ot320 Glendale Drive, Upper Allen Township, Shiremanstown, PA17O11.
STEPHEN BENDER, DEPUTY
09/23/2013 06:07 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
otrua copy to o person representing themselves toba Casey Sipa, huobond,who oocapbad as"Adult
Person in Charge"for Kote|in E Sipe ot32O Glendale Drive, Upper Allen Township, Shinemanatown, PA
17011-6513.
STEPHEN IIENDER, DEPUTY
SHERIFF COST: *GO.Q5 SO ANSWERS,
September 24. 2U13 —RO—N—N-q—R ANDERSON, SHERIFF w���Sheriff,��.Ine.
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
F:kOTHONOTAi,ri'
2311+ APR I1 AM 9:27
CUMBERLAND COUNTY
PENNSYLVANIA
Attorney For Plaintiff
WELLS FARGO BANK, N.A.
Plaintiff
v.
CASEY L. SIPE
KATELIN E. SIPE
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 13-5466-CIVIL
PRAECIPE
TO THE PROTHONOTARY:
Please withdraw the complaint and mark the action Discontinued and Ended without prejudice.
E Please mark the above referenced case Settled, Discontinued and Ended.
L Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
n Please mark the in rem judgment Satisfied and the action Discontinued and Ended.
E Please Vacate the Judgment entered.
Date: gill
ts4
PH # 927435
PHELAN HALLINAN, LLP
By:
Chrisovalante P. Fliakos, Esq., Id. No.94620
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.
CASEY L. SIPE
KATELIN E. SIPE
Defendant(s)
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 13 -5466 -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:
CASEY L. SIPE
KATELIN E. SIPE
320 GLENDALE DRIVE
SHIREMANSTOWN, PA 17011 -6513
Date: 4 1 l 1 1/4t
PHELAN HALLINAN, LLP
By:
Chrisovalante P. Fliakos, Esq., Id. No.94620
Attorney for Plaintiff