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Home My WebLink About13-7339 Supreme Court of Pennsylvania r Cou>I`Com Pleas Goer et CL*13ERaI460 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: ® Complaint ❑ Writ of Summons ❑Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiffs Name: Wells Fargo Bank, NA Lead Defendant's Name: Randy A. Shaw Are money damages requested ?: ❑ Yes ® No Dollar Amount Requested: within arbitration limits (Check one) X outside arbitration limits Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No Name of Plaintiff/Appellant's Attorney: Scott A. Dietterick, Esq. c/o Zucker, Goldberg & Ackerman, LLC A ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) g." Nature of the Cas Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not include " mass tort) ❑ Employment Dispute: ❑ Slander /Libel /Defamation Discrimination ❑Other: ❑ Employment Dispute: Other (: ❑ Zoning Board T ` ❑ Other: MASS TORT ❑ other: ❑ Asbestos ❑ Tobacco N ❑ Toxic Tort- DES ❑ Toxic Tort- Implant El Toxic Waste REAL PROPERTY MISCELLANEOUS ❑ Other: ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations PROFESSIONAL LIABLITY ® Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1//2011 Zucker, Goldberg & Ackerman, LLC XVP- 184111 062 -PA -V3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, CIVIL DIVISION Plaintiff, NO.: 3 . 1� Vs. TYPE OF PLEADING Randy A. Shaw; CIVIL ACTION - COMPLAINT Defendant. IN MORTGAGE FORECLOSURE TO: DEFENDANT FILED ON BEHALF OF: YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS Wells Fargo Bank, NA FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OFTHE PLAINTIFF IS: ZUCKER GOLDBERG & ACKERMAN, LLC 3476 Stateview Blvd. Ft. Mill, SC 29715 Scott A. Dietterick, Esquire AND THE DEFENDANT: Pa. I.D. #55650 824 West Keller Street Kimberly A. Bonner, Esquire Mechanicsburg, PA 17055 -4028 tj Pa. I.D. #89705 Joel A. Ackerman, Esquire x Pa I.D. #202729 I HER FY THAT OO THE LOCATION OF Ashleigh Levy Marin, Esquire �� THE REAL ESTATE AFFECTED BY THIS LIEN IS Pa I.D. #306799 C� - ! O 824 West Keller Street, Mechanicsburg PA 17055 -4028 r G Municipality: Monroe Ralph M. Salvia, Esquire , Pa I.D. #202946 Jaime R. Ackerman, Esquire�� ATTORNEY FOR F Pa I.D. #311032 Jana Fridfinnsdottir, Esquire ATTY FILE NO.: XVP 184111 Pa I.D. #315944 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500 (908) 233 -1390 FAX office@zuckergoldberg.com File No.: XVP- 184111/rbo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, VS. NO.: Randy A. Shaw; Defendant. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990 -9108 Phone (800) 990 -9108 (717) 249 -3166 (717) 249 -3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, VS. NO.. Randy A. Shaw; Defendant. AVISO LISTED HA SIDO DEMANDADO /A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion 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 reclamacion o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI 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, NA CIVIL DIVISION Plaintiff, NO.. VS. Randy A. Shaw; Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, NA, by its attorneys, Zucker, Goldberg & Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, NA, (hereinafter "plaintiff ") with its place of business located at 3476 Stateview Blvd., Ft. Mill, SC 29715. 2. The Defendant, Randy A. Shaw, is an individual whose last known address is 824 West Keller Street, Mechanicsburg, PA 17055 -4028. 3. Wells Fargo Bank, NA, directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, NA 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 February 25, 2009, Randy A. Shaw made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for Sovereign Bank a Mortgage in the original principal amount of $170,341.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on March 3, 2009, Instrument #200905945. 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 September 28, 2012, the mortgage was assigned to Wells Fargo Bank, NA which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument #201229825. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. Zucker, Goldberg & Ackerman, LLC XVP- 184111 062 -PA -V3 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Randy A. Shaw, single man is the record and real owner of the aforesaid mortgaged premises. 7. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due June 1, 2013. 8. As of 11/26/2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $ 158,989.30 Interest From 05/01/2013 to 11/26/2013 $ 4,519.24 Late Charges $0.00 Escrow Advance $ 918.91 Property Inspections $15.00 Property Preservation $0.00 BPO /Appraisal $0.00 Escrow Balance $0.00 Corporate Advance Credit $0.00 Total $164,442.45 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 is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendants) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. Zucker, Goldberg & Ackerman, LLC XVP- 184111 062 -PA -V3 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $ 164,442.45 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 & RMAN, BY: Dated: I I� Scott A. Dietter' , Esquire; PA I.D. #55650 I 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 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Attorneys for Plaintiff XVP- 184111/rbo 200 Sheffield Street, Suite 101 Mountainside, N1 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 XVP- 184111 062 -PA -V3 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XVP- 184111 062 -PA -V3 MIN i NOTE NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUT THE APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. February 25, 2009 Shiremanstown PENNSYLVANIA f Date) (City) Istatel 824 W Keller St Mechanicsburg, PA 17055 [Property Address) I. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ 170, 341. (this amount is called "Principal`), plus interest, to the order of the Lender. The Lender is Sovereign Bank I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Molder." 2, IN'T'EREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 5.000 %u The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on theist day of each month beginning on April 01, 2009 1 will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on March 01, 2039 , 1 still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my monthly payments at 1130 Berkshire Blvd, , Wyomissing, PA 1961.0 or at a different place if required by the Nate Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ 914.43 4. BORROWER'S RIGHT TO PREPAY The Borrower shall have the right to prepay at any time, without premium or fee, the entire indebtedness or any part thereof not less than the amount of one installment, or $100.00, whichever is less. Any Prepayment in full of the indebtedness shall be credited on the date received, and no interest may be charged thereafter. Any partial Prepayment made on other than an installment due date need not be credited until the next following installment due date or 30 days after such Prepayment, whichever is earlier. MULTISTATE FIXED RATE NOTE- Single Family - Fannie MaefFreddle Mae UNIFORM INSTRUMENT • Veterans Affairs Form 3200 1141 Amended 6100 Wolters Kluwer Financial Services VMP - 60s (06071 . � .x ,. Page t ut 3 OeedWV 4 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from mtr which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of Fif teen calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 4 000 % of my overdue payment. I will pay this late charge promptly but only once on each late payment. (8) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default, (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if 1 do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately die full amount of Principal which has not been paid and all the interest that l owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to the or delivered by other means (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if I am in default at a later tithe. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Whose expenses include, for example, reasonable attorneys` fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address, Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. ti. 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 Nate, 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 trade in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 4. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonpr" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. MULTISTATE FIXED RATE NOTE- Single Family - Fannie Mae /Freddie Mae UNIFORM INSTRUMENT • Veterans Affairs Form 3211 Jot VMPSr5G t08071 fags 2 of 3 Enr:ladss A�✓ 10. ALLONGE TO THIS NOTE If an a0onge providing for payment adjustments or for any other supplemental information is executed by the Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this ��Noottte as if the allongc were a part of this Note. (Check applicable box] t..�.1 Graduated Payment Allonge t_ Other (Specify] ❑ Other [Specify] 11. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections givers to the Note Helder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument'), dated the saute date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Sonic of those conditions are described as follows:. Regulations (38 C.F.R, Part 36) issued under the Department of Veterans Affairs ( "VA ") Guaranteed Loan Authority (38 U,S,C. Chapter 37) and in effect on the date of loan closing shall govern the rights, duties and li bilities of the parties to this loan and any provisions of this Note which are inconsistent with such g lations are herebl amended ar supplemented to conform thereto. • Z 4 WITNESS HE HAND(S) AND SEAL(S) OF THE UNDERSIGNED. fe��_ (Seal) (Seal) Ran dy A i saw - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower (Seal) (Seal) - Borrower - Borrower WITHOUT RECOURSE PAY TO THE ORDER OF WELLS FARGO BANK, N.A. SOVEREIGN BA - - - -- (Seal) —(Seal) - Borrower - Borrower S C .Y AID)TWEek, B G OFFICER [Sign Original Only] MULTISTATE FIXED RATE NOTE- Single Family- Fannio MaelFreddle Mae UNIFORM INSTRUMENT - Veterans Affairs Form 3200 1101 VMP O - (0807) Pogo 5 of 3 EXHIBIT B Zucker, Goldberg & Ackerman, LLC XVP- 184111 062 -PA -V3 EXHIBIT "A" ALL THAT CERTAIN place, parcel or tract of land situate In the Township of Monroe, County of Cumborland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING In the Northwest corner of Keller Street and Wertz Avenue; thence along the Eastern line of Wertz Avenue, North 13 degrees 50 minutes Wes;, 142.4 feet to a point on the Eastern line of said Wertz Avenue at the Southwest corner of Lot No. 5 on the Plan of Lots hereinafter mentioned; thence In an Easterly direction along the Southern line of said Lot No. b, 78,4 feet to a point; thence In a Southerly direction along the Westem line of Lot No. 19 on said Plan of tots 141,A feet to a point on the Northern line of Keller Street; thence along the Northern line of said Keller Street, South 09 degrees 30 minutes West, 88.1 feet to the point and place of BEGINNING. BEING Lot No. 14 in the Plan of Lots known as "Revised Plan of Trindie Spring Manor", which said Plan Is recorded In the Recorder's Office In and for said Cumberland County in Plan Book 10, Page 36. UNDER AND SUBJECT TO the same rights, privileges, agreements, rights -of -way, easements, conditions, exceptions, restrictions, and reservations as exist by virtue of prior recorded Instruments, plans, Deeds of Conveyances, or visible on ground. BEING KNOWN AND NUMBERED as 824 West Keller Street, Mechanicsburg, Pennsylvania. BEING THE SAME PREMISES which Andrew J. Semic, by his dead to be recorded simultaneously herewith in the Office of the Recorder of Deeds of Cumberland, granted and conveyed unto Randy A. Shaw, r VERIFICATION Daniel Edward , hereby states that l9i /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 */her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relatin unsworn falsification to authorities. c. Name: Daniel Edward Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 11/29/2013 086 -PA -V2 File # 184111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA r� Wells Fargo Bank, NA CIVIL DIVISION r, Plaintiff, NO.: vs. �� Zp Randy A. Shaw; CPO Defendant. 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 do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. Zucker, Goldberg & Ackerman, LLC XVP- 184111 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 Mid Penn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. 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 & ACKERMMAN, LLC By: Dated: Scott A. Dietteric squire; PA I.D. #55650 1 Kimberly A. Bonner, Esquire; PA I.D. #89705 1 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 ' Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Attorneys for Plaintiff XVP- 184111/cper 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233 -8500; (908) 233 -1390 FAX Email: Office @zuckergoldberg.com Zucker, Goldberg & Ackerman, LLC XVP- 184111 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 •• • First Mortgage Lender: Type of Loan: Loan Number: Date you closed your loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Zucker, Goldberg & Ackerman, LLC XVP- 184111 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 2nd 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 XVP- 184111 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: •• • [/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 XVP- 184111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. NO.: Randy A. Shaw; Defendant. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court - supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel /Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker, Goldberg & Ackerman, LLC XVP- 184111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, VS. NO.: Randy A. Shaw; Defendant. CASE MANAGEMENT ORDER AND NOW, this day of ,20 ,the defendant /borrower in the above - captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant /borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court - supervised conciliation Conference on at M. in at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant /borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant /borrower. Upon 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. 3. The defendant /borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff /lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff /lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable Zucker, Goldberg & Ackerman, LLC XVP- 184111 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. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker, Goldberg & Ackerman, LLC XV P- 184111 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. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ° Sheriff ; I a 'LO.'Ot of � rartta�f 41?h Jody S Smith Chief Deputy ;3DEC23 a�°e Richard W Stewart I ifs B f.iiLl A 111 D c L, � Solicitor :, PENNSYLVANIA Wells Wells Fargo Bank, N.A. Case Number vs. Randy A Shaw 2013-7339 SHERIFF'S RETURN OF SERVICE 12/16/2013 05:38 PM - Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Randy A Shaw at 824 W. Keller Street, Monroe Township, Mechanicsburg, PA 17055. AN BURGETT, DEP SHERIFF COST: $39.30 SO ANSWERS, December 17, 2013 RONIV R ANDERSON, SHERIFF c u�hr ut.o SniF! s�`t.Inc. 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA' . • Wells•Fargo Bank, NA, CIVIL DIVISION . cam°'-'n " ,t Plaintiff No.: 13-7339-CIVIL •• c°1`> .^ vs. • ISSUE NUMBER: ' ':= • Randy A.Shaw.; .TYPE OF PLEADING: . : . • • . Defendant(s). • PRAECIPE FOR ENTRY.OF JUDGMENT BY. .• DEFAULT(MORTGAGE.FORECLOSURE). . Mortgaged Premises: • • 824 West Keller Street, Mechanicsburg, PA 17055- • FILED ON BEHALF OF: • 4028 • • . Wells Fargo Bank, NA . Plaintiff •• COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG &ACKERMAN, LLC . • Scott A. Dietterick, Esquire-Pa'I.D.# 55650 Kimberly A. Bonner, Esquire- Pa I.D.#89705 • Joel A.Ackerman, Esquire- Pa I.D.#202729 Ashleigh L. Marin, Esquire-Pa I.D.#306799 Ralph M.Salvia, Esquire- Pa I.D.#202946 Jaime R.Ackerman, Esquire- Pa I.D.#311032 Jana Fridfinnsdottir, Esquire- Pa I.D.#315944 Brian Nicholas, Esquire- Pa I.D.#317240 Denise Carlon, Esquire- Pa I.D.#317226 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908)233-8500 Atty File No.: XVP-184111 • . al\A 4 tp4 So Cit# Loys-o 7244 26g1-1/.// Praecipe for Entry of Judgment Zucker,Goldberg&Ackerman, LLC VP-184111 ividitited LE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA • CIVIL DIVISION Plaintiff, • • NO.: 13-7339-CIVIL vs. Randy A. Shaw; • Defendant. • PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT(MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above-captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to Plaintiff's Complaint within the appropriate time limits from service thereof, and assess Plaintiffs damages as set forth in Complaint: Amount as set forth in Complaint $164,442.45 plus interest on the judgment amount ($164,442.45)from November 27, 2013,at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 824 West Keller Street address is: Mechanicsburg, PA 17055- 4028 UCKER, GOLBERG &ACKERMAN, LLC Dated: Vc9,,eti 3.42514 B r ,.J•el A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 ❑ Jaime R.Ackerman, Esquire; PA I.D.#311032 lA Denise Carlon, Esquire; PA I.D.#317226 Attorneys for Plaintiff XVP-184111 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908)233-1390 FAX Email: Office @zuckergoldberg.com DAMAGES ARE HEREBY ASSESSED AS INDICATED f a Date SIDS Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION • Plaintiff, •vs. NO.: 13-7339-CIVIL• Randy A. Shaw; • • • Defendant. • • AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true in and correct to the best of my knowledge, information, and that: 1) The Defendant is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. ZUCKER, GOLBERG &ACKERMAN, LLC Dated: �jla.L1/ 9-el l 4 BY: L, . i_L, - . J • Joel A.Ackerman, Esquire; PA I.D.#202729 ❑ Ashleigh L. Marin, Esquire; PA I.D.#306799 ❑ Jaime R. Ackerman, Esquire; PA I.D.#311032 Denise Carlon, Esquire; PA I.D.#317226 Attorneys for Plaintiff XVP-184111 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office @zuckergoldberg.com Sworn to and subscribed before me This -f day of f P�Cj4 , 20 I Nota Pub is My Commission Expires: PAUL C.NADRATOWSKI Notary Public of Ne 0 Jersey My Commission Expires 4/27/2016 Zucker, Goldberg&Ackerman, LLC XVP-184111 -: - Department of Defense Manpower Data Center Results as of:Mar-21-2014 09:44:07 AM SCRA 3.0 g � 1 Status Report 'z $ want to Servicemembers Civil Relief Act Last Name: SHAW First Name: RANDY Middle Name: A Active Duty Status As Of: Mar-21-2014 tiret I Y'° � -!�k]• 7 ° ° ; 'S `rr. t'°, "rte°;.'e NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Eillieffstfitgfallagi d dli. a.°..-a. ; .r1S°Pn �,, 4 �.yyk, t NA NA No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date 131241111111MI r �r RITTi-. ! Eei ITITINM me -d> t NA NA No NA This response reflects whether the Individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. ihut A. t / Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 et seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: B8R4Q83520ADT40 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, • vs. NO.: 13-7339-CIVIL • • Randy A.Shaw • • Defendant. . • • IMPORTANT NOTICE TO: Randy A.Shaw 824 West Keller Street Mechanicsburg, PA 17055-4028 DATE OF NOTICE: 2/24/2014 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you.Unless you act within Ten(10)days from the date of this notice,a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one,go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S.Bedford Street 32 S.Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION • Plaintiff, vs. • NO.: 13-7339-CIVIL • Randy A.Shaw • Defendant. • • • AVISO IMPORTANTE TO: Randy A. Shaw 824 West Keller Street Mechanicsburg, PA 17055-4028 FECHA DEL AVISO:2/24/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS J PORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDL&TAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICLtTA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TG DEFEND &LAWYERREFERRAL SERVICE Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S.Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone(800)990-9108 Phone(800)990-9108 (717)249-3166 (717)249-3166 ZUCKER GOLDBERG&ACKERMAN BY: Scoff A. D i.�fferi ck, Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside,NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL,POSTAGE PREPAID 184111 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ( e ( 1 1 Ronny R Anderson Sheriff iow ul taut+rfy tai Jody S Smith Chief Deputy Richard W Stewart Solicitor esrv,u,E<,-T1.E.sF.-54Nry Wells Fargo Bank, N.A. vs. Case Number Randy A Shaw 2013-7339 SHERIFF'S RETURN OF SERVICE 12/16/2013 05:38 PM-Deputy Ryan Burgett, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Randy A Shaw at 824 W. Keller Street, Monroe Township, Mechanicsburg, PA 17055. N BURGE i t DE_,l.."."''.. SHERIFF COST:$39.30 SO ANSWERS, December 17,2013 RONIY R ANDERSON, SHERIFF (c)CounlySuilo Sheriff,Teleosofi.Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, • NO.: 13-7339-CIVIL vs. Randy A. Shaw; Defendant. • NOTICE OF ORDER, DECREE OR JUDGMENT TO: Randy A. Shaw 824 West Keller Street Mechanicsburg, PA 17055-4028 [ ] Plaintiff [il] Defendant [ ] Additional Defendant You are hereby notifi that n Order, Decree or Judgment was entered in the above captioned proceeding on [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $164,442.45 p cost Prothonotary Zucker,Goldberg&Ackerman, LLC XVP-184111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION File No. 13-7339-CIVIL Wells Fargo Bank, NA, Amount Due $164,442.45 Plaintiff, Interest from 11/28/2013 to date of sale VS. $10,022.08 Costs Randy A. Shaw; �2 C=x Defendant. TO THE PROTHONOTARY OF THE SAID COURT: C3 The undersigned hereby certifies that the below does not arise out of a retail instagl' Qnt'sale, contract of account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue Writ of Execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s): See Exhibit "A" attached �- � PJ 90 Cr3 ' gs` S Pda PRAECIPE FOR ATTACHMENT EXECUTION Issue Writ of Attachmenth6 the Sheriff of Cumberland County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description; supply four copies of lengthy personality list): Zucker,Goldberg&Ackerman,LLC (J(0 XVP-184111 and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: 6111Signature: Print Name: Scott A. Diet rick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 '" Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Address: Zucker, Goldberg &Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Attorney for: Plaintiff Telephone: 908-233-8500 Zucker,Goldberg&Ackerman, LLC XFP-184111 Exhibit"A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel or tract of land situate in the Township of Monroe, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING in the Northwest corner of Keller Street and Wertz Avenue; thence along the Eastern line of Wertz Avenue, North 13 degrees 56 minutes West, 142.4 feet to a point on the Eastern line of said Wertz Avenue at the Southwest corner of Lot NO.5 on the Plan of Lots hereinafter mentioned;thence in an Easterly direction along the Southern line of said Lot No.S, 79.4 feet to a point;thence in a Southerly direction along the Western line of Lot No. 13 on said Plan of Lots 141.4 feet to a point on the Northern line of Keller Street;thence along the Northern line of said Keller Street,South 69 degrees 3D minutes West,89.1 feet to the point and place of BEGINNING. BEING Lot No. 14 in the Plan of Lots known as"Revised Plan of Trindle Spring Manor', which said Plan is recorded in the Recorder's Office in and for said Cumberland County in Plan Book 10, Page 36. UNDER AND SUBJECT TO the same rights, privileges, agreements, rights-of-way,easements, conditions, exceptions, restrictions, and reservations as exist by virtue of prior recorded instruments, plans, Deeds of Conveyances, or visible on ground. HAVING thereon erected a dwelling house being known and numbered as 824 West Keller Street, Mechanicsburg, PA, 17055-4028. BEING the same premises which Andrew J.Semic, unmarried, by Deed dated February 25, 2009 and recorded March 3, 2009 in and for Cumberland County, Pennsylvania, in Deed Book Volume, Page Instrument#: 200905944,granted and conveyed unto Randy A.Shaw, single man. Tax Map No.: 22-24-0783-060. Zucker,Goldberg&Ackerman, LLC XVP-184111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA, CIVIL DIVISION Plaintiff, VS. NO.: 13-7339-CIVIL Randy A. Shaw; Execution No.: r ` Defendant(s). l • c�7F C13 `t AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, NA, Plaintiff in the above action, sets forth as of the date the Praecipe for Writ of Execution was filed the following information concerning the real property located at 824 West Keller Street, Mechanicsburg, PA 17055-4028. 1. Name and Address of Owner(s) or Reputed Owner(s): RANDY A. SHAW, SINGLE MAN 824 West Keller Street Mechanicsburg, PA 17055-4028 2. Name and Address of Defendant(s) in the Judgment: RANDY A. SHAW 824 West Keller Street Mechanicsburg, PA 17055-4028 3. Name and Address of every judgment creditor whose judgment is a record lien on the real property to be sold: WELLS FARGO BANK, NA Plaintiff 4. Name and Address of the last record holder of every mortgage of record: WELLS FARGO BANK, NA Plaintiff Zucker,Goldberg&Ackerman,LLC XVP-184111 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR SOVEREIGN BANK PO Box 2026 Flint, MI 48501-2026 AND 1901 E. Voorhees Street, Suite C Danville, 1161834 AND 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 AND 601 Penn Street Reading PA 19601 5. Name and Address of every other person who has any record lien on the property: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 6. Name and Address of every other person who has any record interest in the property and whose interest may be affected by the sale: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 7. Name and Address of every other person of whom the Plaintiff has knowledge who has any interest in the property which may be affected by the sale: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 UNKNOWN TENANT OR TENANTS 824 West Keller Street Mechanicsburg, PA 17055-4028 Zucker,Goldberg&Ackerman,LLC XVP-184111 UNKNOWN SPOUSE 824 West Keller Street Mechanicsburg, PA 17055-4028 PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 1 verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. ZUCKER, GOLDBERG - KER AN, LL BY: Dated: /O Scott A. Die Brick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XVP-184111/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Zucker,Goldberg&Ackennan,LLC XVP-184111 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel or tract of land situate in the Township of Monroe,County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING in the Northwest corner of Keller Street and Wertz Avenue; thence along the Eastern line of Wertz Avenue, North 13 degrees 56 minutes West, 142.4 feet to a point on the Eastern line of said Wertz Avenue at the Southwest corner of Lot NO.5 on the Plan of Lots hereinafter mentioned;thence in an Easterly direction along the Southern line of said Lot No.S, 79.4 feet to a point;thence in a Southerly direction along the Western line of Lot No. 13 on said Plan of Lots 141.4 feet to a point on the Northern line of Keller Street; thence along the Northern line of said Keller Street, South 69 degrees 3D minutes West, 89.1 feet to the point and place of BEGINNING. BEING Lot No. 14 in the Plan of Lots known as"Revised Plan of Trindle Spring Manor',which said Plan is recorded in the Recorder's Office in and for said Cumberland County in Plan Book 10, Page 36. UNDER AND SUBJECT TO the same rights, privileges, agreements, rights-of-way,easements, conditions, exceptions, restrictions, and reservations as exist by virtue of prior recorded instruments, plans, Deeds of Conveyances,or visible on ground. HAVING thereon erected a dwelling house being known and numbered as 824 West Keller Street, Mechanicsburg, PA, 17055-4028. BEING the same premises which Andrew J.Semic, unmarried, by Deed dated February 25, 2009 and recorded March 3, 2009 in and for Cumberland County, Pennsylvania, in Deed Book Volume, Page Instrument#: 200905944,granted and conveyed unto Randy A. Shaw,single man. Tax Map No.: 22-24-0783-060. Zucker,Goldberg&Ackerman, LLC XVP-184111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. NO.: 13-7339-CIVIL Randy A. Shaw; Defendant. ter= NOTICE OF SHERIFF'S SALE mac; OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 T7 Randy A. Shaw 824 West Keller Street Mechanicsburg, PA 17055-4028 TAKE NOTICE: That the Sheriff's Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on December 5, 2014 at 10:OOam prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT"A"). The LOCATION of your property to be sold is: 824 West Keller Street, Mechanicsburg, PA, 17055-4028 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 13-7339-CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Randy A. Shaw, single man Zucker,Goldberg&Ackerman, LLC XVP-184111 A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it, within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. It has been issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriff's Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland Zucker,Goldberg&Ackerman, LLC XVP-184111 County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. ZUCKER, GOLDBERG & R AN, VC BY: Dated: /^ Scott A. Diette ck, Esquire; PA I.V. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XVP-184111/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker,Goldberg&Ackerman, LLC XVP-184111 of CV THE COURT OF COMMON PLEAS i CUMBERLAND COUNTY PA o Z DAVID D.BUELL,PROTHONOTARY One Courthouse Square - Suite100 - Carlisle,PA- 17013 (717)240-6195 so www.ccpa.net WELLS FARGO BANK,NA Vs. NO 13-7339 Civil Term CIVIL ACTION—LAW RANDY A. SHAW WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $164,442.45 L.L.: $.50 Interest FROM 11/28/2013 TO DATE OF SALE-$10,022.08 Atty's Comm: Due Prothy: $2.25 Atty Paid: $188.05 Other Costs: Plaintiff Paid: - Date: 6/23/14 David D. Buell,Prothonot (Seal) Deputy REQUESTING PARTY: Name:JAIME R.ACKERMAN,ESQUIRE Address: ZUCKER,GOLDBERG &ACKERMAN,LLC 200 SHEFFIELD STREET,SUITE 101 MOUNTAINSIDE,NJ 07092 Attorney for:PLAINTIFF Telephone: 908-233-8500 Supreme Court ID No.311032 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA, CIVIL DIVISION Plaintiff, vs. Randy A. Shaw; Defendant. NO.: 13 -7339 -CIVIL TYPE OF PLEADING Pa. R.C.P. RULE 3129.2(C) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST FILED ON BEHALF OF: Wells Fargo Bank, NA COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire PA I.D. #55650 Kimberly A. Bonner, Esquire- PA I.D. #89705 Joel A. Ackerman, Esquire- PA I.D. #202729 Ashleigh Levy Marin, Esquire -PA I.D. #306799 Ralph M. Salvia, Esquire- PA I.D. #202946 Jaime R. Ackerman, Esquire- PA I.D. #311032 Jana Fridfinnsdottir, Esquire- PA I.D. #315944 Brian Nicholas, Esquire- PA I.D. #317240 Denise Carlon, Esquire- PA I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XVP- 184111/mag Zucker, Goldberg & Ackerman, LLC XVP-184111 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION vs. Randy A. Shaw; Plaintiff, NO.: 13 -7339 -CIVIL Defendant. Pa.R.C.P. RULE 3129(c) AFFIDAVIT OF SERVICE OF DEFENDANT/OWNER AND OTHER PARTIES OF INTEREST I, Margaret Agyepong, a paralegal with the firm of Zucker, Goldberg & Ackerman, LLC, attorneys for Plaintiff, Wells Fargo Bank, NA, being duly sworn according to law depose and make the following Affidavit regarding the service of Plaintiff's Notice of Sheriffs Sale of Real Property in this matter on Defendant/Owner and Other Parties of Interest as follows: 1. Defendant, Randy A. Shaw, single man, is the record owner of the real property. 2. On or about October 3, 2014, defendant Randy A. Shaw was served with Plaintiff's Notice of Sheriffs Sale of Real Property Pursuant to Pa. R.C.P. 3129, via certified mail, return receipt requested at the address of the mortgaged premises, being 824 West Keller Street, Mechanicsburg PA 17055-4028. A true and correct copy of said Notice and proof of Service are marked Exhibit "A", attached hereto and made a part hereof. 3. On or about October 3, 2014, Plaintiff's counsel served all other parties in interest with Plaintiff's Notice of Sheriff's Sale according to Plaintiffs Affidavit Pursuant to rule 3129.1, via First Class U.S. Mail, Postage Pre -Paid, with a Certificate of Mailing. True and correct copies of said Certificates of Mailing are marked Exhibit "B", attached hereto and made a part hereof. Finally, the undersigned deposes and says that the Defendant/Owner and all other Parties of Zucker, Goldberg & Ackerman, LLC XV P-184111 Interest were served with Plaintiffs Notice of Sheriff's Sale of Real Property in accordance with Pa.R.C.P. 3129.2. Dated:•ie ex. 5 , 2014 11)00€tribe/ Sworn to and subscribed before me this . • . of-Oetoiber, 2014 wetnbe/ Ilifsla-ry Public MY COMMISSION EXPIRES: ZUCKER, GOLDBERG & ACKERMAN, LLC Attorneys for Plaintiff MARGA' ,'AGYEPONG Parale:al/Legal Assistant JANELL URLIN NOTARY PUBLIC OF NEW JERSEY ID # 2364963 My Commission Expires 1011712017 Zucker, Goldberg & Ackerman, LLC XVP-184111 EXHIBIT A Zucker, Goldberg & Ackerman, LLC XVP-184111 Zucker, Goldberg & Ackerman, LLC PO Box 1219 Mountainside, NJ 07092-1219 IIII11IIIIIIIHUH 0766 11111119314 7100 1170 26 1"1"/11111111111/llir1111111111 1111191111ll1lrrr�lil I'lln 29-102 Randy A. Shaw 824 W KELLER ST MECHANICSBURG, PA 17055-4028 PANOSS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA vs. Randy A. Shaw; Plaintiff, Defendant. CIVIL DIVISION NO.: 13 -7339 -CIVIL NOTICE OF SHERIFF'S SALE OF REAL PROPERTY PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 Randy A. Shaw 824 West Keller Street Mechanicsburg, PA 17055-4028 TAKE NOTICE: That the Sheriffs Sale of Real Property (Real Estate) will be held at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on December 3, 2014 at 10:OOam prevailing local time. THE PROPERTY TO BE SOLD is delineated in detail in a legal description consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. (SEE LEGAL DESCRIPTION ATTACHED AS EXHIBIT "A"). The LOCATION of your property to be sold is: 824 West Keller Street, Mechanicsburg, PA, 17055-4028 The JUDGMENT under or pursuant to which your property is being sold is docketed to: No. 13 -7339 -CIVIL THE NAME(S) OF THE OWNER(S) OR REPUTED OWNER(S) OF THIS PROPERTY ARE: Randy A. Shaw, single man Zucker, Goldberg & Ackerman, LLC XVP-184111 A SCHEDULE OF DISTRIBUTION, being a Iist of the persons and/or governmental or corporate entitles or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example to banks that hold mortgages and municipalities that are owed taxes), will be filed by the Sheriff thirty (30) days after the sale, and distribution of the proceeds of sale In accordance with this schedule will, In fact, be made unless someone objects by filing exceptions to It, within ten (10) days of the date It is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, One Courthouse Square, Carlisle, PA 17013-3387. THIS. PAPER 1S 'A N.OTjCE. OF Tkif TIME AND p1 ACE OF THE SALE OF YOUR PROPERTY. It has been Issued because there is a Judgment against you. It may cause your property to be held, to be sold or taken to pay the Judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TQ.. OR 1 PHO E T E OFF .CE SET F BELOW 0 FI D OUT WHERE Ya C ET FRE LEGAL ADVICE. Lawyer Referral Service of the Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of Cumberland County to open the Judgment If you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale, you may file a petition with the Court of Common Pleas of Cumberland County to set aside the sale for a grossly Inadequate price or for other proper cause. This petition must be filed before the Sheriff's Deed Is delivered. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of Cumberland Zucker, Goldberg & Ackerman, V1713 1 QA111 County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the Court and a proposed order or rule must be attached to the petition. If a specific return date Is desired, such date must be obtained from the Court Administrator's Office, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013-3387, before presentation of the petition to the Court. Dated: ZUCKER, GOLDBERG & s'. R AN BY: Scott A. Dietterk, Esquire; PA I. o . #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032— Jana Frldfinnsdottir, Esquire; PA I.Q. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XVP-184111/sde 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com VIA CERTIFIED MAIL, RETURN RECEIPT REQUESTED AND VIA PERSONAL SERVICE BY THE SHERIFF OF CUMBERLAND CO. Zucker, Goldberg & Ackerman, U.0 XVP-184111 Exhibit "A" LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel or tract of land situate in the Township of Monroe, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING in the Northwest corner of Keller Street and Wertz Avenue; thence along the Eastern line of Wertz Avenue, North 13 degrees 56 minutes West, 142.4 feet to a point on the Eastern line of said Wertz Avenue at the Southwest corner of Lot N0.5 on the Man of Lots hereinafter mentioned; thence in an Easterly direction along the Southern line of said Lot No.5, 79.4 feet to a point; thence in a Southerly direction along the Western line of Lot No. 13 on said Pian of Lots 141.4 feet to a point on the Northern line of Keller Street; thence along the Northern line of said Keller Street, South 69 degrees 3D minutes West, 89.1 feet to the point and place of BEGINNING. BEING Lot No. 14 In the Plan of Lots known as "Revised Plan of Trindie Spring Manor', which said Plan is recorded in the Recorder's Office in and for said Cumberland County in Plan Book 10, Page 36. UNDER AND SUBJECT TO the same rights, privileges, agreements, rights-of-way, easements, conditions, exceptions, restrictions, and reservations as exist by virtue of prior recorded instruments, plans, Deeds of Conveyances, or visible on ground. HAVING thereon erected a dwelling house being known and numbered as 824 West Keller Street, Mechanicsburg, PA, 17055-4028. BEING the same premises which Andrew J. Semic, unmarried, by Deed dated February 25, 2009 and recorded March 3, 2009 In and for Cumberland County, Pennsylvania, in Deed Book Volume , Page Instrument #: 200905944, granted and conveyed unto Randy A. Shaw, single man. Tax Map No.: 22-24-0783-060. Zucker, Goldberg & Ackerman, LLC XVP-184111 2. Article Number 1 r 111 1 11 i 1 1 11 1 9314 7100 1170 0766 89'93 26 O3. Service Type CERTIFIED MAIL W 4. Restricted Delivery? (Extra Fee) N • 1. Article Addressed to: CO a c5 • COMPLETE THIS SECTION ON DELIVERY A. Received by (Please Print Clearly) B. Date of Delivery C. Signature D. Is de 'very addr different m item 11 If YES, ent elivery address below: Randy A. Shaw 824 W KELLER ST MECHANICSBURG, PA 17055-4028 PS Form 3811, January 2005 Domestic Return Receipt A. t ddressee 1NP4 Reference Informa S`) 1 184111 PANOSS 1 i 9129/20141 9314 7100 1170 0766 8993 26-1021 1 UNITED STATES POSTAL SERVICE First -Class Mail Postage & Fees Paid USPS Permit No. G-10 f 111111111111111111111'11111111111111111111111111111 Zucker, Goldberg & Ackerman, LLC PO Box 9076 Temecula, CA 92589-9076 1 EXHIBIT B Zucker, Goldberg & Ackerman, LLC XVP-184111 Page 1 of 5 NOTICE TO LIENHOLDERS UNITED STATES eitli POSTAL SERVICE Certificate 0 Mailing This Certificate of Mailing provides evidence that mall has beers presented to USWfor mailing. This form may be used for domestic and international mall From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 U.S. POSTAGE >> PITNEY soWES ei;.7ft==oir Ammur ZIP 070 92 $ 001.200 02 111 000 13 87430 OCT 03 2014 To pay fee, affix stamps or meter postage here, To: UNKNOWN TENANT OR TENANTS 824 West Keller Street Mechanicsburg, PA 17055-4028 XVP-184111/sde TEAM -C OCT 03 AM County of P.O.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 • UNITED STATES POSTAL SERVICE@ Certificate Of Mailing This Certificate of Mailing provides ovIdence Chit mall has been presented to USPS. for mailing. This form may he used for domestle and International mail, From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XVP-184111/sde TEAM- C To: COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF WELFARE P.O. Box 2675 Harrisburg, PA 17105 To pay foe, affix stamps or meter postage here. County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 tiOZ CO 100 OCPLEICI 0 0 0 M ZO AZ.1000 $ Z6OLO dIZ '''•••••-aememors.-- , =w1==-11 Sahice A3Nircl «DV1SOd Sfl Page 2 of 5 NOTICE TO LIENHOLDERS UNITED STATES Cita POSTAL SERVICE® Certificate 0 Mailing U.S. POSTAGE )' P1TNEy80WES This Certificate of Mailing provides evidence that mail has been presented to USPS* for mailing. This form may be used for domestic and International mail. From: Scott A. Dietterick, Esquire c Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XVP-184111/sde TEA TD: CUMBERLAND COUNTY TAX CLAIM BUREAU Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 .xr..+aea�.aeai.aar rr}} ZIP 07002 fl .201 02 'WI 000138743DOCT 03 2014 To pay fee, affix stamps or meter postage here, Pot�e0 zurf County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STl1TES MElli POSTAL SERVtC Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS* for mailing. This form may be used for domestic and international mall. From' Scott A. Dietterick, Esquire cjo Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 To' MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR SOVEREIGN BANK PO Box 2026 Flint, MI 48501-2026 To pay fee, affix stamps or meter postage hero. XVP-184111/sde TEAM- Cibo, f n 3 County of P.O..: CUMBERLAND P5 Form 3817, April 2007 PSN 7530-02-000-9065 iLOZ EU .I.000EvLSE1000 t 40 00$ rt0d1Zr7 53M A?N td <30VIS d'Sf1 Page 3 of 5 NOTICE TO LIENHOLDERS ��..f UNITED STIlTES POSTAL SERVICE„ Certificate 0 Mailing This Certificate of Mailing provides evidence that mail has bean presented to USPS• for mailing. This form may be used for domestic and international mail. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 U.S. POSTAGE ») PITNEY e0WES aaaea� �a� ZIP 07092 $ 001.20° 02 10 0001387430 OCT 03 2014 To pay fee, affix stamps or meter postage here, To: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR SOVEREIGN BANK 1901 E. Voorhees Street, Suite C Danville, II 61834 ��,, XVP-184111/sde TEAM- C County of P.Q.: CUMBERLAND PS Form 3817, AprIl 2007 PSN 7530-02-000-9065 �UNlTEDSTI�TE PO5T,6LSE7r?VICE6 Certificate Of Mailing This Certificate of Mailing provides evidence that mall has been presented to USPS. for mailing. This form may be used for domestic and international mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XVP-184111/sde TEAM- C To: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR SOVEREIGN BANK 601 Penn Street Reading PA 19601 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 PIOZ CO 1000EPL8C1000 0OZ-1,00 $ Z60L0 dIZ �tia��ag♦w.i� r s3Moe A3Nlld «(3Ed1SOd '5.11 Postmark Here U.S. POSTAGE* PITNEY eowEs Page 4 of 5 NOTICE TO LIENHOLDERS UNITED STATES Certificate 00 OCT rr e'+ "• . 00 0138743 $ 001 .204 02 111 POSTAL SERVICE Mailing �i � To pay fee, affix stamps or meter postage here. This Certificate of Mating provides evidence that mat has been presented to USPS* for mailing. This form may be used for domestic end International mail. ffOm: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 �,✓�Zt.I.0 N,7 ;vim 0 XVP-184111/sde TEA To: MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR SOVEREIGN BANK 3300 SW 34th Avenue, Suite 101 Ocala, FL 34474 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 �'""'� UNITED STATES PC157/1LSERVICEg Certificate Of Mailing This Certificate of Mailing provides evidence that mag has been presented tot/SPS. for mailing. This form may be used for domestic and International Hiatt, From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XVP-184111/sde TEAM- C To: CUMBERLAND COUNTY DOMESTIC RELATIONS OFFICE Domestic Relations Section 13 N. Hanover Street PO Box 320 Carlisle, PA 17013 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 ►1OZ £0 1000E4L9£I000 r ag'" .0•I00$ Z60LO dIZ Mi. ZO mrimr wwmwrr swop A3Nlld «BOVISOd'S71 To pay fee, affix stamps or meter postage here. 'i 4 .L I.? N:IN, OU 03404 Postmark Here Page 5 of 5 NOTICE TO LIENHOLDERS uNirFasrnres Mg POST/!L SERVICE Certificate 0 Mailing :r —. PIO 12.1 This Certificate of Mailing provides evidence that mail has been presented to USPS• for mailing This form may be used far domestic end International mall. FrIXa' Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XVP-184111/sde TEAM- C To: PA DEPT. OF REVENUE- INHERITANCE TAX DIVISION Dept. 280601 Harrisburg, PA 17128-0601 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 UNITED STATES Z POSTAL SERVICE Certificate Of Mailing This Certificate of Mailing provides evidence that mail has been presented to USPS• for malting. This form may be used for domestic and International mall. From: Scott A. Dietterick, Esquire c/o Zucker, Goldberg & Ackerman, LLC 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 XVP-184111/sde TEAM- C To: UNKNOWN SPOUSE 824 West Keller Street Mechanicsburg, PA 17055-4028 County of P.Q.: CUMBERLAND PS Form 3817, April 2007 PSN 7530-02-000-9065 tI0Z £0 .100 O£PL8C t 000 o0Z" G 00 '$ r,6o/.o dlz amommilmirwmilorAtier- .carr WOO )3:1Id« OV.SOcl'Sri U.S. POSTAGE )i PITNEY BOWES tee. eeaatsme ZIP 07092 $ 001.20° 02 1W 0001387430 OCT 03 2014 To pay fee, affix stamps or meter postage here. OCT 0301 To pay fee, affix stamps or meter postage here. Postmark Here .: _, •,/i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. Randy A. Shaw; Defendant. NO.: 13 -7339 -CIVIL Notice of the Date of Continued Sheriff Sale The Sheriff Sale scheduled for December 3, 2014 at 10:OOam in the above captioned matter has been continued until February 4, 2015 at 10:OOam. BY: Dated: November 24, 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC I Christina Covert, Legal ssistant File No.: XVP-184111 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com .77,27