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Home My WebLink About14-0093 .*' % For Prothonotary Use Only: S uprlem a Court -of Pennsylvania 'CO U Ft �CotTamn Fleas lq' ivil,C - ov r, sheet Cu mbe r land County COumty 7be information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or other a ers as required by law or rules o court. Commencement of Action: S 0 Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: Wells Fargo Bank, NA Lead Defendant's Name: Renee G. Foley T I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits O (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff /Appellant's Attorney: McCabe, Weisberg & Conway, P.C. ❑ Check here if you have no attorney (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 ❑ Department of Transportation ❑ Premises Liability (does not include ❑ Statutory Appeal: Other S mass tort) . ❑ Slander/Libel/ Defamation ❑ Employment Dispute: ❑ Other: Discrimination C ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other I O ❑ Other N MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant B 11 Toxic Waste REAL PROPERTY MISCELLANEOUS ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: ❑ Eminent Domain /Condemnation ❑Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Disput ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY Mortgage ❑ Mort a e Foreclosure: Commercial El Quo Waranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title 11 Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J.McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 C _- BRIAN T. LAMANNA, ESQUIRE - ID # 310321 -p.: c -�- - i rn t;� c,_. ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 -c JOSEPH I. FOLEY, ESQUIRE - ID # 314675 -> -a C 7 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 r - j "I x� JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 -" rT7 123 South Broad Street, Suite 1400 — Philadelphia, Pennsylvania 19109 �E cn (215) 790 -1010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION 3476 Stateview Boulevard Fort Mill, SC 29715 No.: Plaintiff, V. Renee G. Foley 1413 Pheasant Drive South Carlisle, PA 17013 Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, NA, by its attorneys, McCabe, Weisberg & Conway, P.C. and files this Complaint in Mortgage Foreclosure as follows: 062 -PA -V3 File #77496 1. The Plaintiff is Wells Fargo Bank, NA, at 3476 Stateview Boulevard, Fort Mill, SC 29715 (hereinafter "Plaintiff'). 2. The Defendant, Renee G. Foley is an individual whose last known address is 1413 Pheasant Drive South, Carlisle, PA 17013. 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 as Exhibit "A ", attached hereto and made a part hereof. 4. On or about July 31, 2012, Renee G. Foley, made, executed and delivered to Mortgage Electronic Registration Systems, Inc., as nominee for Fulton Bank, N.A. a Mortgage in the original principal amount of $108,007.00 on the premises described in the legal description marked as Exhibit `B ", attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of Cumberland County as Instrument Number 201223335. 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 18, 2013, the mortgage was assigned to Wells Fargo Bank, NA which Assignment is recorded in the Office of the Recorder of Cumberland County as Instrument Number 201330909. 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. Renee G. Foley is the record and real owner of the aforesaid mortgaged premises. 062 -PA -V3 File #77496 7. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due July 1, 2013. S. As of 12/30/2013 the amount due and owing Plaintiff on the mortgage is as follows: Principal $ 106,288.10 Interest From 06/01/2013 to 12/30/2013 $ 2,232.60 Late Charges $ 96.82 Escrow Advance $ 847.19 Property Inspections $ 0.00 Property Preservation $ 0.00 BPO /Appraisal $ 0.00 Escrow Balance $ 0.00 Corporate Advance Credit $ 0.00 Total $ 109,464.71 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 Defendant. 10. This action does not come under Act 91 of 1983 because the mortgage is FHA insured. 11. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant, but reserves its right to do so in a separate legal action if such right exists. If Defendant has received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish 062 -PA -V3 File #77496 such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $ 109,464.71 with interest thereon plus additional costs (including additional escrow advances), and for foreclosure and sale of the mortgaged premises. McCABE, WEISBERG & CONW AV , P.C. BY: [ ] Terrence J. McCabe, Esquire t [ arc . Weisberg, Esquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire { ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff Dated: - T,, A % A Any , 201+ 062 -PA -V3 File #77496 VERIFICATION Denise Goldston; hereby states that he/ Gh is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that he/ 1& is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of hise 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: Denise Goldston Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 12/31/2013 086 -PA -V2 File #: 77496 Exhibit A P. 1 App # Min # NOTE M ultistate F11A Case No. July 31, 2012 [Date] 1413 PHEASANT DRIVE SOUTH CARLISLE, PA 17013 [Property Address] 1. PARTIES "Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender" means FULTON BANK, N.A. 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 Eight Thousand Seven And Zero /100 Dollars (U.S. $108,007 - 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 T h r e e a n d f i v e e i g h t h s percent( 3.625 %) 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 first day of each month beginning on September 01 , 2012 . Any principal and interest remaining on the first day of August, 2042 , will be due on that date, which is called the "Maturity Date." (B) Place Payment shall be made at ONE PENN SQUARE, LANCASTER, PA 17602 or at such place as Lender may designate in writing by notice to Borrower. (C) Amount Each monthly payment of principal and interest will be in the amount of U.S. $ 492.57 This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] OGraduated Payment Allonge OGrowing Equity Allonge F70ther [specify] o Multistate Fixed Rate Note VMP Q VMPt Page 1 of 3 Wolters.Kluwer Financial Services Page 7 of 3 r ; 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 4he 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. fi. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C) of this Note, by the end of fifteen calendar days after the payment is due, Lender may collect a late charge in the amount of Four percent ( 4.000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C) Payment of Costs and Expenses If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. Lender may enforce its rights under this 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. A�luOS nedRateNote VMP O VMP1R (1103).01 Wolters Kluwer Financial Services Page 2 of 3 n f BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. le 2 (Seal) (Seal) RENE G FOLEY - Borrower - Borrower (Seal) (Seal) - Borrow er - Borrow er (Sign Original Only] Refer to the attached Signature Addendum for additional parties and signatures. WELLS FARGO BANK, NA. Pay to L io ci of W Rc ^course Fulivrl .�t, Pay the Order of B M"It" �lu gtiG« �vPt c Y N 44e1; KwamanRVUUVI tvcz" File: eGonaary rM, M 6 Ce Without Reemme Wells Fargo Bank, NA By M ary A. Seamans Vice President 006 FH A Mul ti�sl ie Fixed Rate Note VMP v VMP1R(1103 3 Wolters Kluwer Financial Services Pege 3 0l 3 Exhibit B PARCEL NO. 29 -17- 1583 -095 ALL THAT CERTAIN lot or tract of ground situate in North Middleton Township, Cumberland County, Pennsylvania, more particularly shown on a certain plan entitled "Final Subdivision Plan of Pheasant Run Estates Phase 11 and Phase III for Metlanco, Inc., North Middleton Township, Cumberland County, Pennsylvania Scale: 1" = 50' April 9, 1975 Revised: April 30, 1975" by Gerrit J. Betz Associates, Inc., Engineers & Surveyors, 6 East Main Street, Shiremanstown, Pennsylvania, which plan is filed in Plan Book 29 at Page 7 in the Office of the Recorder of Deeds for Cumberland County. Said lot is more particularly bounded and described as follows: BEGINNING at a point on the southern right -of -way line of Pheasant Drive, South at the dividing line of Lot No. 45 and 46 as shown on the above referred to plan; thence by aforesaid southern right -of -way line by a curve to the left having a radius of 125.00 feet, an arc length of 53.05 feet to a point on the northern line of a recreation and green area; thence on by aforesaid line, North 83 degrees 10 minutes 21 seconds West, 202.06 feet to a point; thence by same, North 06 degrees 49 minutes 39 seconds East, 35.50 feet to a point on the southern line of Lot No. 46 as shown on above mentioned Final Subdivision Plan; thence by aforesaid line, South 83 degrees 10 minutes 21 seconds East, 163.17 feet to a point, being the Place of BEGINNING. BEING Lot No. 45 on a Final Subdivision Plan of Pheasant Run Estates Phase II and III, recorded in Plan Book 26, Page 7. TOGETHER with the right, in common with others, to pass and repass for ingress and egress over the roads as shown on said map from the lot herein conveyed. BEING SUBJECT to a Declaration of Covenants recorded in Miscellaneous Book 242, Page 834, in the Office of the Recorder of Deeds for Cumberland County. HAVING thereon erected a brick and aluminum townhouse being known and numbered 1413 Pheasant Drive S., Carlisle,. Pennsylvania. k FORM 1 Wells Fargo Bank, NA IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA £•': vs.:��r Renee G. Foley Civil Z--;0 Defendant NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM -el 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. 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 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. THIS PROGRAM IS FREE. Respectfully submitted: i atu� of ounsel for P aintif Date [ gn fJ 77496 Page 1 u .R 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 Please provide the following information to the best of your knowledge: APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes 0 No 0 Listing date: Price $ Realtor Name: Realtor Phone: Borrower Occupied? Yes 0 No 0 Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? C O-BORROWER Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payment Amount $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes 0 No 0 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. 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 " Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel /repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money 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: 2 • -Email: . Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes 0 No 0 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 deliquency? Yes 0 No 0 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: 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 Uwe am/are under no obiligation 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: f Proof of income f Past 2 bank statements Proof of any expected income for the last 45 days f Copy of a current utility bill f Letter explaining reason for delinquency and any supporting documentation (hardship letter) f Listing agreement (if property is currently on the market) 3 NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action ex- puestas en las paginas siguientes, usted within twenty (20) days after this complaint tiene veinte (20) dias de plazo al partir de la and notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la or objections to the claims set forth against corte en forma escrita sus defensas o sus you. You are warned that if you fail to do so objeciones a las demandas en contra de su the case may proceed without you and a persona. Sea avisado que si usted no se judgment may be entered against you by the defiende, la corte tomara medidas y puede court without further notice for any money continuar la demanda en contra suya sin claimed in the complaint or for any other previo aviso o notificacion. Ademas, la claim or relief requested by the plaintiff. corte puede decidir a favor del demandante You may lose money or property or other y requiere que usted cumpla con todas las rights important to you. provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros YOU SHOULD TAKE THIS derechos importantes para usted. PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO USTED LE DEBE TOMAR ESTE TO OR TELEPHONE THE OFFICE SET PAPEL A SU ABOGADO FORTH BELOW. THIS OFFICE CAN INMEDIATAMENTE. SI USTED NO PROVIDE YOU WITH INFORMATION TIENE A UN ABOGADO, VA A O ABOUT HIRING A LAWYER. TELEFONEA LA OFICINA EXPUSO IF YOU CANNOT AFFORD TO ABAJO. ESTA OFICINA LO PUEDE HIRE A LAWYER, THIS OFFICE MAY PROPORCIONAR CON INFORMATION BE ABLE TO PROVIDE YOU WITH ACERCA DE EMPLEAR A UN INFORMATION ABOUT AGENCIES ABOGADO. THAT MAY OFFER LEGAL SERVICES SI USTED NO PUEDE TO ELIGIBLE PERSONS AT A PROPORCIONAR PARA EMPLEAR UN REDUCED FEE OR NO FEE. ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON Cumberland County Bar Association INFORMACION ACERCA DE LAS 32 South Bedford Street AGENCIAS QUE PUEDEN OFRECER Carlisle, PA 17013 LOS SERVICIOS LEGALES A (800) 990 -9108 PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990 -9108 062 -PA -V3 File #77496 . r This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Please Note: (1) unless, within thirty (30) days after your receipt of this notice, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid; (2) if you notify us in writing within thirty (30) days of your receipt of this notice that the debt, or a portion of the debt, is disputed, we will cease collection of the debt until we obtain verification of the debt or a copy of the judgment against you and mail to you a copy of the verification or judgment that we obtain; (3) upon your written request to us within thirty (30) days of your receipt of this notice for the name and address of the original creditor of your debt, we will cease collection of the debt until we mail to you the name and address of the original creditor, if different from the current creditor. Case Name: Wells Fargo Bank, NA v. Renee G. Foley Cumberland County 062 -PA -V3 File #77496 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ‘ � ni�"gtebrt r Jody S Smith , 2. Chief Deputy C t rti Richard W Stewart j t a I` Solicitor t w c = r ``�.1 i tp � i!'e Wells Fargo Bank, N.A. Case Number vs. • Renee G Foley 2014-93 SHERIFF'S RETURN OF SERVICE 01/10/2014 02:15 PM- Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Daniel Foley, Son ,who accepted as"Adult Person in Charge"for Renee G Foley at 1413 Phesant Drive South, North Middleton, Carlisle, PA 17013. JAS INSL , DEPUTY SHERIFF COST: $34.78 SO ANSWERS, January 13, 2014 RONO R ANDERSON, SHERIFF McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 �. , EDWARD D. CONWAY,ESQUIRE -ID#34687 : 1r') p . MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 is E" ws i i l HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 E1`INs`1'PIA NIA BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Str:et,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,NA CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Renee G.Foley Number 14-93 Defendant ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendant, Renee G.Foley, in the above- captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Amount Due $ 109,464.71 Interest from 01/01/14 to 03/03/14 $ 644.16 Total $ 110,108.87 McCABE,WEISBERG AND CONjWAY,P.C. BY ence J.McCabe,Esq. [ ]Marc S.Weisberg,Esq. [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ] Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. [ ] Jennifer L.Wunder,Esquire 51(�SOO CO) [ ]Lena Kravets,Esquire �� Attorneys for Plaintiff Ct cC a � 1�1CUC.l� � 3bas�c� AND NOW,this day of ,2014,Judgment is entered in favor of Plaintiff,Wells Fargo NobcC, Bank,NA,and against Defendant,Renee G.Foley,in rem only and not in personam,and damages are assessed in the M amount of$110,108.87,plus interest and costs. BY THE PROTH TAR . r* , McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P. DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE=ID#316421 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 215 790-1010 Wells Fargo Bank,NA CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Renee G.Foley Number 14-93 Defendant AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned, being duly sworn according to law,deposes and says that the Defendant,Renee G. Foley, is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act,50 U.S.C.App.§501,et seq.;and that the Defendant,Renee G.Foley,is over eighteen (18)years of age,and resides as follows: Renee G.Foley, 1413 Pheasant Drive South Carlisle,PA 17013 McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED BY: BEFORE ME THIS ,� DAY T rrence J.McCabe,Esq. [ ]Marc S.Weisberg,Esq. /1'1 Edward D. Conway,Esq. [ ] Margaret Gairo,Esq. OF A( ,2014 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J. Cohen,Esq. [ ]Christine L. Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. NOTARY PUBLI [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ] Celine P.DerKrikorian,Esq. [ ]Jennifer L. Wunder,Esquire COMMONWEALTH OF PENNSYLVANIA [ ]Lena Kravets,Esquire NOTARIAL SEAL Attorneys for Plaintiff ANDREW SWITKAY,Notary Public City of Philadelphia,Phila. County ,r_ My.Commission Expires March 15,2017 'Department of Defense Manpower Data Center Results as of:Mar-03-2014 08:09:53 AM • SCRA 3.0 a �« t a 4 ,. Status Report r Pursuant to Servicemenibers Civil Relief Act Last Name: FOLEY First Name: RENEE Middle Name: G. Active Duty Status As Of: Mar-03-2014 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA . No NA This response reflects the individuals'active',duty status based on the Active Duly Status Date Left Active Duty Within 367 Des of Active Duty Status Date Active Duty Start Data Active Duty End Date Status Service Component NA NA ., '''No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Statue Date Order Notification Start Date Order Notification End Data Status Service Component NA NA ,, 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. Y)taott ---.7,,— BAbilt,gv2,- a ... Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite J4E25 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 10 be provided. Certificate ID: 17C5M8CDDOE7Z40 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S.WEISBERG,ESQUIRE-ID# 17616 EDWARD D. CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J.COHEN,ESQUIRE-ID#87830 CHRISTINE L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE-ID#316421 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,NA COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY v. Number 14-93 Renee G.Foley Defendant AFFIDAVIT OF LAST-KNOWN MAILING ADDRESS OF DEFENDANT COMMONWEALTH OF PENNSYLVANIA: SS. COUNTY OF PHILADELPHIA: The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes and says that the last-known mailing address of the Defendant is: Renee G.Foley 1413 Pheasant Drive South Carlisle,Pennsylvania 17013 McCABE,WEISBERG AND CONWAY,P.C. SWORN AND SUBSCRIBED /-<.e BEFORE ME THIS DAY BY: "- /� A Terrence J.McCabe,Esq. [ ]Marc S. Weisberg,Esq. /),,(. Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. OF ,/" - ,2014 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. ,. 7.L_ 7 -____. [ ]Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. NOTARY PUBLIC [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L. Wunder,Esquire COMMONWEALTH OF PENNSYLVANIA [ ]Lena Kravets,Esquire NOTARIAL SEAL. Attorneys for Plaintiff ANDREW SWITKAY,Notary Public City of Philadelphia,Phila. County My Commission Expires March 15,2017 McCABE,WEISBERG AND CONWAY,P.C. BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff MARC S. WEISBERG,ESQUIRE-ID# 17616 EDWARD D.CONWAY,ESQUIRE -ID#34687 MARGARET GAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 HEIDI R. SPIVAK,ESQUIRE-ID#74770 MARISA J. COHEN,ESQUIRE-ID#87830 CHRISTIN 3 L.GRAHAM,ESQUIRE-ID#309480 BRIAN T.LAMANNA,ESQUIRE-ID#310321 ANN E. SWARTZ,ESQUIRE-ID#201926 JOSEPH F.RIGA,ESQUIRE-ID#57716 JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 JENNIFER L. WUNDER,ESQUIRE-ID#315954 LENA KRAVETS,ESQUIRE=ID#316421 123 South Broad Street, Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 Wells Fargo Bank,NA CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS v. Number 14-93 Renee G.Foley Defendant CERTIFICATION The unders gned hereby certifies that he/she is the attorney for Plaintiff, being duly sworn according to law, deposes and says that a letter was deposited in the United States Mail notifying the Defendant that judgment would be entered against him/her/them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. A copy of said letter is attached hereto and marked as Exhibit"A". McCABE,WISBERG CONWAY,0 C P.C. SWORN AND SUBSCRIBED ��:�i( �/ BEFORE ME THIS ``3 DAY Terrence J.McCabe,Esq. [ ]Marc S. Weisberg,Esq. j [ ]Edward D.Conway,Esq. [ ]Margaret Gairo,Esq. OF C c-LA, ,2014 [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ]Christine L.Graham,Esq. [ ]Brian T.LaMantia,Esq. [ ]Ann E. Swartz,Esq. NOTARY PUBLIC [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. COMMONWEALTH OF PENNSYLVANIA [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L.Wunder,Esquire NOTARIAL SEAL [ ]Lena Kravets,Esquire ANDREW SWITKAY,Notary Public Attorneys for Plaintiff City of Philadelphia,Phila. County My Commission Expires March 15,2017 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, , and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative,who is out of jurisdiction and not available to sign this verification at this time,are true and correct to the best of his/her knowledge,information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. McCABE ERG AND C 0 Y,P.C..X-t' Prrence J.McCabe,Esq. [ ]Marc S. Weisberg,Esq. d Eward D.Conway,Esq. [ ]Margaret Gairo,Esq. [ ]Andrew L.Markowitz,Esq. [ ]Heidi R. Spivak,Esq. [ ]Marisa J.Cohen,Esq. [ ] Christine L.Graham,Esq. [ ]Brian T.LaManna,Esq. [ ]Ann E. Swartz,Esq. [ ]Joseph F.Riga,Esq. [ ]Joseph I.Foley,Esq. [ ]Celine P.DerKrikorian,Esq. [ ]Jennifer L. Wunder,Esquire [ ]Lena Kravets,Esquire Attorneys for Plaintiff Wells Fargo Bank,NA v.Renee G.Foley Cumberland County;Number: 14-93 tor r it;r, ur I nr,rlcv It 1101111.1 Jt Aln I COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle,Pennsylvania 17013 Curt Long Prothonotary February 3, 2014 To: Renee G. Foley 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 Wells Fargo Bank,NA Cumberland County vs. Court of Common Pleas Renee G. Foley Number 14-93 NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE NOTIFICACION IMPORTANTE YoU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO IIABER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR CLAIMS SET FORTH AGAINST'!OU. UNLESS YOU ACT WITHIN TEN(10) ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS DAYS FROM THE DATE OF THIJ NOTICE,A JUDGMENT MAY BE ENTERED RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY ACCION DEBIDA DENTRO DE DIEZ(10)DIAS DE LA FECHA DE ESTA OR OTHER IMPORTANT RIGHTS. NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU COMPARECER USTED EN CORTE U OIR PRELJBA ALGUNA, DICTAR DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH SENTENCIA EN SU CONTRA YUSTED PODRIA PERDERBIENES U OTROS BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT DERECHOS IMPORTANTES. HIRING A LAWYER, USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TO PROVIDE YOU WITH INFORMATIONABOUTAGENCIESTHATMAYOFFER TELEFONEA LA OFICINA EXPUSO ABAJO.ESTA OFICINA LO PUEDE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. Cumberland County Bar Association Si USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, 32 South Bedford Street ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON Carlisle,Pennsylvania 17013 INFORMACION ACERCA DE LAS AGENCIAS QUEPUEDEN OFRECER LOS (800)990-9108 SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NING[JN HONORARIO, Cumberland County Bar Association 32 South Bedford Street Carlisle,Pennsylvania 17013 (800)990-9108 McCABE,WEISBERG AND CONWAY,P.C. BY: 1w [ ]Terrence J.McCabe,Esquire [ Mafc S. Weisberg,Esquire j ]Edward D.Conway,Esquire [ ]' argaret Gairo,Esquire [ ]Andrew L.Markowitz,Esquire Ieidi R. Spivak,Esquire [ ] Marisa J.Cohen,Esquire [...I-Christine L.Graham,Esquire [ ]Brian T.LaManna,Esquire [ ]Ann E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [ ]Joseph I.Foley,Esquire [ ]Celine P. DerKrikorian,Esquire [ ]Jennifer L. Wunder,Esquire [ ]Lena Kravets,Esquire Attorneys for Plaintiff ds �. /!I OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle,Pennsylvania 17013 Prothonotary To: Renee G.Foley 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 Wells Fargo Bank,NA COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY v. Renee G.Foley No. 14-93 Defendant NOTICE Pursuant to Rule 236,you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin , Judgment for Possession 3P)///y If you have any questions concerning this Judgment,please call McCabe.Weisberg and Conway, P.C. at(215)790-1010. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321. ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN - ID #313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 Wells Fargo Bank, NA Plaintiff v. Renee G. Foley Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14 -93 PRAECIPE TO REDUCE JUDGMENT AMOUNT TO THE PROTHONOTARY: Kindly reduce the judgment amount entered in the above captioned case by $644.16 from $110.108.87 to $109,464.71. DATE: `"1 "II LA McCABE, WEISBERG AND CONWAY, P.C. BY: l [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire Attorneys for Plaintiff [ .. arc S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Kevin T. McQuail, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. Derkrikorian, Esquire atA "."Pd '9'46\ GP NCult61 �U� McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID #314675 CELINE P. DERKRIKORIAN - ID #313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 Wells Fargo Bank, NA Plaintiff v. Renee G. Foley Defendant I, Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14 -93 CERTIFICATE OF SERVICE , Esquire, hereby certify that a true and correct copy of the within Praecipe to Reduce Judgment Amount was served on the following persons by first -class mail, postage prepaid, on p-Q\r' \ 1 I , 2014: Renee G. Foley, 1413 Pheasant Drive South Carlisle, PA 17013 DATE: McCABE, WEISBERG AND CONWAY, P.C. BY: [ ] Terrence J. cCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph I. Foley, Esquire Attorneys for Plaintiff [ tac S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Kevin T. McQuail, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. Derkrikorian, Esquire SUITE 210 145 HUGUENOT STREET NEW ROCHELLE, NY 10801 (914)- 636 -8900 FAX (914) 636 -8901 SUITE 201 216 HADDON AVENUE WESTMONT, NJ 08108 (856) 858-7080 FAX (856) 858 -7020 SUITE 130 DELAWARE CORPORATE CENTER ONE RIGHTER PARKWAY WILMINGTON, DE 19803 (302) 409-3520 FAX 855- 425 -1980 Renee G. Foley 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 LAW OFFICES McCABE, WEISBERG & CONWAY, P.C. SUITE 1400 123 SOUTH BROAD STREET PHILADELPHIA, PA 19109 (215) 790 -1010 FAX (215) 790 -1274 Re: Wells Fargo Bank, NA v. Renee G. Foley Cumberland,; C.C.P.; Number: 14 -93 Dear Sir or Madam: record. /dn Enclosed please find a copy SUITE 800 312 MARSHALL AVENUE LAUREL, MD 20707 (301) 490-3361 FAX (301) 490-1568 Also servicing the District of Columbia SUITE 203 722 E. MARKET STREET LEESBURG, VA 20176 (571) 449 9350 FAX: (855) 845 -2585 SUITE 2S06 1 HUNTINGTON QUADRANGLE MELVILLE, NY 11747 (631) 812-4084 FAX: (855) 845 -2584 Praecipe to Reduce Judgment, the original of which is being duly filed of If you have any questions, please feel free to contact me. This is a communication from a debt collector. This letter may be an attempt to collect a debt and any information obtained will be used for that purpose. Name and Address of Sender McCabe, Weisberg and Conway, P.C. 123 S. Broad St., Suite 1400 Philadelphia, PA 19109 ATTN: D. Nguyen Check type of mail or service: 0 Certified 0 Recorded Delivery (International) COD 0 Registered 0 Delivery Confirmation 0 Return Receipt for Merchandise 0 Express Mail '0 Signature Confirmation 0 Insured Article Number Postage Wells Fargo Bank, NA v. Renee G. Foley 6 Renee G. Foley 1413 Pleasant Drive South Carlisle, PA 17013 t✓ b� U.S. POSTAGE» PITNEY BOWES $ ZIP 19109 �P OO q I.2O0 02 Iry 0001377494 APR. 04 2014 P TotalNumber of Pieces Listed by Sender io Total Number of Pie Received at Post Off oes �y s' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FILE NO.: 14 -93 Civil Term Wells Fargo Bank, NA v. AMOUNT DUE: $109,464.71 Renee G. Foley TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or 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. .e' PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and Gt s upon the c following described property of the defendant(s) d) - " "'` "LL INTEREST: from 03/04/14 $3,310.16 at $17.99 ATTY'S COMM.: COSTS: 1413 Pheasant Drive South, Carlisle, Pennsylvania 17013 (More fully described as attached) -r PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to 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 personalty list) 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: ,a sb is tt BY: [ ] Tet't-ence cCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. Attorneys for Plaintiff Address:123 S. Broad Street, Suite 1400 Philadelphia, PA 19109 Attorney for: Plaintiff arc S. Weisberg, Esq. argaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Kevin T. McQuail, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. Telephone: (215) 790 1010 Supreme Court ID No. ?M LI \C4 au an) lbq R�� LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of ground situate in North Middleton Township, Cumberland County, Pennsylvania, more particularly shown on a certain plan entitled "Final Subdivision Plan of Pheasant Run Estates Phase II and Phase III for Met lanco, Inc., North Middleton Township, Cumberland County, Pennsylvania, Scale: 1" = 50' April 9, 1975, Revised: April 30, 1975, by Gerrit J. Betz Associates, Inc., Engineers and Surveyors, 6 East Main Street, Shiremanstown, Pennsylvania, which plan is filed in Plan Book 29 at Page 7 in the Office of the Recorder of Deeds for Cumberland County, Said lot is more particularly bounded and described as follows: BEGINNING at a point on the southern right-of-way line of Pheasant Drive, South at the dividing line of Lot No, 45 and 46 as shown on the above referred to plan; thence by aforesaid southern right-of-way line by a curve to the left having a radius of 125.00 feet, an arc length of 53.05 feet to a point on the northern line of a recreation and green area; thence on by aforesaid line, North 83 degrees 10 minutes 21 seconds West, 202,06 feet to a point; thence by same, North 06 degrees 49 minutes 39 seconds East, 3550 feet to a point on the southern line of Lot No. 46 as shown on above mentioned Final Subdivision Plat; thence by aforesaid line, South 83 degrees 10 minutes 21 seconds East, 163.17 feet to a point, being the Place of BEGINNING. BEING Lot No. 45 on a Final Subdivision Plan of Pheasant Run Estates Phase II and Phase III, recorded in Plan BoalK)61Page 7. TOGETHER with the right, in common with other, to pass and repass for ingress and egress over the roads shown on said map from the lot herein conveyed. BEING SUBJECT to. a Declaration of Covenants recorded in Miscellaneous Book 242, Page 834, in the Office of the Recorder of Deeds for Cumberland County. HAVING thereon erected a brick and aluminum townhouse being known as and numbered 1413 Pheasant Drive S., Carlisle, Pennsylvania. Premises: 1413 Pheasant Drive South, Carlisle, Pennsylvania 17013. BEING the same premises which Mary R. Gibson and Katherine G. Nasser, Co-Executrices of the Last Will and Testament of Lois R. Gibson, deceased, by deed dated July 12, 2012 and recorded August 3, 2012 in Instrument Number 201223334, granted and conveyed unto Renee G. Foley. TAX MAP PARCEL NUMBER: 29-17-1583-095 McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH 1. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790 -1010 Wells Fargo Bank, NA Plaintiff v. Renee G. Foley Defendant Attorneys for Plaintiff t- .! F. 3..:;Ff w PRO 2Gu I PR - l PI 2: 2 5 CUMBERL COUNTY LVAN;A �: CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 14 -93 AFFIDAVIT PURSUANT TO RULE 3129 LP G Q �Ci The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 1413 Pheasant Drive South, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Renee G. Foley 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 2. Name and address of Defendant in the judgment: Name Address Renee G. Foley 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Address Plaintiff herein Redevelopment Authority of the 114 N. Hanover Street County of Cumberland Carlisle, Pennsylvania 17013 5. Name and address of every other person who has any record lien on the property: Name None Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Metiance, Inc., A Pennsylvania Corporation The United Telephone Company of Pennsylvania Address 1884 Storrets Gap Road Carlisle, Pennsylvania 17013 152 East High Street Carlisle, Pennsylvania 17013 The United Telephone Company of 1824 Sterretts Cap Road Pennsylvania Carlisle, Pennsylvania 17013 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants /Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Address 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105 -8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128 -1230 PO BOX 280948 Harrisburg PA 17128 -0948 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America do Atty General of the United States 8. Name and address of Attorney of record: Name None Clearance Support Department 281230 Harrisburg, PA 17128 -1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128 -0946 Attn: Sheriffs Sales do United States Attorney for the Middle District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108 -1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530 -0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530 -0001 Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DAT McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terr ce J. Cabe, Esq. [ ] Edward D nway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff Wells Fargo Bank, NA v. Renee G. Foley Cumberland County; Number: 14 -93 [ ] Marc S. Weisberg, Esq. [i]"Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of ground situate in North Middleton Township, Cumberland County, Pennsylvania, more particularly shown on a certain plan entitled "Final Subdivision Plan of Pheasant Run Estates Phase II and Phase III for Met lanco, Inc., North Middleton Township, Cumberland County, Pennsylvania, Scale: 1" = 50' April 9, 1975, Revised: April 30, 1975, by Gerrit J. Betz Associates, Inc., Engineers and Surveyors, 6 East Main Street, Shiremanstown, Pennsylvania, which plan is filed in Plan Book 29 at Page 7 in the Office of the Recorder of Deeds for Cumberland County. Said lot is more particularly bounded and described as follows: BEGINNING at a point on the southern right-of-way line of Pheasant Drive, South at the dividing line of Lot No, 45 and 46 as shown on the above referred to plan; thence by aforesaid southern right-of-way line by a curve to the left having a radius of 125.00 feet, an arc length of 53.05 feet to a point on the northern line of a recreation and green area; thence on by aforesaid fine, North 83 degrees 10 minutes 21 seconds West, 202.06 feet to a point; thence by same. North 06 degrees 49 minutes 39 seconds East, 35.50 feet to a point on the southern line of Lot No. 46 as shown on above mentioned Final Subdivision Plan; thence by aforesaid line, South 83 degrees 10 minutes 21 seconds East, 163.17 feet to a point, being the Place of BEGINNING. BEING Lot No. 45 on a Final Subdivision Plan of Pheasant Run Estates Phase II and Phase Ill, recorded in Plan Booky,'Page 7. 9‘1 TOGETHER with the right, in common with other, to pass and repass for ingress and egress over the roads as shown on said map from the lot herein conveyed. BEING SUBJECT to a Declaration of Covenants recorded in Miscellaneous Book 242, Page 834, in the Office of the Recorder of Deeds for Cumberland County. HAVING thereon erected a brick and aluminum townhouse being known as and numbered 1413 Pheasant Drive S., Carlisle, Pennsylvania. Premises: 1413 Pheasant Drive South, Carlisle, Pennsylvania 17013. BEING the same premises which Mary R. Gibson and Katherine G. Nasser, Co-Executrices of the Last Will and Testament of Lois R. Gibson, deceased, by deed dated July 12, 2012 and recorded August 3, 2012 in Instrument Number 201223334, granted and conveyed unto Renee G. Foley. TAX MAP PARCEL NUMBER: 29-17-1583-095 McCABE, WEISBERG & CONWAY, P.C. . , ,..„� Fla Attorneys for Plaintiff BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 - r' i; ; Y H 0 H 0 i A cA `I MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 2014 APR —7 PM 2: 25 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 2800 U E RL AND COUNTY HEIDI R. SPIVAK, ESQUIRE - ID # 74770 PENNSYLVANIA MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE -1D # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 CIVIL ACTION LAW Wells Fargo Bank, NA v. Renee G. Foley COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14 -93 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Renee G. Foley 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 Your house (real estate) at 1413 Pheasant Drive South, Carlisle, Pennsylvania 17013 is scheduled to be sold at Sheriffs Sale on September 3, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $109,464.71 obtained by Wells Fargo Bank, NA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be canceled if you pay to Wells Fargo Bank, NA the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790 -1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790 -1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790 -1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENC1DADOS Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of ground situate in North Middleton Township, Cumberland County, Pennsylvania, more particularly shown on •a certain plan entitled "Final Subdivision Plan of Pheasant Run Estates Phase II and Phase 111 for Metlanco, Inc., North Middleton Township, Cumberland County, Pennsylvania, Scale: 1" = 50' April 9, 1975, Revised: April 30, 1975, by Gerrit J. Betz Associates, Inc., Engineers and Surveyors, 6 East Main Street, Shiremanstown, Pennsylvania, which plan is filed in Plan Book 29 at Page 7 in the Office of the Recorder of Deeds for Cumberland CountY. Said lot is more particularly bounded and described as follows: BEGINNING at a point on the southern right-of-way line of Pheasant Drive, South at the dividing line of Lot No, 45 and 46 as shown on the above referred to plan; thence by aforesaid southern right-of-way line by a curve to the left having a radius of 125.00 feet, an arc length of 53.05 feet to a point on the northern line of a recreation and green area; thence on by aforesaid line, North 83 degrees 10 minutes 21 seconds West, 202.06 feet to a point; thence by same, North 06 degrees 49 minutes 39 seconds East, 35.50 feet to a point on the southern line of Lot No. 46 as shown on above mentioned Final Subdivision Plan; thence by aforesaid line, South 83 degrees 10 minutes 21 seconds East, 163.17 feet to a point, being the Place of BEGINNING. BEING Lot No. 45 on a Final Subdivision Plan of Pheasant Run Estates Phase II and Phase III, recorded in Plan BoolcyPage 7. 9'9 TOGETHER with the right, in common with other, to pass and repass for ingress and egress over the roads as shown on said map from the lot herein conveyed. BEING SUBJECT to a Declaration of Covenants recorded in Miscellaneous Book 242, Page 834, in the Office of the Recorder of Deeds for Cumberland County. HAVING thereon erected a brick and aluminum townhouse being known as and numbered 1413 Pheasant Drive S., Carlisle, Pennsylvania. Premises: 1413 Pheasant Drive South, Carlisle, Pennsylvania 17013. BEING the same premises which Mary R. Gibson and Katherine G. Nasser, Co-Executrices of the Last Will and Testament of Lois R. Gibson, deceased, by deed dated July 12, 2012 and recorded August 3, 2012 in Instrument Number 201223334, granted and conveyed unto Renee G. Foley. TAX MAP PARCEL NUMBER: 29-17-1583-095 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square •. Suite100 • Carlisle, PA • 17013 (717) 240 -6195 www.ccpa.net WELLS FARGO BANK, NA Vs. RENEE G. FOLEY WRIT OF EXECUTION NO 14 -93 Civil Term CIVIL ACTION — LAW 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: $109,464.71 Interest FROM 3 /4/14 - $3,310.16 AT $17.99 Atty's Comm: Atty Paid: $200.03 Plaintiff Paid: Date: 4/7/14 (Seal) L.L.: 5.50 Due Prothy: $2.25 Other Costs: REQUESTING PARTY: Name: MARGARET GAIRO, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY, P.C. 123 S. BROAD STREET, SUITE 1400 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215- 790 -1010 Supreme Court ID No. 34419 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215)790-1010 Wells Fargo Bank, NA Plaintiff v. Renee G. Foley Defendant CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-93 AFFIDAVIT OF SERVICE The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 31st day of July, 2014, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129.1 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEFORE ME THIS \ DAY OF. , 2014 TARY PUBLIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL TERRENCE BRATHWAITE, Notary Public City of Philadelphia, Phila. County MCommission Expires June 12, 2018 McCABE, WEI BY: ERG & CONWAY, P.C. [ ] Terrence J. McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff c S. Weisberg, Esquire argaret Gairo, Esquire Heidi R. Spivak, Esquire Christine L. Graham, Esquire Ann E. Swartz, Esquire Joseph I. Foley, Esquire Jennifer L. Wunder, Esquire Carol A. DiPrinzio, Esquire McCABE, WEISBERG & CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, NA Renee G. Foley Plaintiff v. Defendant Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 14-93 AFFIDAVIT PURSUANT TO RULE 3129.1 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 1413 Pheasant Drive South, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owner or Reputed Owner Name Address Renee G. Foley 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 2. Name and address of Defendant in the judgment: Name Address Renee G. Foley 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address File #77496 Page 1 Plaintiff herein 4. Name and address of the last recorded holder of every mortgage of record: Name Plaintiff herein Redevelopment Authority of the County of Cumberland Address 114 North Hanover Street Carlisle PA 17013 5. Name and address of every other person who has any record lien on the property: Name Metiance, Inc., A Pennsylvania Corporation The United Telephone Company of Pennsylvania The United Telephone Company of Pennsylvania 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Address 1884 Storrets Gap Road Carlisle, Pennsylvania 17013 152 East High Street Carlisle, Pennsylvania 17013 1824 Sterretts Cap Road Carlisle, Pennsylvania 17013 Name Address Pheasant Run Estates 6780 CARLISLE PIKE MECHANICSBURG PA 17055-0 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale Name Address Tenants/Occupants 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8th Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 File #77496 Page 2 PA Department of Revenue PA Department of Revenue Bureau of Compliance Lien Section Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance United States of America Domestic Relations Cumberland County Tax Claim Bureau Commonwealth of PA Department of Revenue United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 PO BOX 280948 Harrisburg PA 17128-0948 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 1 Courthouse Square Carlise, PA 17013 Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address None File #77496 Page 3 I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. 1 DA E McCABE, WEISBERG & CONWAY, P.C. BY: [ ] Terrence J. McCabe, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff Re: Wells Fargo Bank, NA v. Renee G. Foley. et al. Cumberland County; Number: 14-93 1 arc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. [ ] Carol A. DiPrinzio, Esq. File #77496 Page 4 McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wells Fargo Bank, NA Plaintiff v. Renee G. Foley Defendant DATE: July 31, 2014 TO: ALL PARTIES IN INTEREST AND CLAIMANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-93 NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Renee G. Foley PROPERTY: 1413 Pheasant Drive South, Carlisle, Pennsylvania 17013 IMPROVEMENTS: Residential Dwelling JUDGMENT AMOUNT: $109,464.71 The above -captioned property is scheduled to be sold pursuant to the judgment of the court caption above at the Sheriffs Sale on September 3, 2014 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY as WE ARE NOT PERMITTED TO GIVE YOU LEGAL ADVICE. Name and Address of Sender McCabe, Weisberg and Conway, P.C. 123 S. Broad St., Suite 1400 Philadelphia, PA 19109p r • ALtI7: KELLIE KELLER Checktype of mail or service: 0Recorded (International) 0CertifieDelivery I ❑ Registered 0 CODor 0 Delivery Confirmation 0 Return Receipt for Merchandise 0 Express Mail 0 Signature Confirmation 0 Insured Affix StampHere (if issued as a y',j�, certificate of mailing,'�: for additional thy, copies of this bill)i• p Postmark and Date of Receipt `.• _T„r. Vatue.> U.S.USPOSTAGE��Plrrdeyspwes r �• 02 0001.37.7494 ti w �� 4 +t. - 2014 i -_. �- 025.20° 31. 19109 $ JUL. Line Article Number Addressee Name, Street and PO Address Postage FeeHand Charles cif RisteFed I F e 1 Wells Fargo Bank, NA v. Renee G. Foley Metiance, Inc., A Pennsylvania Corporation 1884 Storrets Gap Road Carlisle, Pennsylvania 17013 2 Redevelopment Authority of the County of Cumberland 114 North Hanover Street Carlisle PA 17013 3 Pheasant Run Estates 6780 CARLISLE PIKE MECHANICSBURG PA 17055-0 4 The United Telephone Company of Pennsylvania 152 East High Street Carlisle, Pennsylvania 17013 5 The United Telephone Company of Pennsylvania 1824 Sterretts Cap Road Carlisle, Pennsylvania 17013 6 Tenants 1413 Pheasant Drive South Carlisle, Pennsylvania 17013 7 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 8 Commonwealth of Pennsylvania Inheritance Tax Office 110 North 8th Street Suite #204 Philadelphia, PA 19107 a.� o -a = 5� _;1s r` o 1 )r- h o cu 9 Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 V9i Nosy 10 Department of Public Welfare TPL Casualty Unit Estate Recovery Program Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 11 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 12 PA Department of Revenue Bureau of Compliance Lien Section PO BOX 280948 Harrisburg PA 17128-0948 13 Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Clearance Support Department 281230 Harrisburg, PA 1.7128-1230 ATTN: Sheriff's Sales 14 United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 15 Domestic Relations Cumberland County P.O. Box 320 Carlisle, PA 17013 16 Tax Claim Bureau 1 Courthouse Square Carlise, PA 17013 17 Commonwealth of PA Department of Revenue Bureau of Compliance Department 280946 Harrisburg, PA 17128-0946 Attn: Sheriffs Sales 18 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 • 19 United States of America c/o United States Attorney for the Middle District of PA Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 20 United States of America c/o Atty General of the United States U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 21 United States of America c/o Atty General of the United States U.S. Dept of Justice, Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Total Number of Pieces Listed by Sender 21 Total Number of Pieces Received at Post Office Postmaster, Per (Name of receiving employee) The full declaration of value is required on all domestic and international registered mail. Thc maxim m indemnity payable or the reconstruction of nonnegotiable documents under Express Mail document reconstruction insurance is $500 per piece subject to additional limits ions for multiple pieces lost or damages in a single catastrophic occurrence. The maximum indemnity payable on Express Mail merchandise insurance is 5500, but optional Express Mail Service merchandise is available for up to 55,000 to some, but not all countries. The maximum indemnity payable 's 525,000 for registered mail. See Domestic Mail Manual R900, 5913, and S921 for limitations of coverage on insured and COD mail. See International Mail Manual for limitations of coverage on international mail. Sp ia1 handling charges apply only to Standard Mail (A) and Standard Mail (B) parcels. PS Form 3877, August 2000 Complete by Typewriter, Ink, or Ball Point Pen Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY oppsy,-,E or ME 2,Th r � } f 0~C 31 NI 2: CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Renee G Foley Case Number 2014-93 SHERIFF'S RETURN OF SERVICE 06/16/2014 05:22 PM - Deputy Shawn Harrison, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 1413 Pheasant Drive South, Carlisle, PA 17013, Cumberland County. 06/16/2014 08:54 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Renee G Foley at 1413 Phesant Drive South, North Middleton, Carlisle, PA 17013, Cumberland County. 09/03/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013, on Wednesday, September, 3, 2014 at 10:00 a.m. He sold the same for the sum of $1.00 to Attorney Terrance McCabe, on behalf of Wells Fargo Bank, N.A., being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $1,437.79 SO ANSWERS, November 04, 2014 RONIIS' R ANDERSON, SHERIFF IV pI ' as1d' b. 5P a -196r 3/ --ids- ::) CountySu: STheriff, '}eleosoft Inc. THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square •. Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net WELLS FARGO BANK, NA' Vs. NO 14-93 Civil Term CIVIL ACTION — LAW RENEE G. FOLEY 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: $109,464:71 Interest FROM 3/4/14 - $3,310.16 AT $17.99 Atty's Comm: Atty Paid: $200.03 Plaintiff Paid: Date: 4/7/14 (Seal) L.L.: $.50 Due Prothy: $2.25 Other Costs: REQUESTING PARTY: Name: MARGARET GAIRO, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY, P.C. 123 S. BROAD STREET, SUITE 1400 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 34419 LXIII 29 CUMBERLAND LAW JOURNAL 07/18/14 Writ No. 2014-93 Civil WELLS FARGO BANK, N.A. vs. RENEE G. FOLEY Atty.: Terrance McCabe ALL THAT CERTAIN lot or tract of ground situate in North Middle- ton Township, Cumberland County, Pennsylvania, more particularly shown on a certain plan entitled . "Final Subdivision Plan of Pheasant Run Estates Phase II and Phase III for Metlanco, Inc., North Middleton Township, Cumberland County, Pennsylvania, Scale: 1" = 50' April 9, 1975, Revised: April 30, 1975, by Gerrit J. Betz Associates, Inc., Engineers and Surveyors, 6 East Main Street, Shiremanstown, Penn- sylvania, which plan is filed in Plan Book 29 at Page 7 in the Office of the Recorder of Deeds for Cumberland County. Said lot is more particularly bounded and described as follows: BEGINNING at a point on the southern right-of-way line of Pheas- ant Drive, south at the dividing line of Lot No. 45 And 46 as shown on the above referred to plan; thence by aforesaid southern right-of-way line by a curve to the left having a radius of 125.00 feet, an arc length of 53.05 feet to a point on the northern line of a recreation and green area; thence on by aforesaid line, North 83 degrees 10 minutes 21 seconds West, 202.06 feet to a point; thence by same, North 06 degrees 49 minutes 39 seconds East, 35.50 feet to a point on the southern line of Lot No. 46 as shown on above mentioned Final Subdivi- sion Plan; thence by aforesaid line, South 83 degrees 10 minutes 21 seconds East, 163.17 feet to a point, being the place of BEGINNING. Being Lot No. 45 on a final subdi- vision plan of Pheasant Run Estates Phase 1I and Phase III, recorded in Plan Book 29, Page 7. 43 TOGETHER with the right, in common with other, to pass and re- pass for ingress and egress over the roads as shown on said map from the lot herein conveyed. BEING SUBJECT TO a declara- tion of covenants recorded in Miscel- laneous Book 242, Page 834, in the Office of the Recorder of Deeds for Cumberland County. HAVING THEREON erected a brick and aluminum townhouse be- ing known as and numbered 1413 Pheasant Drive S, Carlisle, Penn- sylvania. Under and subject to any restric- tions, covenants, easements, and rights of way as of record in chain of title. Tax Parcel No. 29-17-1583-095. Being the premises that Mary R. Gibson and Katherine G. Nasser, Co - Executrices of the Last Will and Tes- tament of Lois R. Gibson, deceased, by.deed dated July 12, 2012 and re- corded August 3, 2012 as Instrument Number 201223334 in the Office of the Recorder of Deeds of Cumberland County, Pennsylvania, granted and conveyed unto Renee G. Foley. '7 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF. PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: July 11, July 18 and July 25, 2014 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. L Marie Coyne, SWORN TO AND SUBSCRIBED before me this 5 da of Jul 2014 Notary COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO.. CUMBERLAND CNTY My Commission Expires Apr 28. 2018 The Patriot -News Co' at�K�t��rive ~��ec'anicsburg,PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 thepatriogews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Amy Kotula, beinduly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 1900 Patriot Drive, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and aH have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot -News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stdckholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. 2014-93 Civil Term vs. /ELLS Atty: Terrance Mccabe . ALL THAT CERTAIN LOT OR TRACT' 0FGROUND SITUATE IN NORTH MlDDLET}N TOWNSHIP, CUMI3ERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY SHOWN ON A CERTAIN PLAN ENTITLED "FINAL " SUBDIVISION PLAN OF PHEASANT RUN ESTATES PHASE 11 AND PHASE III FOR KdEILANCO. INC.. NORTH NlDDLE3DN TOWNSHIP, CUMBERLAND 'COUNTY, PENNSYLVANIA. SCALE: l^ = 5� APRIL 9, 1975, REVISED: APRIL 30, 1975, BY GERRIT J. BETZ ASSOCIATES, INC., ENGINEERS AND SURVEYORS, 6 EAST MAIN STREET, SjoillREISTOWN, PENNSYLVANIA, WHICH PLAN --' IS FILED IN PLAN BOOK 29 AT PAGE 7 IN THE OFFICE OF THE _RECORDER OF nEF,DSMR Sworn This ad ran on the shown below: 07/13/14 07/20/14 07/27/14 bscribed befo e e this 20 day of August, 2014 A.D. N �cmmowm/sALTMop PENNSYLVANIA NOTARIAL SEAL Sheryl Mane Leggore,Notary Public P.ampderi Twp.. Cumberlandrland County My Commission Expires July 16, 2018 *aE EP., PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Wells Fargo Bank N A is the grantee the same having been sold to said grantee on the 3rd day of September A.D., 2014, under and by virtue of a writ Execution issued on the 7th day of April, A.D., 2014, out of the Court of Common Pleas of said County as of Civil Term, 2014 Number 93, at the suit of Wells Fargo Bank N A against Renee G Foley is duly recorded as Instrument Number 201430365. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this Rif ,A.D. c26/11 day of Recorder of Deeds Recorder of Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan. 2018