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HomeMy WebLinkAbout14-0526 Supreme Courtof Pennsylvania C ' Pleas UUr w:O COIIlIl10I1,, For Prothonotary Use Only: vll�duef heet CUMBE ' b AND . , 'J�'� County Docket No: n L �� Sys The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. S Commencement of Action: Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: WELLS FARGO BANK, N.A. Lead Defendant's Name: SUSAN E. MYERS A/K/A SUSAN T SB/M TO WACHOVIA BANK, N.A. ELAINE MYERS I Are money damages requested? El Yes 0 No Dollar Amount Requested: ❑ within arbitration limits O (Check one) ❑x outside arbitration limits N Is this a Class Action Suit? ❑Yes ❑x No Is this an MDJ Appeal? ❑ Yes ❑x No A Name of Plaintiff/Appellant's Attorney: Jonathan Lobb, Esq., Id. No.312174, Phelan Hallinan, LLP ❑ Check here if you have no attorney (are a Self- Represented [Pro Se] Litigant) Nature of:the Case ' Place an "X" to the left of the- ONE _:case category that most accurately describes::your . PRIMARY.: CASE. If you are making more.than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not S include mass tort) ❑ Employment Dispute: ❑ Slander/Libel/ Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: T j MASS TORT ❑Other: 0 ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration Br ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: El Other: ❑ Medical ❑ Other Professional: Pa.R.C.P. 205.5 Updated 01/01/2011 PF OUN PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb @phelanhallinan.com 215 -563 -7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. SB /M TO WACHOVIA BANK, N.A. CIVIL DIVISION 101 N PHILLIPS AVE ^ U SIOUX FALLS, SD 57104 -6738 NO.: Plaintiff, VS. SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS 111 RUNSON ROAD CAMP HILL, PA 17011 -2739 Defendant. CIVIL ACTION — COMPLAINT IN MORTGAGE FORECLOSURE And now comes WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK, N.A., by its attorneys, Phelan Hallinan, LLP and files this Complaint in Mortgage Foreclosure as follows: 062 -PA -V3 201b 89 C) 1. The Plaintiff is WELLS FARGO BANK, N.A. S /B/M TO WACHOVIA BANK, N.A., 101 N PHILLIPS AVE, SIOUX FALLS, SD 57104 -6738 (hereinafter "plaintiff'). 2. The Defendant, SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS, is an individual whose last known address is 111 RUNSON ROAD, CAMP HILL, PA 17011 -2739. 3. WELLS FARGO BANK, N.A. S/B /M TO WACHOVIA BANK, N.A., directly or through an agent, has possession of the Promissory Note. WELLS FARGO BANK, N.A. S /B/M TO WACHOVIA BANK, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit "A ", attached hereto and made a part hereof. 4. On or about October 19, 2007, SUSAN E. MYERS made, executed and delivered to WACHOVIA BANK, NATIONAL ASSOCIATION a Mortgage in the original principal amount of $132,961.50 on the premises described in the legal description marked Exhibit "B ", attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 200742589. 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. 6. SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS is record and real owner of the aforesaid mortgaged premises. 7. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due July 18, 2012. 062-PA-V3 8. As of January 7, 2014 the amount due and owing Plaintiff on the mortgage is as follows: The total amount due the Plaintiff on said Note through 01/07/2014 is $144,834.98 which breaks down as follows: Principal $128,294.51 Interest [Fixed] From 07/29/2012 to 01/07/2014 @7.16% $13,276.00 Pre - acceleration Late Charges $143.91 Property Inspections $28.00 Appraisals/Brokers Price Opinion $0.00 Escrow Deficit $3,092.56 Total $144,834.98 Per diem interest in the amount of $25.16681 will accrue on the principal from 01/07/2014 and thereafter in accordance with the Note. plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above - captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 10. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of 062 -PA -V3 personal liability in a bankruptcy proceeding, this action is in no way an attempt to re- establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $144,834.98, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. By: Date: Z Jo than Lobb, Esq., Id. No.312174 Attorney for Plaintiff 062 -PA -V3 Exhibit "A" $il a y S "g E$ 9 Qgg gs e ? rgf € pa Au � Ym� @e 3E 2 iy 4 Y E E ga ggg g� Sf$E 3pg s g� GE all H u ngE $eFa= 55 n�EE $ € pis s $ s� g apg ' g i g s , @ o ga y es 26 € s s a e Egg o e fr €._ 8 Z $• g SF s y lai y S� � a gSa 1 � " sB s �.. a scl @€ ,a °a "QSeeP a p §d ass @E m $ =$ a :& g Sa »s gE 94 E si �E sge:ygg _ -ag #a�ga_ vi Es = gg "..g _ jes_$9 M ® 0S��`s= ' it ', ��� 3gs a $ x�•� s n R � S � S€� ¢se$ a$ €fin a lit € � g € $� a• a a 3 ag�F'€ S A ES €° C�,;,B f g8g 8 g 3s s 5 r as E Eg g E � $�� g5g { tae s % gy @ a l l 0 1 0 02 11 j $$P I g 4 F bFs n s' 8 n B•� A n � � �. g g g gd � Zvi gg 4 O S y : n¢ �. � !� � •gaff. $ 4.a &� � p �3 X b n �• cp i $ � 35'� $ Sg.. fiBiB °8 @ fifi F g § E 7$8 $ F g.���n.F � $ d ie �iE � g � is n n � .c6 iE $ NE H IT SE t..g &fig ° P § €`E a #ff $s- € P -211 m mm-1111 �b g ¢ �A fle N @ g F € $� €FP % .� �� €��' i ' I g E �¢ P gs Lda� {s� s gg �� g $ aE ° €I E. E; 9 ' �E i L g 8 $ � Ev gn $ $ = 6$ ajaP ES jigs e' gg2 a J! `a pp p5 rT.��fi 8 pyypd g$ g5 'es c 5 E E iE f e PCs PP p V. Egg g $��g� T ESQ E g 4i$a e�� F J il_ 7 y t g €€EE 'e : €a o i l s8 ➢ 8g o36ma5aga���ts € 3�eg a ; : E nL Al g =E a �$ ICI 'I I �I I Nil wgsI €s 31 Ali 8 5 8 g � € Ali $i'� NOTICE TO BORROWER: 1. CAUTION: IT IS IMPORTANTTHAT THE BORROWER THOROUGHLYREADS THIS NOTE BEFORE THE BORROWER SIGNS IT. 2 THIS NOTE IS SECURED BY EITHER A FIRST OR SUBORDINATE LIEN ON REAL PROPERTY. J. THE BORROWER IS ENTITLED TO A COPY OF THIS NOTE. 4. DO NOT SIGN THIS NOTE IF IT CONTAINS ANY BLANK SPACES. S. THE BORROWER ACKNOWLEDGES RECEIPTOF A COMPLETED COPY OF THIS NOTE. EY gpn . b acelab tliv Note, I apse ualer a¢el b pa bmY ar bmi anove. eanenr� IEEAII Ea�aer My UwnMer, 6uMy, Cedbmr er Enpaur d Ink NMe ack,owkipM raedpl arW exacutlon d tM Ce• Ebner Nona. MALI ouanmr- coapnr 1 8EAtl ceanma- coapnr FOR OFFICE USE ONLY ErnAMnbnL Paikme aderd vmnan scam. ar Nenn: Tile: aaa oovn Exhibit "B" LEGAL DESCRIPTION All that certain lot or parcel of land situate in the borough of Camp Hill, County of Cumberland and State of Pennsylvania, more particularly bounded and described, as follows, to wit: BEGINNING AT A POINT at the easterly side of Runson Road, which point is two hundred thirty -eight and eighty -five one - hundredths (238.85) feet southwardly from the southeasterly corner of the intersection of Runson road and Logan Street; and which point is also at the dividing line between Lots No. 49 and 50 on the hereinafter mentioned plat of lots; thence along the last said dividing line north seventy -seven (77) degrees thirty -two (32) minutes east one hundred three and twenty -four one - hundredths (103.24) feet to a point; thence south twelve (12) degrees twenty -eight (28) minutes east seventy -three (73) feet to a point at the dividing line between lots No. 48 and 49 feet thence south seventy -seven (77) degrees thirty -two (32) minutes west one hundred three and twenty -four one - hundredths (103.24) feet to a point at the easterly side of Runson Road; thence along the easterly side of Runson Road north twelve (12) degrees twenty -eight (28) minutes east seventy -three (73) feet to a point, the place of beginning. BEING Lot No. 49 on the Revised Plan of Part of Hollywood Development, which plan is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 6, page 14. The improvements thereon being known as 111 Runson Road, Camp Hill, PA 17011. BEING the same property, which by Deed dated January 29, 1993, and recorded among the aforesaid Land Records in Book No. D36, page 197, was granted and conveyed by Susan E. Filek 930881 • Schwartz and William C. Myers and Betty C. Lowman unto William C. Myers and Susan E. Myers, the within named Grantors. CUMBERLAND COUNTY, PENNSYLVANIA: TAX ID# 01 -21- 0273 -167 PROPERTY ADDRESS: 111 RUNSON ROAD, CAMP HILL, PA 17011 -2739 PARCEL #01 -21- 0273 -167 File #: 930881 i VERIFICATION Chelsea Leigh Morgan, hereby states that he /she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action - Complaint in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. B �\ Chelsea Leigh Morgan Vice President Loan Documentation Employed by Wells Fargo Bank N.A. 01/07/2014 086 -PA -V2 FORM 1 IN THE COURT OF COMMON PLEAS WELLS FARGO BANK, N.A. SB/M TO OF CUMBERLAND COUNTY, PENNSYLVANIA WACHOVIA BANK, N.A. Plaintiff c--> s) SUSAN E. MYERS A /K/A SUSAN ELAINE --� MYERS v ' Defendant(s) VCivil p i . NOTICE OF RESIDENTIAL MORTGAGE FORECLOSi DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be a>be 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 canbe prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a Request for Conciliation Conference with the Court, which must be filed with the Coot 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 woksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation onference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: J Date nathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff ' FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: CUSTOM ER/1 11 11IMARY APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: -- Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? Mailing Address: City: State: Zit) Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Year: Amount owed: Value: Automobile #2 : Model: Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co- Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2 Id Mortgage Utilities Car Payment(s) ) Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I /We understand that I /we am /are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BEABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 930881 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff H_ PRO THONG i A „001 at Comber, Jody S Smith 2-1J I t4 FEB 19 PM 3: I D Chief Deputy Richard W Stewart CUMBERLAND COUNT`` Solicitor op,C E rt-E&i.ERIF- PENNSYLVANIA Wells Fargo Bank, N.A. vs. Case Number Susan E Myers 2014-526 SHERIFF'S RETURN OF SERVICE 02/04/2014 04:24 PM- Deputy Ronald Hoover, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Susan E Myers at 111 Runson Road, Camp Hill Borough, Camp Hill, PA 17011. RONALD HOOVER, DEPUTY SHERIFF COST: $44.95 SO ANSWERS, February 05, 2014 RONIY R ANDERSON, SHERIFF c e,sc.t 1 E, Con i?''l r. Z:1 {; JUL 3 FM 12: 2 1 CUMBERLAND OU ' `,` PENNSYLVANIA PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 Attorney for Plaintiff WELLS FARGO BANK, N.A. S/B/M TO Court of Common Pleas WACHOVIA BANK, N.A. 101 N PHILLIPS AVE Civil Division SIOUX FALLS, SD 57104-6738 No. 14 -526 -CIVIL Plaintiff v. Cumberland County SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS 111 RUNSON ROAD CAMP HILL, PA 17011-2739 Defendant MOTION TO LIFT CONCILIATION STAY Plaintiff, Wells Fargo Bank, N.A. S/B/M to Wachovia Bank, N.A. (hereinafter "Plaintiff'), by its attorney, Joseph P. Schalk, Esquire, hereby files the within Motion to Lift Conciliation Stay and in support thereof avers as follows: 1. On January 27, 2014, Plaintiff filed a Complaint in Mortgage Foreclosure against Defendants for their failure to make monthly payments of principal and interest upon their mortgage due July 18, 2012, and each month thereafter. A true and correct copy of the Complaint is attached hereto, made part hereof and marked as Exhibit "A". 930881 2. On February 4, 2014, Plaintiff completed service of the Complaint in Mortgage Foreclosure along with the Cumberland County Residential Mortgage Foreclosure Diversion Program Notice upon the Defendants. A true and correct copy of the Sheriff's Return of Service is attached hereto, made part hereof and marked as Exhibit "B". 3. Pursuant to the Cumberland County Administrative Order February 28, 2012, which created the Cumberland County Residential Mortgage Foreclosure Diversion Program, the Foreclosure action is stayed for sixty (60) days from the date of service. 4. Within 60 days after service of the complaint, the Defendant may opt into the program by filing a Request for Conciliation Conference with the Court. Upon the filing of the request, the Court will schedule a Conciliation Conference. The program provides that Defendant must contact MidPenn Legal Services within the first twenty (20) days of receipt of notice if not represented by counsel. 5. If more than sixty (60) days has elapsed since the service of Notice of Residential Mortgage Foreclosure Diversion Program and the Defendant has not opted to participate in the Diversion Program Plaintiff may petition the Court to lift the stay and remove the case from the Diversion Program. 6. Defendant has failed to opt into the Cumberland County Residential Mortgage Foreclosure Diversion Program within sixty (60) days of service. 7. Since Defendant has opted not to participate in the Diversion Program, it is appropriate for the stay to be lifted. 930881 WHEREFORE, Plaintiff respectfully requests that this matter be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program and the automatic stay be lifted. Date: 930881 BY: Respectfully submitted, PHELAN HALLINAN, LLP k, ` squire y for Plaintiff PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 JonathanLobb@phelanhallinan.com 215-563-7000 2814 JAN 27 AH 32 CUNSERL PENNS LVANIANT ATTORNEY FOR PLAINTIFF IN TRE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A. CIVIL DIVISION 101 N PHILLIPS AVE SIOUX FALLS, SD 57104-6738 NO.: 1 4-'sa(P Plaintiff, vs. SUSAN E MYERS A/K/A SUSAN ELAINE MYERS 111 RUNSON ROAD CAMP HILL, PA 17011-2739 Defendant. CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE And_ now comes WELLS FARGO BANK, N.A. SB/M TO WACHOVIA BANK, N.A., by its attorneys, Phelan Hallinan, LLP and files this Complaint in Mortgage Foreclosure as follows: PLEASE RETURN 062 -PA -V3 WOO�''tw�� cr1� VNIthm .. to be 2, t ata tA Nicopy ai recOt° ©erect filed oC�q�n�`1 s E c T I O N A s E T I O' N Cour �,t'tC_oM ani'i Pleas i iI:Cov,�,r. Sheet _ t Cii,121A�.' County For Prothonotary Use Only: Docket No: The information collected on this form is used solely for court administration purposes. This form does not ,sttp111ement or replace the /Win and service at pleadings or other )RijJels as rerlttii•ed by law or rules y) court. Commencement of Action: O Complaint 0 Writ of Summons 0 Petition 0 Transfer from Another Jurisdiction 0 Declaration of Taking Lead Plaintiff's Name: WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A. Lead Defendant's Name: SUSAN E. MYERS A/KJA SUSAN ELAINE MYERS Dollar Amount Requested: • within arbitration limits Are money damages requested? ■Yes ©No (Check one) i3 outside arbitration limits Is this a Class Action Suit? • Yes 13 No Is this an MDJ Appeal? ■ Yes 1 No Name of Plaintiff/Appellant's Attorney: Jonathan Lobb, Esq., Id. No.312174, Phelan Hallinan, LLP 0 Check here if you have nn attorney (are a Self -Represented [Pro Se] Litigant) B 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) ❑ Intentional ❑ Malicious Prosecution ❑ Motor Vehicle ❑ Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slander/Libel/ Defamation ❑ Other: MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other: PROFESSIONAL LIABILITY ❑ Dental ❑ Legal ❑ Medical ❑ Other Professional: Pa.R.C.P. 205.5 CONTRACT (do not include Judgments) ❑ Buyer Plaintiff ❑ Debt Collection: Credit Card ❑ Debt Collection: Other ❑ Employment Dispute: Discrimination ❑ Employment Dispute: Other 0 Other: REAL PROPERTY ❑ Ejectment 0 Eminent Domain/Condemnation ❑ Ground Rent ❑ Landlord/Tenant Dispute CO Mortgage Foreclosure: Residential ❑ Mortgage Foreclosure: Commercial ❑ Partition ❑ Quiet Title ❑ Other: CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections ❑ Dept. of Transportation ❑ Statutory Appeal: Other 0 Zoning Board 0 Other: MISCELLANEOUS ❑ Common Law/Statutory Arbitration ❑ Declaratory Judgment ❑ Mandamus ❑ Non -Domestic Relations Restraining Order ❑ Quo Watranto ❑ Replevin ❑ Other: Updated 01/01/2011 WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A. Plaintiff(s) vs. SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS FORM 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be aloe 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) 2439400 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 canbe prepared on your behalf. if you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangenents 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 fmancial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial woksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation onference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: nathan,Lobb, Esq., Id. No.312174 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: CUSTOMER/PRIMARY APPLICANT Borrower name(s): Property Address: City: .State: Zip: Is the property for sale? Yes ❑ No [] Listing date: Price: $, Realtor Name: 'Realtor. Phone: Borrower Occupied? Yes No ❑. Mailing Address (if different): City: Phone Numbers: Email: # of people in household:. Home: Cell: State: Zip:' Office: Other: How long?... CO -BORROWER Mailing Address: City: Phone Numbers: Email: State: Zip: Hopi ei Cell: Office: Other: # of people in household: How long? First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value; Home: $ $ Other Real Estate: $ $ Retirement Funds: $.. $. Investments: $ $ Checking: $ $ Savings: $ ,, $ Other: $ $ Automobile #1.: Model: Year: Amount owed: Value: Automobile #2: Model; Year: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: .1. Monthly Gross Monthly Net 2, Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description (not wages): I. monthly amount: 2, monthly amount: I3orrower Pay Days: Co -Borrower Pay Days Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food .........._ 2"d Mortgage .. Utilities Car Pa. ment(s) Auto Insurance Condo/Neigh. Fees Med. (not covered) Other prop. payment Cable TV Auto fuel/repairs Install. Loan Payment Child Support/Alim. Spending Money Other Expenses Day/Child Care/Tuft. 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: Phone (Office); __.. Fax: Counselor: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations:: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone; Servicing Company (Name): Phone: Contact: I/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co -Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement.(if property is currently on the market) NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BEABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 930881 PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A. CIVIL DIVISION 101 N PHILLIPS AVE SIOUX FALLS, SD 57104-6738 NO.: Plaintiff, vs. SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS 111 RUNSON ROAD CAMP HILL, PA 1 701 1-273 9 Defendant. CIVIL ACTION — COMPLAINT IN MORTGAGE FORECLOSURE And now comes WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A., by its attorneys, Phelan Hallinan, LLP and files this Complaint in Mortgage Foreclosure as follows: 062 -PA -V3 1, The Plaintiff is WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A., 101 N PHILLIPS AVE, SIOUX FALLS, SD 57104-6738 (hereinafter "plaintiff'). 2, The Defendant, SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS, is an individual whose last known address is 111 RUNSON ROAD, CAMP HILL, PA 17011-2739. 3. WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A., directly or through an agent, has possession of the Promissory Note. WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory Note is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about October 19, 2007, SUSAN E. MYERS made, executed and delivered to WACHOVIA BANK, NATIONAL ASSOCIATION a Mortgage in the original principal amount of $132,961.50 on the premises described in the legal description marked Exhibit "B", attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 200742589. 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. 6. SUSAN E. MYERS A/KJA SUSAN ELAINE MYERS is record and real owner of the aforesaid mortgaged premises. 7. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due July 18, 2012. 062 -PA -V3 8. As of January 7, 2014 the amount due and owing Plaintiff on the mortgage is as follows: The total amount due the Plaintiff on said Note through 01/07/2014 is $144,834.98 which breaks down as follows: Principal Interest [Fixed] From 07/29/2012 to 01/07/2014 @7.16% Pre -acceleration Late Charges Property Inspections Appraisals/Brokers Price Opinion Escrow Deficit $128,294.51 $13,276.00 $143.91 $28.00 $0.00 $3,092.56 Total $144,834.98 Per diem interest in the amount of $25.16681 will accrue on the principal from 01/07/2014 and thereafter in accordance with the Note. plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above -captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 10. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of 062 -PA -V3 personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $144,834.98, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. By: Date 1 I 2. Jo o than Lobb, Esq. . No 312174 Attorney for Plaintiff 062 -PA --V3 28 !I r 1 1 1 :NOTICE 10 OORROWER. t :CATJPO1t frlsndpofTA11i,Ifutnt6o0RAj3i4YitTItOROU0ILYf+EAp9 TrtiAKottne)ORChteeas cittpi paw IT 9 YHI NOTCd6.fd4sURs0 Df t?1fthNAtoi6�COR AUUO1101NATEI.IGN ON wi?ROFtRTY (WOWPItts�'lr r iOACQPY•titPotNOTE-: 44894 1111t40tvit:o0omir,pty, BLANK-'SI'ACC p�pw4r:x+�iM�••�W *rxszt 6..�wi•a+s. LEGAL DESCRIPTION All that certain lot or parcel of land situate in the borough of Camp Hill, County of Cumberland and State of Pennsylvania, more particularly bounded and described, as follows, to wit: BEGINNING AT A POINT at the easterly side of Runson Road, which point is two hundred thirty-eight and eighty-five one -hundredths (238.85) feet southwardly from the southeasterly corner of the intersection of Runson road and Logan Street; and which point is also at the dividing line between Lots No. 49 and 50 on the hereinafter mentioned plat of lots; thence along the last said dividing line north seventy-seven (77) degrees thirty-two (32) minutes east one hundred three and twenty-four one -hundredths (103.24) feet to a point; thence south twelve (12) degrees twenty-eight (28) minutes east seventy-three (73) feet to a point at the dividing line between lots No. 48 and 49 feet thence south seventy-seven (77) degrees thirty-two (32) minutes west one hundred three and twenty-four one -hundredths (103.24) feet to a point at the easterly side of Ronson Road; thence along the easterly side of Runson Road north twelve (12) degrees twenty-eight (28) minutes east seventy-three (73) feet to a point, the place of beginning. BEING Lot No. 49 on the Revised Plan of Part of Hollywood Development, which plan is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 6, page 14. The improvements thereon being known as 111 Runson Road, Camp Hill, PA 17011, BEING the same property, which by Deed dated January 29, 1993, and recorded among the aforesaid Land Records in Book No, D36, page 197, was granted and conveyed by Susan E, File ll: 930881 Schwartz and William C. Myers and Betty C. Lowman unto William C. Myers and Susan E. Myers, the within named Grantors, CUMBERLAND COUNTY, PENNSYLVANIA: TAX ID# 01-21-0273-167 PROPERTY ADDRESS: 111 RUNSON ROAD, CAMP HILL, PA 17011-2739 PARCEL #01-21-0273-167 Fila 8: 930881 VERIFICATION Chelsea Leigh Morgan, hereby states that he/she is Vice President Loan Documentation of WELLS FARGO BANK, N.A., plaintiff in this matter, that he/she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action -Complaint in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. 13Y Chelsea Leigh Morgan Vice President Loan Documentation Employed by Wells Fargo Bank N.A. 01/07/2014 086 -PA -V2 Exhibit "B" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY :L{zu-oFFIL' THE:. PROTI-IONOIAi 2014 FEB 19 FH 3: I 0 CUMBERLAND COUNTY PENNSYLVANIA 44" Wells Fargo Bank, N.A. Case Number vs. 2014-526 Susan E Myers SHERIFF'S RETURN OF SERVICE 02/04/2014 04:24 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Susan E Myers at 111 Runson Road, Camp Hill Borough, Camp Hill, PA 17011. RONALD HOOVER, DEPUTY SHERIFF COST: $44.95 SO ANSWERS, February 05, 2014 RONI4Y R ANDERSON, SHERIFF m.] PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 Attorney for Plaintiff WELLS FARGO BANK, N.A. S/B/M TO Court of Common Pleas WACHOVIA BANK, N.A. 101 N PHILLIPS AVE Civil Division SIOUX FALLS, SD 57104-6738 No. 14 -526 -CIVIL Plaintiff v. Cumberland County SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS 111 RUNSON ROAD CAMP HILL, PA 17011-2739 Defendant CERTIFICATION OF SERVICE I, Joseph P. Schalk, Esquire, certify that I caused true and correct copies of Plaintiffs Motion to Lift Conciliation Stay and proposed Order to be sent sent via first class mail to the person listed below on the date indicated: Susan E. Myers A/K/A Susan Elaine Myers 111 Runson Road Camp Hill, PA 17011-2739 Date: r)11—// 5 By. 930881 Schalk, Esquire rney for Plaintiff • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A. 101 N PHILLIPS AVE SIOUX FALLS, SD 57104-6738 Plaintiff v. Court of Common Pleas Civil Division No. 14 -526 -CIVIL Cumberland County SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS -t) 111 RUNSON ROADCAMP HILL, PA 17011-2739CD 4 Defendant > cD ORDER AND NOW, this day of 901,7 , 2014, upon consideration of Plaintiff s Motion to Lift Conciliation Stay in the above captioned matter, it is hereby ORDERED and DECREED that this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program; it is further ORDERED and DECREED that the automatic Stay is lifted and Plaintiff may proceed with its Mortgage Foreclosure Action. cc: 930881 Susan E. Myers Joseph P. Schalk, Esquire, Id. No. 91656 Attorney for Plaintiff 4 ,7‘ELAN HALL1NAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 7*(usan E. Myers AJKJ A Susan Elaine Myers 111 Runson Road Camp Hill, PA 17011-2739 ancEs) Lc, ./9/Izc 930881 PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 WELLS FARGO BANK, N.A. S/B/IVI TO WACHOVIA BANK, N.A. vs. SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS Attorney for Plaintiff : CUMBERLAND COUNTY . COURT OF COMMON PLEAS : CIVIL DIVISION : No. 14 -526 -CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above -captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS 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, as amended. (b) that defendant SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS is over 18 years of age and resides at 111 RUNSON ROAD, CAMP HILL, PA 17011-2739. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date 7/Jiy Phe F Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 930881 Department of Defense Manpower Data Center tatus Report uaut to Servicememlbers Civil. Relief Act Last Name: MYERS First Name: SUSAN Middle Name: E Active Duty Status As Of: Sep -03-2014 Results as of : Sep -03-2014 07:55:39 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA NA This response reflecis thelritlividuats aative duty status based on the Active Duty Status Dale Left Active Duly Within 367 Days of Active Duty Status Date Active Duly Start Date Active Duty End Date Status Service Component NA 1. ,NA . _ . -: r. - Nov r NA This response reflects where the individual leftactive duty`stutus 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 Status Date Order Notification Start Date Order Notification End Date Status Service Component NA " NA .* ' No" NA This response reflects whether the'individuat or hislhsr 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. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 PHELAN HALLMAN, LLP Jonathan Lobb, Esq.,,Id:,No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan:dom 215-563-7000 WELLS FARGO BANK, N A S ' WACHOVIA BANK, N.A. vs. SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS FILED -OFFICE OF THE PROTHONOTARY 20i14 SEP 10 AM 10; 14 1 CU -MERL AND COUNTY PENNSYLVANIA • Attorney for Plaintiff TO : CUMBERLAND COUNTY : COURTOr COMMON PLEAS : CIVIL DIVISION No. 14 -526 -CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO -ANSWER AND*ASSSSMENT 04DAMAdEs ' TO THE PROTHONOTARY: Kindly enter judgment in favor of the.Plaintiff aridgitist SUSAN E: MYERS A/K/A SUSAN ELAINE MYERS, Defendant(s) for failure to filetaiiAnSWer to Plaintiff's Complaint within 20 day's from service and for foreclosure and a -le of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Corritifaint' TOTAL $144,834.98 $144,834.98 I hereby certify that (1) the Defendant's last known address is 111 RUNS ON ROAD, CAMP HILL, PA 17011-2739, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date Cf 1111V J than tobb, Esq., Id. No.312 74 Attiirney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PH # 930881 PROTHONOTARY ctrivk 1,16.sopd butt 14 S3Viy 930881 12-tv Soyi /el Department of Defense Manpower Data Center Status Report Pursuant to Sendeemembers Civil Relief Act Last Name: MYERS First Name: SUSAN Middle Name: E Active Duty Status As Of: Sep -09-2014 Results as of : Sep -09-2014 12:05:17 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ,f.' ,. •• ,• r- - ="" -- .=/-e tiN NA This response reflects the Individualsactive duty status based ori -the Active lijiy Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA 1 NA , --..' .1 -- . s' : , , ' -7- 7:7 -'l4/;:;-' :. '' .3/4 NA This response reflects ere the individual left active did," status withir1'36iLlaysprececH ing thd Active Ditty Status Date IV/ 4 The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA • . L. 'No., '. NA This response reflects whether the individual or his/her unit has received tarlyablif6ation. 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. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center Status Report Pursuant to Sery cetnembers Civil Relief Act Last Name: MYERS First Name: SUSAN Middle Name: ELAINE Active Duty Status As Of: Sep -09-2014 Results as of : Sep -09-2014 12:44:22 AM SCRA 3.0 On Active Duty On Active Duty Status Dale Active Duly Start Date Active Duly End Date Status Service Component NA NAL ^ l� No 5. NA This response retests the individuate' active duty status be on the Active DutyStatus Date I Left Active Duly Within 367 Days of Active Duty Status Dale Active Duty Start Date Active Duty End Dale Status Service Component NA ' :,NA , , ... No; t'. 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 Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA -. NA , No , i" NA This response reflects whether the IndMdual orhis/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. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A. Plaintiff V. SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS Defendant(s) TO: SUSAN E. MYERS A/K/A SUSAN ELAINE 111 RUNSON ROAD 7 CAMP HILL, PA 17011-2793 DATE OF NOTICE: COURT OF COMMON PLEAS CIVIL DIVISION NO, 14 -526 -CIVIL CUMBERLAND COUNTY MYERS THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEB IEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU .MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 PH # 930881 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: Michael Dingerdissen, Esq., Id. No.317124 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (Rule of Civil Procedure No. 236) - Revised WELLS FARGO BANK, N.A. S/BIM TO WACHOVIA BANK, N.A. vs. SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS against you on CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 14 -526 -CIVIL Notice is given that a Judgment in the above captioned matter has been entered 4(Ilbll4'. By: .. If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM ISA DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. * * 930881 PRAECIPE FOR WRIT OF EXECUTION -(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Wells Fargo Bank, N.A. s/b/m to Wachovia Bank, N.A. : COURT OF COMMON PLEAS Plaintiff V. Susan E. Myers a/Ida Susan Elaine Myers Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due : CIVIL DIVISION : NO.: 14 -526 -CIVIL CUMBERLAND COUNTY $144,834.98 Interest from 09/11/2014 to Date of Sale $4,166.75 ($23.81 per diem) TOTAL Note: Please attach description of property. PH # 930881 o‘.INA Y. -rots C,$F 0 S. -1S t' kt Q) • SO $149,001.73 Ph n Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff CD CD --- F7 r— CD cp rci CD CD 41,9.9s)/A/ Ctiji7-• LI, )(1 ,31,61S TA- r310q3 Lt) 7/ _ / LEGAL DESCRIPTION All that certain lot or parcel of land situate in the borough of Camp Hill, County of Cumberland and State of Pennsylvania, more particularly bounded and described, as follows, to wit: BEGINNING AT A POINT at the easterly side of Runson Road, which point is two hundred thirty-eight and eighty-five one -hundredths (238.85) feet southwardly from the southeasterly corner of the intersection of Runson road and Logan Street; and which point is also at the dividing line between Lots No. 49 and 50 on the hereinafter mentioned plat of lots; thence along the last said dividing line north seventy-seven (77) degrees thirty-two (32) minutes east one hundred three and twenty-four one -hundredths (103.24) feet to a point; thence south twelve (12) degrees twenty-eight (28) minutes east seventy-three (73) feet to a point at the dividing line between lots No. 48 and 49 feet thence south seventy-seven (77) degrees thirty-two (32) minutes west one hundred three and twenty-four one -hundredths (103.24) feet to a point at the easterly side of Runson Road; thence along the easterly side of Runson Road north twelve (12) degrees twenty-eight (28) minutes east seventy-three (73) feet to a point, the place of beginning. BEING Lot No. 49 on the Revised Plan of Part of Hollywood Development, which plan is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 6, page 14. TITLE TO SAID PREMISES IS VESTED IN Susan E. Myers, by Deed from William C. Myers and Susan E. Myers, h/w, dated 08/19/2003, recorded 09/05/2003 in Book 259, Page 619. PREMISES BEING: 111 Runson Road, Camp Hill, PA 17011-2739 PARCEL NO. 01-21-0273-167 PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 UF L DOFFICLI THE PROTHONO 2014 SEP /0 AH 10; 4 9 CUMBERL AND COUNTY PENNS YL VA NIA Wells Fargo Bank, N.A. s/b/m to Wachovia Bank, N.A. Plaintiff V. Susan E. Myers a/k/a Susan Elaine Myers Defendant(s) CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS .• : CIVIL DIVISION : NO.: 14 -526 -CIVIL • : CUMBERLAND County The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: the mortgage is an FHA Mortgage the premises is non -owner occupied the premises is vacant Act 91 procedures have been fulfilled Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: P Ian Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 Attorney for Plaintiff Wells Fargo Bank, N.A. s/b/m to Wachovia Bank, N.A. Plaintiff V. Susan E. Myers a/k/a Susan Elaine Myers Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 14 -526 -CIVIL CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 Wells Fargo Bank, N.A. s/b/m to Wachovia Bank, N.A., Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 111 Runson Road, Camp Hill, PA 17011-2739. Name and address of Owner(s) or reputed Owner(s): Name Susan E. Myers a/k/a Susan Elaine Myers 2. Name and address of Defendant(s) in the judgment: Name Susan E. Myers a/k/a Susan Elaine Myers Address (if address cannot be reasonably ascertained, please so indicate) 111 Runson Road Camp Hill, PA 17011-2739 Address (if address cannot be reasonably ascertained, please so indicate) 111 Runson Road Camp Hill, PA 17011-2739 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 (if address cannot be reasonably ascertained, please indicate) William T. Walker William T. Walker C/O Jennifer B. Hipp, Esquire 170 Brindle Road Mechanicsburg, PA 17055 1 West Main Street Shiremanstown, PA 17011 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) MERS, as Nominee for Wilmington Finance, A Division of Aig Federal Savings Bank MERS, Inc. MERS, Inc. Wilmington Finance, A Division of Aig Federal Savings Bank PH # 930881 P.O. Box 2026 Flint, MI 48501-2026 Formerly 3300 Sw 34th Avenue Suite 101 Ocala, FL 34474 as of 12/6/10, 1901 E. Voorhees Street Suite C Danville, IL 61834 401 Plymouth Road Suite 400 Plymouth Meeting, PA 19462 r ri rri -71 - LO Wilmington Finance, A Division of Aig Federal Savings Bank C/O Interstate Title 77 East Main Street Suite #300 Westminster, MD 21157 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff hasknowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant Department of Public Welfare, TPL Casualty Unit, Estate Recovery Program 111 Runson Road Camp Hill, PA 17011-2739 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 PA Department of Revenue Bureau of Individual P.O. Box 280601 Taxes Inheritance Tax Division Harrisburg, PA 17128-0601 Homeq Servicing 1661 Worthington Road Suite 100 West Palm Beach, FL 33409 Homeq Servicing P.O. Box 13309 Mail Code #CA3501 Sacramento, CA 95813 MERS, as Nominee for Homeq Servicing P.O. Box 2026 Flint, MI 48501-2026 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle, PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg, PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 PH # 930881 • Wells Fargo Bank, N.A. s/b/m to Wachovia Bank, N.A. vs. Susan E. Myers a/k/a Susan Elaine Myers : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION : NO.: 14 -526 -CIVIL Defendant(s) : CUMBERLAND County NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Susan E. Myers a/k/a Susan Elaine Myers 111 Runson Road Camp Hill, PA 17011-2739 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 111 Runson Road, Camp Hill, PA 17011-2739 is scheduled to be sold at the Sheriffs Sale on 03/04/2015 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $144,834.98 obtained by Wells Fargo Bank, N.A. s/b/m to Wachovia Bank, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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: -117 n1cu rri r -- (z) CD2. -71 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, cos arrld reasonable attorney's fees due. To find out how much you must pay, you may call: 215 -56S -100075230;i' c 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. 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 notice on page two 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 Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 in the sale. To find out if this has happened, you may call 215-563-7000. 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 the 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 house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution No. 14 -526 -CIVIL Wells Fargo Bank, N.A. s/b/m to Wachovia Bank, NA. V. Susan E. Myers a/k/a Susan Elaine Myers owner(s) of property situate in CAMP HILL BOROUGH, CUMBERLAND County, Pennsylvania, being 111 Runson Road, Camp Hill, PA 17011-2739 Parcel No. 01-21-0273-167 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $144,834.98 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION All that certain lot or parcel of land situate in the borough of Camp Hill, County of Cumberland and State of Pennsylvania, more particularly bounded and described, as follows, to wit: BEGINNING AT A POINT at the easterly side of Runson Road, which point is two hundred thirty-eight and eighty-five one -hundredths (238.85) feet southwardly from the southeasterly corner of the intersection of Runson road and Logan Street; and which point is also at the dividing line between Lots No. 49 and 50 on the hereinafter mentioned plat of lots; thence along the last said dividing line north seventy-seven (77) degrees thirty-two (32) minutes east one hundred three and twenty-four one -hundredths (103.24) feet to a point; thence south twelve (12) degrees twenty-eight (28) minutes east seventy-three (73) feet to a point at the dividing line between lots No. 48 and 49 feet thence south seventy-seven (77) degrees thirty-two (32) minutes west one hundred three and twenty-four one -hundredths (103.24) feet to a point at the easterly side of Runson Road; thence along the easterly side of Runson Road north twelve (12) degrees twenty-eight (28) minutes east seventy-three (73) feet to a point, the place of beginning. BEING Lot No. 49 on the Revised Plan of Part of Hollywood Development, which plan is recorded in the Cumberland County Recorder of Deeds Office in Plan Book 6, page 14. TITLE TO SAID PREMISES IS VESTED IN Susan E. Myers, by Deed from William C. Myers and Susan E. Myers, h/w, dated 08/19/2003, recorded 09/05/2003 in Book 259, Page 619. PREMISES BEING: 111 Runson Road, Camp Hill, PA 17011-2739 PARCEL NO. 01-21-0273-167 THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suitel00 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net WELLS FARGO BANK, N.A. s/b/m to WACHOVIA BANK, N.A. Vs. NO 14-526 Civil Term CIVIL ACTION — LAW SUSAN E. MYERS a/k/a SUSAN ELAINE MYERS 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: $144,834.9.8 L.L.: $.50 Interest FROM 9/11/2014 TO DATE OF SALE ($23.81 PER DIEM) - $4,166.75 Atty's Comm: Atty Paid: $193.70 Plaintiff Paid: Date: 9/10/2014 (Seal) REQUESTING PARTY: Name: JONATHAN LOBB,ESQUIRE Address: PHELAN HALLINAN, LLP 1617 JFK BLVD., SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 312174 Due Prothy: $2.25 Other Costs: -1,24.4L.L1 David D. Bue 1, Prothonotary Deputy AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNT_ Y " WELLS FARGO BANK, N.A. S/B/M TO WACHOVIA BANK, N.A. Ttl, {_'�'t if ( DEFENDANT SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS SERVE SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS AT: 111 RUNSON ROAD CAMP HILL, PA 17011-2739 PH # 930881 �t P� SERVICE TEAM/',lxi �,EC 30 All 9: 9 COURT NO.: 14=526 -CIVIL TYPE OFACTIONtlBE LA1,10 cOU'AT i XX Notice of Sheriff'r " cJ Y C SALE DATE: March 4, 2015 SERVED Served and made known to SUSAN E. MYERS A/K/A SUSAN ELAINE MYERS, Defendant on the - ' day of ,2011_1-, at ✓�: 40 , o clock. M. at ► f ► Rt.; MON Pb , e4,14 1 Ll, rit the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is _ Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other. Description: Age 40 S Height 5 5 „ Weight l ¢ d Race _ W Sex r Other Ronald Moit , a competent adult, hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: /4 6 (1(t NAME: PRINTED NAME: Ronald Moll TTILE: Process Server NOT SERVED On the day of20 at o'clock _. M., I, , a competent adult hereby state that Defendant NOT FOUND of, _ Vacant — Does Not Exist _ Moved Does Not Reside (Not Vacant) _ No Answer on at at _ Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 (215) 563-7000 No g.41 642.