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HomeMy WebLinkAbout14-1000 Court of Common Pleas Civil Cover Sheet For Prothonotary Use Only: Docket No: Cumberland County I DUD • vv` The 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 papers as required by law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking S Lead Plaintiff's Name: Wells Fargo Bank, National Lead Defendant's Name: Daniel J. Troutman a/k/a Daniel E Association, as Trustee for Park Place Securities, Inc. Asset- Troutman; Tracy L. Troutman a/k/a Tracy Troutman and C Backed Pass - Through Certificates, Series 2005 -WCH1, by Occupants T its attorney-in-fact, Ocwen Loan Servicing, LLC I Dollar Amount Requested: ❑ within arbitration limits O Are money damages requested ?: ❑ Yes ® No (Check one) ® outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJ Appeal? ❑ Yes ® No A Name of Plaintiff/Appel]ant's Attorney: Bradley J. Osborne, Esquire ❑ 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 ❑ Employment Dispute: include mass tort) Discrimination S ❑ Slander /Libel /Defamation ❑ Employment Dispute: Other E ❑ Other: ❑ Zoning Board C ❑ Other: T ❑ Other: I O MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS B ❑ Toxic Waste ® Ejectment ❑ Common Law /Statutory ❑ Other: ❑ Eminent Domain /Condemnation Arbitration ❑ Ground Rent ❑ Declaratory Judgment ❑ Landlord /Tenant Dispute ❑ Mandamus ❑ Mortgage Foreclosure: Residential ❑ Non- Domestic Relations PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Restraining Order ❑ Dental Commercial ❑ Quo Warranto ❑ Legal ❑ Partition ❑ Replevin ❑ Medical ❑ Quiet Title ❑ Other: ❑ Other Professional: ❑ Other: Updated 1/1/2011 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 } { t { +t AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 Hj 1 1 7 , FEB 21 S iG: 18 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 f,(1N'3rRLANO COUNT TELEPHONE: (610)278 -6800 P ENNsYLVA N{A S & D FILE NO. 13- 044362 Wells Fargo Bank, National Association, as COURT OF COMMON PLEAS Trustee for Park Place Securities, Inc. Asset- CUMBERLAND COUNTY Backed Pass - Through Certificates, Series I (I _' DIT U t 2005 -WCH1, by its attorney -in -fact, Ocwen NO.: "I lJV Loan Servicing, LLC PLAINTIFF VS. Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a/k/a Tracy Troutman and ; Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 DEFENDANTS CIVIL ACTION EJECTMENT 21000 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 - 249 -3166 p 1 NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIEREDEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LADEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIAESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE ENFORMA ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS ENCONTRA DE SU PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE,LA CORTE TOMARA MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SINPREVIO AVISO O NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ESPEDIDO EN LA PETICION DE DEMANDA. USTED PUEDE PERDER DINERO OSUS PROPIEDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABODAGO INMEDIATAMENTE. SI NO TIENEABOGADO O S1 NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDECONSEGUIR ASISTENCIA LEGAL. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 -249 -3166 13- 044362 l SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 AMY GLASS, ESQUIRE, ATTORNEY I.D. NO. 308367 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044362 Wells Fargo Bank, National Association, as ; COURT OF COMMON PLEAS Trustee for Park Place Securities, Inc. Asset- CUMBERLAND COUNTY Backed Pass - Through Certificates, Series 2005 -WCH1, by its attorney -in -fact, Ocwen NO.: Loan Servicing, LLC PLAINTIFF VS. ' Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a/k/a Tracy Troutman and Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 DEFENDANTS CIVIL ACTION EJECTMENT Plaintiff hereby complains against Defendants as follows: 1. Plaintiff, Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCH1, by its attorney -in- fact, Ocwen Loan Servicing, LLC ( "Plaintiff'), a corporation, has an office located at c/o Ocwen Loan Servicing, LLC, 1661 Worthington Road, Suite 100, West Palm Beach, FL 33409, and is properly conducting business in the Commonwealth of Pennsylvania. 2. Defendants are Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a/k/a Tracy Troutman and Occupants ( "Defendants ") and they reside at 320 Mt. Allen Drive, Mechanicsburg, PA 17055 ( "the Premises "). . 3. The Premises, which is where the ejectment is to take place, is located at 320 Mt. Allen Drive, Mechanicsburg, PA 17055. A true and correct copy of the legal description of the Premises, is attached hereto, incorporated herein by reference, and marked as Exhibit "A." 4. The Premises were sold at Sheriffs sale by the Sheriff of Cumberland County, Pennsylvania, after due advertisement and according to law, under and by virtue of a Writ of Execution issued to satisfy a Judgment In Mortgage Foreclosure entered in the Court of Common Pleas of Cumberland County, Pennsylvania, at the suit of: Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCH1, by its attorney -in -fact, Ocwen Loan Servicing, LLC v. Daniel J. Troutman a/k/a Daniel Troutman and Tracy L. Troutman a/k/a Tracy Troutman. 5. The case number of said Judgment is: 2012 -6243 Civil Term. 6. The sale was held on: September 4, 2013. 7. Plaintiff purchased the Premises at the Sheriffs sale. 8. The Plaintiff acquired valid title to the Premises on the date of and by virtue of said Sheriffs sale. 9. Plaintiff is still the real owner of said Premises and is entitled to immediate possession of the Premises. 10. The Deed in favor Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCH1, by its attorney -in -fact, Ocwen Loan Servicing, LLC was recorded with the CUMBERLAND County Department of Records in Deed Document ID# 201334231, on October 18, 2013. 11. Said Deed is a matter of State public record and therefore, is hereby incorporated by reference herein as if fully set forth at length. A true and correct copy of the Sheriff s Deed, is attached hereto, incorporated herein by reference, and marked as Exhibit "B." 12. The persons in possession of the Premises are believed to be the Defendants in this action who are occupying the Premises without right and without claim to title. 13. Plaintiff is entitled to immediate possession of the Premises. WHEREFORE, Plaintiff demands judgment, in ejectment, for immediate possession of the Premises, issuance of a Writ of Possession and a judgment of its costs and disbursements in this action. SHAPIRO & DeNARDO, LLC Date: 2 11 ct 114 BY: ---Atto f---f-Plaintiff BBORNE, ESQUIRE File # 13- 044362 GERALD M.SHAPIRO Admitted in Illinois and Florida Only DAVID S. KREISMAN Admitted in Illinois Only SHAPIRO & DENARDO, LLC CHRIST Partner A. DeNARDO Managing Partner Admitted in Pennsylvania Only ATTORNEYS AT LAW PA Attorneys CAITLIN M. DONNELLY + 3600 Horizon Drive, Suite 150, King of Prussia, Pennsylvania 19406 AMY GLASS+ BRADLEY J. OSBORNE + Tel: (610) 278 -6800 Fax: (610) 278 -9980 NJ Attorneys RHONDI LYNN SCHWARTZ STEPHANIE L. SOONDAR + Also Licensed in New Jersey 90 DAY NOTICE PURSUANT TO PROTECTING TENANTS OF FORECLOSURE ACT PUBLIC LAW 111 -22 TO: Tenants 320 Mt. Allen Drive Mechanicsburg, PA 17055 AND ALL OTHER TENANTS IN POSSESSION: AT PREMISES KNOWN AS 320 Mt. Allen Drive Mechanicsburg, PA 17055 NOTICE IS HEREBY GIVEN, that Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset- Backed Pass - Through Certificates, Series 2005 -WCHI, by its attorney -in -fact, Ocwen Loan Servicing, LLC has purchased the above - described property at a foreclosure sale and is the record owner of the Property. NOTICE IS FURTHER GIVEN that, pursuant to the Protecting Tenants of Foreclosure Act, Public Law I 1I- 22, All Tenants are given ninety (90) day notice to vacate the premises. If you fail to vacate the premises within the ninety (90) day period, Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCH1, by its attorney -in -fact, Ocwen Loan Servicing, LLC will proceed to have an eviction and lockout scheduled to have you removed from the Property. Pursuant to Protecting Tenants of Foreclosure Act, Public Law 111 -22, if you have a pre- existing lease extending beyond ninety (90) days from the date of receipt of this notice, you may choose to deliver a bona fide lease agreement to the attorney's office listed below. If you choose to produce your lease agreement, you will be expected to pay contractual rent monthly to the Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCH1, by its attorney -in -fact, Ocwen Loan Servicing, LLC for the rest of the period of your lease agreement to the attorney's office listed below. If rent is not paid timely, Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCHI, by its attorney -in -fact, Ocwen Loan Servicing, LLC will proceed with legal action for POSSESSION. ALL TENANTS ARE REQUIRED TO DELIVER POSSESSION of the premises at the scheduled end of said lease agreement. Enclosed herewith is a copy of the recorded Deed declaring Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCHI, by its attorney -in -fact, Oewen Loan Servicing, LLC as the lawful owner of said premises. I suggest you consult an Attorney or contact the undersigned to discuss the actual date you plan to vacate the premises or submit your lease agreement pursuant to Protecting Tenants of Foreclosure Act, Public Law 111 -22. Z J � Bra 1 Osborne, Esquire Attor 0 r Purchaser Shapiro & DeNardo, LLC 3600 Horizon Drive, Suite 150 King of Prussia, PA 19406 (610)278 -6800 VERIFICATION I am Caroline Cochran, Contract Management Coordinator of Ocwen loan servicing, LLC ( "Ocwen ") the Servicing agent (or servicer) for Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 - WCH 1 ("plaintiff"), am authorized to make this verification on behalf of Ocwen and hereby certify that the facts set forth in the foregoing complaint are true and correct to the best of my knowledge, information and belief. Except where otherwise stated and/or based upon public record, this verification is based upon a review of business records regularly created, kept and maintained in the course of Ocwen's mortgage servicing business conducted on plaintiff s behalf. In making this verification, I understand that it is a crime under 18 pa C.S. Section 4904 To make a written statement to a public servant, or to invite a public servant's reliance upon a Written statement or instrument, which I do not believe to be true or which I know to be false DATE: 1 NAME: Caroline Cochran TITLE: Authorized Signer Ocwen Loan Servicing, LLC as servicer for Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass- Through Certificates, Series 2005 -WCH1 Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a%k/a Tracy Troutman and Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 File 13- 044362 BEGINNING at a point in the center of Mt. Allen Drive, said point being one 'hundred twenty- five (1255) feet in a northerly direction ;from the:intersection of the center line of Mt. Alien Drive vith the side line of Nittany Road, said point being also on:the northent Iine of Lot No. 9 on the liereinafter mentioned plan of Lots: thence along the northern line of Lot No. 9, South eighty -one (81). degrees forty -five (45) minutes West one hundred fifty. (1 S0) feet to a point, thence North eight (08) :degrees fiteen.(1.5) minutes West one hundred. (100) feet to a point on the southern line of Lot No. 7; thence along the southern line of Lot No. 7 North eighty-one (8 1) degrees forty -five (45) minutes Bast one hundred fifty (150) feet to a point on' the .center. line. ofMt. Allen Drive; South eight (08)' degrees fifteen (15) minutes East one hundred (1'00) feet .to a point; the place of BEGINNING. BEING LOT NO. 8, SectioW'V% Plan' of Mt. Allen Heights, recorded in Plan .Book "B ", Page 46. BEING the same premises which Eugene R. -Arnold,- Sr., and .Margaret A. Arnold, husband and wifc by Deed .dated October 14,2004 and recorded November 8, 2004 in the Office of the Recorder of Deeds in and for Cumberland County in.Deed Book 266 Page 652, .granted. and conveyed unto Daniel Troutman, and Tracy Troutman, husband and wife PARCEL NO.42 -28- 2423 -014 EXHIBIT A ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE ` = :.:�` CARLISLE, PA 17013 717 -240 -6370 = Instrument Number - 201334231 Recorded On 10/18/2013 At 1:42:52 PM Total Pages - 5 • Instrument Type - DEED - SHERIFF'S Invoice Number - 149634 User ID - BMM • Grantor - TROUTMAN, DANIEL Grantee - WELLS FARGO BK N A * Customer - SHERIFF * FEES STATE WRIT TAX $0.50 Certification Page STATE JCS /ACCESS TO $23.50 JUSTICE DO NOT DETACH RECORDING FEES - $13.00 RECORDER OF DEEDS PARCEL CERTIFICATION $15 This page i s now part FEES of this legal document. AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 MECHANICSBURG SCHOOL $0.00 DISTRICT UPPER ALLEN TOWNSHIP $0.00 TOTAL PAID $68.50 1 Certify this to be recorded in Cumberland County PA r,�a og a / ° RECORDER ° O D EDS f ' - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 0032YS !11!!I!!!llll!! Ill1!!I ii[ gib' 1032YS Tax Parcel No, 42 -2$- 2423 -014 Know all Men by these Presents That I, Ronny R. Anderson, Sheriff of the County of Cumberland, In the State of Pennsylvania, for and in consideration of the sum of $1.00 (One Dollar) to me in hand paid, do hereby grant and convey to Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCHI 2012 -6243 Civil Term Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCHI, by its attorney -in -fact, Oewen Loan Servicing, LLC Vs Daniel J. Troutman, a /k/a Daniel Troutman Tracy L. Troutman, a /k/a Tracy Troutman BEGINNING at a point in the center of Mt. Allen Drive, said point being one hundred twenty - five (125) feet in a northerly direction from the intersection of the center line of Mt. Allen Drive with the side line of Nittany Road, said point being also on the northern line of Lot No. 9 on the hereinafter mentioned plan of Lots: thence along the northern line of Lot No. 9, South eighty -one (8 1) degrees forty -five (45) minutes West one hundred fifty (150) feet to a point, thence North eight (08) degrees fifteen (15) minutes West one hundred. (100) feet to a point on the southern line of Lot No. 7; thence along the southern line of Lot No. 7 North eighty -one (81) degrees forty -five (45) minutes East one hundred fifty (150) feet to a point on the center line of Mt. Allen Drive; South eight (08) degrees fifteen (15) minutes East one hundred (100) feet to a point; the place of BEGINNING. BEING LOT NO. 8, Section `B ", Plan of Mt. Allen Heights, recorded in Plan Book `B ", Page 46. BEING the same premises which Eugene R. Arnold, Sr., and Margaret A. Arnold, husband and wife, by Deed dated October 14, 2004 and recorded November 8, 2004 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 266 Page 652, granted and conveyed unto Daniel Troutman, and Tracy Troutman, husband and wife PARCEL NO. 42-28-2423-014 The same having been sold by me to the said grantee on the 4th day of September Anno Domini Two Thousand and Thirteen (2013) after due advertisement according to law, under and by Virtue of a Writ of Execution issued on the 31 of January Anno Domini 2013 out of the Court of Common Pleas of Cumberland County, Pennsylvania, as of Civil Term, Two Thousand and Twelve (2012) Number 6243 at the suit of Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCHI, by its attorney -in -fact, Ocwen Loan Servicing, LLC vs- Daniel J. Troutman, a /k/a Daniel Troutman and A Tracy L. Troutman, a/k/a Tracy Troutman In Witness Whereof, I have hereunto affixed my signature this 27th day of September Anno Domini Two Thousand and Thirteen (2013) nny An erson, Sheriff Commonwealth of Pennsylvania, ss. County of Cumberland Before the undersigned, David D. Buell, Prothonotary of the Court of Common Pleas of Cumberland County, Pennsylvania, personally appeared Ronny R. Anderson, Sheriff of Cumberland County aforesaid, and in due form of law declared that the facts Set forth in the foregoing Deed are true, and that he acknowledged the same in order that Said deed might be recorded. Witness my hand and seal of said Court, this 2 7th day Of September Anno Domini Two Thousand and Thirteen (2013) Ls OT Pr thonotary, A AV- ry r.J •�Sn•'r,�l•- n mow+» prothonotary, Cumberland County, Carlisle, pA �= My Commission Expires the first Monday o�jan *4 I hereby certify that the residence 'r ^ -_• " = And Post Office address of the ` "J 4 Within Grantee is c/o Ocwen 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 Richard W. Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson -, j. Sheriff HE:Pt;O"r � ��y tr of qtr i t_;jr a I,'` . Jody S Smith ' n Chief Deputy c3/4 MAR —7 AM IU. 20 Richard W Stewart CUMBERLAND CU Solicitor r s w Fm PENNSYLVANIA T Wells Fargo Bank Case Number vs. Daniel J Troutman 2014-1000 SHERIFF'S RETURN OF SERVICE 02/26/2014 07:57 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint in Ejectment by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Occupant at 320 Mount Allen Drive, Upper Allen Township, Mechanicsburg, PA 17055. 16_11_ C I�.J4-t1Y1'1 DAWN KELL, DEPUTY 02/26/2014 07:57 PM- Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint in Ejectment by"personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Tracy L Troutman at 320 Mount Allen Drive, Upper Allen Township, Mechanicsburg, PA 17055. �CLtdYY1 � �� DAWN KELL, DEPUTY 02/26/2014 07:57 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint in Ejectment by handing a true copy to a person representing themselves to be Tracy L Troutman, Wife, who accepted as"Adult Person in Charge"for Daniel J Troutman at 320 Mount Allen Drive, Upper Allen Township, Mechanicsburg, PA 17055. kat. DAWN KELL, DEPUTY SHERIFF COST: $71.30 SO ANSWERS, February 28, 2014 RON R ANDERSON, SHERIFF u ,rF,u c c. SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY ID. NO. 312169 0„cliur, CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044362 Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset- Backed Pass-Through Certificates, Series 2005-WCHI PLAINTIFF VS. Daniel J. Troutman a/k/a Daniel Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Tracy L. Troutman a/k/a Tracy Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 DEFENDANTS 261t4 APR IL AM 9:52 i.,UMBERL AND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2014-01000 PRAECIPE FOR JUDGMENT FOR POSSESSION FOR FAILURE TO ANSWER Enter Judgment for immediate possession of the Premises located at: 320 Mt. Allen Drive, Mechanicsburg, PA 17055, in favor of Plaintiff and against the Defendants above captioned for failure to file an answer to Plaintiffs Complaint within 20 days from service of the Complaint. Date: BY: SHAPIRO & DeNARDO, LLC AND NOW, judgment for immediate possession Mechanicsburg, PA 17055 is entered in favor of the Plain ed at 320 efend Allen Drive, cu' 11,66pixi Loc(oF)g, R4I ?() Li 385 Nryk.to IiiJ SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044362 Wells Fargo Bank, National Association, as COURT OF COMMON PLEAS Trustee for Park Place Securities, Inc. Asset- CUMBERLAND COUNTY Backed Pass-Through Certificates, Series 2005-WCH1 NO: 2014-01000 PLAINTIFF VS. Daniel J. Troutman afk/a Daniel Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Tracy L. Troutman a/k/a Tracy Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the attached papers on to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Daniel J. Troutman a/k/a Daniel Troutman, 320 Mt. Allen Drive, Mechanicsburg, PA 17055 Tracy L. Troutman a/k/a Tracy Troutman, 320 Mt. Allen Drive, Mechanicsburg, PA 17055 Occupants, 320 Mt. Allen Drive, Mechanicsburg, PA 17055 Date: BY: SHAPIRO & DeNARDO, LLC Atsys for Plaintiff L OSBORNE, ESQUMB SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044362 Wells Fargo Bank, National Association, as COURT OF COMMON PLEAS Trustee for Park Place Securities, Inc. Asset- CUMBERLAND COUNTY Backed Pass - Through Certificates, Series 2005 -WCH1 NO: 2014 -01000 1661 Worthington Road, Suite 100 P.O. Box 24737 West Palm Beach, Florida 33409 PLAINTIFF VS. Daniel J. Troutman alk/a Daniel Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Tracy L. Troutman a/k/a Tracy Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 DEFENDANTS CERTIFICATION OF ADDRESS I hereby certify that the correct addresses of the judgment creditor (Plaintiff) and that the last known address of the judgment Debtors (Defendants) are as above. Date: 'i`'-I j'-i BY: SHAPIRO & DeNARDO, LLC At e s for Plaintiff J. OSBORNE, ESQUIRE SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044362 Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCH1, by its attorney -in -fact, Ocwen 2014 -01000 Loan Servicing, LLC 1661 Worthington Road, Suite 100 West Palm Beach, FL 33409 PLAINTIFF VS. Daniel J. Troutman a/k /a Daniel Troutman and Tracy L. Troutman a/k/a Tracy Troutman DEFENDANT(S) COURT OF COMMON PLEAS CUMBERLAND COUNTY STATE OF: Pennsylvania COUNTY OF: Cumberland AFFIDAVIT OF NON - MILITARY SERVICE THE UNDERSIGNED being duly sworn, states that he /she is over the age of eighteen years and competent to make this affidavit and the following averments are based upon information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that the above captioned Defendants last known address is as set forth in the caption and they are not to the best of our knowledge, information or belief, in the Military or Naval Service of the United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of 1940, as amended. Date: `//t Sworn to and subsc before me this of r:ibed No day 2014. BY: SHAP .b'! & DeNARDO, LLC ,' A y s for Plaintiff " ?J. OSBORNE, ESQUIRE COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer M. Sharkey, Notary Public Upper Merlon Twp., Montgomery County My Commission Expires Oct. 19, 2014 Member, Pennsylvania Association of Notaries SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY l.D. NO.311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO.312169 CHANDRA M. ARKEMA, ATTORNEY 1.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044362 Wells Fargo Bank, National Association, as COURT OF COMMON PLEAS Trustee for Park Place Securities, Inc. Asset- CIVIL DIVISION Backed Pass - Through Certificates, Series 2005- CUMBERLAND COUNTY WCH 1 PLAINTIFF NO: 2014 -01000 VS. Daniel J. Troutman a/Ida Daniel Troutman, Tracy L. Troutman a/k/a Tracy Troutman and Occupants DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Daniel J. Troutman a/k/a Daniel Troutman DATE OF NOTICE: March 19, 2014 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 -249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICAC1ON IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER TOMADO LA ACCION REQU1RIDA DE SU PARTE EN ESTE CASO. AL NO TON,1AR LA ACCION DEB1DA DENTRO DE UN TERMINO DE DIEZ (10). DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNA PODRA. SIN NECESIDAD DE COMPARARECER USTED awn:: 0 ESCUCHAR PREUBA ALGUNA, DICTAR SENTENCIA EN SU CONTRA. USTED PUEDE, PERDER. BIENES V OTROS DERECHOS IMPORTANTES, DEI3E LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE. Si USTED NO TIENE ABOGADO 0 SI NO TIENE DINERO SUFICIENTE PARA TAL,SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA AI3AJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITENCI A LEGAL: Cumberland County Lawyer Referral Service Cumberland:County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO Ti E FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Daniel Troutman a/k/a Daniel Trautman, 320 Mt. Allen Drive, Mechanicsburg,.PA 17055 Tracy L. Troutman .a/Ida Tracy Troutman, 320 Mt. Allen Drive, Mechanicsburg, PA 17055 Occupants. 320 Mt. Allen Drive, Mechanicsburg. PA 17055 SHAPIRO & DeNARDO. LIE Date: BY: Al r cys for Plaintif SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO.311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044362 Wells Fargo Bank, National Association, as COURT OF COMMON PLEAS Trustee for Park Place Securities, Inc. Asset- CIVIL DIVISION Backed Pass - Through Certificates, Series 2005- CUMBERLAND COUNTY WCH I PLAINTIFF NO 2014 -01000 VS, Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a/k/a Tracy Troutman and Occupants DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Tracy L. Troutman a/k/a Tracy Troutman DATE OF NOTICE: March 19, 2014 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717- 249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REI3ELDIA POR NO HABER TOMADO LA ACCION REQU1RIDA DE SU PARTE EN ESTE CASO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE UN TERMING DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNA PODRA, SIN NECESIDAD DE CONIPARARECER USTED IN CORTE 0 ESCUCHAR PREUBA A LGUNA, DICTAR SE.NTENCIA F.N SU CONTRA. USTED PUEDE. PERDER BIENES Y OTROS DERECHOS IMPORTANTES. DEB LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE. Si USTED NO TIENE A BOGADO 051 NO TIENE DINER° SUFICIENTE PARA TAL SERVICIO, VA YA EN PERSONA 0 LLAME. POR TELEFONO A LA OFICINA CUYA DIRECCIONSE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASSITENCIA LEGAL: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1 NOTICE SENT TO: Daniel J. Troutman a/k/a Daniel Troutman. 320 Mt. Allen Drive, Mechanicsburg, PA 17055 Tracy L. Troutman. a/k/a Tracy Troutman, 320 Mt. Allen Drive. Mechanicsburg, PA 17055 Occupants, 320 Mt. Allen Drive, Mechanicsburg, PA 17055 SHAPIRO & DeNARDO, LLC Date: BY: A Plaintiff La/v.14..6y' J. OSBOANE, ESQUIRB SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO.311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO.312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044362 Wells Fargo Bank, National Association, as COURT OF COMMON PLEAS Trustee for Park Place Securities, Inc. Asset- CIVIL DIVISION Backed Pass - Through Certificates, Series 2005- CUMBERLAND COUNTY WCH l PLAINTIFF NO: 2014 -01000 VS. Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a/k/a Tracy Troutman and Occupants DEFENDANTS NOTICE OF INTENTION TO TAKE DEFAULT UNDER Pa.R.C.P. 237.1 IMPORTANT NOTICE TO: Occupants DATE OF NOTICE: March 19, 2014 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717 -249 -3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTIFICACION impoRTANTE USTED SE ENCUENTRA EN ESTADO DE, REBELDIA POR NO HABER TOMADO LA ACCION REQUIRI DA DE SU PARTE EN ESTE CASO. Al.. NO TOMAR LA ACCION DEBIDA DENTRO DE, UN TERMINO DE DIEZ (.10) DIAS DE LA FECHA DE ESTA NOTIFICACION ,,EL TR1BUNA PODRA, SIN NECE.'SIDAD•DE COMPARARECER USTED IN CORTE 0 ESCUCHAR PREUI3A A LGUNA, .DICTA.R SENTENCI A EN SO CONTRA. USTED PUEDF: PERDER BIENES Y OTROS DERECHOS IMPORTANTES. DEBE LLEVAR ESTA NOTIFICACION A UN ABOGADO IMMEDIATAMENTE. Si USTED NO TIENE ABOGADO 0 S.I NO TIENE DINERO SUFICIENTE PARA TAL SERVICIO, VA VA EN PERSONA 0 LLAN1E POR TELEFONO A LA OFICINA CUYA DIRECCION SE 'ENCUENTRA ESCRITA ABAJOPARA A VER IGUAR DONDE SE PUEDE CONSEGUIR A SSITENCIA LEGAL: Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTLNG TO COLLECT A DEBT, ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. PERSONS TO WHOM RULE 237.1. NOTICE SENT TO: Daniel J. Troutman a/kfa Daniel Troutman. 320 Mt Allen Drive, Mechanicsburg, PA 17055 Tracy L. Troutmarvaik/a Tracy Trothinan 320 Mt, Allen Drive, Mechanicsburg, PA 17055 Occupants, 320 Mt. Allen Drive, Mcchanicsburtl, PA 17055 SHAP IR° & DeNARDO, LLC Date: -3 '44 BY: r Plaintiff . OSBOAZNE, ESQUIRE SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278 -6800 S & D FILE NO. 13- 044362 Wells Fargo Bank, National Association, as COURT OF COMMON PLEAS Trustee for Park Place Securities, Inc. Asset- CIVIL DIVISION Backed Pass - Through Certificates, Series CUMBERLAND COUNTY 2005 -WCH1 PLAINTIFF NO: 2014 -01000 VS. Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a/k/a Tracy Troutman and Occupants DEFENDANTS CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1 The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of record, if any, after the default occurred and at least (10) days prior to the date of the filing of the Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto, March 19, 2014, to: Daniel J. Troutman a/k/a Daniel Troutman, 320 Mt. Allen Drive, Mechanicsburg, PA 17055 Tracy L. Troutman a/lc/a Tracy Troutman, 320 Mt. Allen Drive, Mechanicsburg, PA 17055 Occupants, 320 Mt. Allen Drive, Mechanicsburg, PA 17055 Tiffany Donnell, Legal Assistant SHAPIRO & DeNARDO, LLC OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS David D. Buell, Prothonotary TO: Daniel J. Troutman a/k/a Daniel Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCH1 PLAINTIFF VS. Daniel J. Troutman a/k/a Daniel Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Tracy L. Troutman a/k/a Tracy Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2014 -01000 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default [XX] Judgment for Possession IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BRADLEY J OSBORNE BY CALLING (610)278 -6800 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS David D. Buell, Prothonotary TO: Tracy L. Troutman a/k/a Tracy Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass - Through Certificates, Series 2005 -WCH1 PLAINTIFF VS. Daniel J. Troutman a/k/a Daniel Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Tracy L. Troutman a/k/a Tracy Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2014 -01000 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default [XX] Judgment for Possession IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BRADLEY J OSBORNE BY CALLING (610)278 -6800 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS David D. Buell, Prothonotary TO: Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset- Backed Pass-Through Certificates, Series 2005-WCH1 PLAINTIFF VS. Daniel J. Troutman a/k/a Daniel Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Tracy L. Troutman a/k/a Tracy Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 DEFENDANTS COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2014-01000 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. David D. Buell Prothonotary [XX] Judgment by Default [XX] Judgment for Possession IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY BRADLEY J OSBORNE BY CALLING (610)278-6800 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044362 Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset- Backed Pass-Through Certificates, Series 2005-WCH1 PLAINTIFF VS. Daniel J. Troutman a/k/a Daniel Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Tracy L. Troutman a/k/a Tracy Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Occupants 320 Mt. Allen Drive Mechanicsburg, PA 17055 DEFENDANTS I.D. NO. 78447 311403 ;.• _ THJNO% 2014 APR / AN 9: 52 CUMBERL A ND COUNT)/ PEN,',ISYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 2014-01000 PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Kindly issue a Writ of Possession in the above matter for property located at 320 Mt. Allen Drive, Mechanicsburg, PA 17055 as more fully described in the Complaint. (Costs to be added) Date: 00),Qc- k. ID CAg to LL k9 sp BY: 'rsTht4 C/k-41 14 61 Zbur- (c) SHAPIRO & DeNARDO, LLC s for Plainti L OSBORNE, ESQUIRE lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160 -3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NATIONAL ASSOCIATION, AS TRUSTEE FOR PARK PLACE SECURITIES, INC. ASSET - BACKED PASS - THROUGH CERTIFICATES, SERIES 2005 - WCH1 VS. No. 14 -1000 Civil Term DANIEL J. TROUTMAN a/k/a DANIEL TROUTMAN, TRACY L. TROUTMAN a/k/a TRACY TROUTMAN AND OCCUPANTS 320 MT. ALLEN DRIVE MECHANICSBURG, PA 17055 Costs Attorney's $ 220.05 Plaintiff's $ Prothonotary $ 2.25 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) WELLS FARGO BANK, NATIONAL ASSOCIATION, AS TRUSTEE FOR PARK PLACE SECURITIES, INC. ASSET - BACKED PASS - THROUGH CERTIFICATES, SERIES 2005 - WCH1 being: (Premises as follows): 320 MT. ALLEN DRIVE, MECHANICSBURG, PA 17055 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his /her (or their) interest therein. A,i/__/i Da id D. Buell, Prothonotary, Common Pleas Court of Cumberland County, PA Date 4/14/2014 2 of 2 No 14 -1000 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NATIONAL ASSOCIATION, AS TRUSTEE FOR PARK PLACE SECURITIES, INC. ASSET - BACKED PASS - THROUGH CERTIFICATES, SERIES 2005 -WCH1 VS. DANIEL J. TROUTMAN a/k/a DANIEL TROUTMAN, TRACY L. TROUTMAN a/k/a TRACY TROUTMAN AND OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160 -3165 ETC. Costs Att'y $ 220.05 P1ff (s) $ Prothy $ 2.25 Sheriff $ Plaintiff (s) attorney name and address: BRADLEY J. OSBORNE, ESQUIRE SHAPIRO & DENARDO, LLC 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the day of , . I caused the within named , to have possession of the premises described with the appurtenances, and Sworn and subscribed to before me this Day of So Answers, Sheriff By Prothonotary Deputy SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044362 Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass -Through Certificates, Series 2005-WCH1 PLAINTIFF VS. Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a/k/a Tracy Troutman and Occupants DEFENDANTS loff');, I.D. NO. 7844%r/ .1y21 311403 C Jt . P 2•/01194C6,04441 COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 2014-01000 PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly mark the Judgment entered on April 14, 2014 in the above entitled action vacated without prejudice to Plaintiff. Date: 'A\ 144 BY: SHAPIRO & DeNARDO, LLC tqk eys for Plaintiff 7:01121' J. OSBORNE, ESQUIRE avr 661SDpd a; 36(k Gln 0, SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY LI/ NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044362 Wells Fargo Bank, National Association, as COURT OF COMMON PLEAS Trustee for Park Place Securities, Inc. Asset- CIVIL DIVISION Backed Pass -Through Certificates, Series CUMBERLAND COUNTY 2005-WCH1 PLAINTIFF NO: 2014-01000 VS. Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a/Ida Tracy Troutman and Occupants DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Vacate Mortgage Foreclosure Judgment on to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Daniel J. Troutman a/k/a Daniel Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Tracy L. Troutman a/k/a Tracy Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Date: BY: SHAPIRO & DeNARDO, LLC SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY T.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044362 Wells Fargo Bank, National Association, as Trustee for Park Place Securities, Inc. Asset - Backed Pass -Through Certificates, Series 2005-WCH1 PLAINTIFF VS. Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a/k/a Tracy Troutman and Occupants DEFENDANTS 7-1-1/6. r 1-80,10}/4, Ea No. 7844' if 14 Y P11 5 311403 pE„y,,14/ yDCNO/411Ty COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO: 2014-01000 PRAECIPE TO SETTLE, DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above -captioned matter SETTLED, DISCONTINUED AND ENDED, without prejudice. Date: BY: SHAPIRO & DeNARDO, LLC neys for Plaintiff L OSBORNE, ESQUIRE .1 SHAPIRO & DeNARDO, LLC BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY LD. NO. 78447 CAITLIN M. DONNELLY, ESQUIRE, ATTORNEY I.D. NO. 311403 BRADLEY J. OSBORNE, ATTORNEY I.D. NO. 312169 CHANDRA M. ARKEMA, ATTORNEY I.D. NO. 203437 3600 HORIZON DRIVE, SUITE 150 KING OF PRUSSIA, PA 19406 TELEPHONE: (610)278-6800 S & D FILE NO. 13-044362 Wells Fargo Bank, National Association, as COURT OF COMMON PLEAS Trustee for Park Place Securities, Inc. Asset- CIVIL DIVISION Backed Pass -Through Certificates, Series CUMBERLAND COUNTY 2005-WCH1 PLAINTIFF NO: 2014-01000 VS. Daniel J. Troutman a/k/a Daniel Troutman, Tracy L. Troutman a/k/a Tracy Troutman and Occupants DEFENDANTS CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Praecipe to Settle, Discontinue and End on tA\IC\N to all parties named herein at their last known address or upon their attorney of record as below listed by regular mail, postage prepaid: Daniel J. Troutman a/k/a Daniel Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Tracy L. Troutman a/k/a Tracy Troutman 320 Mt. Allen Drive Mechanicsburg, PA 17055 Date: [5H BY: SHAPIRO & DeNARDO, LLC ✓0 Att e s for Plaintiff L ,� : -L OSBO NB, ESQUIRE