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Home My WebLink About14-1396 Supreme Court�of Pennsylvania Cou . i Com �; f Pleas ,m.l.o �\eyxp .\ *1:: F : a ",:=1.)'et dttonotg**b' y C' tt ` County Spy The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. ;,0 ' Commencement of Action: r �x t ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking 1 Lead Plaintiff's Name: Wells Fargo Financial Pennsylvania,Inc. Lead Defendant's Name: Tracy L. Spadafore 4-- Are money damages requested?: ❑Yes ® No Dollar Amount Requested: within arbitration limits (Check one) x outside arbitration limits �, Is this a Class Action Suit? ❑Yes ® No Is this an MDJ Appeal? ❑Yes ® No Name of PlaintiffYAppellant's Attorney: Scott A.Dietterick,Esq.do Zucker,Goldberg&Ackerman,LLC ❑ Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant) o Nature..of the"Case Place aft"X"to the left of the QNE,case category that most accurately describes your 'R; I'`C4 S .If you are''Making more one type of claim,cheek the one that _ _ . you cons der° ost imps tant. - , 0 4 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 w ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other n ❑ Product Liability(does not include mass tort) ❑ Employment Dispute: . ❑ Slander/Libel/Defamation Discrimination , ❑ Other: ❑ Employment Dispute: Other a ❑ Zoning Board .4. ❑ Other: MASS TORT ❑ Other: ❑ Asbestos - ' ❑ Tobacco i ❑ Toxic Tort-DES 3 ❑ Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste 4 ❑ Other: ❑ Ejectment ❑ Common Law/Statutory Arbitration M ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ® ❑ Landlord/Tenant Dispute 0 Relations ,; ® Mortgage Foreclosure:Residential Restraining Order � PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure:Commercial 0 Quo Warranto ❑ Dental ❑ Partition ❑ Replevin A, ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/11/2011 • IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO FINANCIAL PENNSYLVANIA, INC., CIVIL DIVISION , Plaintiff, NO )(-4_4 Jci Vs. mow, i� TYPE OF PLEADING __M Tracy L.Spadafore;Sandra N.Spadafore; CIVIL ACTION -COMPLAINT �, `'_ Defendants. IN MORTGAGE FORECLOSURE = ` y} C TO: DEFENDANTS FILED ON BEHALF OF: YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY(20)DAYS Wells Fargo Financial Pennsylvania, Inc.. FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. COUNSEL OF RECORD FOR THIS PARTY: I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: ZUCKER,GOLDBERG &ACKERMAN, LLC c/o Wells Fargo Bank,NA,3476 Stateview Blvd. Ft.Mill,SC 29715 Scott A. Dietterick, Esquire- Pa. I.D.#55650 AND THE DEFENDANT: Kimberly A. Bonner, Esquire- Pa. I.D.#89705 115 Mountain View Drive Joel A.Ackerman, Esquire-Pa I.D.#202729 Enola,PA 17025 Ashleigh Levy Marin, Esquire- Pa I.D.#306799 Ralph M.Salvia, Esquire-Pa I.D.#202946 CERTIFICATE OF LOCATION Jaime R.Ackerman, Esquire- Pa I.D.#311032 I HEREBY CERTIFY THAT THE LOCATION OF Jana Fridfinnsdottir, Esquire- Pa I.D.#315944 THE REAL ESTATE AFFECTED BY THIS LIEN IS Brian Nicholas, Esquire-Pa I.D.#317240 115 Mountain View Drive,Enola PA 17025 Denise Carlon, Esquire- Pa I.D.#317226 Municipality: East Pennsboro A. A 200 Sheffield Street,Suite 101 ATT:NE�•R 'LAINTIFF Mountainside, NJ 07092 (908)233-8500 ATTY FILE NO.:XCP 158555 (908)233-1390 FAX office@zuckergoldberg.com File No.:XCP- 158555/mme atrt)A-- I a4 � LQ 'sae) IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY(30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY(30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Financial Pennsylvania, Inc. CIVIL DIVISION • Plaintiff, vs. NO.: Tracy L.Spadafore;Sandra N.Spadafore; • • Defendants. • • NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty(20)days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 5. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800)990-9108 Phone (800)990-9108 (717) 249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Financial Pennsylvania, Inc. CIVIL DIVISION Plaintiff, •vs. . NO.. Tracy L.Spadafore;Sandra N.Spadafore; • Defendants. • • AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamacion o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR UNO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800)990-9108 Phone (800) 990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Financial Pennsylvania, Inc. ▪ CIVIL DIVISION • c/o Wells Fargo Bank, NA. 3476 Stateview Blvd. ▪ NO.: • Ft. Mill,SC 29715. Plaintiff, • • vs. Tracy L.Spadafore • 115 Mountain View Drive Enola, PA 17025; Sandra N.Spadafore 115 Mountain View Drive Enola, PA 17025; Defendants. CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Financial Pennsylvania, Inc., by its attorneys,Zucker,Goldberg& Ackerman, LLC,and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Financial Pennsylvania, Inc., (hereinafter "plaintiff") c/o Wells Fargo Bank, NA,with its place of business located at 3476 Stateview Blvd., Ft. Mill,SC 29715. 2. The Defendant, Tracy L. Spadafore, is an individual whose last known address is 115 Mountain View Drive, Enola, PA 17025. 3. The Defendant, Sandra N. Spadafore, is an individual whose last known address is 115 Mountain View Drive, Enola, PA 17025. 4. In order to protect the borrower's privacy, certain personal information of the borrower (such as loan account, Social Security numbers and birth dates), may have been partially or completely redacted on the exhibits to this complaint. 5. Wells Fargo Financial Pennsylvania, Inc., directly or through an agent, has possession of the Promissory Note. Wells Fargo Financial Pennsylvania, Inc. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A copy of said Promissory Note is marked Exhibit A,attached hereto and made a part hereof. 6. On or about January 25, 2008,Tracy L. Spadafore, single woman made, executed and delivered to Wells Fargo Financial Pennsylvania, Inc. a Mortgage in the original principal amount of Zucker,Goldberg&Ackerman, LLC 062-PA-V4 $211,121.14 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on February 5, 2008, Instrument#200803556.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. 7. Plaintiff is the current mortgagee. 8. Tracy L. Spadafore, single woman is the record and real owner of the aforesaid mortgaged premises. 9. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the monthly installments of principal and interest due February 1, 2011. 10. As of November 30, 2013 the amount due and owing Plaintiff by Defendant(s) is as follows: Principal $208,962.54 Interest from 02/01/2011 through 11/30/2013 $51,750.27 Tax Disbursements $10,510.18 Total $271,222.99 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. 11. 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). 12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding,this action is in no way an attempt to re-establish such liability. Zucker,Goldberg&Ackerman, LLC 062-PA-V4 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $271,222.99 with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER,GOLDBERG &ACKERMAN, LLC BY: I� Dated: 3 ` \ Scott A. Dietterick, Esquire; PA I.D.#55650 Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D.#317226 Attorneys for Plaintiff XCP-158555/mme 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX Email: Office @zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT,AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker,Goldberg&Ackerman, LLC 062-PA-V4 EXHIBIT A Zucker,Goldberg&Ackerman, LLC 062-PA-V3 JAN. 25. 2008 12:02PM WELLSFAR30FINANCIAL 7172367705 N0, 6415 P, 8 NOTE 01/25/08 HARRISBURG,PA 17101 [Date] [City,State,Zip] 115 MOUNTAIN VIEW DR ENOLA.PA 17025 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received,I promise to pay U.S.$211121,14 (this amount is called"Principal"and consists of the amount financed plus points),plus interest,to the order of the Lender.The Lender is Wells Fargo Financial Pennsylvania,Inc. I will make all payments under this Note in the form of cash,check or money order. I understand that the Lender may transfer this Note.The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the"Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid.I will pay interest at a yearly rate of 8.88%.This Note is interest bearing. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B)of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the 1ST day of each month beginning on 03/01/08 . I will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied to interest before Principal, If,on 02/01/38 I still owe amounts under this Note, I will pay those amounts in full on that date,which is called the "Maturity Date." I will make my monthly payments at P.O.BOX 98784 LAS VEGAS,NV 89193 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments My monthly payment will be in the amount of U.S.$1680.53 4. BORROWER'S RIGHT TO PREPAY I can prepay my loan at any time.However,if the Loan Statement indicates that a prepayment penalty may be charged,and if my loan is prepaid in whole for any reason(including after a default) within 3 years from the Date of Loan shown above,the Note Holder may charge a prepayment charge equal to 3%of the original principal balance of this loan if the loan is prepaid during the first year of the loan,2%of the original principal balance if the loan is prepaid during the second year of the loan and 1%of the original principal balance if the loan is prepaid during the third year of the loan.I agree to pay Note Holder this prepayment charge on the date I make the full prepayment.I also agree that any delay or failure to collect this prepayment charge does not prevent the Note Holder from collecting the prepayment charge at a later time.However,regardless of how I prepay my loan,I will never have to pay more than one prepayment charge. The prepayment penalty described in this paragraph will be waived if:(a)my loan is prepaid by a loan made by Note Holder or a non-brokered loan by one of Note Holder's affiliates,more than 12 months after the date of this Note; or,(b)as required by applicable state or federal law or regulation, 5. LOAN CHARGES if a law,which applies to this loan and which sets maximum loan charges,is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits,then:(a)any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit;and(b)any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me.If a refund reduces Principal,the reduction will be treated as a partial Prepayment. ORIGINAL Paso 1 w8 PA.2D2s•100E RECEIVED 2008/01/25 11:04:12 JAN, 25, 2008 12:03PM WELLSEARSOEINANCIAL 7172367705 NO. 6415 9 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the Rill amount of any monthly payment by the end of I5 calendar days after the date it is due,I will pay a late charge to the Note Holder.The amount of the charge will be the greater of 10%of the full amount of my payment of principal and interest or S20. I will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default,the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date,the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount.That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (0) No Waiver By Note Holder Even if at a time when I am in default,the Note Holder does not require me to pay immediately in full as described above,the Note Holder will still have the right to do so if I am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above,the Note Holder will have the right to be paid back by me for all of its casts and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorney's fees. 7. GIVING OF NOTICES Unless applicable law requires a different method,any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A)above or at a different address if I am given a notice of that different address. S. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note,each person is fully and personally obligated to keep all of the promises made in this Note,including the promise to pay the full amount owed.Any person who is a guarantor,surety or endorser of this Note is also obligated to do these things,Any person who takes over these obligations,including the obligations of a guarantor,surety or endorser of this Note,is also obligated to keep aII of the promises made in this Note.The Note Holder may enforce its rights under this Note against each person individually or against all of us together.This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment"means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor"means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions.In addition to the protections given to the Note Holder under this Note,a Mortgage,Deed of Trust,or Security Deed (the"Security Instrument"),dated the same date as this Note,protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note.Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred(or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument.However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of ORIGINAL Page 2 W 2 PA.2029.1009 RECEIVED 2008/01/25 11:04:12 JAN. 25. 2048 12:03PM WEL LSFARGOFINANCIAL 7172367705 NO. 6415—'P, 10 acceleration.The notice shall provide a period of not less than 3O days from the date the notice is given in accordance with Section 13 within which Borrower must pay all sums secured by this Security Instrument.If Borrower fails to pay these sums prior to the expiration of this period,Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HANDS)AND SEAL(S)OF THE'UNDERSIGNED. Borrower 11114 Zy �j /111 W e, (Seal) TRACYL SPADAPORE Borrower SANDRA N SPADAPORE Borrower (Seal) Borrower (Seal) [Sign Original Only] ORIGINAL Ph202&1008 Pape3e13 RECEIVED 2008/01/25 11:04:12 EXHIBIT B Zucker,Goldberg&Ackerman, LLC 062-PA-V3 FEB. 20• 2008 4:54PM WELLSFARSOF[NANCIAL 7172367705 ivu, coi9 F. IU,' r ADDENDUM A TO MORTGAGE Description of Property LAND REFERRED TO IN THIS COMMITMENT IS DESCRIBED AS ALL THAT CERTAIN PROPERTY SITUATED IN EAST PENNSBORO TOWNSHIP IN THE COUNTY OF CUMBERLAND,AND STATE OF PA AND BEING DESORIBED IN A DEED DATED 07/2411998 AND RECORDED Q&23!19$$IN BOOK 206 PAGE 317 AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE,AND REFERENCED AS FOLLOWS: 115 MOUNTAIN VIEW PARCEL No.00-12-2991.127 �..... �nnoin9i7n 1S- 34 VERIFICATION Chelsea Leigh Morgan, hereby states that he/she is Vice President of Wells Fargo Financial Pennsylvania, INC., Plaintiff in this matter,that he/she is authorized to make this Verification,and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best 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. Byati Uk- Lei Lel 171 1/171( Chelsea Leigh Morgan Vice President of Wells Fargo Financial Pennsylvania, INC. Employed by Wells Fargo Bank N.A. 02/06/2014 086-PA-V2 WELLS FARGO FINANCIAL PENNSYLVANIA, INC., Plaintiff vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 14 -1396 CIVIL TRACY L. SPADAFORE, Defendant : MORTGAGE FORECLOSURE ORDER AND NOW, this `7 day of March, 2014, action on the captioned mortgage foreclosure action is stayed pending service upon the defendant of the documents giving notice of the Cumberland County Mortgage Diversion Program. BY THE COURT, ■Ashleigh L. Marin, Esquire 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 Tracy L. Spadafore 115 Mountain View Drive Enola, PA 17025 fr/..i [LC C374/// ,=1 1 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor oe4a�rH'E�mFF ~O\�C�P-� P�k.|1 /".'"`" -2 ... `. .` CU "[OUNTY PENNSYLVANIA Wells Fargo Financial Pennsylvania Inc vs. Tracy L. Spadafore Case Number SHERIFF'S RETURN OF SERVICE 03/21/2014 11:52 AM - Deputy Amanda Ebersole, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a tru copy to a person representing themselves to be Sandy Spadafore, Mother, who accepted as "Adult Person in Charge" for Tracy L. Spadafore at 115 Mountain View Drive, East Pennsboro Township, Enola, PA 17025. DAEBRSOLE.DEPUTY SHERIFF COST: $44.95 SO ANSWERS, March 24, 2014 RbN R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Financial Pennsylvania, Inc. CIVIL DIVISION. Plaintiff, vs. Tracy L. Spadafore; Sandra N. Spadafore; Defendants. TO THE PROTHONOTARY: NO.: 14 -1396 -CIVIL PRAECIPE TO REINSTATE COMPLAINT C Please mark the Complaint in Mortgage Foreclosure filed at the above -captioned term and number reinstated. Bv: Dated: Mayc —1, 2014 ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire; PA I.D. #55650 Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A. Ackerman, Esquire; PA I.D. #202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M. Salvia, Esquire; PA I.D. #202946 Jaime R. Ackerman, Esquire; PA I.D. #311032 Jana Fridfinnsdottir, Esquire; PA I.D. #315944 Brian Nicholas, Esquire; PA I.D. #317240 Denise Carlon, Esquire; PA I.D. #317226 Attorneys for Plaintiff XCP-158555/ns 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com .g 73 -pd u WI Ow Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY f R. 0 -1 F i r: l It JUN 17 AN 9 49 CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Financial Pennsylvania Inc vs. .Tracy L. Spadafore (et al.) Case Number 2014-1396 SHERIFF'S RETURN OF SERVICE 06/05/2014 03:05 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Sandra Spadafore, Mother, who accepted as "Adult Person in Charge" for Tracy L. Spadafore at 115 Mountain View Drive, East Pennsboro Township Enola, PA 17025. '62-7= T�01v i ARTLE, DEPUTY 06/05/2014 03:05 PM - Deputy Jamie DiMartle, being duly sworn according tdla erved the requested Notice of Residential Mortgage Foreclosure Diversion Program and Compl- nt in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Sandra Spadafore at 115 Mountain View Drive, East Pennsboro, Enola, PA 17025. SHERIFF COST: $60.95 JAMI RTLE, DEPUTY ANSWERS, June 09, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosofi, inc.