HomeMy WebLinkAbout14-2197 For Prothonotary Use Only:
Suprem a Cou:r -tpf Pennsytva.ni',a
Cou
Pleas
t.
• mHti ` Docket No.
)nd C oqunity
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 o court.
Commencement of Action:
S ® Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiffs Name: Wells Fargo Bank, N.A., Lead Defendant's Name: Unknown Surviving Heirs of Carl J. Avara, Deceased
T Mortgagor and Real Owner
I Are there money damages requested? 0 Yes 0 No Dollar Amount Requested: ❑ within arbitration limits
0 (check one) ❑ outside arbitration limits
N Is this a Class Action Suit? 0 Yes ® No Is this an MDJAppeal? ❑ Yes 0 No
A Name of Plaintiff/Appellant's Attorney: McCabe, Weisberg & Conway, P.C.
0 Check here if you have no attorney (a Self - Represented [Pro Sel .Litigant)
Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Plaintiff Administrative Agencies
❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Department of Transportation
❑ Premises Liability (does not include
❑Statutory Appeal: Other
S mass tort)
E ❑ Slander/Libel/ Defamation ❑ Employment Dispute:
❑ Other: Discrimination
C ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other
I
O ❑ Other
N MASS TORT
❑ Asbestos
❑ Tobacco
❑ Toxic Tort - DES
❑ Toxic Tort - Implant
B ❑ Toxic Waste REAL PROPERTY MISCELLANEOUS
❑ Other: ❑ Ejectment ❑ Common Law /Statutory Arbitration
❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlordfrenant Dispute ❑ Non - Domestic Relations
® Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial 0 Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑ Other:
❑ Medical ❑ Other:
❑ Other Professional:
Updated 1/1/2011
V �• r
McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff. .
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770 C �� �• J
MARISA J. COHEN, ESQUIRE - ID # 87830 C'�' `.•
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716 g j�✓
JOSEPH 1. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790 -1010
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Wells Fargo Bank, N.A., I CIVIL DIVISION
101 North Phillips Avenue `
Sioux Falls, SD 57104 ( J 1 V
Plaintiff, No.: �j
V.
Unknown Surviving Heirs of Carl J. Avara, Deceased
Mortgagor and Real Owner
6316 Stephens Crossing j
Mechanicsburg, PA 17055
and
Leigh A. Avara, Known Surviving Heir of Carl J. Avara,
Deceased Mortgagor and Real Owner
5027 NE Everett Street
Portland, OR 97213
and
Alessia Louise Avara, Known Surviving Heir of Carl J. Avara,
Deceased Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, PA 17050 j
and
Tina L. Morelli a/k/a Tina L. Avara, Mortgagor and Known
Surviving Heir of Carl J. Avara, Deceased Mortgagor and Real
Owner
6316 Stephens Crossing
Mechanicsburg, PA 17050 1
Defendants.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes Wells Fargo Bank, N.A., successor by merger to Wachovia Bank, N.A., by
its attorneys, McCabe, Weisberg & Conway, P.C. and files this Complaint in Mortgage Foreclosure
as follows: �. � I Fi 1 G3 .—) S
C � v
062 -PA -V4 �6 C1 3�0
Fite #74251
NOTICE AVISO
You have been sued in court. If you wish to Le han demandado a usted en la corte. Si
defend against the claims set forth in the usted quiere defenderse de estas demandas
following pages, you must take action within ex- puestas en las paginas siguientes, usted
twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la
notice are served, by entering a written fecha de la demanda y la notificacion. Hace
appearance personally or by attorney and falta asentar una comparencia escrita o en
filing in writing with the court your defenses persona o con un abogado y entregar a la corte
or objections to the claims set forth against en forma escrita sus defensas o sus objeciones
you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea
the case may proceed without you and a avisado que si usted no se defiende, la corte
judgment may be entered against you by the tomara medidas y puede continuar la demanda
court without further notice for any money en contra suya sin previo aviso o notificacion.
claimed in the complaint or for any other Ademas, la corte puede decidir a favor del
claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con
may lose money or property or other rights todas las provisioner de esta demanda. Usted
important to you. puede perder dinero o sus propiedades u otros
derechos importantes para usted.
YOU SHOULD TAKE THIS PAPER
TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE
DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO
TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO TIENE
BELOW. THIS OFFICE CAN PROVIDE A UN ABOGADO, VA A O TELEFONEA
YOU WITH INFORMATION ABOUT LA OFICINA EXPUSO ABAJO. ESTA
HIRING A LAWYER. OFICINA LO PUEDE PROPORCIONAR
IF YOU CANNOT AFFORD TO CON INFORMATION ACERCA DE
HIRE A LAWYER, THIS OFFICE MAY BE EMPLEAR A UN ABOGADO.
ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE
INFORMATION ABOUT AGENCIES THAT PROPORCIONAR PARA EMPLEAR UN
MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER
ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON
OR NO FEE. INFORMACION ACERCA DE LAS
AGENCIAS QUE PUEDEN OFRECER LOS
Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS
32 South Bedford Street ELEGIBLES EN UN HONORARIO
Carlisle, PA 17013 REDUCIDO NI NINGUN HONORARIO.
(800) 990 -9108
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(800) 990 -9108
062 -PA -V4
File #74251
This is a communication from a debt collector who is attempting to collect a debt, and any
information obtained will be used for that purpose.
Please Note: (1) unless, within thirty (30) days after your receipt of this notice, you dispute
the validity of the debt, or any portion of the debt, we will assume that the debt is valid; (2)
if you notify us in writing within thirty (30) days of your receipt of this notice that the debt,
or a portion of the debt, is disputed, we will cease collection of the debt until we obtain
verification of the debt or a copy of the judgment against you and mail to you a copy of the
verification or judgment that we obtain; (3) upon your written request to us within thirty
(30) days of your receipt of this notice for the name and address of the original creditor of
your debt, we will cease collection of the debt until we mail to you the name and address of
the original creditor, if different from the current creditor.
Case Name: Wells Fargo Bank, N.A., v. Unknown Surviving Heirs of Carl J. Avara, Deceased
Mortgagor and Real Owner, Leigh A. Avara, Known Surviving Heir of Carl J. Avara, Deceased
Mortgagor and Real Owner, Alessia Louise Avara, Known Surviving Heir of Carl J. Avara,
Deceased Mortgagor and Real Owner, Carl J. Avara, Deceased Mortgagor and Real Owner and
Tina L. Morelli a/k/a Tina L. Avara, Mortgagor and Known Surviving Heir of Carl J. Avara,
Deceased Mortgagor and Real Owner
Cumberland County
062 -PA -V4
File #74251
1. The Plaintiff is Wells Fargo Bank, N.A., successor by merger to Wachovia Bank,
N.A., at 101 North Phillips Avenue, Sioux Falls, SD 57104 (hereinafter "plaintiff').
2. The Defendant is Leigh A. Avara, Known Surviving Heir of Carl J. Avara, Deceased
Mortgagor and Real Owner, with a last known address is 5027 NE Everett Street, Portland, OR
97213.
3. The Defendant is Alessia Louise Avara, Known Surviving Heir of Carl J. Avara,
Deceased Mortgagor and Real Owner, with a last known address is 6316 Stephens Crossing,
Mechanicsburg, PA 17050.
4. The Defendant is Tina L. Morelli a/k/a Tina L. Avara, Mortgagor and Known
Surviving Heir of Carl J. Avara, Deceased Mortgagor and Real Owner, with a last known address is
6316 Stephens Crossing, Mechanicsburg, PA 17050.
5. The Defendant is Unknown Surviving Heirs of Carl J. Avara, Deceased Mortgagor
and Real Owner, related to the property located at 6316 Stephens Crossing, Mechanicsburg,
Pennsylvania 17055.
6. 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.
7. Wells Fargo Bank, N.A., successor by merger to Wachovia Bank, N.A., directly or
through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A., successor by
merger to Wachovia Bank, N.A., 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.
062 -PA -V4
File #74251
8. On or about February 5, 1999, Carl J. Avara and Tina L. Morelli, a/k/a Tina L. Avara,
made, executed and delivered to First Union National Bank a Mortgage in the original principal
amount of $80,000.00 on the premises described in the legal description marked Exhibit `B ",
attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder
of Cumberland County on March 5, 1999 in Mortgage Book 1524, Page 888. 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.
9. Plaintiff is the current Mortgagee by successor by merger to the original Mortgagee.
10. Carl J. Avara is the record and real owner(s) of the aforesaid mortgaged premises.
11. Carl J. Avara died on December 28, 2007. On or about April 19, 2011, Tina L. Morelli
a/k/a Tina L. Avara, executed a Deed title vesting solely in the name of Tina L. Morelli a/k/a Tina L.
Avara. However, no estate has been probated for Carl J. Avara; subsequently, Tina L. Morelli a/k/a
Tina L. Avara was never appointed Executrix of the estate of Carl J. Avara and lacked the authority
to execute the Deed so the aforesaid Deed is invalid. Decedent's surviving heir(s) at law and next -of-
kin are Leigh A. Avara, Known Surviving Heir of Carl J. Avara, Deceased Mortgagor and Real
Owner, Alessia Louise Avara, Known Surviving Heir of Carl J. Avara, Deceased Mortgagor and
Real Owner, and Tina L. Morelli a/k/a Tina L. Avara, Mortgagor and Known Surviving Heir of Carl
J. Avara, Deceased Mortgagor and Real Owner.
12. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the installments of principal and interest due March 7, 2012.
062 -PA -V4
File #74251
13. As of March 19, 2014, the amount due and owing Plaintiff on the mortgage is as
follows:
The total amount due the Plaintiff on said Note through March 19, 2014 is $119,225.91
which breaks down as follows:
Principal: $112,200.00
Accrued interest at a variable rate: $6,922.09
Pre- acceleration Late Charges: $61.82
Property Inspections: $42.00
Appraisals /Brokers Price Opinion: $0.00
Escrow Deficit: $0.00
Total: $119,225.91
A daily variable per diem will accrue on the principal in accordance with the variable rate as
set forth in 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.
14. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's
Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or
Notice of Default as required by the mortgage document, as applicable, have been sent to
Defendant(s).
15. Plaintiff does not hold the named Defendants personally liable on this cause of action
and releases them from any personal liability. This action is being brought to foreclose their interest
in the aforesaid real estate only.
062 -PA -V4
File #74251
16. 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.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the
amount due of $119,225.91, with interest thereon plus additional costs (including additional escrow
advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged
premises.
McCABE, WEISBERG & CONWAY, P.C.
BY:
[ ] Terrence J. McC e, Es re [ ] Marc S. Weisberg, Esquire
[ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire
[ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire
[ ] Marisa J. Cohen, Esquire [ ] Christine L. Graham, Esquire
[ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire
[ ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire
[ ] Celine P. DerKrikorian, Esquire [xj] Jennifer L. Wunder, Esquire
[ ] Lena Kravets, Esquire
Attorneys for Plaintiff
Dated: 2014
062 -PA -V4
File #74251
VERIFICATION
Maritza Tucker, 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 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.
By:
Name: Maritza Tucker
Title: Vice President Loan Documentation
Company: Wells Fargo Bank, N.A.
Date: J� 12+
086 -PA -V2
File #74251
EXHIBIT
«A„
Account Number:
FIRST UNION
NA7
PRIME EQUITY LINE AGREEMENT DN
- --
Maximum Credit Limit. $ 80000.00 L -
Customer Name(s) CARL J. AVARA
TINA L AVARA
Date of Agreement 02105/99
This Agreement and Disclosure Statement contains the terns which apply to the prime Equity Account ( "Account ") with First Union National
Bank. The words "I", "me" and "my" which also mean "we ". "W and "our ", if more than one customer, mean the person or persons
signing this Agreement. The words "you ", "your ", "yours ", and First Union mean First Union National Bank.
ACCESSING THE pREWE EQUITY LINE.
(a) I, concurrent with the approval of the prime Equity Lane, shall open a special checking account, the number of
which will appear on the checks ("Prime Equity Line Checks "). This special checking account shall not be dependent
upon the maintenance or use of, or otherwise connected with any other checking or savings account with First Union
except as provided herein. The Prime Equity Line Checks issued with the special checking account may be used to
obtain extensions of credit under the prime Equity Line up to the amount of the Maximum Credit s
established and et
out above. All amounts advanced by First Union to pay Prime Equity Line Checks and any other charges against my
special account shall constitute extensions of credit and shall be charged to my prime Equity Line.
(b) First Union Shall issue to me a VISA Gold Card for the purpose of obtaining extensions of credit on the Prime
Equity Line.
(c) If I have requested First Union, pursuant to an overdraft protection agreement, to pay checks which would otherwise
overdraw my deposit account with First Union, such overdrafts will be charged to my Prime Equity Line and will
constitute extensions of credit hereunder.
(d) The extensions of credit to pay Prime Equity Line Checks will be in the amount of those checks. The extensions of
credit made pursuant to an overdraft protection agreement shall be in increments of $100. The extensions of credit
for purchases trade using. the VISA Gold Card will be in the amount of the purchase.
(e) I may obtain Cash Advances from any of our branches or ATM locations up to the unused portion of the Credit
Limit.
Maximum Credit LimiL MY maximum credit line is indicated above. I agree never to allow the balance due on my Account to
exceed this limit. I also agree that you are not obligated to pay any Draft or other charge against my Accotmt, for an amount that
would make my Account balance exceed my maximum credit limit, or for any amount if my Account balance is already over the
maximum credit limit. Any increases in my maximum credit limit I request will require that I make a written application and sign any
ry agreements and mortgage modifications which in your opinion are necessary to secure your interest. -
Monthly Statement. If I have an outstanding debit or credit New Balance in excess of $1.00 or if there is any finance charge imposed
during a billing cycle, you will send me a statement. I promise to pay you for all Drafts plus finance charges on my Account, if any,
all payable in United States Dollars according to the terms and conditions of this Agreement. I understand I am prohibited from using
my Drafts to make my payments on this Account I understand I am responsible for any fees or costs associated with the processing of
my payments on my Account should I use a method of payment that results in extra costs or fees being assessed to you.
FINANCE CHARGES.
(a) A FINANCE CHARGE computed on a montldy periodic rate will be imposed, if at the end of any day of the billing cycle,
there is an outstanding balance owing on my Account. The monthly periodic rate for an initial advance, if any, made by you
will begin to accrue on the date of this Agreement. The monthly periodic rate for any Drafts will begin to accrue on the
Transaction Date (the date you pay the draft) as indicated on my billing statement.
(b) First Union calculates the FINANCE CHARGE on the Prime Equity Line by applying the monthly Periodic rate to the
"average daily balance." First Union takes the beginning balance of the Prime Equity Line each day, adds,any new
advances, and subtracts any payments or credits and unpaid finance charges, Credit We premiums and late charges. This
gives First Union the daily balance. Fuss Union then adds up all the daily balances for the billing cycle and divides the total
by the number of days in the billing cycle. This gives the "average daily balance." The annual percentage rate is determined
by multiplying the periodic rate by the number of billing cycles in a year (12).
(c) Finance Charges on,purchases made with checks of VISA Gold Card will be imposed from the date of transaction.
(d) On cash advances incurred by use of Prime Equity Line Checks or made pursuant to an overdraft protection agreement,
Finance Charges will be imposed from the date of posting. Finance Charges on all cash advances made with the VISA Gold
Card will be imposed from the date of transaction.
(e) Finance Charges on the average daily balance will continue to accrue until the new balance is paid. The "new balance" is `
the unpaid balance of extensions of credit hereunder and Finance Charges thereon as of the last day of the billing cycle. If I
pay the new balance appearing on my statement, the Finance Charges which accrued during the billing cycle in which
payment was received will appear on my next billing statement.
(fl On cash advances incurred by the use of an Automatic Teller Machine (ATM), Finance Charges will be imposed as of the
date of the transaction.
537M
Page 105 (11VA PA ML AS—
(g) Variable -Rate Feature: The FINANCE CHARGE imposed during a billing cycle will be determined by applying the monthly
periodic rate which is I/12 ofathe corresponding. ANNUAL PERCENTAGE RATE to the average daily balance: The ANNUAL
PERCENTAGE RATE and monthly periodic rate are variable rates and subject to change on the first day of each billing cycle, if
there was a prior change in the "Pririle.Rate" which is published regularly in the Wall Street Journal ( "WSJ ") Money Rates table.
The Wall Strcet.loumal is generally available in my state or area. If the WSJ Prime Rate becomes unavailable, you will select a new
index which is based on an historical movement substantially similar to the original index and the new index and margin will result in
an Annual Percentage Rate substantially similar to the rate in effect at the time theMSJ Prime Rate becomes unavailable. You will
_ give me notice of this change. The corresponding ANNUAL PERCENTAGE RATE is the WSJ Prime Rate published on the 15th
day of the last calendar month which ended prior to the billing date indicated on your previous billing statement plus 0.00 %. If
more than one prime rate is published on the 15th day of the month, you will use the higher rate as the WSJ Prime Rate. If the WSJ
Prime Rate is not published on the 15th day of the month, the WSJ Prime Rate will be the prime rate published on the last day prior
to the 15th. The current effective monthly peri odic rate applicable to this line is 0.646 % and the current effective ANNUAL
PERCENTAGE RATE applicable to this line is 7.750 %. An increase in the ANNUAL PERCENTAGE RATE and monthly
periodic rate will result in increased FINANCE CHARGES and increased minimum payment amounts. The ANNUAL
PERCENTAGE RATE will never be less than 0_00% and will never exceed the maximum interest rate permitted under State law,
but not more than 18_00 %. The corresponding ANNUAL PERCENTAGE RATE for each billing cycle will be shown on my billing
statement for that cycle. The ANNUAL PERCENTAGE RATE will include my interest and no other costs.
Fees.
(A) Late Payment Fee: My minimum payment will be past due if it is not received by you on or before the payment due date
shown on each monthly statement. A fee equal to 5% of the past due payment amount will be charged to my Account, if at
_ . least the minimum payment, is not received by you within 10 days after said payment due date.
(B) Returned Check Fee: If I make payment by check, and said check is returned unpaid for any reason. my Account will be
charged $15 for each such returned check.
(C) ❑ If checked, I will pay an annual non -usage fee of $ to be billed on my billing date during the thirteenth
(13th) monthly billing cycle after the opening date of my Account and every thirteenth (13th) monthly billing cycle
thereafter, following any 12 month period from the date my account balance is zero. If I obtain a credit advance under my
Account at any time during the twelve (12) monthly billing cycle period following the opening date of my Account, or at any
time during every twelve monthly billing cycle period thereafter, you will waive the non -usage fee.
(D) ❑ If checked, I will pay an annual maintenance fee of $ to be billed on my billing date during the thirteenth (13th)
monthly billing cycle after the opening date of my Account and every thirteenth (13th) monthly billingcycle thereafter.
Other Charges. In addition to the FINANCE CHARGE which will be added to my Account each billing cycle, I will pay the following real
estate closing and security filing fees:
"X" = First Union Pays Fee "X" = First Union Pays Fee
-' • Survey $ _ •GA/FL Intangible Tax $ _
Title Examination $ _ *GA Res Mtg Per Ln Fee $ —
• Check Fee $ 3.00 „X. - *Document Stamps
• Title Insurance $ - _ *Mist... _ $ —
Recording Fees $ _ •Miss $ —
Appraisal Fees $ _ TOTAL S 00
Flood Certification Fee $ —
FIRST UNION FEES PAID $ inn CUSTOMER FEES PAID $ 0 00
Security. I am giving you a mortgage, deed of trust or deed to secure debt (referred to as "Security Instrument" in this Agreement) on my
home or real estate as security for my Account. This security is referred to as "Property" in this Agreement.
Payment Schedule. I will pay:
I . The entire outstanding balance ( "New Balance") due on my Account; or
2. (a) Minimum payments equal to the finance charge or $50.00 for the billing tyke as indicated on my billing statement; or
(b) ❑ If checked, minimum payments of $50.00 or 1.5% of balance of the New Balance, whichever is greater; and
3. All amounts of credit extensions over the maximum credit limit, any unpaid minimum payments and other charges, if any.
4. The entire outstanding balance, if not sooner paid, on nsncitq (referred to as the "maturity date ").
I agree to pay the minimum payment not later than the payment due date on my billing statement. If I should make a payment at any time on
or before the due date which is equal to the New Balance, the entire amount of the payment will be applied to the New Balance. Any payment
which is less than the New Balance will be applied in the following order: first, to the FINANCE CHARGE due on the outstanding balance
and the remainder of the payment to the outstanding balance. I understand that I may prepay my Account in whole or in part at any time
without penalty.
I understand that the minimum payment of finance charge only will not fully reduce the balance that is outstanding on my Account and the
percentage of the outstanding balance or $50 payment, may not fully reduce the balance that is outstanding-on my Account. I understand that,
if this occurs. I will be required to pay the entire balance in a single "balloon" payment on the maturity date specified in this Agreement.
ASSUMPTION NOTICE
THE DEBT SECURED- HEREBY IS SUBJECT TO CALL IN FULL OR THE TERMS THEREOF BEING MODIFIED IN THE EVENT
THE REAL ESTATE SECURING THE DEBT IS SOLD, CONVEYED OR OTHERWISE TRANSFERRED. t .
' Obliption to Lend. You are absolutely obligated under the term of this Agreement to make advances not to exceed, at any one time in the
aggregate, the amount indicated as the maximum credit limit and I agree to repay any advances under the terms of this Agreement. Your
obligation to make advances to me under this Agreement ends when you terminate advances and demand repayment of the outstanding
obligation or prohibit additional extensions of credit under this Agreement or the Security Instrument.
Pape 2of$ (i PAM AV00o e
S
C '
Nevertheless, you may waive the right to terminate or prohibit additional advances. If you do not terminate or prohibit additional advances,
you remain obligated to make advances to me under the terms of this Agreement. However, that waiver does not bind you if the same or a
different event occurs or is continuing at a later time. Your obligation to make advances under the terms of this Agreement also terminates
when this Agreement is terminated or advances suspended by me in accordance with the terms of this Agreement.
Change of Terms of this Agreement. In addition to other rights you may have under this Agreement, you may change the terns and
conditions of this Agreement when any of the following.events shall occur;
(1) if the index and margin used with this Account are no longer available; rr
(2) if you matte a change that I specifically agree to in writing;
(3) if you make a change that will unequivocally benefit me the remainder of the term of this Agreement; ar
(4) if you make any insignificant change in the terms of this Agreement.
r'
Temporary Suspension of Credit and Reduction of Credit Limit. I agree that you may prohibit additional extensions of credit or reduce
the credit limit when any of the following events shall occur.
(1) A�� u of the Property that secures this Agreement declines significantly below the Property's appraised value during the time of this
(2) if you reasonably believe I will be unable to fulfill the repayment obligations under this Agreement due to a material change in my c"
financial circumstances;
(3) if I am in default of any material obligations under this Agreement;
(4) if action by a governmental body does not allow you to impose the Annual Percentage Raze currently applicable to this Agreement;
(5) if action by a governmental body adversely affects the priority of your Security Instrument to the extent that the value of the
security interest is less (ban 120 percent of the amount of my maximum credit limit;
(6) if you are notified by a governmental agency that regulates your lending activities that continuing .advances constitute an unsafe and
unsound practice;
(7) if during any period in which the Annual Percentage Rate corresponding to the monthly periodic rue reaches the maximum interest raze
allowed under this Agreement. Provided I am in compliance with the other terms of this Agreement, I understand you will reinstate
credit privileges if the Annual Percentage Rate declines below the maximum Annual Percentage Rate;
(8) if I request that you suspend any advances or reduce the credit limit;
(9) if I indicated at the time of application that I would occupy the Property and I no longer occupy the Property or I rent a part or all of the
Property to other parties.
I understand at no time will you reduce my credit limit below the outstanding balance. 1 understand that it is my responsibility to request
reinstatement of my credit privileges that have been suspended. I further understand that I may be required to pay for an appraisal of the
Property to determine if the value has changed. - I agree to furnish you current personal financial statements within 30 days of your written
request.
If you temporarily suspend advances or reduce the maximum credit limit, I understand you will mail or deliver written notice of your action
no later than three business days after the action and the specific reason for the action.
Termination of this Agr'tmment. I will be in default and you may terminate this Agreement and demand repayment of the entire outstanding
balance in advance of the maturity date if any of the following events shall occur:
(1) if I fail to make my payments within 10 days of the due date,
(2) if I write Drafts in excess of my available credit limit or my maximum credit limit;
(3) if a petition is filed or other proceedings started under the Federal Bankruptcy code or any state insolvency statute or if a receiver is
appointed or writ or order of attachment, levy or judgment is issued against me or my Property, assets or income that affects my ability
to repay this Agreement in accordance with the terms of this Agreement or that adversely affects your security rights in the Property;
(4) if I permit any other, lienholder to gain or appear to gain priority over you, except whatever first mortgage, deed of trust or deed to
secure debris outstanding on the Property, as you agree, at the time of recording of your Security Instrument to secure this Agreement;
(5) if the Property is condemned or is totally or partially destroyed by fire or other hazards or any proceeding is commenced which
materially affects your interest in the Property;
ty;
(6) if the secured note for any prior mortgage, deed of trust or deed to secure debt or lien on the real Property is in default by failure to pay
Principal, interest, charges, fees, escrow items or the commencement of a foreclosure proceeding or collection action that adversely -
affects your security interest in the Property;
(7) if you believe, in good faith, that I have allowed the Property to deteriorate, committed waste or destructively used or failed to maintain
the Property;
(8) if I commit fraud or misrepresent any information in the loan application, this Agreement or the Security Instrument at any time;
(9) if I fail to disclose any known environmental condition or hazard which adversely affects your security interest in the Property;
(10) if I fail to maintain adequate insurance coverage on the Property naming you as insured:
01) if I fail to pay taxes and assessments on the Property that results in a filing of a lien senior to your lien that irr>pairs your security interest
- in the Property; or
''(12) if I transfer any interest or title to the Property without your consent as set forth in the terms of the Security Instrument or transfer of title
occurs due to my death or by governmental action such as oondentration, however, I understand you will not terminate this Agreement
and accelerate payment if such action is prohibited by federal law as of the date of this Agreement.
If ari event occurs which allows the termination of advances and demand for repayment of the outstanding balance, you may, at your option
and in your sole discretion, take the following action:
(1) temporarily or permanently prohibit additional advances or reduce the maximum credit limit without demanding payment in full;
(2) change the payment terms or payment option for the repayment of the loan; or
(3) charge a higher rate or higher fees if I fail to meet the repayment terms or otherwise act so that the creditor is permitted to terminate the
Account and accelerate the balance.
If you do not immediately terminate the Account and demand repayment, you may take such action at a later time, if the event still exists or
another event occurs at that time.
If you do terminate the Account, you may require that the outstanding balance shall become due and payable immediately in full in a single
payment, without notice to me unless required by law and with interest due on the balance at the Annual Percentage Rate as provided for in
the Agreement until paid. If I do not immediately pay the outstanding balance and if this obligation is referred to an attorney -at -law for
collection, subject to applicable law, 1 agree to pay all costs and expenses, including court costs and reasonable attorney's fee, not exceeding
fifteen percent (15%) of the unpaid balance and interest, providing the attorney is not a salaried employee of yours.
Minimum Payment Change. If I fail to pay any minimum payment by its due date or if I request a different minimum payment, you may, at
your option, change the minimum payment and cancel the payment schedule 2(b) option.
I agree to give you prior written notice of my request to change my minimum payment option. -
___ -_ NP 3ofS (TIM PAPELAg-
Required Property Insurance. I agree to purchase and to continue to maintain property insurance, including flood coverage if required, on
the second Property in an amount not less than the entire outstanding balance for all prior and current obligations secured by my Property for
this loan or in such an amount satisfactory to you. If I fail to maintain adequate coverage as described above; you may, either at your option
or as required by law, obtain coverage to protect your rights in accordance with other provisions of this Agreement. If my Property is
damaged or destroyed, I agree that you may use any insurance settlement either to repair the Property or to apply it to my outstanding balance.
1 agree to assign the proceeds of my insurance to you to the extent of the debt I owe and agree that the insurance company may pay you
directly. I agree that you have an irrevocable power of attorney to file proofs of loss and anything else necessary to obtain the insurance
proceeds in my name. Loss, damage or "destruction of Property will not release me from any liability under this Agreement.
Ownership of Drafts. Any Draft which you supply to me is your property and must be returned to you immediately upon demand in
accordance with this Agreement.
Transfer of Account. I cannot transfer or assign my Account to any other person, however, I recognize you-can assign this Agreement.
Change of Address. 1 will advise you promptly if I change my mailing address. All written notices and statements from you to me will be
considered given when placed in the United States mail, postage prepaid, and addressed to me at my current address as it appears in your
records. If this is a joint account, written notice to one person is notice to the other person(s).
Irregular Payments. You may accept late payments or partial payments, or checks, drafts or money orders marked "Payment in Full",
without losing any of your rights under this Agreement and/or applicable law.
Deferred Payment Option. At your option and as you designate, I understand that I may not be required to make a minimum payment
during certain billing cycles. If I elect not to make my minimum payment as provided in the Agreement, I understand that this election does
not eliminate the accrual of charges, including finance charges, which will continue to be applied to my account. Beginning with the next
billing cycle following a deferred payment, I understand all of the provisions of this Agreement shall apply.
Amendments. Subject to the provisions of this Note and applicable law, you may change any part of this Agreement a_ t any time, as long as
you give me notice required by this Agreement or as may be required by law, I agree that the new terms, including any increase in the finance
charge or other charges provided in this Agreement shall apply to credit extensions made on and after the effective date and to any outstanding
balance owing to you on the effective date, provided that the new terms shall not apply to the outstanding balance if I pay the entire
outstanding balance before the effective date of the change in terms.
Cancellation. I can cancel my Account at any time by returning to you all of my unused Prime Equity Line Checks, along with a letter
requesting that you cancel my Account. However, my obligations under this Agreetneat and any changes trade under it prior to cancellation
will continue to apply until I have paid you all the money I owe on the Account.
Termination or Suspension of Credit by Me and/or Joint Account Owner(s). If one or more persons are liable with me under this
Agreement, and less than all of us request in writing that future advances be terminated or temporarily suspended hereunder, you will block or
otherwise suspend advances under this Agreement for ten (10) days. You will also give notice of the request for suspension or termination to
all borrowers. If you do not receive a court order enforcing the termination or suspension of advances under this Agreement beyond the ten
day period stated above, from the person requesting the termination or suspension of advances within the ten -day period stated above, you will
unblock the Account and allow advances as if no request for termination or suspension was made.
Removal of Lien.. At any time when the outstanding balance secured by the Security Instrument is zero, and your obligation to make
advances to me under this Note has terminated, you shall at my written request to terminate my Account, return the Security htstrument to me
appropriately marked as satisfied and satisfy the Security Instrument of record, however, I will pay the recording costs of that satisfaction.
Other Provisions. Each of us who signed this Agreement or are issued Drafts or are allowed to use this Account, are both individually and
jointly obligated for all payments due under this Agreement. If you request, I will give you any information needed to reevaluate my Account
or my creditworthiness. You may, at any time seek information about my financial condition from others and may provide information
aboutmy Account to others. If I apply for an increase in the credit limit for my Account or if you require that an appraisal be obtained to
continue my Account, you will advise me of the cost of the appraisal before the appraisal is conducted. I understand that the appraisal will be
for your use only and that 1 will not be entitled to a copy of the appraisal report. I agree that this Agreement shall be governed by and
interpreted entirely under Pennsylvania law. In the event that the amount of interest on my Account exceeds the maximum permitted by law,
you agree to repay me upon demand the amount paid which exceeds the maximum interest rate, or at your option, to reduce the then
outstanding principal balance by the excess amount of interest. If any part of this Agreement is not valid, all other parts will remain
enforceable. I understand I should consult a tax advisor regarding the deductibility of interest and charges for my Account.
MY BILLING RIGHTS - I SHOULD KEEP THIS NOTICE FOR FUTURE USE
This notice contains important information about my rights and your responsibilities under the Fair Credit Reporting Act.
I Should Notify You in Case of Errors or Questions About My Statement.
If 1 think my Statement is wrong, or if I need more information about a transaction on my Statement, I should write you on a separate sheet at
the address listed on my Statement. I should write you as soon as possible. You must hear from me no later than 60 days after you sent me the
first statement on which the error or problem appeared. I can telephone you, but doing so will not preserve my rights.
In my letter, I must give you the following information.
. My full name and account number.
• The dollar amount of the suspected error.
• I must describe the error and explain, if I can, why I believe there is an error. If I need more information, I should
describe the item I am not sure about.
My Rights and Your Responsibilities After You Receive My Written Notice.
You roust acknowledge my letter within 30 days, unless you have corrected the error by then. Within 90 days, you must either correct the
error or explain why you believe the Statement was correct. +
After you receive my letter, you cannot try to collect any amount I question, or report as delinquent. You can continue to bill me for the ;
amount I question, including finance charges, and you can apply any unpaid amount against my credit limit. I do not have to pay any
questioned amount while you are investigating, but I am still obligated to pay the parts of my Statement that are not in question.
Pare! d3 (liffl n PA PEL AX—to
r
If you find that you made a mistake on my Statement, I wilf not have to pay any finance charges related to any questioned amount. If you
didn't make a mistake, I may have to pay finance charges, and I will have to make up any missed payments on the questioned amount. In
either case, you will send me a statement of the amount I owe and the date that it is due.
If I fail to pay the amount that you think I owe, you may report me as delinquent. However, if your explanation does not satisfy me and I
write to you within ten days telling you that I still refuse to pay, you must tell anyone you report me to that I have a question about my
Statement. And, you must tell me the name of anyone you reported me to. You must tell anyone you report me to that the matter has been
settled between us when it finally is.
If you don't follow these rules, you can't collect the first $50 of the questioned amount, even if my Statement was correct.
ARBITRATION: At my, any guarantor, or your request, any controversy arising out of or relating to this loan shall be decided by binding
arbitration under the Commercial Arbitration Rules of the American Arbitration Association. Any controversy that is related to a class action
or is part of a class action shall, at my, any guarantor, or your request, be referred for decision by arbitration as provided herein. A judgment
upon award may be entered by any court having jurisdiction.
Notwithstanding the preceding binding arbitration provisions, 1, any guarantor, or you may employ or exercise free, either alone, in
conjunction with or during an arbitration proceeding, any provisional or ancillary remedies including foreclosure and sale of any collateral by
judicial or non - judicial foreclosure, self help, set -off, attachment, garnishment and sequestration. Preservation of these remedies does not
limit the power of the arbitrator to grant similar remedies.
INFORMATION REPORTED TO CONSUMER REPORTING AGENCIES: Under the Fair Credit Repotting Act, I have the tight
to notify you if I believe you have reported inaccurate information about my account to any Consumer Reporting Agency. Such
notices should be sent in writing and include my complete name, current address, Social Security number, telephone number, account
number, type of account, specific item of dispute and the reason why I believe the information reported is in error. I must send my
notice to: First Union, P.O. Box 560726, Charlotte, NC 28256 -0726.
SHARING INFORMATION REGARDING MY FIRST UNION RELATIONSHIPS. I understand that from time to time you may
share and use with any First Union Corporation Affiliate (e.g. First Union National Bank, Fust Union Brokerage Services, Inc., First
Union Mortgage Corporation, etc.) my account and "other information" as you in your sole discretion consider necessary or
appropriate. I have the right to direct you not to share my "other information" by notifying you in writing. I must send my name,
address, Social Security number, telephone number and account type and number to: First Union, P.O. Box 11716, Roanoke, VA
24022 -1726.
By signing below, I agree to all the terms contained herein and certify that I received completed copies of this Agreement and Disclosure
Statement, Mortgage, and Important Terror, and 2 copies of a Notice of Right to Cancel this Agreement on the date shown above, i will refer
to the above instructions if I have a problem with any billing statement you send to me.
(SEAL) " '- "� (SEAL).
Signature CARL VAVARA Signature TINA L AVARA
(SEAL) (SEAL)
Signature Signature
P,p 5 of s (IM PA PEL Ay-
EXHIBIT
«B„
I
we�
Ou THAT CERTAIN lot of land aitust• in the Township of Hampden,
descri bed as fol Cumber land and State of pennaylvanla, more particularly
eacsllows:
BEGINNING at a point on the eastern 11:0 of Stephen's Creasing, which
point is the line dividing Leta Yo, pB and 79 ant the hereim flee
47 i inutes peen of Leta; ute thence along tae said line South 85 degrees
4? m east, one Hundred Twenty -Five ( iaet to a poi t
south 04 degrees 28 minutes 50 aeeonda east, $12c
Nine �e_lhindredCha 68- ty -Eight and hlnety-
tats Ho. 79 and B01 t(69e)al et to a point on the line dividing
minutes 45 seconds west, One Hundred Twenty -one andnThirty-cnneaGre-
Hundre3trs (121,311 feet to A point on the eastern line of Stephen's
Crosaingl thence along Stepheaia Crossing north 10 degrees 21 inutes
o west,
to p
a pointint Forty -Wo and Twenty -Two One- Hondrsdtha (42 22) foot
to s thence continuing slang the same in a northerly direction
on a curve to the right having a radius of 233 an are distance of
Pifty -Bight and Porty -Nina one -H Adredths (58,
place of Beginning, feet to a point, the
�..i BEING Lot No. 79, Plan 4, of The village of Westover, which plan is
recorded in the Cumberland County Recorders 4tflcs la Plan Book 23,
Pegs 22.
I 'NC the sasu prea.sea wti ch Carlo * Urven and Kather.na Anq Marvtn, tits w'.a
o deed dated June 20. 197. and �eco•ded in •tie Cupberidrd County po.v:dsr•s
of to it tread book R -25, Page 90 grancsd and conveyed -n�o Carl J Avara and
Kay J avara, why as also known as Kav r Aeara, his w,fe mortgogdrs Rerev%
hA"NC thereon ereetad A dwe1lire house snovn and rurWered as 6310 Stephe
Crossirq
UNDER AND SJbJ6CT 4 MArHeLPSS, to reltritclone, conditions and easaaenta of
record pertainirg to said pr ■muea prior
TW' MORTGAGORS reP'esrnt and rArrAAL that ♦4,thsr of the
P
anstitaeed dlvcroe proepdtngs agar -st t -le other and it Ls further aqr .d chat she
11" operation Ard affect of this aoregage st not ae changed in air -4n.1er as
a result of or part of any property settlopent or Gquitaole dutribLtion by the
court it any divorce Proceed.n9s nor or hereafter
so instituted by eich•r of the rcgagors hereto against the other
• !AIlT.
eoo� bib ru�lUfa
FORM l
Wells Fargo Bank, N.A., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
vs.
Unknown Surviving Heirs of Carl J. Avara, Deceased r Civil `=
Mortgagor and Real Owner, Leigh A. Avara, Known
Surviving Heir of Carl J. Avara, Deceased Mortgagor tz;
and Real Owner, Alessia Louise Avara, Known - E-
Surviving Heir of Carl J. Avara, Deceased Mortgagor
and Real Owner, Carl J. Avara, Deceased Mortgagor
and Real Owner and Tina L. Morelli, a /k/a Tina L. * �'
Avara, Known Surviving Heir of Carl J. Avara, =' C
Deceased Mortgagor and Real Owner
Defendants
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may
be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your
lender.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal
Services at (717) 243 -9400 extension 2510 or (800) 822 -5288 extension 2510 and request appointment of a
legal representative at no charge to you. Once you have been appointed a legal representative, you must
promptly meet with that legal representative within twenty (20) days of the appointment date. During that
meeting, you must provide the legal representative with all requested financial information so that a loan
resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial
Worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the
appointment of a legal representative. However, you must provide your lawyer with all requested financial
information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete
a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation
Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of
the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements
with your lender before the mortgage foreclosure suit proceeds forward.
74251
Page 1
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:
Date [Sign re o ounsel for Plaintiff)
i
74251
Page 2
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date:
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to determine possible
options while working with your
Please provide the following information to the best of your knowledge:
CUSTOMER/PRIMARY
Borrower name(s):
Property Address:
City: State: Zip:
Is the property for sale? Yes ❑ No ❑ Listing date: Price $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes ❑ No ❑
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people on household: How long?
CO-BORROWER
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people on household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payment. Amount $ Included Taxes & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ❑ 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.
2.
3.
Additional Income Description (not wages):
1 • monthly amount:
2 • monthly amount:
Borrower Pay Days: Co- Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE
Mortgage AMOUNT
Food
2n Mortgage Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not �pa )
Auto fuel /repairs Other proent
Install . Loan Payment Cable TV
Child Support/Alim. Spending Money
Da /Child Care /Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ❑ No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance?
Yes ❑ 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 deliquency?
Yes ❑ No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender or lender's loan servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
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 obiligation
to use the services provided by the above named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this document along with the following information to lender and lender's counsel:
Proof of income
V Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation (hardship letter)
Listing agreement (if property is currently on the market)
3
McCABE, WEISBERG & CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A., NIL DIVISION
101 North Philips Avenue
Sioux Falls, SD 57104 o.: 14-2197 Civil
Plaintiff,
v.
Unknown Surviving Heirs of Carl J. Avara, Deceased
Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, PA 17055
and
Leigh A. Avara, Known Surviving Heir of Carl J. Avara,
Deceased Mortgagor and Real Owner
5027 NE Everett Street
Portland, OR 97213
and
Alessia Louise Avara, Known Surviving Heir of Carl J.
Avara, Deceased Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, PA 17050
and
Tina L. Morelli a/k/a Tina L. Avara, Mortgagor and
Known Surviving Heir of Carl J. Avara, Deceased
Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, PA 17050
Attorneys for Plaintiff
Defendants.
MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT
Plaintiff, Wells Fargo Bank, N.A., by its counsel, moves this Honorable Court for an Order directing service
of the Complaint and of all subsequent notices and pleadings that require personal service, including Notice of Sheriff's
Sale upon Defendant, Unknown Surviving Heirs of Carl J. Avara Deceased Mortgagor and Real Owner by mail and by
posting the mortgaged premises and by publication and in support thereof, avers the following:
1. Carl J. Avara was an individual and is the record owner and mortgagor of the premises that is the
subject of Plaintiffs action in Mortgage Foreclosure.
2. The premises that is subject of this mortgage foreclosure action is 6316 Stephens Crossing,
Mechanicsburg, Pennsylvania 17055 and is the last -known address of the decedent.
3. Carl J. Avara is deceased, having departed this life on December 28, 2007. No estate or administration
has been opened as a result of the demise of Carl J. Avara. The only known heirs of Carl J. Avara are Leigh A. Avara,
Alessia Louise Avara, and Tina L. Morelli a/k/a Tina L. Avara. Accordingly, Unknown Surviving Heirs of Carl J. Avara,
Deceased Mortgagor and Real Owner have been named as Defendants to this foreclosure action.
4. Leigh A. Avara, Alessia Louise Avara, and Tina L. Morelli a/k/a Tina L. Avara are the only known
surviving heirs of Carl J. Avara. Plaintiff retained Attorney Outsourcing Support Services, Inc. to investigate the identity
of any additional heirs of Carl J. Avara. No additional heirs were found. An Affidavit of Good Faith Investigation setting
forth the specific inquiries made and the results therefrom is attached hereto, made a part hereof and marked as Exhibit
5. Plaintiff has obtained a property search of the mortgage premises which indicates that
the record owner of the premises is Carl J. Avara. On or about April 19, 2011, Tina L. Morelli a/k/a Tina L. Avara,
executed a Deed title vesting solely in the name of Tina L. Morelli a/k/a Tina L. Avara. However, no estate has been
probated for Carl J. Avara; subsequently, Tina L. Morelli a/k/a Tina L. Avara was never appointed Executrix of the estate
of Carl J. Avara and lacked the authority to execute the Deed so the aforesaid Deed is invalid. A true and correct copy
of the property search is attached hereto and marked as Exhibit "B."
6. Plaintiff will never be able to personally serve the Complaint and subsequent pleadings upon the
Unknown Surviving Heirs of Carl J. Avara, Deceased Mortgagor and Real Owner.
7. Pursuant to Pennsylvania Rule of Civil Procedure 430(b)(2), service upon Unknown
Heirs may be made by publication.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order pursuant to Pennsylvania
Rules of Civil Procedure 430 and 3129.2(D) directing service of the Complaint by posting, publication and by mail and
further directing that all subsequent Notices and pleadings that require personal service may be served in this manner
except that publication of the Notice of Sheriff's Sale by the Sheriff set forth in Pa.R.C.P 3129.2(D) is legally sufficient
and Plaintiff need not republish the Notice of Sheriff's Sale.
McCABE, WEISBERG & CONWAY, P.C.
] Terrence J. cCabe, sq.
] Edward D. Conway, Esq.
] Andrew L. Markowitz, Esq.
] Marisa J. Cohen, Esq.
] Brian T. LaManna, Esq.
] Joseph F. Riga, Esq.
1 Celine P. DerKrikorian, Esq.
] Lena Kravets, Esq.
Attorneys for Plaintiff
[ ] Marc S. Weisberg, Esq.
[ ] Margaret Gairo, Esq.
[ ] Heidi R. Spivak, Esq.
[ ] Christine L. Graham, Esq.
[ ] Ann E. Swartz, Esq.
[ ] Joseph I. Foley, Esq.
[so] Jennifer L. Wunder, Esq.
[ ] Carol A. DiPrinzio, Esq.
Exhibit A
Attorney Outsourcing Support Services, Inc.
Suite 2SO4
1 Huntington Quadrangle
Melville, NY 11747
(516) 284 -5850
Fax (855) 427 -1280
Affidavit of Death Investigation for the Estate of Carl J. Avara
SUR.TFCT OF INVESTIGATION: Carl J. Avara
CLIENT: McCabe, Weisberg and Conway, P.C.
MATTER #: 302- 2644PA
AOSS FILE #: 136186
SUBJECTS LAST - KNOWN /PROPERTY ADDRESS: 6316 Stephens Crossing, Mechanicsburg, PA
17055
I, Rita Mastrangelo, being duly sworn according to law, depose and say that I completed a death
investigation into the whereabouts of the above -named subject and the extent of the investigation and the
results are as follows:
I. Verification of Death
1. SOCIAL SECURITY DEATH INDEX
Social Security Death Index has a record for the subject, listing the date of death as
December 28, 2007.
OBITUARY ARCHIVE
The Obituary Archive has a record for the subject.
Surviving Heirs:
Spouse — Tina L. Morelli Avara
Daughter — Leigh Ann Fox
Daughter — Alessia Louise Avara
II. Investigation for Estate Information
1. SURROGATES SEARCH
A search for estate documents was conducted with the Cumberland County Register
of Wills. After inquiry, the office of the Cumberland County Register of Wills
provided documentation that that there are no records for the subject on file.
III. Investigation for Next of Kin
1. TRACERS INFORMATION SPECIALISTS, INC.
Page 2
Investigation of Carl J. Avara continued:
Premium People Search:
Tina L. Morelli A/K/A Tina L. Avara (Spouse)
6316 Stephens Crossing
Mechanicsburg, PA 17050
717 766 -4275
443 324 -0895
Approximate age: 52
Leigh A. Avara (Daughter)
5027 NE Everett Street
Portland, OR 97213
503 230 -4858
Approximate age: 38
Alessia Louise Avara (Daughter)
6316 Stephens Crossing
Mechanicsburg, PA 17050
717 766 -4275
Kay F. Avara
6316 Stephens Crossing
Mechanicsburg, PA 17050
717 766 -4275
717 766 -1199
Approximate age: 29
Roscarol E. Kennedy A/K/A Rose R. Morelli A/K/A Roscarol E. Kennedy
811 Carol Circle
New Cumberland, PA 17070
717 770 -1333
Approximate age: 57
2. NEIGHBORS SEARCH
Jane P. Tamanini
6317 Stephens Crossing
Mechanicsburg, PA 17050
717 766 -7049
Approximate age: 50
Page 3
Investigation of Carl J. Avara continued:
Peter R. S. Burry
6313 Stephens Crossing
Mechanicsburg, PA 17050
501 851 -8345
717 766 -2780
Approximate age: 45
3. PHONE INVESTIGATION
Called (717) 766 -4275: On September 24, 2013 and September 27, 2013 and
September 30, 2013, deponent left voicemails for Tina Morelli. To date, they have
not been returned.
Called (443) 324 -0895: On September 24, 2013 and September 27, 2013, the
voicemail box was full, and deponent was unable to leave a voicemail for Tina
Morelli.
Called (503) 230 -4858: Number is not in service.
Called (717) 766 -1199: Number is not in service.
Called (717) 770 -1333: On September 24, 2013, deponent spoke with Mr. Kennedy.
Deponent left message with Mr. Kennedy to have Rose Kennedy return deponent's
call. To date, it has not been returned. On September 27, 2013 and September 30,
2013, deponent called and left voicemails for Rose Kennedy. To date, they have not
been returned.
Called (717) 766 -7049: On September 24, 2013 and September 27, 2013, deponent
left voicemails for Jane Tamanini. To date, they have not been returned.
Called (717) 766 -2780: On September 24, 2013 and September 27 2013, deponent
left voicemails for Peter Burry. To date, they have not been returned.
Called (501) 851 -8345: Number is not in service.
Called (717) 766 -2780: On September 27, 2013, deponent left a voicemail for Peter
Burry. On September 29, 2013, Peter Burry left deponent a voicemail stating that
he does not have any information regarding the subject.
Page 4
Investigation of Carl J. Avara continued:
The information set forth in this Death Investigation is true and correct to the best of my
knowledge, information and belief.
Notary Public:
Sworn to and subscribed
Before me this / day
of (f , 2013
,YAVOtee—tel
SIGNED:
PRINT NAME: Rita Mastrangelo
DATE: October 1, 2013
VERONICAANN IRVING
Notary Public, State of NEW YORK
01!R6273373
Quallried In Suffolk County
Commission Expires, DECEMBER 24, 2010
Carl J. Avara: Death Record from the Social Security Death Index (SSDI) -... Page 1 of 1
Carl J. Avara: Social Security Death Index (SSDI)
Death Record
Name: Carl J. Avara
State of Issue: Maryland
Date of Birth: Sunday January 12, 1941
Date of Death: Friday December 28, 2007
Est. Age at Death: 66 years, 11 months, 16 days
Confirmation: Verified
Last known residence:
Mechanicsburg; Defense Depot; Goodhope;
City: Hampden; Hampden Township; Hogestown;
Navy Ships; Navy Sup Dpt; Trindle Spring;
Wertzville
County: Cumberland
State: Pennsylvania
ZIP Code: 17050
Latitude: 40.2485
Longitude: - 77.0142
The Social Security Death Index (SSDI) is made available by the
Social Security Administration (SSA) to the public through a
number of websites, including GenealogyBank.com. As a result, we do
not control the information that is provided us in the SSDI.
In order to have information corrected or removed, please contact
your local Social Security Administration office. Documented proof of
an error may be required. Contact information for your local office can
be found at http: / /www.ssa.gov.
http:// www. genealogybank .com /gbnk/ssdi /doc /ssdi /v 1:11 E24E2C94824268 9/23/2013
Avara, Carl J. - Baltimore Sun
Our Best Job Posting Produci
Bundled at a &O% Discount!
-mo ns tenon,
Page 1 of 1
MARYLAND SPORTS ORIOLES BUSINESS LIFE HEALTH ENTERTAINMENT EVENTS OPINION VIDEO DEALS
Home —. Collections —. Katharine
Mortgage Rates Hit 3.16% APR Avara, Carl J.
soled Mortgage Amount:
S225
' $400
al.; $500
a ' $000
' s700
$e0o
5000
$1,000
$1,100
°s'•: $1,200
s1,300
$1,400
$1,500
61,600
•
ter tDtngtr ee-
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Related Articles
$1,700
ie $1,800
.' 61,900
62,000
$2,100
i4 $2,200
. 62,300
62,400
u 62,500
<.
roar. $2 >800
. 62,700
62,800
$2,900
63,000
Calculate New Payment
"I like the'Junie B. Jones' series by Barbara Park...
September 13, 2000
Ferrante, Sebastian F.
October23, 2004
Quote of the Week
June 2, 2005
Shriver, Robert C.
April 16, 2003
Find More Stories About
Katharine
December 31, 2007
ShE8balbthtore
0
On Friday, December 28, 2007, CARL JOSEPH AVARA, of Mechanicsburg, PA.
Born January 12, 1941 In Baltimore, son of the late Simon and Angelina Diggerstein Avara. Husband of Tina L. Morelli
Avara, father of Leigh Ann Fox of Portland, OR, Alessia Louise Avara at home. Preceded in death by first wife Kay
Franklin Avara and brother Salvatore. Mass 10:30AM Thursday, St. Katharine Drexel Church, Mechanicsburg. Viewing 6
to 8PM Wednesday at Malpezzl Funeral Home, Mechanicsburg. For complete obit and to sign guest book visit
www.malpezzlfuneralhome.com
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Possible Relatives
Search
5 Records
PP = Premium Profile, NC = National criminal records search, SX = Sex offender search,
RM = Possible roommates search, PL = Professional license search,
VO = Vehicle ownership search
SUBJECT INFORMATION
Name
SSN
DOB
PPNCSXSCRMPLVO
AVARA,CARLJ
1
1
PP NC SX SC RM PL VO
AVARA, CARL J
1
1
PP SX SC RM PL VO
AVARA, KAY F
I
1
Possible Relatives - 5 records
Name
Address
Phone
Dates
AVARA, KAY F
SSN:
Possible AKAs:
AVARA, KAY, J
Name
6316 STEPHENS
MECHANICSBURG, PA 17050
County: CUMBERLAND
05/14/2005
6316 STEPHEWS CROS
MECHANICSBR, PA 17055
County: CUMBERLAND
07/10/1996
6316 STEPHENS CRSNG
MECHANICSBURG, PA 17055
County: CUMBERLAND
11/01/1992
120 FARMINGTON
CHERRY HILL, NJ 08034
County: CAMDEN
Address
05/01/1971
Phone Dates
5027 EVERETT
PORTLAND, OR 97213
County: MULTNOMAH
09/11/2010
3529 TAYLOR
PORTLAND, OR 97214
County: MULTNOMAH
06/05/2007
3529 TROY
PORTLAND, OR 97219
County: MULTNOMAH
04/15/2007
6316 STEPHENS
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Tracers Information Specialists, Inc. - Possible Relatives Search
AVARA, LEIGH A
SSN:
DOB
Possi"6Te AR7As:
AVARA, LEIGH
AYARS, LEIGH, A
Name
MECHANICSBURG, PA 17050
County: CUMBERLAND
6316 STEPHENS XING
MECHANICSBURG, PA 17055
County: CUMBERLAND
25537 PERKINS
VENETA, OR 97487
County: LANE
3100 HAXTON
BELLINGHAM, WA 98226
County: WHATCOM
1429 JEFFERS
BALTIMORE, MD 21204
County: BALTIMORE
1429 JEFFERS
TOWSON, MD 21204
County: BALTIMORE
527 BEAVER
STATE COLLEGE, PA 16801
County: CENTRE
364 TRUMBULL
NEWFIELD, NY 14867
County: TOMPKINS
364 TRUMBULLS CORNERS
NEWFIELD, NY 14867
County: TOMPKINS
Address
Phone
Page 2 of 4
04/26/2005
11/13/2000
01/01/2000
02/24/1999
01/13/1998
01/01/1998
09/24/1997
08/01/1997
08/01/1997
Dates
MORELLI, AVARA TINA
SS
DO
Possible AKAs:
AVARA, TINA
MORELLI, TINA, L
AVARA, TINA, L
6316 STEPHENS
MECHANICSBURG, PA 17050
County: CUMBERLAND
11/14/2011
12 MALLARD
OCEAN PINES, MD 21811
County: WORCESTER
02/21/2011
12 MALLARD
BERLIN, MD 21811
County: WORCESTER
04/24/2009
6316 STEPHENS CROSS
MECHANICSBURG, PA 17050
County: CUMBERLAND
02/25/2008
7490304 T 66 58 67 85 304
MECHANICSBURG, PA 17050
County: CUMBERLAND
04/23/2003
6316 STEPHENS CROSS
MECHANICSBURG, PA 17055
County: CUMBERLAND
05/10/2002
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Tracers Information Specialists, Inc. - Possible Relatives Search Page 3 of 4
Name
5316 STEPHENS
MECHANICSVLLE, PA 18934
County: BUCKS
4623 OCEAN B
BERLIN, MD 21811
County: WORCESTER
11000 COASTAL 1610
OCEAN CITY, MD 21842
County: WORCESTER
Address
Phone
MORELLI, LOUISE B
SSN:
DOB:
Posse a s:
MORELLI, LOUISE, C
MORELLI, LOUISE
MORRELLI, LOUISE, C
6316 STEPHENS XG
MECHANICSBURG, PA 17050
County: CUMBERLAND
215 CHOCOLATE 3E
HERSHEY, PA 17033
County: DAUPHIN
RR2 BOX 330
HERSHEY, PA 17033
County: DAUPHIN
663 DERRY
HERSHEY, PA 17033
County: DAUPHIN
PO BOX 2
HERSHEY, PA 17033
County: DAUPHIN
RR 2 BOX 330A
HERSHEY, PA 17033
County: DAUPHIN
PO BOX 330
HERSHEY, PA 17033
County: DAUPHIN
POB 330
HERSHEY, PA 17033
County: DAUPHIN
0 2 POB 30 A
HERSHEY, PA 17033
County: DAUPHIN
PO BOX 330A
HERSHEY, PA 17033
County: DAUPHIN
RR 2 POB 330
HERSHEY, PA 17033
County: DAUPHIN
RR 2 BOX 330
HERSHEY, PA 17033
03/18/2002
07/17/2001
07/13/2001
Dates
10/04/2011
07/04/2011
12/16/2006
04/29/2005
08/16/2001
08/16/2001
11/13/2000
11/13/2000
11/13/2000
08/31/1998
09/01/1993
09/01/1993
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Name
County: DAUPHIN
Address
Phone
Page 4 of 4
Dates
MORELLI. ROSCAROL E
SSN:
DOB:
Posse a s:
MORELLI, ROSE
KENNEDY, ROSCAROL,
KENNEDY, ROSCAROL
KENNEDY, ROSE, E
ROSCASOL, KENNEDY
E
811 CAROL
NEW CUMBERLAND, PA 17070
County: CUMBERLAND
09/07/2011
6316 STEPHENS
MECHANICSBURG, PA 17050
County: CUMBERLAND
04/29/2011
811 CAROL
NEW CUMBERLND, PA 17070
County: CUMBERLAND
10/15/2005
3010 DERRY
HARRISBURG, PA 17111
County: DAUPHIN
07/13/2001
RR 3010
HARRISBURG, PA 17111
County: DAUPHIN
11/13/2000
801 WALNUT 6
LEMOYNE, PA 17043
County: CUMBERLAND
10/05/2000
801 WALNUT P
LEMOYNE, PA 17043
County: CUMBERLAND
11/20/1999
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Tracers Information Specialists, Inc. - Premium People Search Page 1 of 1
Premium People Search
4 Records
Search Criteria
Address: 6316 STEPHENS CROSSING
City: MECHANICSBURG
State: PA
Zip: 17055
Reports
Name Address
Maps SSN / DOB Phone
MORELLI
TINA L
AKA:
AVARA
TI NA L
6316 STEPHENS 1x
CROSSING
MECHANICSBURG
PA 17050
Reported: 07/01/2000 -
07/01/2000
County: Cumberland
Map
It
AVARA
KAY J
6316 STEPHENS 1x
CROSSING
MECHANICSBURG
PA 17055
Reported: 09/01/1999 -
09/01/1999
County: Cumberland
Map
It
- _- -� -_"-_
INC
PINKY
LEE
6316 STEPHENS 2x
CROSSING
MECHANICSBURG
PA 17055
Reported: 10/01/1998 -
10/01/1998
County: Cumberland
Map
It
AVARA
KAY F
6316 STEPHENS 1x
CROSSING
MECHANICSBURG
PA 17055
Reported: 10/01/1987 -
10/01/1987
County: Cumberland
Map
It
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53 Records
Search Criteria
SSN:
Reports Name Address Maps SSN / DOB Phone
MORELLI
TINA L
6316 STEPHENS 8x
XING
MECHANICSBURG PA
17050-2338
Reported: 06/30/1995 -
09/19/2013
County: Cumberland
Land line:
(717)
766-
Map 4275
It Cell:
(443)
324-
0895
1-0
TL
AVARA
6316 STEPHENS 4x
XING
MECHANICSBURG PA
17050-2338
Reported: 01/01/2003 -
09/19/2013
County: Cumberland
Land line:
(717)
766-
Map 4275
It Cell:
(443)
324-
0895
AVARA
TINA L
6316 STEPHENS 7x
XING
MECHANICSBURG PA
17050-2338
Reported: 06/30/1995 -
09/19/2013
County: Cumberland
Land line: (717)
766-
Map 4275
It Cell:
(443)
324-
0895
MORELLI
AVARA
TINA
6316 STEPHENS 3x
XING
MECHANICSBURG
PA 17050-2338
Reported: 06/30/1995 -
09/19/2013
County: Cumberland
Map
2414
MORELLI
TINA L
12 MALLARD DR 2x
OCEAN PINES MD
21811-1747
Reported: 08/01/2000 -
02/21/2011
County:
WORCESTER
Map
It
12 MALLARD DR 6x
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O LEAN PINES MD
1747
Reported: 08/01/2000 _
02/21/2011
County:
WORCESTER
2 MALLARD p
2x
21811 -1747
OCEAN PINES MD
Reported: 11108/0 ?/2000 _ Map
County: it
WORCESTER
.
AVARA
TINA L
MORELLI
AVARA
TINA
AVARA
TINA L
AKA:
AVARA
TIIVARA
AKA:
MORELLI
TINA L
AKA:
AVARA
TINA
TINA LlLl
AKA:
AVARA
TINA L
AKA:
AVARA
TINA
MORELLI
TINA L
AKA:
AVARA
TINA L
AKA:
AVARA
TINA
Repot Name
AVARA
TINA L
AKA:
AMORELLI
TINARA
AKA:
MORELLI
Map
It
42 BMALLARD DR 8
BERLIN MD 21811_
1747
Reported. 08/0112000
04/24/2009
County: WORCESTER
:2rALLARDDR 10x
BERLIN MD 21811_
1747
04 24/2010/10/1997 -
County:
WORCESTER
Map
It
Map
lt
6316 STEPHENS XI 4
MECHANICSg URG PA
17050 -2338
11/24 2 08 7/01 /2000 _ Map
County Cumberland It
Address
6316 STEPHENS XI 6
MECHANICSBURG 050- PA
2338
Reported: 10/0111999 _
Count
Cumberland
Maps
Map
It
Page 2 of 8
Landline:
(410)
208-
2882
Landline:
(717)
766_
4275
Landline:
(410)
208_
2882
Landline:
(717)
766-
4275
Phone
Landline:
(717)
766 -
https: / /wvW .trace rsinfo, c 4275
Landline:
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urn Php3 ?pargs_y
°x0 • 9/23/2013
Tracers Information Specialists, Inc. _ Premium p
TINA L eoPle Search
AKA:
AVARA
TINA
6316 CROSS EPHENs
AE1 0501CSBURG
Reported. 02/25/2008
02/25/2008
County; Cumberland
631 STEPHENS
CROSS
T NA
RA MECHANICSBU
L A 17050 RG
Reported: 0 0225/2008
Cunt 8
County: Cumberland
6316 STEPHENS
MORELLI CROSS 1 x
NARA AE1 0501CSBURG
Reported. 02/25/2008
02/25/2008
County; Cu
6316 STEP HENS RA X/NG HENS 4x
L
READING PA 19604
Reported, 12/31/2002 rap
12/18/2006 t
County- Berks
304 7490304 T66 Ix
58
MECHANICSBURG G
Reported: 12/17/2006 -
Count
County: Cumberland
XING STEPHENS 1
MECHANICSBURG
PA 17050 -2338
05/28/2004
5/28/2004
County' Cumberland
A
T/
NA
VA
TINA
AVARA
TINA L
MOA ELLI
AVARA
MORELLI
AVARA
TINA
12 A/IALLARD DR
AKA: BERLNMD2181
MORELL/ 1747 1 _ 5x
MORELLI
TINA L
M
x
Map
It
Map
It
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nfo, com /Se (410) archCentral /vie 208_
return. php3 ?pargs_yTox0
9/23/24.13
Page 3 of 8
208_
2882
Reports
Tracers Information rmatioa Specialists, Inc. _
TINA L premium people Search
h
AKA: A
03/14/2004 3/05/200 ] _
AKA County: WORCESTER
AVARA
TINA L
A
TI
MOR
TINA
MOREL
TINA L
MORELLI
AVARA
TINA
I
7490304 T 66 58 672x
85 304
AEC 050ICSSURG
Reported: 04/23/2003
04/23/2003
County: Cumberland
85
7490304 T 66 58 672/Map
PA 17050
1CSQURG
Reported: 04/23/2003
County: Name Cumber/and
Address
7490304
OREL 85304 T6658671x
RA LI AEC oANICSBURG
A 50
04/23/2003 4/23/2003 -
County; Cumberland
+nberiand
CROSS EPHENS 1x
ELLI MECHANICSg
L PA 17055 URG
05/10/2002 10/20/1998
:N0:nt1an EPHENS 1x
LI $934 ANICSVLL A
EP
Reported. 03/18/200 Mt p
03t18/2002 2 I
County: SUCKS
XING ST EPHENS Ix
8934 ANICSVLLE PA
Reported: 3 0 3/18/2002
County: SUCKS
MNRELLI
AL
Map
It
Map
it
AVARA
TINA L
Map
It
Maps
Map
It
Map
It
I
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p3 • pargs- yl'ox0 9/23/2013
Page 4 of 8
2882
Landline:
(717)
766_
4276
Phone
Reports
Tracers Information Specialists,
Inc, - Premium P
epple Search
5316 XING ST EPHENS 2x
18934 MECHANICSVLLE PA
03/1812002 3/18/2002
County: BUCKS
4623OCEANB
Reported: MD 21811 6x
ported: 07/17/2001 _
07/1712001 Map
County. It
WORCESTER
4623 OCEAN 8
Reported:
BERLIN MD 21811 3x
07 00 ?07/1712001 - Ma
LI
County: It p
WORCESTER
HW 16 /0OASTAL 6
OCEAN CITY MD
21842 -.7996
07/13/2001 07/13/2001
County' WORCESTER
AVgRA
TINA L
TINA RELLI
L
AVARA
TINA L
A VARA
TINA L
M R:
TINA LL
AVgRA
TINA L
AKA:
A ORELLI
TINA A
AKA:
MORELLI
L
A ARALi
TINA
AKA:
MORELLI
L
Map
It
11000 COASTAL
HW 1610
OCEAN CITY MD
21842_7996
Reported: 07/13/2001
07/13/2001
County:
WORCESTER
Map
It
3x
Map
It
11000 COASTAL 6x
TINA
OCEAN 0 AST
21842- CITY MD
RA
Reported: 7996
07/13/2001 07/13/200, /Map
County:
Name WORCESTER
Address
MORELLt DR
TINA BERLIN MD D 1
AVgRA Reported, 03/05 2
03/05/2001 6t2001 -
County: WORCESTER
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MORELLI
TINA L
AKA:
AVARA
TINA L
POB 330 4x
HERSHEY PA 17033 -
0330
Reported: 11/13/2000
11/13/2000
County: Dauphin
MORELLI
AVARA
TINA
MORELLI
TINA L
6316 STEPHENS 1x
XING
MECHANICSBURG
PA 17055
Reported: 10/01/2000 -
10/01 /2000
County: Cumberland
Map
It
MORELLI
AVARA
TINA
AKA:
MORELLI
TINA L
6316 STEPHENS 2x
XI
MECHANICSBURG
PA 17050 -2338
Reported: 10/01/2000 -
10/01/2000
County: Cumberland
Map
It
MORELLI
TINA L
AKA:
AVARA
TI NA L
6316 STEPHENS 1x
CROSSING
MECHANICSBURG
PA 17050
Reported: 07/01/2000 -
07/01/2000
County: Cumberland
Map
It
AVARA
TINA L
AKA: .
MORELLI
AVARA
TINA
AKA:
MORELLI
TINA L
6316 STEPHENS 1
XING
MECHANICSBURG PA
17055
Reported: 10/01/1999 -
10/01/1999
County: Cumberland
Map
It
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MORELLI
TINA L
PO BOX 330A 1x
HERSHEY PA 17033 -
0330
Reported: 09/06/1996
05/12/1999
County: Dauphin
My
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AVARA
TINA L
PO BOX 330A 2x
HERSHEY PA 17033-
0330
Reported: 09/06/1996 -
05/12/1999
County: Dauphin
PO BOX 330A lx
HERSHEY PA 17033-
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AVARA
TINA L
MORELLI
AVARA
TINA
AVARA
TINA L
MORELLI
AVARA
TINA
MORELLI
AVARA
TINA
ANDERSONTOWN
PA 17055
Reported: 06/23/1996 -
06/23/1996
County: Cumberland
2036 JO 1x
ANDERSONTOWN
PA 17055
Reported: 06/23/1996 -
06/23/1996
County: Cumberland
11000 COASTAL 1 x
HWY 1610
OCEAN CITY MD
21842 -7903
County:
WORCESTER
330 PO BOX 1 x
HERSHEY PA 17033-
0330
County: Dauphin
11000 COASTAL
HWY 1610
OCEAN CITY MD
21842 -7903 •
County:
WORCESTER
Map
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Map
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Map
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Map
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Reports
Name
MORELLI
TINA L
MORELLI
AVARA
TINA
AVARA
TINA L
Address
Maps Phone
RR 2 3x
HERSHEY PA 17033
County: Dauphin
RR 2 3x
HERSHEY PA 17033
County: Dauphin
RR 2 3x
HERSHEY PA 17033
County: Dauphin
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Reports Name Address
Maps SSN / DOB Phone
AVARA
LEIGH A
5027 NE EVERETT 4x
ST
PORTLAND OR
97213 -3030
Reported: 06/30/2007 -
09/20/2013
County: Multnomah
Map
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AYARS
LEIGH A
5027 NE EVERETT 1x
ST
PORTLAND OR
97213 -3030
R eported: 07/11/2007 -
09/11 /2010
County: Multnomah
Map
It
AVARA
LEIGH A
6316 STEPHENS 7x
XING
MECHANICSBURG
PA 17050 -2338
Reported: 07/01/1994 -
06/29/2007
County: Cumberland
Map
It
AVARA
LEIGH A
3529 SE TAYLOR 4x
ST
PORTLAND OR
97214 -4489
Reported: 10/31/2000 -
06/29/2007
County: Multnomah
Map
It
AYARS
LEIGH A
3529 SE TAYLOR 1x
ST
PORTLAND OR
97214 -4489
Reported: 01/24/2004 -
06/05/2007
County: Multnomah
Map
It
AVARA
LEIGH A
3529 SW TROY ST 2x
PORTLAND OR 97219-
1660
Reported: 04/09/2007 -
Map
It
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04/15/2007
County: Multnomah
3529 SW TROY ST Ix
PORTLAND OR
County: Arlultnomah
Reported: N/09/2007 - It
04//5/2007
97219-1660 /Map 1
XING
3/6 STEPHENS 'Ix
MECHANICSBURG
PA /7050-2338 Map
Reported: 07/14/1994 -
04/26/2005 It
County: Cumber/and
C/R
18365 LOST KNIFE ix
MONTGOMEF?Y
VILLAGE MD 20886-
0324
Rported: 04/2001 -
04/2001
County:
MONTGOMERY
XING
6316 STEPHENS IxI
County: Cumberfand
Reported: 11/13/2000 -
PA 17055
11/13/2000
MECHANICSBURG / Map
It
Address
6316
XI STEPHENS 2x
MECHANICSBURG
PA 17050-2338
Reported: 1 -
/1/13/2000 1/13/2000
Count
25537 y: Cumberland
RD
PERKINS 4x
VENETA OR 97487-
9758
Reported: 01/01/2000 -
01/01/2000
County: LANE
AY,ARS
LEIGH A
AYARS
LEIGH A
AVARI
VIRAF
AVARA
LEIGH A
Reports Name
Map
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AVARA
LE/GH A
AVARA
LEIGH A
Maps
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354 MILL GREEN Ix
AVARITT
STREET IVID 21154-
1727
/
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Page 2 of 4
1111(L3a0an1d)line:
1 216.-
2396
/11
Phone
lair
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G Reported: 08/1999
08/1999 It
County: HARFORD
AVARA
LEIGH
AVARA
LEIGH A
WAY HAXTON 7x
AVARA BELLINGHAM
LEIGH A
AY
LEI
527 AVE W BEAVER 3x
STATE LOLL
A 116801 -4035 COLLEGE PA Map _ It p
County Centre
527 VV STATEBEAVER L 5x
EGE
16801 -4035 E PA
07� 999d' 09101!1997 _
County. Centre
Map
It
98226-7219 WA
Reported: 08/01/1998 /MaP
t
02/24/1999
County: Whatcom
3100 HAXTON
WAY 1x
ARS BELLINGHAM
LEIGH A `98226 -7219 WA
02/24/1999
/01/1998 _
County: Whatcom
1429 JEFFERS
A TOWSONMD21204_I A 1929
Reported, 01/01/1998 Map
09/1998 It
County: BALTIMORE
1429 JEFF
BALTIMORE D 3x
21204 -1929
Reported: 01/13/1998 3/1998 _
County: BALTI
1429 JEFF MORE'
BALTIMOREEMD D 1 x
21204_1929
01/13/1998 01/13/1998 _
County BALTIMORE
AVAR
LEIGH
AVARA
LEIGH A
AYARS
LEIGH A
Map
It
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It
Map
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Page 3 of 4
Landline:
(814)
861_
6629
Landline:
(814)
I 61648
min
• is I. 1.1
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Reports Name Address Maps SSN / DOB Phone
r-
AYARS
LEIGH A
527 W BEAVER 1 x
AVE
STATE COLLEGE PA
16801-4035
Reported: 12/12/1995 -
09/24/1997
County: Centre
Map
It
AVARA
LEIGH
364 S TRUMBULL ix
NEWFIELD NY 14867
Reported: 08/01/1997 -
08/01/1997
County: Tompkins
Map
It
AVARA
LEIGH A
364 TRUMBULLS 5x
CORNERS RD
NEWFIELD NY
14867-9274
Reported: 07/17/1997 -
08/01/1997
County: Tompkins
Map
It
AYARS
LEIGH A
364 TRUMBULLS lx
CORNERS RD
NEWFIELD NY
14867-9274
Reported: 07/17/1997 -
07/17/1997
County: Tompkins
Map
It
AVARA
LEIGH A
1429 JEFFERS RD lx
TOWSON MD 21204-
1929
County: BALTIMORE
Map
It
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Search Criteria
Name: AVARA, ALESSIA
Zip: 17050
Reports Name Address Maps SSN / DOB Phone
AVARA
ALESSIA
•
6316 STEPHENS Ix
XI
MECHANICSBURG
PA 17050-2338
Reported: 06/01/2011 -
06/01/2011
County: Cumberland
Map
It
Land line:
(717)
766-
4275
AVARA
ALESSIA
6316 STEPHENS 2x
XING
MECHANICSBURG
PA 17050-2338
Reported: 03/2008 -
03/2008
County: Cumberland
Map
It
mum
Landline:
(717)
766-
4275
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Search Criteria
SSN: 11111111
Reports
Name Address Maps SSN / DOB Phone
KENNEDY
ROSCAROL E
811 CAROL CIR 5x
NEW CUMBERLAND PA
17070 -1418
Reported: 01/01/2000 -
09/20/2013
County: Cumberland
Map
It
Landline: (717)
770 -1333
MORELLI ROSE R
811 CAROL CIR 3x
NEW CUMBERLAND PA
17070 -1418
Reported: 01/01/2000 -
09/20/2013
County: Cumberland
Map
It
Landline: (717)
770 -1333
MORELLI ROSE E
811 CAROL CIR 1x
NEW CUMBERLAND PA
17070 -1418
Reported: 01 /01/2000-
09/20/2013
County: Cumberland
Map
It
ROSCASOL
KENNEDY
AKA: KENNEDY
ROSCAROL E
AKA: KENNEDY
ROSE E
811 CAROL ST 5x
NEW CUMBERLAND PA
17070 -1418
Reported: 01/01/2000 -
09/20/2013
County: Cumberland
Map
It
Landline: (717)
770 -1333
,
MORELLI
ROSCAROL E
811 CAROL CIR 3x
NEW CUMBERLAND PA
17070 -1418
Reported: 01/01/2000 -
09/20/2013
County: Cumberland
Map
It
Landline: (717)
770 -1333
MORELLI ROSE R
6316 STEPHENS XING 2x
MECHANICSBURG PA
17050 -2338
Reported: 12 /31/1999-
09/19/2013
County: Cumberland
Map
It
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KENNEDY
ROSCAROL E
6316 STEPHENS XING 4x
MECHANICSBURG PA
17050 -2338
Reported: 12/31/1999 -
09/19/2013
County: Cumberland
Map
It
MORELLI
ROSCAROL E
6316 STEPHENS XING 2x
MECHANICSBURG PA
17050 -2338
Reported: 12/31/1999 -
09/19/2013
County: Cumberland
Map
It
MORELLI ROSE
AKA: KENNEDY
ROSCAROL E
AKA: KENNEDY
ROSE E
811 CAROL CI 1x
NEW CUMBERLAND PA
17070 -1418
Reported: 06/01/2011 -
06/01/2011
County: Cumberland
Map
It
Landline: (717)
770 -1333
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LEMOYE WALNUT T ST 6 3x
Reported: 10/01/1995 1 __
12/01/2007
County: Cumberland
Address
LEMOyLNUT ST6
Reported: 1P0/01/1995 1579
12/01/2007
County' Cumberland
801 WALNUT
LEMOYNE PA 17043 -1579 ex
112101200710J01 /1995
County: Cumberland
801 WALNUT ST 6
Reportedly 01 /10 51579
12/01/2007
County: Cumberland
801 WALNUT
ST 6
LEMOYNE PA 17043 -1579 3x
Reported: 10/01/1995 _
12/01/207
County Cumberland
Reports
MORELLI
ROSCAROL E
Name
ROSCASOL
KENNEDY
KENNEDY
ROSCAROL E
MORELLI ROSE R
MORELLI ROSE E
ROSCAROL
AKA: AROL E
ROSEMORELLI
AKA: KENNEDY
ROSCAROL
AKA: KENNEDY
ROSCAROL
ROSC LLl
AKA. AROL E
ROSEMORELLt
AKA: KENNEDY
ROSCAROLE
AKA: KENNEDY
ROSCAROL
KENNEDY
ROSCAROL
AKA: MORELL/
ROSCAROLE
AKA: KENNEDY
ROSCAROL
KENNEDY
ROSCAROLE
AKA: MORELLI
ROSCAROLE
MORELLI
ROSCAROL E
KENNEDY
ROSCAROL E
811 CAROL CI
/ 70 70-1 4186ERLND PA
Reported: 10/15/205 -
10/15/2005
County: Cumberland
811 CAROL CI
7p CUMBERLAND PA
ap 5/2 0510!15/2005 _
County: Cumberland
811 CAROL CI
170 0 14186ERLND PA
Reported: 10/15/2005 -
10/15/2005
County: Cumberland
811 CAROL CIR
NEW CUMBERLAND
17070-1418 PA
Reported: 01/01/200
03/22/20D2
County: Cumberland
3010 DERRY ST
HARRISBURG PA 17111_
Reported: 07/13/2001 -
07/13/2001
County: Dauphin
3010 DERRY ST
HARRISBURG PA 17111_ 1
1603
0713 200107113/2001 -
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MORELLI
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KENNEDY
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ROSCLLI
ROSCAROL
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MORELLI ROSE
KENNEDY
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ROSCAROL E
ounty: Cumberland
801 WALNUT P
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Reported: EPA 17p�3 S lx
LEMO
11/20/19911120 /1999 _
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WALNUT P
RepportYNE' PR 1 043 S 2x
11/20/199911 /20/1999
County: Cumberland
DERRY ST
HARRISBURG PA 17111- 2x
Reported: 09/17/1993
02/12/1999
County: Dauphin
3010 DERRY ST
HARRISBUIG PA 17111_ 2x
Reported: 09/17/1993 _
County: �`: Dauphin
3010 DERRY ST
HARRISBURG PA 17111- 3x
1603
Reported: 09/17/1993 _
0y12/1999
County: Dauphin
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801 LEMOyLNUTST
Reported: 09/01/1997 0l X9971555
09/01/1997
County, Cumberland
80/ WALNUT ST
DYNE PA 17043 -1555 2x
09/01/199d: 9/01/1997 _
County: Cumberland
801 WALNUT ST
LEMOYNE PA 17043.15 5S
3x
Reported: 09/01/1997 _
09/01/1997
County: Cumberland
1102 GREEN ST
HARRISBURG A 17102_ 3x
P
10/15/1992 10/16/1989 _
County: Dauphin
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2919
10/15 99210/1611989.
County: Dauphin
1102 GREEN ST
HARRISBURG PA 17102- 2x
2919
ROp 5!199210/16/1989
County: Dauphin
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2630 RUMSON DR 1u
HARRISBURG PA 17104-
1542
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HARRISBURG PA 17104-
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1542
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Search Criteria
SSNMIIIME
Reports Name Address Maps SSN / DOB Phone
KAY F
6316 STEPHENS 5x
XING
MECHANICSBURG PA
17050 -2338
10/17/1991 -
09/19/2013
County: Cumberland
Map
AVARAReported:
YRMECHANICSBURG
6316 STEPHENS 2x
XING
PA 17050 -2338
Reported: 10/17/1991 -
09/19/2013
County: Cumberland
Map
Mat
AVARA
KAY F
120 FARMINGTON 6x
CHERRY HILL NJ
08034 -3311
Reported: 05/01/1971 -
05/30/2005
County: Camden
Map
It
AVARA
KAY J
120 FARMINGTON lx
RD
CHERRY HILL NJ
08034 -3311
Reported: 05/01/1971 -
05/30/2005
County: Camden
Map
It
..at°
AVARA
KAY F
6316 STEPHEWS 2x
CROS
MECHANICSBR PA
17055
Reported: 05/01/1988 -
07/10/1996
County: Cumberland
Ma p
It
6316 STEPHEWS 1x
CROS
MECHANICSBR PA
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AVARA
KAY J
17055
Reported: 05/01/1988 -
07/10/1996
County: Cumberland
Map
It
AVARA
KAY F
6316 STEPHENS 2x
XI
MECHANICSBURG
PA 17050-2338
Reported: 11/01/1992 -
11/01/1992
County: Cumberland
Map
It
AVARA
KAY F
6316 STEPHENS lx
CRSNG
MECHANICSBURG
PA 17055
Reported: 11/01/1992 -
11/01/1992
County: Cumberland
Map
It
AVARA
KAY F
6313 STEPHENS 2x
XING
MECHANICSBURG
PA 17050-2347
Reported: 04/30/1971 -
04/30/1971
County: Cumberland
Map
It
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Reports
Name
KENNEDY
ROSCAROL
MORELLI
ROSE R
ROSELU
EE
ROSCASO L
KENNEDY
AKA:
KENNEDY
ROSCAROL
AKA:
KENNEDY
ROSE E
MORELLI
E OSCARO
MORELLI
ROSE R
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Address
CV 5x Maps
PA 1707T -AND , 09!20/2013 Q 1/2000 _ Mp ICounty; CumberlROL CPA 1x
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5x
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811 CAROLCounty; Cumber /a
811 CARA W070 -14 01/01/2000
09t200Cout: Cumberl
CR
Reported: 01/01/20009/20/2013 County: CumberlanXING
6316 STEPHENS 2x
1/1999 County Cumbea
5310 STEPHENS 4x
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County: Cumber
MORELLI
ESCAROL
AKA:
MORELLI
ROSE
AKA:
KENNEDY
ROSCAROL
AKA:
KENNEDY
ROSCAROL
MORELLI
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AKA:
MORELLI
ROSE
AKA:
KENNEDY
ROSCAROL
AKA:
KENNEDY
ROSCAROL
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ROSCAROL
AKA:
MORELLI
ESCAROL
AKA:
KENNEDY
ROSCAROL
KENNEDY
ROSCAROL
AKA:
MORELLI
ESCAROL
MORELLI
ROSCAROL
County: Cumberland
Reported: 10/15/2005 -
10/15/2005 lap
It
811 CAROL CI lx
NEW CUMBERLND PA
17070-1418
811 CAROL CI 2x
NEW CUMBERLAND
PA 17070-1418
Reported: 10/15/2005 -
10/15/2005
County: Cumberland
County: Cumberland
Reported: 10005 -
10/15/2005 I
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It
811 CAROL C/ lx
NEW
ND PA
17070-1418
8/1 CAROL CIR 2x
NEW CUMBERLAND
PA 17070-1418
Reported:
03/22/2002 01/01/2000 -
County: Cumberland
3010 DERRY ST Ix
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7111-/603
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Reported: 07/13/2001 -
07/13/2001
County: Dauphin
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KENNEDY
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County: Dauphin
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17111 -1603
HARRISBURG PA DERRY ST 2x
Reported: 09/17/1993
02/12/1999
County; Dauphin
3010 DERRY ST 3x
HARRISBURG PA
17111 -1603
Reported: 09/17/1993
02/12/1999
County; Dauphin
LEMpyNE WALNUT ST 2x
1555 A 17043_
09/01/1997 /01/1997
County: Cumberland
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801 WALNUT ST 3x
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17102 -2919
Repo 10/1/199d: 210/16/1989
County: Dauphin
Address
1102 GREEN ST
HARRISBURG PA 2x
17102 -2919
Reported: 10/16/1989
10/15/1992
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County: Dauphin
1102 GREEN ST
17102-29HARRISBURG PA 2
19
Reported: 10/16/1989
/0/15/1992
County: Dauphin
2630 RUMSO
HARRISBURG PA
17104-1542
County: Dauphin
2630 RUMSON DR lx
HARRISBURG PA
17104-1542
County: Dauphin
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2630 RUMSON DR lx
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17104-1542
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County: Dauphin
3010 DERRY ST R1lx
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1102 GREEN ST 'Ix
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County: Dauphin
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17111
County: Dauphin
RR 30/0
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17111
County: Dauphin
RR 3010
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MORELLI
ROSE R
1102 GREEN ST lx
HARRISBURG PA
17102 -2919
County: Dauphin
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HARRISBURG PA
17111 -1603
County: Dauphin
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TAMANINI
JANE P
6317 STEPHENS 5x
XING
MECHANICSBURG
PA 17050 -2347
Reported: 09/19/1992 -
09/21/2013
County: Cumberland
Map
It
Landline:
(717)
766 -
7049
TAMANINI
JANE M
6317 STEPHENS 1x
XING
MECHANICSBURG
PA 17050 -2347
Reported: 10/01/1992 -
09/21/2013
County: Cumberland
Map
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PELLEGRINO
JANE M
6317 STEPHENS 2x
XING
MECHANICSBURG
PA 17050 -2347
Reported: 10/01/1992 -
09/21/2013
County: Cumberland
Map
It
Landline:
(717)
766-
7049
JANE
TAMANINI
6317 STEPHENS lx
XING
MECHANICSBURG
PA 17050 -2347
09/19/1992 -
05/17/2010
County: Cumberland
Map
It
TAMANINI
JANE
TAMANIN
6317 STEPHENS lx
XING
MECHANICSBURG
PA 17050 -2347
Reported: 09/19/1992 -
05/17/2010
County: Cumberland
Map
It
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TAMANINI
JANE P
610 BRIDGE ST A 3x
NEW CUMBERLAND
PA 17070 -1932
Reported: 07/18/2001 -
07/18/2001
County: Cumberland
Map
It
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JANE P 610 BRIDGE REAR lx
AKA: ST A
PELLEGRINO NEW CUMBERLAND
JANE M PA 17070
AKA: Reported: 07/18/2001
TAMANINI 07 /18/200/
TAMA/Nil/VI
JANE County: Cumberland
JANE P
AKA:
PELLEGR/NO
JANE M
AKA:
TAMANINI
JANE
TAMANINI
JANE P
AKA:
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JANE
AKA:
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JANE P
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19 CEDARHURST 8x
County: Cumberland
Reported: 06/08 -
11/13/2000 1/198
9A0M6P HILL PA 170/ IMap
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3/7 STEPHENS XI 3x
County: Cumberland
Reported: 08/01/200 -
08/01/2000 IMap
It
MECHANICSBURG PA
17050-6865
317 STEPHENS
County: Cumberland
Reported: 0 8/01/2000 -
08/01/2000 "Map
It
CROSSING 'Ix
17050 U
MECHANICSBRG PA
Address
XING
317 STEPHENS 'Ix I
County: Cumberland
Reported i : 10/01/1992
07/31/2000
PA 17050
MECHANICSBURG Map
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6317 STEPHENS 3x
CROSS/
MECHANICSBURG
PA /7055
Reported: 09/28/1998 -
09/28/1998
County: Cumberland
6317 STEPHENS
CROSS!
MECHANI
17055 CSBURG PA
Reported: 0
09/28/1998 9/28/1998
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ounty: Cumberland
6317 STEPHENS lx
CROSS/
MECHAN/CSBURG
/Map
PA 17055
It
Reported: 09/28/1998 -
09/28/1996
County: Cumberland
6317 STEPHENS 2x
XI
MECHANICSBURG /Map
PA 17050-2347
It
Reported: 10/01/1992 -
10/01/1992
County: Cumberland
6317 STEPHENS 1x
CROSSING
MECHANICSBURG PA
17055
Reported: 10/01/1992 -
10/01/1992
County: Cumberland
19 CEDARHURST lx
LN
CAMP HILL PA
/Map
170/1-7906
It
Reported: 09/30/1992 -
09/301/992
County: Cumberland
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LN
INo
CAMP HILL PA
1701 1-7906
Reported: 09/30/1992
09/30/1992
County: cumberiand
19 CEDARHURST
LN
CAMp HILL PA
1701 1-7906
Reported: 06/01/1988 -
06/15/1992
County: Cumberland
19 CEDARHURST
LN
CAMP HILL PA
17011-7906
Repoted: 06/01/1988 -
06/15/1992
County: Cumberland
Address
Page 3 of4
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610 BRIDGE ST A lx
PELLEGRINO NEW CUMBERLAND Map
JANE M PA 17070 -2077 It
County: Cumberland
Page 4 of 4
TAMANINI
JANE M
610 BRIDGE ST A lx
NEW CUMBERLAND
PA 17070 -2077
County: Cumberland
Map
It
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BURRY
PETER
R S
6313 STEPHENS 8x
XING
MECHANICSBURG
PA 17050 -2347
Reported: 01/01/2002 -
09/19/2013
County: Cumberland
Map
It
BURRY
PETER
R
6313 STEPHENS lx
XING
MECHANICSBURG
PA 17050 -2347
Reported: 01/01/2002 -
09/19/2013
County: Cumberland
Map
It
BURRY
PATER
R S
6313 STEPHENS lx
XING
MECHANICSBURG
PA 17050 -2347
Reported: 03/02/2006 -
05/07/2010
County: Cumberland
Map
It
PETER
BURRY
S
6313 STEPHENS lx
XING
MECHANICSBURG
PA 17050 -2347
Reported: 03/02/2006 -
05/07/2010
County: Cumberland
Map
It
BURRY
PATER
R S
214 COUNTRY lx
CLUB PKWY
MAUMELLE AR
72113 -6732
Reported: 10/02/2002 -
03/05/2008
County: Pulaski
Map
It
PETER
214 COUNTRY lx
CLUB PKWY
MAUMELLE AR
Map
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72113 -6732
Reported: 10/02/2002 _ It
03/05/2008
County: Pulaski
BURRY
CLUB COUNTRY 5x
PETER
2A1 MELK AR
3 6732
Reported. 10/02/2002 _ Map
03/05/2008
County: Pulaski
21 MARLBERRY 8x
CT
R ALPHARETTA GA
30004_4340
Reported: 10/07/1996 - Map
01/31/200?
County: FULTpN
CT
21 MARLBERRY 7/Map
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Reported: /0 /07/1
01/31/2007 996 It
County: FULTpN
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BURRY
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BURRY
PETER
BURRY
PETER
AKA:
BURRY
PETER
AKA:
PETER
BURRY
Name
2070 DERBY ON A 2x
30517_2448
01/01/2007
Reported: _
County: JACKSON
3343 p Address
RY NERD HTREE lx
R 1085
ATLANTA GA 30326_
1130 20pg11/30/2g06 _
County: FULTpN
CT MARLBERRY lx
30004ARETTA GA
4349
Reported, 08/06/1998 -
11/29/2006
County: FULTpN
BURRY
PETER
BURRY
Map
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1085
Reported: 09/22/1999 -
07/23/2003
County: FULTON
Reports
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BU
PE
RS
P
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Name
PETER
BURRY
BURRY
RS
Map
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Address
8390 ROSWELL RD1/Map
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ATLANTA GA 3035o_
2827
Reported: 05/19/
03/09/2p03 2001 It
County: FULTON
8390 RO
B SWELL Rp1x
PATER
GA 30350_
2827
03/09/2003 5119/2001,
County: FULTON
BUR CLUB COUNTRY 1x
PETER
MAUMELLE AR
72/13-6732
11Q120211/01/2002
County: Pulaski
DR
4096 BRYMOND 6x
BURRY
TUCKER GA 30084-
2560
Reported: 11/26/1993 -
07/19t2001
County' DEKALB
4950 WALNUT GR
y ALPHARETTA GA 3x
R 30022-6210
Reported: 07/19/2001
07/19/2001
County: FULTON
1441 EASTHAM
ATLANTA GA 30338- ix
2301
Reported: 0 5/01/2000
County: DEKALB
ATLANTA G AM
2301 A 3033g_ 1x
Reported. 05/01/2000
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LILBURN GA 30047-
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Exhibit B
REO America Abstract Inc.
123 South Broad Street
Philadelphia, PA 19109
Title No. 2013-24860
FORECLOSURE SEARCH I 07/20/1973 - 06/ 12/2013
Prepared For:
Client Ref. No.:
Premises:
McCabe, Weisberg & Conway, P.C.
6316 STEPHENS CROSSING County: CUMBERLAND
MECHANICSBURG, PA 17055
Tax Map/Parcel ID No.: District: Section: Block: Lot:
PARCEL ID: 10-18-1323-019
HAMPDEN TOWNSHIP
That a search has been made against the premises described in Schedule "A" to the
date hereof, and title to said premises is vested of record in TINA L AVARA.
Current Deed:
Grantor: TINA L. AVARA, EXECUTRIX OF THE ESTATE OF CARL J. AVARA
Grantee: TINA L AVARA
Dated: 04/19/2011 Recorded: 06/09/2011
Liber: Page:
INSTRUMENT NO. 201116391
Prior Chain of Title: (See Attached)
This search includes appended schedules, as follows:
Description of Mortgaged Premises (Schedule A)
Mortgages and Assignments of Record (Schedule B)
Judgment and Lien Information
Tax Information
Effective as of 06/12/2013
REO America Abstract Inc.
123 South Broad Street
Philadelphia, PA 19109
Title No. 2013-24860
PRIOR CHAIN OF TITLE INFORMATION
Prior Deed:
Grantor: DANIEL MARVIN AND KATHERINE ANN MARVIN, HIS WIFE
Grantee: CARL J. AVARA AND KAY J. AVARA, HIS WIFE
Dated: 06/20/1974 Recorded: 06/21/1974
Liber: R25 Page: 90
FEE SIMPLE DEED (KAY J. AVARA DOD 03/13/1993, CARL J. AVARA DOD
12/28/2007, NO ESTATE FOUND IN CUMBERLAND COUNTY)
Grantor: PENNSBORO HOMES, INC., A PENNSYLVANIA CORPORATION
Grantee: DANIEL MARVIN AND KATHERINE ANN MARVIN, HIS WIFE
Dated: 07/20/1973 Recorded: 07/25/1973
Liber: H25 Page: 224
REO America Abstract Inc.
123 South Broad Street
Philadelphia, PA 19109
SCHEDULE A
DESCRIPTION OF MORTGAGED PREMISES
Title No. 2013 -24860
ALL THAT CERTAIN LOT OF LAND SITUATE IN THE TOWNSHIP OF
HAMPDEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA,
MORE PARTICULARLY DESCRIBED AS FOLLOWS:
BEGINNING AT A POINT ON THE EASTERN LINE OF STEPHEN'S CROSSING,
WHICH POINT IS THE LINE DIVIDING LOTS NO. 78 AND 79, ON THE
HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG THE SAID LINE
SOUTH 85 DEGREES 47 MINUTES EAST, ONE HUNDRED TWENTY -FIVE (125)
FEET TO A POINT; THENCE SOUTH 04 DEGREES 28 MINUTES 50 SECONDS
EAST, SIXTY -EIGHT AND NINETY -NINE ONE - HUNDREDTHS (69.99) FEET TO
A POINT ON THE LINE DIVIDING LOTS NO. 79 AND 80; THENCE ALONG THE
SAID LINE SOUTH 79 DEGREES 38 MINUTES 45 SECONDS WEST, ONE
HUNDRED TWENTY -ONE AND THIRTY -ONE ONE - HUNDREDTHS (121.31)
FEET TO A POINT ON THE EASTERN LINE OF STEPHEN'S CROSSING;
THENCE ALONG STEPHEN'S CROSSING NORTH 10 DEGREES 21 MINUTES
15 SECONDS WEST, FORTY -TWO AND TWENTY -TWO ONE - HUNDREDTHS
(42.22) FEET TO A POINT; THENCE CONTINUING ALONG THE SAME IN A
NORTHERLY DIRECTION ON A CURVE TO THE RIGHT HAVING A RADIUS OF
230' AN ARC DISTANCE OF FIFTY -EIGHT AND FORTY -NINE ONE -
HUNDREDTHS (58.49) FEET TO A POINT, THE PLACE OF BEGINNING.
BEING LOT NO. 79 PLAN 4, OF THE VILLAGE OF WESTOVER, WHICH PLAN
IS RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE IN
PLAN BOOK 23, PAGE 22.
REO America Abstract Inc.
123 South Broad Street
Philadelphia, PA 19109
SCHEDULE B
MORTGAGES AND ASSIGNMENTS OF RECORD
Title No. 2013 -24860
One
Mortgagor: CARL J. AVARA AND KAY F. AVARA, A /K /A KAY J. AVARA, HIS
WIFE
Mortgagee: HARRIS SAVINGS ASSOCIATION
Amount: $110,000.00
Dated: 08/27/ 1987
Recorded: 08/28/1987
Liber: 878
Page: 1061
REO America Abstract Inc.
123 South Broad Street
Philadelphia, PA 19109
SCHEDULE B - CONTINUED
MORTGAGES AND ASSIGNMENTS OF RECORD
Title No. 2013 -24860
Two
Mortgagor: CARL J. AVARA
Mortgagee: FIRST UNION NATIONAL BANK
Amount: $80,000.00
Dated: 02/05/ 1999
Recorded: 03/05/1999
Liber: 1524
Page: 888
MODIFICATION OF MORTGAGE IN BOOK 648, PAGE 755, DATED 06/16/2000,
RECORDED 07/10/2000, MODIFYING AMOUNT, NEW AMOUNT $110,000.00.
REO America Abstract Inc.
123 South Broad Street
Philadelphia, PA 19109
Title No. 2013 -24860
JUDGMENT AND LIEN INFORMATION
JUDGMENT - DISCOVER BANK VS. TINA L AVARA - 2011 -05408 -
07/01/2011 - $10,858.65.
THE FOLLOWING NAMES WERE SEARCHED FOR JUDGMENTS: DANIEL
MARVIN, KATHERINE MARVIN, CSRL AVARA AND TINA AVARA.
PROBATE WAS CHECKED ON CURRENT VESTING DEED.
PMM 579 /349 SATISFIED 09/01/1987.
MECHANICS /MUNICIPAL LIENS - NONE FOUND OF RECORD.
US DISTRICT COURT, BANKRUPTCY - WERE NOT SEARCHED.
DOMESTICS /PACS WERE NOT SEARCHED.
SUBJECT TO PLAT RECORDED AT 23/22
Title No. 2013 -24860
REO America Abstract Inc.
123 South Broad Street
Philadelphia, PA 19109
TAX INFORMATION
PARCEL ID: 10 -18 -1323 -019
HAMPDEN TOWNSHIP
ASSESSMENT
LAND $87,500.00
BUILDING $203,900.00
TOTAL $291,400.00
FULL YEAR 2012 COUNTY TAXES PAID.
McCABE, WEISBERG & CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE -II) # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A., CIVIL DIVISION
101 North Phillips Avenue
Sioux Falls, SD 57104 No.: 14-2197 Civil
Plaintiff,
V.
Unknown Surviving Heirs of Carl J. Avara, Deceased
Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, PA 17055
and
Leigh A. Avara, Known Surviving Heir of Carl J. Avara,
Deceased Mortgagor and Real Owner
5027 NE Everett Street
Portland, OR 97213
and
Alessia Louise Avara, Known Surviving Heir of Carl J.
Avara, Deceased Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, PA 17050
and
Tina L. Morelli a/k/a Tina L. Avara, Mortgagor and
Known Surviving Heir of Carl J. Avara, Deceased
Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, PA 17050
Defendants.
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 430(a) specifically provides:
Attorneys for Plaintiff
If service cannot be made under the applicable rule the Plaintiff may move the court for a special order directing
the method of service. The motion shall be accompanied by an Affidavit stating the nature and extent of the investigation
which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made.
Furthermore, Pennsylvania Rule of Civil Procedure 430(b)(2) specifically provides:
When service is made by publication upon the heirs and assigns of a named former owner or party in interest,
the court may permit publication against the heirs or assigns generally if it is set forth in the complaint or an affidavit
that they are unknown.
Plaintiff has named Unknown Surviving Heirs of Carl J. Avara, Deceased Mortgagor and Real Owner, Leigh
A. Avara, Known Surviving Heir of Carl J. Avara, Deceased Mortgagor and Real Owner, Alessia Louise Avara, Known
Surviving Heir of Carl J. Avara, Deceased Mortgagor and Real Owner, and Tina L. Morelli a/k/a Tina L. Avara,
Mortgagor and Known Surviving Heir of Carl J. Avara, Deceased Mortgagor and Real Owner, as Defendants in this
action as known heirs of Carl J. Avara. However, Plaintiff has been unable to identify and/or locate additional heirs of
Carl J. Avara.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order
pursuant to Pennsylvania Rules of Civil Procedure 430 and 3129.2(D) directing service of the Complaint by posting,
publication and by mail and further directing that all subsequent Notices and pleadings that require personal service may
be served in this manner except that publication of the Notice of Sheriffs Sale by the Sheriff set forth in Pa.R.C.P
3129.2(D) is legally sufficient and Plaintiff need not republish the Notice of Sheriff s Sale.
McCABE, WEISBERG & CONWAY, P.C.
BY:
[ ] Terrence J cCa :, Esq.
[ ] Edward D. Conway, Esq.
[ ] Andrew L. Markowitz, Esq.
[ ] Marisa J. Cohen, Esq.
[ ] Brian T. LaManna, Esq.
[ ] Joseph F. Riga, Esq.
[ ] Celine P. DerKrikorian, Esq.
[ ] Lena Kravets, Esq.
Attorneys for Plaintiff
[ ] Marc S. Weisberg, Esq.
[ ] Margaret Gairo, Esq.
[ ] Heidi R. Spivak, Esq.
[ ] Christine L. Graham, Esq.
[ ] Ann E. Swartz, Esq.
[ ] Joseph I. Foley, Esq.
[fie] Jennifer L. Wunder, Esq.
[ ] Carol A. DiPrinzio, Esq.
VERIFICATION
The undersigned attorney hereby certifies that he /she is the Attorney for the Plaintiff in the
within action, and that he /she is authorized to make this verification and that the foregoing facts
based on the information from the Plaintiffs representative, who is out of jurisdiction and not
available to sign this verification at this time, and are true and correct to the best of his/her
knowledge, information and belief and further states that false statements herein are made subject
to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities.
McCABE, WE c ERG
BY:
[ ] Terrence J. "Cabe, r sq.
[ ] Edward D. Conway, Esq.
[ ] Andrew L. Markowitz, Es
[ ] Marisa J. Cohen, Esq.
[ ] Brian T. LaManna, Esq.
[ ] Joseph F. Riga, Esq.
[ ] Celine P. DerKrikorian, E
[ ] Lena Kravets, Esq.
Attorneys for Plaintiff
CONWAY, P.C.
q.
sq.
[ ] Marc S. Weisberg, Esq.
[ ] Margaret Gairo, Esq.
[ ] Heidi R. Spivak, Esq.
[ ] Christine L. Graham, Esq.
[ ] Ann E. Swartz, Esq.
[ ] Joseph I. Foley, Esq.
DO Jennifer L. Wunder, Esq.
[ ] Carol A. DiPrinzio, Esq.
Wells Fargo Bank, N.A. v. Unknown Surviving Heirs of Carl J. Avara, Deceased Mortgagor and
Real Owner, et. al.
Cumberland County; C.C.P.; Number: 14 -2197 Civil
McCABE, WEISBERG & CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A., CIVIL DIVISION
101 North Phillips Avenue
Sioux Falls, SD 57104 No.: 14 -2197 Civil
Plaintiff,
v.
Unknown Surviving Heirs of Carl J. Avara, Deceased
Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, PA 17055
and
Leigh A. Avara, Known Surviving Heir of Carl J. Avara,
Deceased Mortgagor and Real Owner
5027 NE Everett Street
Portland, OR 97213
and
Alessia Louise Avara, Known Surviving Heir of Carl J.
Avara, Deceased Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, PA 17050
and
Tina L. Morelli alk/a Tina L. Avara, Mortgagor and
Known Surviving Heir of Carl J. Avara, Deceased
Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, PA 17050
Defendants.
CERTIFICATE OF SERVICE
Attorneys for Plaintiff
I hereby certify that service of a true and correct copy of the Motion for Service Pursuant to Special Order of
Court was made on the
Paid.
day of April, 2014 to the individual(s) named below by United States Mail, Postage Pre-
Unknown Surviving Heirs of Carl J. Avara, Deceased
Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, Pennsylvania 17055
Alessia Louise Avara, Known Surviving Heir of Carl J.
Avara, Deceased Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, Pennsylvania 17050
Leigh A. Avara, Known Surviving Heir of Carl J.
Avara, Deceased Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, Pennsylvania 17050
McCABE, WE IS„ RG
BY:
[ ] Terrence J.
[ ] Edward D. Conway, Esq.
[ ] Andrew L. Markowitz, Esq.
[ ] Marisa J. Cohen, Esq.
[ ] Brian T. LaManna, Esq.
[ ] Joseph F. Riga, Esq.
[ ] Celine P. DerKrikorian, Esq.
[ ] Lena Kravets, Esq.
Attorneys for Plaintiff
Leigh A. Avara, Known Surviving Heir of Carl J.
Avara, Deceased Mortgagor and Real Owner
5027 NE Everett Street
Portland, Oregon 97213
Tina L. Morelli a/k/a Tina L. Avara, Mortgagor and
Known Surviving Heir of Carl J. Avara, Deceased
Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg, Pennsylvania 17050
0NW Y, P.C.
q
arc S. Weisberg, Esq.
[ ] Margaret Gairo, Esq.
[ ] Heidi R. Spivak, Esq.
[ ] Christine L. Graham, Esq.
[ ] Ann E. Swartz, Esq.
[ ] Joseph I. Foley, Esq.
[yo] Jennifer L. Wunder, Esq.
[ ] Carol A. DiPrinzio, Esq.
Wells Fargo Bank,N.A., 1V1L DIVISION
101 North Phillips Avenue
Sioux Falls, SD 57104 o.: 14-2197 Civil
Plaintiff,
V.
Unknown Surviving Heirs of Carl J. Avara,Deceased
Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg,PA 17055
and
Leigh A. Avara,Known Surviving Heir of Carl J.Avara,
Deceased Mortgagor and Real Owner :
5027 NE Everett Street c ;
Portland,OR 97213
rnrn
�
and =.-Q n .
Alessia Louise Avara,Known Surviving Heir of Carl J. - WCD
Avara,Deceased Mortgagor and Real Owner
6316 Stephens Crossing
C-) ___
Mechanicsburg,PA 17050 CD <=;c�
and
Tina L. Morelli a/k/a Tina L.Avara,Mortgagor and �� w
Known Surviving Heir of Carl J. Avara,Deceased
Mortgagor and Real Owner
6316 Stephens Crossing
Mechanicsburg,PA 17050
Defendants.
ORDER
AND NOW, this 3n day of P�v.,'l , 2014,upon consideration of Plaintiff's
Motion for Service upon the Defendant,Unknown Surviving Heirs of Carl J. Avara, Deceased
Mortgagor and Real Owner, Pursuant to Special Order of Court, it is hereby ORDERED that
pursuant to Pennsylvania Rules of Civil Procedure 430, Plaintiff may comply with the applicable
service requirements by one PUBLICATION of a NOTICE of the filing of the Complaint in
Cumberland County newspaper with daily circulation and by one PUBLICATION of a NOTICE
of the filing of the Complaint in the Cumberland Law Journal; by POSTING the premises 6316
Stephens Crossing, Mechanicsburg, Pennsylvania 17055 with a copy of the Complaint filed in
the above captioned matter and by MAILING by Certified Mail, Return Receipt requested a true
and correct copy of the Complaint to the premises which is the subject of the action.
FURTHER,it is ORDERED that the Plaintiff may serve all subsequent Notices and
pleadings, that require personal service, in the manner set forth above except that Notice of
Sheriffs Sale made by the Sheriff in the manner set forth in Pa.R.C.P. 3129.2(D) is legally
sufficient and Plaintiff need not re-publish.
SERVICE shall be deemed effectuated and completed upon the PUBLICATION,
POSTING or MAILING, whichever is later.
BY THE COURT:
J.
Y
s�i��
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson is
Sheriff - ; HE PROT11ONU }-17 t
„, ctt r f tr�r�t
Jody S Smith " 2014 AP 30 P I
Chief Deputy e
Richard W Stewart CUMBERLAND COUNTY
Solicitors �' PENNSYLVANIA
Wells Fargo Bank, N.A. Case Number
vs. 2014-2197
Unknown Surviving Heirs of Carl J. Avara (et al.)
SHERIFF'S RETURN OF SERVICE
04/22/2014 05:43 PM - Deputy Dawn Kell, 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 Tina Morelli Avara, Mother of defendant, who
accepted as"Adult Person in Charge"for Alessia Avara at 6316 Stephens Crossing, Hampden Township,
Mechanicsburg, PA 17050.
•
DAWN KELL, DEPUTY
04/22/2014 05:43 PM - Deputy Dawn Kell, 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:Tina
Morelli at 6316 Stephens Crossing, Hampden Township, Mechanicsburg, PA 17055.
ypQ
DAWN KELL, DEPUTY
04/23/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Leigh A Avara, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 6316 Stephens Crossing,
Hampden Township, Mechanicsburg, PA 17055. Deputies were advised that the defendant now resides
in Oregon.
04/25/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Unknown Surviving Heirs of Carl J.Avara, but was unable to locate
the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential
Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Served" at
6316 Stephens Crossing, Hampden Township, Mechanicsburg, PA 17055. There are no other heirs
reisding at this adress.
SHERIFF COST: $97.30 SO ANSWERS,
April 23, 2014 RONNY R ANDERSON, SHERIFF
COURT OF COMMON PLEAS OF PENNSYLVANIA, CUMBERLAND COUNTY
WELLS FARGO BANK, N.A.,
Plaintiff(s), Index No.: 14-2197CIVIL
vs. Date Issued: 04/11/2014
UNKNOWN SURVIVING HEIRS OF CARL J.
AVARA, DECEASED MORTGAGOR AND REAL
OWNER, et al.,
Defendant(s).
STATE OF O re.1011
County of M41) i ming
ss:
AFFIDAVIT OF SERVICE
11111111111 Hill 011111111 ID 11 0111111
‘rsti09.c.k VrA1 , the undersigned being duly sworn, deposes and says that I was at the time of
service over the age Of eighteen and not a party to this action.
On April 21 , SDI`{ at 1:37 AM / I served the within CIVIL ACTION - COMPLAINT IN
MORTGAGE FORECLOSURE on LEIG1TA. AVARA, KNOWN SURVIVING HEIR OF CARL J. AVARA,
DECEASED MORTGAGOR AND REAL OWNER at 5027 NE EVERETT STREET, PORTLAND, OR 97213 ,
in the manner indicated below:
n PERSONAL SERVICE: By delivering thereat a true copy of the aforementioned documents to said recipient
personally; deponent knew the person so served to be the person described herein by deponent asking if he or she
is the named Recipient and the person responding that he or she is in fact the person named in this action as the
Recipient.
SUITABLE AGE SERVICE: By delivering thereat a true copy of the aforementioned documents to a person of
suitable age and discretion at the above address which is LEIGH A. AVARA, KNOWN SURVIVING HEIR OF
CARL J. AVARA, DECEASED MORTGAGOR AND REAL OWNER's usual place of residence/place of
abode/place of business, with:
Recipient's Name: L= f i0t x
Relationship: 044646) F°
, a family member or other person at said address.
1 1
PREVIOUS ATTEMPTS: I previously attempted to serve the above named defendant on , at
AM / PM, on , at AM / PM, and on , at AM / PM.
Additional Comments:
Description of person process was left with:
Sex: lglt. Skin/Race: whirApprox. Age: 36 Hair Color: IrOtu ` Height: 1 "
Weight: 4. f,;,, Other: u,L4rJ 4 yec Hoses
Is defendant in the military? YES L.J NO Ud"
Signal and sworn t before me on
this .Z day of y it
Not •ry Public
, Lid 4.
OFFICIAL SEAL
KIMBERLY R BURNS
NOTARY PUBLIC - OREGON
COMMISSION NO. 472908
NY COMMISSION EXPIRES OECEMIEA 31, MIR
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Polikt
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(Print Name) rd/
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ClientRef#: 302-2644PA E./5r— r t=
LawFirmRef#: 302-2644PA r n`'
fir,
McCabe, Weisberg & Conway, P.C. C$ 8 • -
123 S. Broad StreetZp
Philadelphia, PA 19109 A. E.-3(7-
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1ENrdS YL V4 COW
McCABE, WEISBERG & CONWAY, P.C.
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE - ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009
HEIDI R. SPIVAK, ESQUIRE - ID # 74770
MARISA J. COHEN, ESQUIRE - ID # 87830
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH I. FOLEY, ESQUIRE - ID # 314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
JENNIFER L. WUNDER, ESQUIRE - ID # 315954
LENA KRAVETS, ESQUIRE - ID # 316421
CAROL A. DiPRINZIO, ESQUIRE - ID # 316094
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
(215) 790-1010
Wells Fargo Bank, N.A.
Plaintiff
v.
Unknown Surviving Heirs of Carl J. Avara, Deceased
Mortgagor and Real Owner, Leigh A. Avara, Known
Surviving Heir of Carl J. Avara, Deceased Mortgagor and
Real Owner, Alessia Louise Avara, Known Surviving Heir
of Carl J. Avara, Deceased Mortgagor and Real Owner and
Tina L. Morelli, a/k/a Tina L. Avara, Mortgagor and Known
Surviving Heir of Carl J. Avara, Deceased Mortgagor and
Real Owner
Defendants
Attorneys for Plaintiff
Cumberland County
Court of Common Pleas
Number 14-2197 Civil
PRAECIPE TO REINSTATE COMPLAINT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in Mortgage Foreclosure in the above -captioned matter.
McCA
BY:
[ ] Terren e J. McCabe, Esq.
[ ] Edward D. Conway, Esq.
[ ] Andrew L. Markowitz, Esq.
[ ] Marisa J. Cohen, Esq.
[ ] Brian T. LaManna, Esq.
[ ] Joseph F. Riga, Esq.
[ ] Celine P. DerKrikorian, Esq.
[ ] Lena Kravets, Esquire
Attorneys for Plaintiff
ERG AND
AY, P.C.
] Marc S. Weisberg, Esq.
[ ] Margaret Gairo, Esq.
[ ] Heidi R. Spivak, Esq.
[ ] Christine L. Graham, Esq.
[ ] Ann E. Swartz, Esq.
[ Ioseph I. Foley, Esq.
[ ] Jennifer L. Wunder, Esquire
[ ] Carol A. DiPrinzio, Esquire
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
-11:1111 MAY 28 PM 2: S.
CUMBERLAND COUNTY
PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Unknown Surviving Heirs of Carl J. Avara (et al.)
Case Number
2014 -2197
SHERIFF'S RETURN OF SERVICE
05/19/2014 07:38 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure upon the within named Defendant, to wit: Unknown Surviving Heirs of Carl J.
Avara, pursuant to Order of Court by "Posting" the premises located at 6316 Stephens Crossing,
Hampden Township, Mechanicsburg, PA 17055 with a true and correct copy according to law.
JASON PUTY�� �!(
SHERIFF COST: $45.30 SO ANSWERS,
May 20, 2014 RONNR ANDERSON, SHERIFF