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HomeMy WebLinkAbout14-2941 Supreme Court of Pennsylvania ' Cour d tonu Pleas For Prothonotary Use Only: "~►._ Civil Cover Slteet CUMBEHLAW County Docket No: The information collected on this,form is used solely.for court administration purposes. This form does not su a#lenwi I or re)lave the,filing and service ref pleadings or other papers its Lc uireyd by law or rules of court. Commencement of Action: D Complaint 0''Writ of Summons ❑Petition. E ❑Transfer from Another Jurisdiction 0 Declaration of Taking C Lead Plaintiffs Name: WELLS FARGO BANK,N.A. Lead Defendant's Name: SHAWNDI RESSLER T - � Are money damages requested? 13 Yes D No Dollar Amount Requested: Elwithin arbitration limits Q (Check one) ©outside arbitration limits,...m�...,.. N Is this a Class Action Suit? 0 Yes rX1 No Is this an.MDJ Appeal? ❑Yes Z No Name of Plaintiff/Appellant's Attorney: Meredith Wooters.Esq. Id No.307207 Phelan Hallinan,LLP .A. 0 Check here if,you have no attorney(are a Self-Represented [Pro Sel Litigant) Mature 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 youconsider most important. TORT(do not include?Mass Tort) CONTRACT(do not include.ludgments) CIVIL APPEALS ❑Intentional ❑Buyer Plaintiff Administrative Agencies, ©Malicious Prosecution ❑Debt Collection:Credit Card ❑Board of Assessment •Motor Vehicle Cl Debt Collection:Other ❑Board of Elections •Nuisance __ _..._. ,......._,........___.............. ❑Dept.of Transportation ❑Premises Liability _._._.__. . ❑Statutory Appeal:Other ❑Product Liability(does not S include mass tort Cl Employment Dispute: P 0 Slander/Libel/Defamation Discrimination E ©Other: 0 Employment Dispute:Other 0 Zoning Board _ _.... _ __,._.___ _.._ ©Other: T _.....__ _._._._._._..._u.:...... _ _..._....__ w . _ _.__.._._.,. QMASS TORT El Other: Q Asbestos N ❑Tobacco .M.m.............................................,............... ..__...._.........._ Cl Toxic Tort-DES CI Toxic Tort-Implant REAL PROPERTY M. MISCELLANEOUS 0 Toxic Waste D Ejectment n Common Law/Statutory Arbitration $ 0 Other: n Eminent Domain/Condemnation ©Declaratory Judgment _.,....._.................... _...._...._............_........_...___.._.._....__ Ground Rent 0 Mandamus ❑Landlord/Tenant Dispute ❑Non-Domestic Relations ®Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY ❑Mortgage foreclosure:Commercial ❑Quo Warranto 0 Dental ❑Partition ❑Replevin ❑Legal ❑Quiet Title ❑Other: 0 Medical ❑Other 0 Other Professional: - -- - — -— — Pa.R.C.P. 205.5 Updated 0110112011 w , PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF Meredith Wooters,Esq., Id. No.307207 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Meredith..Wooters@phelanhallinan.com ` 215-563-7000 '• apt.-n. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA -- ro WELLS FARGO BANK,N.A. -� t 3476 STATEVIEW BOULEVARD CIVIL DIVISION y© , � FORT MILL, SC 29715 C ! Plaintiff., NO.: VS. SHAWNDI RESSLER ANDREW RESSLER 900 OAKVILLE ROAD NEWVILLE,PA 17241-9667 Defendants. CIVIL ACTION—COMPLAINT IN MORTGAGE FORECLOSURE And now comes WELLS FARGO BANK,N.A.,by its attorneys, Phelan Hallinan,LLP and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is WELLS FARGO BANK, N.A., 3476 STATEVIEW BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff'). 2. The Defendants, SHAWNDI RESSLER and ANDREW RESSLER, are individuals whose last known address are 900 OAKVILLE ROAD, NEWVILLE, PA 17241- 9667. 3. WELLS FARGO BANK, N.A., directly or through an agent, has possession of the Promissory Note. WELLS FARGO BANK, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A true and correct copy of said 062-PA-V3 a Cl�-� 1201 S' t , Promissory Note is harked Exhibit "A", attached hereto and made a part hereof. 4. On or about November 8, 2010, SHAWNDI RESSLER and ANDREW RESSLER made, executed and delivered to WELLS FARGO BANK, N.A. a Mortgage in the original principal amount of $142,900.00 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 in Instrument No. 201032840. The Mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 5. Plaintiff is the current Mortgagee. 6. ANDREW RESSLER is record and real owner of the aforesaid mortgaged premises. 7. Defendants are in default under the terms of the aforesaid Mortgage for, inter alfa, failure to pay the monthly installments of principal and interest due September 1, 2013. 8. As of 01/07/2014, the amount due and owing Plaintiff on the mortgage is as follows: Principal Balance $ 136,506.81 Interest from 08/01/2013 to 01/07/2014 $2,660.48 Late Charges $ 197.85 Escrow Advance $ 267.95 Property Inspections $ 0.00 Property Preservations $ 0,00 BPO/Appraisals $ 0.00 Escrow Balance $ (0.00) Corporate Advance Credit $ (15.30) TOTAL $ 139,617.79 062-PA-V3 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff,including but not limited to, costs(including escrow advances)and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 9. Notice of .Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 10. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of 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$ 139,617.79,with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. By: Date: �j `�f� � Meredith WoJot erAsE Asq. Id. No.3072Q7 Attorney for Plaintiff 062-PA-V3 Exhibit "A" «a NOTE NOTICE: THIS LOAN IS NOT ASSUMABLE EWITHOUT ANS AFFAIRS APPROVAL OF IZED DEPARTMENT 0 OR ITS AUTHOR NOVEI0ER 08, 2010 [Date] [city] [State] 900 OAKVILLE RD, NEWVILLE, PA 17241 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $ *****142,900.00 (this amount is called "Principal"), plus interest, to the order of the Lender. The Lender is WELLS FARGO BANK, N.A. I will make all payments under this Note in the form of cash,check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of ****4.500 %. The interest rate required by this Section 2 is the rate I will pay both before and after any default described in Section 6(B) of this Note. 3. PAYMENTS (A)Time and Place of Payments I will pay principal and interest by making a payment every month. I will make my monthly payment on the FIRST day of each month beginning on JANUARY 01, 2011 I will make these payments every month until i have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest before Principal. If, on DECEMBSR 01, 2040 , I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the"Maturity Date." I will make my monthly payments at WELLS FARGO HOME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 or at a different place if required by the Note Holder. (B) Amount of Monthly Payments ****724.05 My monthly payment will be in the amount of U.S. $ 4. BORROWER'S RIGHT TO PREPAY The Borrower shall have the right to prepay at any time, without premium or fee, the entire indebtedness or any part thereof not less than the amount of one installment, or$100.00, whichever is less. Any Prepayment in full of the indebtedness shall be credited on the date received, and no interest may be charged thereafter. Any partial Prepayment made on other than an installment due date need not be credited until the next following installment due date or 30 days after such Prepayment, whichever is earlier. MULTISTATE FIXED RATE NOTE-Single Family-Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Amended for Veterans Affairs Form 3200 1101 (0 5G(00051 Amended 6100 VMP MORTGAGE FORMS-18001521.7291 Pape 1 of 3 Initials: A _�1' 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a)any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due, I will pay a late charge to the Note Holder, The amount of the charge will be 4.000 % of my overdue payment. 1 will pay this late charge promptly but only once on each late payment. (B)Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that t owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D) No Waiver By Note Holder Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as described above,the Note Holder will still have the right to do so if I Mn in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that different address. 8. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I and any other person who has obligations under this Note waive the rights of Presentment and Notice of Dishonor. "Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. Form 320f� -5G(000s) Page 2 of 3 Initlah:-��.`(�,— � 10. ALLONGE TO THIS NOTE If an allonge providing for payment adjustments or for any other supplemental information is executed by the Borrower together with this Note, the covenants of the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. [Check applicable box] ❑Graduated Payment Allonge ❑Other[Specify] ❑Other[Specify] 11. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed(the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: Regulations (38 C.F.R. Part 36) issued under the Department of Veterans Affairs ("VA") Guaranteed Loan Authority (38 U.S.C. Chapter 37)and in effect on the date of loan closing shall govern the rights, duties and liabilities of the parties to this loan and any provisions of this Note which are inconsistent with such regulations are hereby amended and supplemented to conform thereto. WITNESS THE HAND(S)AND SEAL(S)OF THE UNDERSIGNED. (Seal) llkz Cc1nrQ.ti .r��, (Seal) z -Borrower stiAWNDZ RESSLER Borrower ANDREW RESSLER (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -borrower [Sign Original Only] -5G t000si Pape 3 of 3 Form 3200 1101 Exhibit "B" LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in North Newton Township, Cumberland County, Commonwealth of Pennsylvania, as is more particularly bounded and described as follows: BEGINNING at a railroad spike at existing nail at the intersection of the centerline of Legislative Route 21007 and the centerline of Township Route T-367;thence by the centerline of Township Route T-367, South seventy-seven(77) degrees thirty-five (35) minutes seventeen (17) seconds West, one hundred ninety-four and fifty-one hundredths (194.51)feet to a railroad spike;thence by the same, South seventy-two (72) degrees fourteen (14) minutes forty-eight(48) seconds West,forty-seven and ninety hundredths (47.90)feet to a railroad spike;thence continuing by the same, South sixty-eight(68) degrees forty-six (46) minutes fifty-four(54) seconds West, thirteen and sixty-three hundredths (13.63)feet to a railroad spike at corner of lands now or formerly of William E. Rotz;thence by said lands now or formerly of William E. Rotz,through a fence post on line located twenty and ninety hundredths (20.90) feet from the centerline of said Township Route T-367,North seven(07) degrees twenty-one(21)minutes forty-four(44) seconds West, two hundred seventy-six and ninety-six hundredths (276.96) feet to a fence post on line of lands now or formerly of Emory F. Graham;thence by said lands now or formerly of Emory F. Graham and through a fence post on line located sixteen and zero hundredths (16.00)feet from the centerline of Legislative Route 21007,North fifty-seven(57)degrees eight(08) minutes fifty-eight(58) seconds East, one hundred and ninety-three hundredths (100.93) feet to a railroad spike in the centerline of Legislative Route 21007; thence with the centerline of said Legislative route 21007, South thirty-six (36) degrees thirty-five(35)minutes eighty (08) seconds East, three File#: 939213 hundred thirty-three and eighty-six hundredths (333.86)feet to a railroad spike at existing nail, the place of BEGINNING. CONTAINING 1.1787 acres according to draft dated October 26, 1976,prepared by Carl D. Bert, R.S., entitled "Land Subdivision for Oliver R. Rotz,Jr." and recorded among the deed records of Cumberland County Pennsylvania in Plan Book Volume 29,Page 42. TOGETHER with and under and subject to notations as shown on said plan. UNDER AND SUBJECT, to an Easement and Sewage System Agreement, dated November 9, 1994 and recorded November 29, 1994 in the Office of the Recorder of Deeds, in and for Cumberland County, in Misc. Book 486,Page 798. UNDER AND SUBJECT to existing covenants, agreements, conditions, easements, restrictions and rights of record,to the extent valid and enforceable and still applicable to the above described premises. PROPERTY ADDRESS: 900 OAKVILLE ROAD,NEWVILLE,PA 17241-9667 PARCEL#30-08-0597-022A File#: 939213 VERIFICATION Darren Britt,hereby states thatl ie 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 o is ier information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Name: Darren Britt Title: Vice President Loan Documentation Company: Wells Fargo Bank,N.A. Date: 01/08/2014 086-PA-V2 File# 939213 FORM i IN THE COURT OF COMMON PLEAS WELLS FARGO BANK,N.A. OF CUMBF.,RLAND COUNTY,PENNSYLVANIA Plaintiff(s) s n, SHAWNDI RESSLER ANDREW RESSLER Defendant(s) Civil � y- NOTICE OF RESIDENTIAL MORTGAGE FORECLOWRE c DIVERSION PROGRAM y , 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 251.0 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 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 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 arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKETHE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date Meredith Wooters,Esq.,Id. No.307207 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: Slate: Zip: Is the property for sale? Yes[0 Non Listing date: Price: $ Realtor Name: Realtor Plione: Borrower Occupied? Yes No [] Mailing Address(if different):,..._............_ —._—.........—........_..............� City: State: __Zip:_ Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: __ How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender:-_­ Type ____ _ Type of Loan: �...___...._... _ ..__ Loan Number: Total Mortgage Payments Amount: $^ Includ.ed Taxes&Insurance: Date of Last Payment: ,.... Primary Reason for Default: a 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 trams"po.rtation(�iitocilol)iles. boa-ts,-motore cies_ Model: --Year: Amount owed: Value Monthly Income Name of Employers:. 1. Monthly Gross .............._._.......__Mopthly Net_..... 2. Monthly Gross Monthly Net 3. _ Monthly Gross Monthly Net Additional Income Description(not wages): 1. monthly amount: 2.� monthly amount: Borrower Pay Days Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE JAMOUNT Mortgage food T' Most a -"„ Utilities Car_Payment(s) - C'ondk7/Neila,Fees Auto Insurance Med (not covered) _ .._.....__. Auto fu!l!rep►rs _ Other rci . ayn�cnt install_.Loan Payment Cable TV Child Su ort/Ahm. S endm r Mone Da Child Care/Tuit. � 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); 1" : Email; Have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP) assistance? Yes ❑ No❑ If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes❑ No❑ If yes,please indicate the status of those negotiations:_ Please provide the following information, if known,regarding your lender and lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): , Contact: Phone: authorize the above named _ to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Uwe am/are under no obligation to use the counseling services provided by the above named Borrower Signature Date - — _ .............. Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1 Proof of income 2 Past 2 bank statements 3 Proof of any expected income for the last 45 days 4 Copy of a current utility bill 5 Letter explaining reason for delinquency and any supporting documentation (hardship letter) b Listing agreement(if property is currently on the market) r ry NOTICE You have been sued in Court. If you wish to defend a ' following pages, you must take action within twent galnst the claims set Earth in the are served b y�20� days after this Complaint and Notice y entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to you fail to do so, the case maypmceed the claim'sset forth against you. You are warned that if ' by the Court without further notice for an without you, and a Judgment may be entered against you y money claimed in the Complaint or for any other claim or relief requested by the plaintiff You may lose important to you money or property or other rights YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE T H HE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WIT INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER T TO PROVIDE YOU WITH INFORMATION ABOUT HIS OFFICE MAY BE ABLE LEGAL SERVICES TO ELIGIBLE PERSON'S AGENCIES THAT MAY OFFER AT A REDUCED FEE OR NO FEE. CUMBERLAND UMBERI D COUNTY ATTORNEY CUMBERLAND COUNTRY$ CUMBERLAND COUNTY COURTH ASSOCIATION 2 LIBERTY AVE URTHOUSE Nur.•.. CARLISLE,PA 17013 (717)249-3166 (800)990-9108 File#; 939213 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ����"°"����"~��"�.��� �~������ . . Ronny R Anderson - - T�\��� ''-.` � Sheriff Jmdy����h �»�° t -=��^ c�� P� ~� o - �y� oa`^ 20 ^ ^` Chief Deputy ° ' �Or���T Y R�h�dVVStemm� -��«��� �1 ^' &�\� Solicitor wkcm=p ��M� � -,^ `'' Wells N�� ' Bank, Case Number vs. 2014-2941 Shawndi Ressler(et al.) SHERIFF'S RETURN OF SERVICE 05/15/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Andrew Ryan Ressler, but was unable to locate the Defendant in the Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Allegheny, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 05/15/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Shawndi Ressler, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Perry, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 05/10/2014 01:22 PM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Andrew Ryan Ressler, 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 900 Oakville Road, North Newton Twp, Newville, PA 17241. Residence is vacant. 05/19/2014 01:22 PM- Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Shawndi Ressler, 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 900 Oakvi!le Road, North Newton, Newville, PA 17241. Residence is vacant. 05/28/2014 01:30 PM-The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Perry CoShawndi Ressler, personally, at 158 Old Trail Road, Duncannon, PA 17020. Carl E. Nace, Sheriff, Return of Service attached to and made part of the within record 06/17/2014 The Sheriff of Allegheny County, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Andrew Ryan Ressler, but was unable to locate the Defendant in his bailiwick. The Allegheny County Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Served"et2D54SunnyhU| Road, Imperial, R415128. SHERIFF COST: $77.56 SO ANSWERS, e's ` June 17, 2014 RON R ANDERSON, SHERIFF 1,6,, ,,,,,,,,,,,..,..,,,,,„, Exp 47//3 SHERIFF'S.OFFICE OF CUMBERLAND COUNTY P Ronny R Anderson , i„ rat ...etto., Sheriff 0 io Jody S Smith --'- = Richard W Stewart Chief Deputy ,,, "F,',7,,,- ,-,;1/41-1, Solicitor Wells Fargo Bank, N.A. Case Number vs. 111111011nakelegilli Shawndi Ressler(et al.) Nr SERVICE COVER SHEET 7:1 ,c2 Service Details; Zo* cz, Category: Civil Action -Notice of Residential Mortgage Foreclosure Diversion Progr Zone: Manner: Deputize Expires; 10110MINUM Warrant: Lu Notes: CD Cs1 tO a" Serve To: - --'''41'-'1' '' 'FillittSeritiaf?- 4,,,L, -J Name: • ,.., ; ... Served: Personally-Adult In Charge • Posted ' Other 's'i., 'et Phone: DOB: Relation: 0 Alternate Date: 6cv. / y ' Time: IL:11 pl.., ±- Address: . Phone: " - - Deputy: itz 1.0,..t.r, Mileage: .-- . .... _ u) I'S Attorney/Originator: a cs' Name: Phelan Hallinan Phone: 215-563-7000 Service Attempts: , '1-r-*''''-',.---*!:,,. ,,.. ,., ,„:„,„:**,:,,L7 _ . Date: I ri. Time: cr) Cli Mileage: .tr g Deputy: 0, Notes 1 SPeoletki:stroottOos: ' =i- ''''''''.'"T"'"7„. ' ---::;:;:;ot-44*-;:::13'N----e---,;--"''4-=i--,-,-,--::;::--::'w:'::::, -A---e---:- -,k..74 z < ce Lu ce 0 z Now, May 15, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Allegheny County to execute service of the documents herewith and make return thereof according to law. Lu (71) Return To: 6 Cumberland County Sheriff's Office r‘ One Courthouse Square Carlisle, PA 17013 P('-a-nny R Anderson, Sheriff Wells Fargo Bank NA IN THE COURT OF COMMON PLEAS OF THE 41st JUDICIAL DISTRICT OF PENNSYLVANIA, PERRY COUNTY BRANCH Versus Shawndi Ressler No. 2014-2941 Cumberland Co. SHERIFF'S RETURN And now May 28 , 2014 : Served the within name Shawndi Ressler the defendant(s) named herin, personally at her place of residence in Watts Twp-150 Old Trail Rd.Duncannon, PA Perry County, PA, on May 28, 2014 at 1:30 o'clock PM by handing to Shawndi Ressler, Def. 1 true and attested copy(ies) of the within Complaint in Mortgage Foreclosure and made known to her the contents thereof Sworn and subscribed to before me this 4-6 day ofCe GIy So answers r` 111 altAol y- Wzjze-n4...a. Deputy Sheriff of Perry County COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL MARGARET F.FLICKINGER,Notary Public Bloomfield Boro,Perry County My Commission Expires February 16,2016 PHELAN HALLINAN, LLP Paul Cressman, Esq., Id. No.318079 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 paul.cressman@phelanhallinan.com 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff vs. SHAWNDI RESSLER ANDREW RESSLER Defendants OF ��� �-OF F ICy 1U14JUL -g ctIMQER� Aft 9: 56 PENNSYL ANIA J! : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : No. 14-2941 CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. By: Date: /bsd, Svc Dept. File# 939213 , LLP Pa7M-14 an, sq., Id. No.318079 Attorn for Plaintiff Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 0-0r i 1C. HE MHONG 20113 AUG 14 PIS 3: 06 CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Case Number Shawndi Ressler (et al.) 2014-2941 SHERIFF'S RETURN OF SERVICE 07/09/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Andrew Ryan Ressler, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Washington, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 07/30/2014 12:00 PM - The Sheriff of Washington County, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Andrew Ryan Ressler, but was unable to locate the Defendant in his bailiwick. The Washington County Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Served" at 2054 Sunnyhill Road, Imperial, PA 15126. SHERIFF COST: $37.00 August 12, 2014 (c) CountySuite Shentl, Teleosoft, Inc. SO ANSWERS, RONR ANDERSON, SHERIFF WASHINGTON COUNTY, PENNSYLVANIA SAMUEL F. ROMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 2014-2941 OFFICE OF THE SHERIFF County of Washington, Commonwealth of Pennsylvania WELLS FARGO BANK, N.A. vs. ANDREW RYAN RESSLER COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 FAX 724-223-4719 Sheriff File Number — 14002141 Affidavit of Service COMPLAINT IN MORTGAGE FORECLOSURE I hereby CERTIFY and RETURN that on 7/30/2014 at 12:00 PM service was attempted with the due diligence and inquiry for ANDREW RYAN RESSLER. Service was unable to be made for the following reasons: ROAD CLOSED, UNABLE TO LOCATE SERVICE ATTEMPTS Date: 7/30/2014 @ 12:00 PM - 2054 SUNNYHILL ROAD IMPERIAL, PA 15126 Fees Received from Attorney: FIRST DEFENDANT BASE COST ($24.50) POSTAGE ($1.00) MILEAGE ($20.16) Total: $45.66 Attorney Name: PHELAN HALLINAN, LLP, ONE PENN CENTER PLAZA 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103 Affirmed & Subscribed to before Me 8/1/2014 JOSEPH RUSCELLO, Deputy Sheriff 2-0GZ.g/-4 Notary Public My commission expires: Sheriff of Washington County NOTARIAL SEAL Uh51�dFL-.:.4.ke R.'Uik 5 KJ Nota¢y Public WASHINGTON CITY, V.1ASHINGTON COUNTY tfly Commission s:.ni,r..°August 15.21)1,'7 ©SoftCode. Inc. - PA WASH POS NOTSERVED WASHINGTON COUNTY, PENNSYLVANIA OFFICE OF THE SHERIFF SAMUEL F. ROMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 2014-2941 County of Washington, Commonwealth of Pennsylvania WELLS FARGO BANK, N.A. vs. ANDREW RYAN RESSLER COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 FAX 724-223-4719 Sheriff File Number — 14002141 Affidavit of Service COMPLAINT IN MORTGAGE FORECLOSURE I hereby CERTIFY and RETURN that on 7/30/2014 at 12:00 PM service was attempted with the due diligence and inquiry for ANDREW RYAN RESSLER. Service was unable to be made for the following reasons: ROAD CLOSED, UNABLE TO LOCATE SERVICE ATTEMPTS Date: 7/30/2014 @ 12:00 PM - 2054 SUNNYHILL ROAD IMPERIAL, PA 15126 Fees Received from Attorney: FIRST DEFENDANT BASE COST ($24.50) POSTAGE ($1.00) MILEAGE ($20.16) Total: $45.66 Attorney Name: PHELAN HALLINAN, LLP, ONE PENN CENTER PLAZA 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103 Affirmed & Subscribed to before Me 8/1/2014 Notary Public My commission expires: CSoltCode, Inc. - PA_WASIL_POS_ NOTARIAL SEAL PS-',iti�"ey r. )t," -Pr Public WASIIING TOP! CITY, WASHINGTON COUNTY rqy Ccvr:rniscr,on F..4.,es August 15, 2017 JOSEPH RUSCELLO, Deputy Sheriff .)licvvv."-Ak.e.ovv4.4~-0 Sheriff of Washington County PHELAN HALLINAN, LLP Kenya Bates, Esq., Id. No.203664 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 kenya.bates@phelanhallinan.com 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff vs. SHAWNDI RESSLER ANDREW RESSLER Defendants SEP 23 uf TH cf RU rH FLED-FFICr:. 20/h Quo ��;f, �.'1w:191 OU BER Sa N0 YLVANIAHry PENN : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : No. 14-2941 CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. By: Date: /alg, Svc Dept. File# 939213 PHELJ N HALLINAN, LLP Kenya Bates, Esq., Id. No.203664 Attorney for Plaintiff am4 sit 3Spg.i4_ &tit 1,4Pil" ��J '�IIyoS PHELAN HALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 WELLS FARGO BANK, N.A. Plaintiff VS. SHAWNDI RESSLER ANDREW RESSLER Defendants -0= rn zrTl z7.-) -0> : COURT OF COMMON PLE : CIVIL DIVISION : CUMBERLAND COUNTY : No. 14-2941 CIVIL PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. By: Date: /bsd, Svc Dept. File# 939213 PHELAN HALLINAN. LP Jonatf Lobb, Esq., Id. No.312174 Attorney for Plaintiff ra. 7 (u' PHELAN HALLINAN, LLP �• Jonathan Lobb, Esq., Id. No.312174 "' ' ' ` 1 ' �; -j, 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 WELLS FARGO BANK, N.A. vs. SHAWNDI RESSLER ANDREW RESSLER Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 14-2941 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above -captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendants SHAWNDI RESSLER and ANDREW RESSLER are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended. (b) that defendant SHAWNDI RESSLER is over 18 years of age and resides at 150 OLD TRAIL ROAD, DUNCANNON, PA 17020-7121 and 900 OAKVILLE ROAD, NEWVILLE, PA 17241-9667. (c) that defendant ANDREW RESSLER is over 18 years of age and resides at 2054 SUNNYHILL RD, IMPERIAL, PA 15126-9405 and 900 OAKVILLE ROAD, NEWVILLE, PA 17241-9667. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date (2' 1 . IV/ //i Phela/ allinan, LLP Jona ' an Lobb, Esq., Id. No.312174 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 939213 Department of Defense Manpower Data Center Status .Report Pursuant to Service nennbe s Civil Relief Act Last Name: RESSLER First Name: ANDREW Middle Name: Active Duty Status As Of: Dec -18-2014 Results as of : Dec -18-2014 12:05:45 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA i, • w No \ NA This response reflects the indivtduals'.active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA I - NA ' No + NA This response reflects Where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA \. ' _ . No' NA This response reflects whether the individual or his/her unit has received early notification to report for active duty +, Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Y�. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center Status Report Pursuant to Sery oemernbers Civil. Relief Act Last Name: MUTZABAUGH First Name: SHAWNDI-ANNE Middle Name: Active Duty Status As Of: Dec -18-2014 Results as of : Dec -18-2014 12:10:10 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duly Start Date Active Duty End Date Status Service Component NA NA_1r No'. NA This response reflects the`mdrviduals' active duty status based on the Active Duty Status Date . Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA t, -, NA - - `y -' ... No.:, NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA , NA' ?1,. _. • r - No NA This response reflects whetherthe individual oi• hisiher unit has received early notification to report for active duty -_._ R, - Upon searching the data banks of the Department of Defense Manpower Data Center„based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center Status Report Pursuant to Sery cemeinbers Civil Relief Act Last Name: RESSLER First Name: SHAWNDI-ANNE Middle Name: Active Duty Status As Of: Dec -18-2014 Results as of : Dec -18.2014 12:10:43 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - - - - No ' NA This response reflects the individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA i 1 NA . , 1 .i — No :- t NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA ; „ • ,1 - No i NA This response reflects whether the individual or his/her unit has received early nelification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the UniformedServices (Arrny, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center Status Report Pursuant to Servicemems Civil ;Relief Act Last Name: RESSLER First Name: SHAWNDI Middle Name: Active Duty Status As Of: Dec -18-2014 Results as of : Dec -113-2014 12:05:43 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA • NA ,' �'•- — - - - Nod,.. NA This response reflects the indivlduats' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ` . No -' - NA This response reflects where the individual left -active duty status within 367 days preceding ihdAClive Duty Status Date The Member or His/Her Unit Was Noted of a Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA ` . No -' - NA This response reflects whether the individual orhis/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed; Services -(Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE 2g Ili DEC 29 PM 3: 02 CMBE RLAND COU PENNSYLVANIA Wells Fargo Bank, N.A. vs. Shawndi Ressler (et al.) Case Number 2014-2941 SHERIFF'S RETURN OF SERVICE 09/23/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Andrew Ryan Ressler, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Washington, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 09/26/2014 The Sheriff of Westmoreland County, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Andrew Ryan Ressler, but was unable to locate the Defendant in his bailiwick. The Westmoreland County Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Served" at 2054 Sunnyhill Road, Imperial, PA 15126. Cumberland County Sheriffs Office sent the Complaint to the wrong county by mistake, consequently no service was made at this time. 10/23/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Washington County upon Ella McCullough, Relative, who accepted for Andrew Ryan Ressler, at 2054 Sunnyhill Road, Imperial, PA 15126. Samuel F. Romano, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, December 29, 2014 RONNY R ANDERSON, SHERIFF (c) Count Suite Sharif`, Te eoscft rc. 12/29/2014 11:29 FAX R] 002/002 WASHINGTON COUNTY, PENNSYLVANIA OFFICE OF THE SHERIFF SAMUEL F. ROMANO SHERIFF JAMES B. DALESSANDRO CHIEF DEPUTY Court Docket #: 2014-2941 County of Washington, Commonwealth of Pennsylvania WELLS FARGO BANK, N.A. vs. ANDREW RYAN RESSLER COURTHOUSE SQUARE SUITE 303 100 WEST BEAU STREET WASHINGTON, PA 15301 724-228-6840 FAX 724-223-4719 Sheriff File Number — 14003076 Affidavit of Service COMPLAINT IN MORTGAGE FORECLOSURE I hereby CERTIFY and RETURN that on 10/23/2014 at 3:20 PM at 2054 SUNNYHILL ROAD IMPERIAL, PA 15126 the within COMPLAINT IN MORTGAGE FORECLOSURE, was served on ANDREW RYAN RESSLER, the defendant named therein, in the following manner: ALTERNATE PERSON. By delivering to and leaving with ELLA MCCULLOUGH the RELATIVE to the defendant a true copy thereof, a person over the age of eighteen. Said address was the home of the defendant. SERVICE ATTEMPTS Date: 10/23/2014 @ 3:20 PM - 2054 SUNNYHILL ROAD IMPERIAL., PA 15126 Fees Received from Attorney: FIRST DEFENDANT BASE COST ($24.50) POSTAGE ($1.00) MILEAGE ($22.40) Total: $47.90 Attorney Name: PHELAN HALLINAN, LLP, ONE PENN CENTER PLAZA 1617 JOHN F. KENNEDY BOULEVARD SUITE 1400 PHILADELPHIA, PA 19103 Affirmed & Subscribed to before Me 10/27/2014 DARRIN PATTERSON, Deputy Sheriff �Af ISAMe, Notary Public My commission expires: Sheriff of Washington County NOT/AR/4i. '.,HAL inn PHELAN HALLINAN, LLP PETER WAPNER, Esq., Id. No.318263 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 peter.wapner@phelanhallinan.com 215-563-7000 WELLS FARGO BANK, N.A. vs. SHAWNDI RESSLER Attorney for Plaintiff CUMBERLAND COUNTY c-) COURT OF COMMON PLEA` ', zo : CIVIL DIVISION ANDREW RESSLER : No. 14-2941 CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: c7 C) N C.) Kindly enter judgment in favor of the Plaintiff and against SHAWNDI RESSLER, and ANDREW RESSLER, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $139,617.79 TOTAL $139,617.79 I hereby certify that (1) the Defendants' last known addresses are 150 OLD TRAIL ROAD, DUNCANNON, PA 17020-7121, 900 OAKVILLE ROAD, NEWVILLE, PA 17241- 9667, and 2054 SUNNYHILL RD, IMPERIAL, PA 15126-9405, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date L4//y PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ii2429�1�✓. X16 .Sp( '4 C -It -14P294› 31 sore{ INS 939213 WELLS FARGO BANK, N.A. V. SHAWNDI RESSLER ANDREW RESSLER Plaintiff Defendant(s) T� SHAWNDI RESSLER 150 OLD TRAIL ROAD DUNCANNON, PA 1702077121 DATE OF NOTICE: COURT OF COMMON PLEAS CIVIL DIVISION NO. 14-2941 CIVIL CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL 13E USED FOR THAT PURPOSE, IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY. THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. ;IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195. PH # 939213 CUIVIBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION V. SHAWNDI RESSLER ANDREW RESSLER NO. 14-2941 CIVIL Defendant(s) CUMBERLAND COUNTY TO; SHAWNDI RESSLER 900 OAKVILLE ROAD NEWVILLE, PA 17241-9667 1 DATE OF NOTICE: - • THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. TF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE TN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. .IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY All ORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE 01-FICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: PH # 939213 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 PETER WAPNER, Esq., Id. No. 8263 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 WELLS FARGO BANK, N.A. V. SHAWNDI RESSLER ANDREW RESSLER Plaintiff Defendant(s) TO: ANDREW RESSLER 2054 SUNNYHILL RD IMPERIAL, PA 15 126-9405 11 • •—• DATE OF NOTICE: .. COURT OF COMMON PLEAS CIVIL, DIVISION NO. 14-2941 CIVIL CUMBERLAND COUNTY THIS I-41RM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED -TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE N WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 By: PH # 939213 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1 249-3166 PETER APNER, Esq., Id, No.318263 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 WELLS FARGO BANK, N.A. COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION v. SHAWNDI RESSLER ANDREW RESSLER NO. 14-2941 CIVIL Defendant(s) CUMBERLAND COUNTY TO: ANDREW RESSLER 900 OAKVILLE ROAD NEW V ILLE, PA 17241-966 DATE OF NOTICE: ijiq THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT, THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. 1F YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY, IMPORTANTNOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY API ORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES T.HAT MAY OPER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 PH # 939213 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 By: PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Perin Center Plaza Philadelphia, PA 19103 PHELAN HALLINAN, LLP PETER WAPNER, Esq., Id. No.318263 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 peter.wapner@phelanhallinan.com 215-563-7000 WELLS FARGO BANK, N.A. vs. SHAWNDI RESSLER ANDREW RESSLER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS-) : CIVIL DIVISION : No. 14-2941 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE 57-,T CD rpt C)• -o CGJ w Con The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above -captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) SHAWNDI RESSLER and ANDREW RESSLER are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, as amended. (b) that defendant SHAWNDI RESSLER is over 18 years of age and resides at 150 OLD TRAIL ROAD, DUNCANNON, PA 17020-7121 and 900 OAKVILLE ROAD, NEWVILLE, PA 1.7241-9667. (c) that defendant ANDREW RESSLER is over 18 years of age and resides at 2054 SUNNYHILL RD, IMPERIAL, PA 15126-9405 and 900 OAKVILLE ROAD, NEWVILLE, PA 1.7241-9667. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date Phelan Hallinan, LLP PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff PHELAN HALLINAN, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia, PA 19103 215-563-7000 939213 Department of Defense Manpower Data Center Staff Rt }ort :o Service enibers Civil leaf Act Last Name: RESSLER First Name: ANDREW Middle Name: Active Duty Status As Of: Dec -24-2014 Results as of : Dec -24-2014 12:53:53 AM SCRA 3.0 .On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status ", - Service Component NA NA ":1,---f.;'''':; r + l x fi.7'`' N4 11"1, -:.1A -NA NA This response reitects the indivlduatsactive- fury 's sed on Active' Duty;Status Date Left Active Duty Within 367 Days of Active Duty Status Date .. .. Active Duty Start Date Active Duty End Dale Status Service Component NA{� g - r -�"'.'�.�tlA "'"t r + l x fi.7'`' N4 11"1, -:.1A -NA NA This response reflects where,tttie individual tett active dutyStatu5 within 367 days preceding th Active Dirty Status Date The Member or HisiHer Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date •. Order Notification Start Date Order Notification End Date Status Service Component NA , NA ' i )., .. - J . *`N.a .: NA This response reflects whether ttie individual orhisiher.unit has ;received earty,notification to'ieport for active duty Upon searching the data banks of the Department of Defense M'anpower`Data Center;ybased ora -the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Seivices_(Ar ny, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or hislher unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 Department of Defense Manpower Data Center Status Report I to Se! vice= Last Name: RESSLER First Name: SHAWNDI Middle Name: Active Duty Status As Of: Dec -24-2014 9 i Civil Relief Act Results as of : Dec -24-2014 12:53:51 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA-.- _...-r .._ ...:-. - -' No' NA This response reflects the individuals' active duty status.based on the Active Duty. Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA - ;, NA - __ .__ .. No ri NA This response reflects where the individual left active dutyStatus within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Futu e Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA : NA ' No ' NA This response reflects whether the individual or`hislher unit has recelved-eady notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Sery ices (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. yji Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 41. Department of Defense Manpower Data Center Status Report Pursuant to Scry cemembcrs Civil Relief Act Last Name: RESSLER First Name: SHAWNDI-ANNE Middle Name: Active Duty Status As Of: Dec -24-2014 Results as of : Dec -24-2014 12:53:52 AM SCRA 3.0 On Active Duty On Active Duty, Status Date Active Duty Start Date . Active Duty End Date` Status Service Component NA NA_..,,45<:t,'''',% _ :,.=::i�"c ,.J'. Np:`-. NA This response tett ecis theindmduais active�duty-strttus'sa"sed Tithe:As DiitStatus Date The Member or Nis/Her Unit Was Notified of a Future Cal -Up to Active Duly on Active Duty Status Date Left Active Duty within 367 Pays of Active Duty Status Date . .. Active Duty Start Date - Active Duty End Date . Status :r'No - Service Component NA ! ., 3I;NA a, .:?;:. 1-< - V .M :+c . -:`No. i iFit R � '.{. NA 'i '. {- 'r+ - :A‘: -.:,'k, _4 k _A: .- _.,. e individual left active;duty status'Within,367 days' preceding This response reflects where,th't 'J moi: theActive. Duty Status Date The Member or Nis/Her Unit Was Notified of a Future Cal -Up to Active Duly on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA, ,,A ,, �..3' :r'No - NA This response reflects whether the indiVldual or;hlufffer unit has _receNed'uadynotfication to=report tor active duty ti Upon searching the data banks of the Department of Defense Manpower Data Center;ibased on<th"e information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Unifoimed:Seivices-(Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or histher unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 (Rule of Civil Procedure No. 236) - Revised WELLS FARGO BANK, N.A. : CUMBERLAND COUNTY vs. : COURT OF COMMON PLEAS SHAWNDI RESSLER ANDREW RESSLER • CIVIL DIVISION : No. 14-2941 CIVIL against you on Notice is given that a Judgment in the above captioned matter has been entered a I; il/e/ By: If you have any qu6stions concerning this matter please contact: Phelan Hallinan, LLP PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** 939213 PRAECIPE FOR WRIT OF EXECUTION -(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 Wells Fargo Bank, N.A. Plaintiff V. Shawndi Ressler Andrew Ressler Defendant(s) : COURT OF COMMON PLEAS : CIVIL DIVISION NO.: 14-2941 CIVIL : CUMBERLAND COUNTY To the Prothonotary: Issue writ of execution in the above matter: C) Amount Due $139,617.79 a -13 Interest from 12/30/2014 to Date of Sale $3,580.20 ($22.95 per diem) _<7> r-- < TOTAL $143,197.99 Note: Please attach description of property. PH #939213 lan,'LLP ushwood, Esq., Id. No.310592 ttorney for Plaintiff Cl C ' 45.5o pc KW/ 771..5060 37 3 1: 31 0 ..7055 10 11: 11. 75 " 11. '75 110 • 5o $335.56 - ATT'/ 4,a .025 ijiee.0 • 50 LL - R E + 4 9-a ID di B18 (Official Form 18) (12/07) United States Bankruptcy Court Middle District of Pennsylvania Case No. 1:14—bk-00092—RNO Chapter 7 _ In re Debtor(s) (name(s) used by the debtor(s) in the last 8 years, including married, maiden, trade, and address): Shawndi—Anne Ressler fka Shawndi—Anne Mutzabaugh 150 Old Trail Road Duncannon, PA 17020 Social Security / Individual Taxpayer ID No.: xxx—xx-9807 Employer Tax ID / Other nos.: DISCHARGE OF DEBTOR It appearing that the debtor is entitled to a discharge, IT IS ORDERED: The debtor is granted a discharge under section 727 of title 11, United States Code, (the Bankruptcy Code). Dated: 4/30/14 BY THE COURT Honorable Robert N. Opel United States Bankruptcy Judge SEE THE BACK OF THIS ORDER FOR IMPORTANT INFORMATION. Case 1:14-bk-00092-RNO Doc 17 Filed 04/30/14 Entered 04/30/14 01:00:17 Desc Ch 7 Discharge Page 1 of 2 B18 (Official Form 18) (12/07) — Cont. EXPLANATION OF BANKRUPTCY DISCHARGE IN A CHAPTER 7 CASE This court order grants a discharge to the person named as the debtor. It is not a dismissal of the case and it does not determine how much money, if any, the trustee will pay to creditors. Collection of Discharged Debts Prohibited The discharge prohibits any attempt to collect from the debtor a debt that has been discharged. For example, a creditor is not permitted to contact a debtor by mail, phone, or otherwise, to file or continue a lawsuit, to attach wages or other property, or to take any other action to collect a discharged debt from the debtor. [In a case involving community properly: There are also special rules that protect certain community property owned by the debtor's spouse, even if that spouse did not file a bankruptcy case.] A creditor who violates this order can be required to pay damages and attorney's fees to the debtor. However, a creditor may have the right to enforce a valid lien, such as a mortgage or security interest, against the debtor's property after the bankruptcy, if that lien was not avoided or eliminated in the bankruptcy case. Also, a debtor may voluntarily pay any debt that has been discharged. Debts That are Discharged The chapter 7 discharge order eliminates a debtor's legal obligation to pay a debt that is discharged. Most, but not all, types of debts are discharged if the debt existed on the date the bankruptcy case was filed. (If this case was begun under a different chapter of the Bankruptcy Code and converted to chapter 7, the discharge applies to debts owed when the bankruptcy case was converted.) Debts That are Not Discharged Some of the common types of debts which are gat discharged in a chapter 7 bankruptcy case are: a. Debts for most taxes; b. Debts incurred to pay nondischargeable taxes; c. Debts that are domestic support obligations; d. Debts for most student loans; e. Debts for most fines, penalties, forfeitures, or criminal restitution obligations; f. Debts for personal injuries or death caused by the debtor's operation of a motor vehicle, vessel, or aircraft while intoxicated; g. Some debts which were not properly listed by the debtor; h. Debts that the bankruptcy court specifically has decided or will decide in this bankruptcy case are not discharged; i. Debts for which the debtor has given up the discharge protections by signing a reaffirmation agreement in compliance with the Bankruptcy Code requirements for reaffirmation of debts; and j. Debts owed to certain pension, profit sharing, stock bonus, other retirement plans, or to the Thrift Savings Plan for federal employees for certain types of loans from these plans. This information is only a general summary of the bankruptcy discharge. There are exceptions to these general rules. Because the law is complicated, you may want to consult an attorney to determine the exact effect of the discharge in this case. Case 1:14-bk-00092-RNO Doc 17 Filed 04/30/14 Entered 04/30/14 01:00:17 Desc Ch 7 Discharge Page 2 of 2 District/Off: 0314-1 Case: 1:14—bk-00092-RNO Notice Recipients User: admin Form ID: B18 Recipients of Notice of Electronic Filing: ust United States Trustee ustpregion03.ha.ecf@usdoj.gov tr Leon P. Haller (Trustee) lhaller@pkh.com aty Dorothy L Mott DorieMott@aol.com Date Created: 04/30/2014 Total: 22 TOTAL: 3 Recipients submitted to the BNC (Bankruptcy Noticing Center): db Shawndi—Anne 'Ressler 150 Old Trail Road Duncannon, PA 17020 cr Ally Financial P.O. Box 130424 Roseville, MN 55113 4430676 AES/WELLSFARGO PO BOX 2461 HARRISBURG, PA 17101 4430677 ALLY PO BOX 130424 ROSEVILLE, MN 55113 4430678 ANDREW RYAN RESSLER 900 OAKVILLE ROAD NEWVILLE, PA 17241 4430679 APPLE FCU GENERAL CORRESPONDENCE . PO BOX 1200 FAIRFAX, VA 22038-1200 4430680 CAPITAL ONE (BANKRUPTCY NOTIFICATION) (p PO BOX 30285 SALT LAKE CITY, UT 84130-0285 4430681 COMM OF PA DEPT L ,READING BCUNIT UTCS 625 CHERRY ST ROOM 203 READING, PA 19602-1152 4430682 COMM OF PA DEPT OF REVENUE BUREAU OF COMPLIANCE PO BOX 280946 HARRISBURG, PA 17121-0946 4430683 FEDLOAN PO BOX 69184 HARRISBURG, PA 17106 4430684 FEDLOAN SERVICING PO BOX 2461 HARRISBURG, PA 17101 4430685 INTERNAL REVENUE SERVICE — CIO PO BOX 7346 PHILADELPHIA, PA 19101-7346 4430686 PINNACLE HEALTH EMERGENCY 6880 W SNOWVILLE ROAD SUITE 210 BRECKSVILLE, OH 44141 4430687 PINNACLE HEALTH HOSPITALS PO BOX 2353 HARRISBURG, PA 17105 4430688 QUEST DIAGNOSTICS PO BOX 7306 HOLLISTER, MO 65673-7306 4430689 SHIPLEY ENERGY 550 E KING STREET PO BOX 946 YORK, PA 17405-0946 4430690 VETERANS ADMINISTRATION BISHOP HENRY WHIPPLE FEDERAL BLDG FORT SNELLING ST PAUL, MN 55111 4430691 WELLS FARGO HOME MORTGAGE ATTN: BANKRUPTCY, MAIL MAC# X7801-014 3476 STATEVIEW BLVD FORT MILL, SC 29715 4430692 YORK CR BUREAU 33 S DUKE STREET YORK, PA 17401 TOTAL: 19 Case 1:14-bk-00092-RNO Doc 17-1 Filed 04/30/14 Entered 04/30/14 01:00:17 -Desc Ch 7 Discharge: Notice Recipients ' Page 1 of 1 PHELAN HALLINAN, LLP Matthew Brushwood, Esq., Id. No.310592 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 matthew.brushwood@phelanhallinan.com 215-563-7000 Wells'Fargo Bank, N.A. Plaintiff v. Shawndi Ressler Andrew Ressler Defendant(s) • THE PROTHONO.'�`1i. 2015 JAN -9 Ail 10: 55 CUMBERLAND COUNTY PENNSYLVANIA CERTIFICATION Attorneys for Plaintiff COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 14-2941 CIVIL . CUMBERLAND County The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: the mortgage is an FHA Mortgage the premises is non -owner occupied the premises is vacant Act 91 procedures have been fulfilled Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. § 4904 relating to unsworn falsification to authorities. By: linan, LLP a Brushwood, Esq., Id. No.310592 Att.rney for Plaintiff Wells Fargo Bank, N.A. r Shawndi Ressler Andrew Ressler INEtROIHON,liA, 2015 JAPE --9 AM 10:56 CUMBERLAND COUNTY v ENNSYLVANIA : COURT OF COMMON PLEAS • Plaintiff : CIVIL DIVISION • : NO.: 14-2941 CIVIL : CUMBERLAND County Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: Shawndi Ressler 150 Old Trail Road Duncannon, PA 17020-7121 Andrew Ressler 2054 Sunnyhill rd Imperial, PA 15126-9405 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house (real estate) at 900 Oakville Road, Newville, PA.17241-9667 is scheduled to be sold at the Sheriff's Sale on 06/03/2015 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $139,617.79 obtained by Wells Fargo Bank, N.A. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. The sale will go through only if the buyer pays the Sheriff thefull amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32. SOUTH. BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution No. 14-2941 CIVIL Wells Fargo Bank, N.A. v. Shawndi Ressler Andrew Ressler owner(s) of property situate in the NORTH NEWTON TOWNSHIP, CUMBERLAND County, Pennsylvania, being 900 Oakville Road, Newville, PA 17241-9667 Parcel No. 30-08-0597-022A (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $139,617.79 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL THAT CERTAIN lot or tract of land situate in North Newton Township, Cumberland County, Commonwealth of Pennsylvania, as is more particularly bounded and described as follows: BEGINNING at a railroad spike at existing nail at the intersection of the centerline of Legislative Route 21007 and the centerline of Township Route T-367; thence by the centerline of Township Route T-367, South seventy-seven (77) degrees thirty-five (35) minutes seventeen (17) seconds West, one hundred ninety- four and fifty-one hundredths (194.51) feet to a railroad spike; thence by the same, South seventy-two (72) degrees fourteen (14) minutes forty-eight (48) seconds West, forty-seven and ninety hundredths (47.90) feet to a railroad spike; thence continuing by the same, South sixty-eight (68) degrees forty-six (46) minutes fifty- four (54) seconds West, thirteen and sixty-three hundredths (13.63) feet to a railroad spike at corner of lands now or formerly of William E. Rotz; thence by said lands now or formerly of William E. Rotz, through a fence post on line located twenty and ninety hundredths (20.90) feet from the centerline of said Township Route T-367, North seven (07) degrees twenty-one (21) minutes forty-four (44) seconds West, two hundred seventy-six and ninety-six hundredths (276.96) feet to a fence post on line of lands now or formerly of Emory F. Graham; thence by said lands now or formerly of Emory F. Graham and through a fence post on line located sixteen and zero hundredths (16.00) feet from the centerline of Legislative Route 21007, North fifty- seven (57) degrees eight (08) minutes fifty-eight (58) seconds East, one hundred and ninety-three hundredths (100.93) feet to a railroad spike in the centerline of Legislative Route 21007; thence with the centerline of said Legislative route 21007, South thirty-six (36) degrees thirty-five (35) minutes eighty (08) seconds East, three hundred thirty-three and eighty-six hundredths (333.86) feet to a railroad spike at existing nail, the place of BEGINNING. CONTAINING 1.1787 acres according to draft dated October 26, 1976,.prepared by Carl D. Bert, R.S., entitled 'Land Subdivision for Oliver R. Rotz, Jr.' and recorded among the deed records of Cumberland County Pennsylvania in Plan Book Volume 29, Page 42. TOGETHER with and under and subject to notations as shown on said plan. UNDER AND SUBJECT, to an Easement and Sewage System Agreement, dated November 9, 1994.and recorded November 29, 1994 in the Office of the Recorder of Deeds, in and for Cumberland County, in Misc. Book 486, Page 798. TITLE TO SAID PREMISES VESTED IN Andrew Ressler, individually, by Deed from Andrew Ressler and Shawndi Ressler, his wife, dated 01/23/2012, recorded 09/21/2012 in Instrument Number 201229068. PREMISES BEING: 900 Oakville Road, Newville, PA 17241-9667 PARCEL NO. 30-08-0597-022A THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net WELLS FARGO BANK, N.A. Vs. SHAWNDI RESSLER ANDREW RESSLER WRIT OF EXECUTION NO 14-2941 Civil Term CIVIL ACTION — LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $139,617.79 L.L.: $ .50 Interest from 12/30/14 to Date of Sale ($22.95 per diem) -- $3,580.20 Atty's Comm: Atty Paid: $335.56 Plaintiff Paid: Date: 1/9/15 (Seg}l) Due Prothy: $ 2.25 Other Costs: David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name: MATTHEW BRUSHWOOD, ESQUIRE Address: PHELAN HALLINAN, LLP 1617 JFK BOULEVARD, SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 310592