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Home My WebLink About14-3251 Supreme Court of \Pennsylvania ,fd CourtCommon Pleas .,._. G vi'1 Cover.Sheet For Prothonotary Use Only: Cult/BERLAND' County Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiff's Name: Wells Fargo Bank,NA Lead Defendant's Name: Carol E.Harling as Executrix of the C Estate of Isabella Cline,a/k/a Isabella Krater Cline T j Are money damages requested?: ❑Yes ® No Dollar Amount Requested: within arbitration limits O (Check one) X outside arbitration limits N Is this a Class Action Suit? ❑Yes ® No Is this an MDJ Appeal? ❑Yes ® No A Name of Plaintiff/Appellant's Attorney: Scott A.Dietterick,Esq.c/o Zucker,Goldberg&Ackerman,LLC ❑ Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.if you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance El Premises Liability El Dept.of Transportation ❑ Statutory Appeal: Other S El Product Liability(does not include mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C El Zoning Board T ❑ Other: I MASS TORT ❑ Other: O ❑ Asbestos ❑ Tobacco N ❑ Toxic Tort-DES ❑ Toxic Tort-Implant El Toxic Waste REAL PROPERTY MISCELLANEOUS ❑ Other: ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment B ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ® Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 111112011 062-PA-t/4 Zucker,Goldberg&Ackerman, LLC '' 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, CIVIL DIVISION Plaintiff, NO.: R 3 , U . VS. TYPE OF PLEADING Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline; CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE Defendants. FILED ON BEHALF OF: TO: DEFENDANTS Wells Fargo Bank, NA YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY(20)DAYS FROM SERVICE HEREOF ORA DEFAULTJUDGMENT MAY BE COUNSEL OF RECORD FOR THIS PARTY: ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS ZUCKER, GOLDBERG &ACKERMAN, LLC OF THE PLAINTIFF IS: 3476 Stateview Blvd. Scott A. Dietterick, Esquire- Pa. I.D.#55650 Ft.Mill,SC 29715 Kimberly A. Bonner, Esquire- Pa. I.D. #89705 AND THE DEFENDANT: Joel A.Ackerman, Esquire-Pa I.D.#202729 386Stonehedge Lane Ashleigh Levy Marin, Esquire- Pa I.D. #306799 Mechanicsburg,PA 17055 Ralph M.Salvia, Esquire- Pa I.D.#202946 Jaime R.Ackerman, Esquire- Pa I.D. #311032-- CERTIFICATE OF LOCATION Jana Fridfinnsdottir, Esquire- Pa I.D.#315944 IHEREBY CERTIFY THAT THE LOCATION OF Brian Nicholas, Esquire- Pa I.D. #317240 THE REAL ESTATE AFFECTED BY THIS LIEN IS Denise Carlon, Esquire- Pa I.D.#317226 12 Highland Drive,Camp Hill PA 17011-7513 Municipality: Lower Allen 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 ATTORNEYI( PINTI F (908) 233-8500 a (908)233-1390 FAX ", r ATTY FILE NO.:XWP 189044 office@zuckergoldberg.com File No.:XWP- 189044/rbo -r'C--) _=C�j u-� a 99 1 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF, IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY(30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY(30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. NO.. Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline; Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty(20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU SHOULD NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717)249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. NO.. Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline; Defendants. AVISO LISTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar accion dentro de los proximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamacion o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. LISTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR LINO, LLAME O VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION 3476 Stateview Blvd. Ft. Mill, SC 29715. NO.: Plaintiff, VS. Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline 386 Stonehedge Lane Mechanicsburg, PA 17055; Defendants. CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, NA, by its attorneys,Zucker, Goldberg&Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, NA, 3476 Stateview Blvd., Ft. Mill, SC 29715 (hereinafter"plaintiff"). 2. The Defendant(s) is/are Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline, with a last known address of 386 Stonehedge Lane, Mechanicsburg, PA 17055. 3. 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. 4. Wells Fargo Bank, NA, directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, NA 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. 5. On or about November 23, 2010, Isabella Cline, a single person made, executed and delivered to Wells Fargo Bank, N.A. a Mortgage in the original principal amount of$70,000.00 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 Deeds of Cumberland County on December 2, 2010, Instrument #201035378. The mortgage is a matter of public record and is Zucker,Goldberg&Ackerman, LLC 062-PA-V4 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. 6. Plaintiff is the current Mortgagee. 7. Isabella Cline a/k/a Isabella Krater Cline was the record and real owner(s) of the aforesaid mortgaged premises. 8. Isabella Cline a/k/a Isabella Krater Cline died on September 27, 2013, leaving a Will dated November 8, 2007. Letters Testamentary were granted to Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline on November 1, 2013 in Cumberland County, #21- 13-1161. Decedent's surviving heir(s)at law and next-of-kin is: Paul E. Cline Mary E. Bollinger 9. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the installments of principal and interest due December 1, 2013. 10. As of 05/14/2014 the amount due and owing Plaintiff on the mortgage is as follows: Principal $63,351.48 Interest $1,569.38 From 11/01/2013 to 05/14/2014 Late Charges $104.56 Escrow Advance $2,611.00 Property Inspections $0.00 Property Preservation $0.00 BPO/Appraisals $0.00 Escrow Balance $0.00 Corporate Advance Credit $0.00 Total $67,636.42 Zucker,Goldberg&Ackerman, LLC 062-PA-V4 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 11. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or. Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 12. Plaintiff hereby releases Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline from personal liability for the debt evidenced by the Note and secured by the Mortgage as she is named only in her administrative capacity 13. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is Lot seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendants) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. Zucker,Goldberg&Ackerman, LLC 062-PA-V4 WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of$ 67,636.42 with interest thereon plus additional costs (including additional escrow advances), additional attorneys'fees and costs and for foreclosure and sale of the mortgaged premises. ZUCKER,GOLDBERG&ACKERMAN, LLC BY: Dated: Scott A. Diette ick, Esquire; PA I.D. #55650 f Kimberly A. Bonner, Esquire; PA I.D. #89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D. #306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D.#317226 Attorneys for Plaintiff XWP-189044/rbo 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908)233-1390 FAX Email: Office@zuckergoldberg.com THIS IS AN ATTEMPT TO COLLECT A DEBT,AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker,Goldberg&Ackerman, LLC 062-PA-V4 EXHIBIT A Zucker,Goldberg&Ackerman, LLC 062-PA-V4 x lv NOTE NOVEMBER 23, 2010 Matel ]Cityl IState) 12 HIGHLAND DRIVE,. CAMP SILL, PA 17011 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $******70.000.00 (this amount is called "Principal'). plus interest, to the order of the Lender.The Lender is SPELLS 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 4.625 %. 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 t will make these payments every month until I have paid all of the principal and interest and any other charges described below that t 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 DECEMBER 01, 2030 , 1 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 ROME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 or at a different place if requited by the Note Halder. (8)Amount of Monthly Pati ments My monthly payment will be in the amount of U.S. $ •***447.59 4. BORROWER'S RIGHT TO PREPAY \. � I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, 1 will tell the Nate Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. as wer t BrvwBS MULTISTATE FIXED RATE NOTE-Sime family-Famde MaeJFtWI14 Mee UNIFORM INSTRUMENT form 320X)1101 VMPSN i0so3i.00 NM L 3200 OCNOTI Rev 3!2009 Irtit.als: Psga of 3 S. 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 5.000 `Yo of my overdue payment of principal and interest. 'I will pay this late charge promptly but only once on each late payment. (B)Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C)Notice of Default If I am in default, the Note Holder may send me a written notice telling me that if 1 do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (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 am in default at a later time. (E)Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above. the Note Holder will have the right to be paid back by me for all of its 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 1 am given a notice of that different address. S. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep 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. MULTISTATE FIXED RATE NOTE-SiVe Family-Fannie MaelFr*We Mac UNIFORM INSTRUMENT Form 3200 1101 v"0 Sa VMPSN t08031.00 Watws Ktuwer Financial Services mkin4s: !' r Page 2 of 3 10. UNIFORIM 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 1 do not keep the promises which 1 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 1 owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred) without Lender's prior written consent. Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period. Lender may invoke any remedies permitted by this Security Instrument without further notice or demand on Borrower. WITNESS THE HAND(S)AND SEAL(S)OF THE UNDERSIGNED. _j.,-, Q� al-t-- (Seal) (Seal) ISABELLA CLINE -Borrower -Borrower (Seal) (Seal) -Bormwer -Borrower (Seal) (Seal) -Bormwer -Bormwer (Seal) (Seal) .Borrower -Borrower /Sign Original Onlyl MULT/STATE FiXEO RATE NOTE-ShVIe Fatuity-Fvwv a Maelkeddie Mac UNIFORM INSTRUMENT Form 3200 1101 vMP C� VMPSN 1080300 writers Khtwer Financial Services Page 3 et 3 EXHIBIT B Zucker,Goldberg&Ackerman, LLC 062-PA-V4 ALL THAT CERTAIN lot or tract of land situate in the Township of Lower Allen, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows to wit; BEGINNING at a point,which point is on the northerly side of Highland Drive, 120 feet In an easterly direction by same from Village Road at the dividing line between Lots Nos.28 and 27 on the hereinafter mentioned Plan of Lots; thence, North 9 degrees 22 minutes West along Lots Nos,26 and 27 on said Plan 85.75 feet;thence,North 85 degrees 25 minutes East on a line parallel to Highland Drive 109,5 feet to Lot No,28 on said plan; thence, South 10 degrees 5 minutes West along the western line of Lot No.29 on said Plan, 75.37 feet to the northern line of Highland Drive;thence,South 80 degrees West along the northern line of Highland Drive 110 feet to the place of BEGINNING. Being Lot No.27 on the Pian of Highland Village which plan is recorded in the Cumberland County Recorder's Office In Plan Book 3,Page 98. Having thereon erected a one-story brick bungalow known and numbered as 12 Highland Drive, Highland Village. PARCEL 13-23-0847-449 (2010969.PFD12010989. MA7) VERIFICATION Linwood Williams , hereby states that hshe is Vice President Loan Documentation of WELLS FARGO BANK, N.A.,plaintiff in this matter, thatoi /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 hei /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. Name: Linwood Williams Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 05/15/2014 086-PA-V2 File# 189044 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, 51 c U t' VS. NO.: 1 C-) Carol E. Harling as Executrix of the Estate of s 4T Isabella Cline, a/k/a Isabella Krater Cline; ;f� - � c� co Defendants. - NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE ={ a 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 Zucker,Goldberg&Ackerman, LLC XW P-189044 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. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE.TIDS PROGRAM IS FREE. ZUCKER, GOLDBERG &AGKNIVIAN, LLC By: Dated: Scott A. Diett-erick, Esquire; PA I.D.#55650 �3 Kimberly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032, Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D.#317226 Attorneys for Plaintiff XWP-189044/mti 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX Email: Office@zuckergoldberg.com Zucker,Goldberg&Ackerman,LLC XW P-189044 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: CUSTOM , . APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date you closed your loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes& Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes,provide names, location of court,case number&attorney: Zucker,Goldberg&Ackerman, LLC XW P-189044 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: 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 AMOUNT Mortgage Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/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): Fax: Email: Zucker,Goldberg&Ackerman, LLC XWP-189044 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 or lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): Contact: Phone: AUTHORIZATION I/We, , authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the 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: V Proof of Income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of current utility bill V Letter explaining reason for delinquency and any supporting documentation(hardship letter) V Listing agreement(if property is currently on the market) Zucker,Goldberg&Ackerman, LLC XW P-189044 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, NO.. VS. Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline; Defendants. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28,2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program,the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property,which is defendant's primary residence; 2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program"and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker,Goldberg&Ackerman, LLC XW P-189044 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, NO:. VS. Carol E. Harling as Executrix of the Estate of Isabella Cline,a/k/a Isabella Krater Cline; Defendants. CASE MANAGEMENT ORDER AND NOW, this day of ,20 ,the defendant/borrower in the above- captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on at M. in at the Cumberland County Courthouse,Carlisle, Pennsylvania. 1. At least twenty-one (21)days prior to the date of the Conciliation Conference,the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2)which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court,the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court,the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 2. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference.The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable Zucker,Goldberg&Ackerman, LLC XW P-189044 resolution,and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference,the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 3. At the Conciliation Conference,the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure;entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker,Goldberg&Ackerman, LLC XWP-189044 SHERIFF'S OFFICE OF CUMBERLAND COUNTY RonnyR Anderson Sheriff � � . TA� PRO-HA�0 T8NY Jody��h CIO `v Chief Deputy Y]|� JUN 25 �M �` ~� �°'` ""., �" ' .. °. �� Richard VVStewart Solicitor CUMBERLAND TPENNSYLVANIAy Wells Fargo Bank, N.A . Case Number vs. | 2014'3251 Carol EHarling, Executrix ofthe Estate of}mbmUaCline | SHERIFF'S RETURN OF SERVICE 0602/2014 O3:U9PN1' Deputy Noah Cline, being duly sworn according hzlaw, served the requested Notice cf Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Amy Knauss, niece and Patrick Schwartz, occupant,who accepted as"Adult Person in Charge"for Carol E Harling, Executrix of the Estate of |obeUmCline ad12Highland Drive, Lower Allen, Camp Hill, PA17O NOAH CLINE, DEPUTY 08/16/2014 03:00 PM-Deputy William Cline, being duly sworn according to law, served the requestedNotice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing otrue copy toaperson representing themselves tobethe Defendant,towit: Carol EHarling, Executrix ofthe Estate uf|sbeUaCline at38G8hunehed Lane, PA 17055. E: WLIAM CLINE, DEPUTY SHERIFF COST: *83.20 S[)ANSWERS, June 17. 2O14 RQNNYRANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA, vs. Plaintiff, Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline; Defendants. Mortgaged Premises: 12 Highland Drive, Camp Hill, PA 17011-7513 CIVIL DIVISION No.: 14 -3251 -CIVIL ISSUE NUMBER: TYPE OF PLEADING: PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) FILED ON BEHALF OF: Wells Fargo Bank, NA Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa. I.D. #55650 Kimberly A. Bonner, Esquire- Pa. I.D. #89705 Joel A. Ackerman, Esquire- Pa I.D. #202729 Ashleigh L. Marin, Esquire- Pa I.D. #306799 Ralph M. Salvia, Esquire- Pa I.D. #202946 Jaime R. Ackerman, Esquire- Pa I.D. #311032 Jana Fridfinnsdottir, Esquire- Pa I.D. #315944 Brian Nicholas, Esquire- Pa I.D. #317240 Denise Carlon, Esquire- Pa I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XWP-189044 C.: • s1/4LP ertt -k+-31S9 Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, LLC No Asp," nA/)-189041 UN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, »S. Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline; NO.: 14 -3251 -CIVIL Defendants. PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above -captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to Plaintiff's Complaint within the appropriate time Iimits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $67,636.42 plus interest on the judgment amount ($67,636.42) from May 15, 2014, at the statutory rate and for foreclosure and sale of the mortgaged premises. 1 hereby certify that the defendant's last known address is: 386 Stonehedge Lane 12 Hihland Drive Mechanicsburg, PA 17055 Camp Hill, PA 17011- 7513 ZUCKER, GO BERG&ACKERKAN,UI Dated: �~� \~V ' BY� ��V�/ � � , Li Scott A. DietterickEsquire; PA. ia#SS6SD Kimberly A.Bonner, Esquire; PA. |.D.#897O5 Ralph M. Salvia, Esquire; PAiD.#2O2946 Ei Joel A^Ackerman, Esquire; PAID. #2OZ729 12 Ashleigh L.Marin, Esquire; PA|.D.#3OG799 11) Jaime R.Ackerman, Esquire; PA|.D.#311032 \ 1 Jana Fridfinnsdottir, Esquire; PA |.D.#31S844 ri Denise Carlon, Esquire; PA|.D.#317Z26 Brian Nicholas, Esquire; PA|.D.#317Z4O [_] Roger Fay, Esquire; PAiD.#]IS9D7 Attorneys for Plaintiff XVVP-189044 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: fice@zuckergoldberg.com DAMAGES — HEREBY //q7 Date �Y�/. UN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANA Wells Fargo Bank, NA CIVIL DIVISION »S. NO.: 14 -3251 -CIVIL Caroi E. Hariing as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline; Defendants. AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true and correct to the best of my knowledge, information, and that: 1) The Defendant Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline is not in the military service of the United States of America to the best of my knowledge, information and belief as evidenced by the attached copies; 2) The Notice of lntent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time Iimits providecl for that notice have expired. Dated: M `t k � ' Sworn to and subscribed bfore me Thisl-1- k/ , day �pu�o&120� ^_. . �— '. NotaryPublic & ACKERMAN, LLC BY: hiL"" El Scott A. Dietterick, Esquire; PA. I.D. #55650 Kimberly A.Bonner, Esquire; PA. iD.#897D5 El Ralph M. Salvia, Esquire; PA I.D. #202946 Ei Joel A`Ackerman, Esquire; PAiD.#2027Z9 Ashleigh L.Marin, Esquire; PAiD.#306799 Jaime R. Ackerman, Esquire; PAiD.#B11D33 EI Jana Fridfinnsdottir, Esquire; PAiD.#315944 Denise Carlon, Esquire; PA|.D.#3172Z6 Brian Nicholas, Esquire; PAiD.#317Z40 E Roger Fay, Esquire; PAiD.#31S987 Attorneys for Plaintiff XVVP'189044 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com My Commission Expires: PAUL C. NADRATOWSKI Notary Public of New Jersey ID# 2407850 My Commission Expires 4/27/2016 Zucker, Goldberg & Ackerman, LLC m^/n'`*noux Department of Defense Manpower Data Center Status Report Pursuant to Servieemembers Civil Relief Act Last Name: HARLING First Name: CAROL Middle Name: E Active Duty Status As Of: Nov -14-2014 Results as of : Nov -14-2014 01:59:06 PM 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 at Active Duty Status Date Active Duty Start Date Active Duty End Dale Status Service Component NA NA No NA This response reflects where the Individual left active duly status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified ole Future Call -Up to Active Duly 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 hls/her unit has received early notification to report for active duly 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. YA. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: FF5421 FAZOD2170 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline; Defendants. NO.: 14 -3251 -CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT TO: Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline 386 Stonehedge Lane Mechanicsburg, PA 17055 AND 12 Highland Drive Camp Hill, PA 17011-7513 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ki\\C1`\t{ [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $67,636.42 pluosts. Zucker, Goldberg & Ackerman, LLC X W P-189044 Ronny RAnderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND ��:�U8N�� .~.��..��..��... . y3|� JUN 25 PM 3: ��--`�— ..,_ ,~oFfice OF TH SHERIFF CUMBERLAND COUNTYPENNSYLVANIA W&ls Fargo Bank,N.A. Case Number `~. 2014-3251 Carol EHarling, Executrix ofthe Estate nf|mboUmCline | SHERIFF'S RETURN OF SERVICE 00028014 Noah Cline, being according law, served the roquested Notie of Resictential Mortgage Foreclosure Diversion Program and Complaint inhanding a true copy to a person representinthemselves to be Amy Knauss, niece and Patrick Schwartz, occupant, who accepted as "Adult Person in Charge" for Carol E Harling, Executrix of the Estate of iobela Cline o112Highland Drive, Lower Allen, Camp Hill, RA17O11. NOAH CLINE, DEPUTY 06/16/2014 03:00 PM - Deputy William Cline, 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: Carol E Harling, Executrix of the Estate of Isbella Cline at 386 Stonehedge Lane, U per Allen, Mechanicsburg, PA 17055. INE, DEPUTY SHERIFF COST: $83.20 SO ANSWERS, June 17, 2014 (c)CountySuite Sheriff, Teleosoft, Inc. g_ ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline; Defendant. NO.: 14 -3251 -CIVIL IMPORTANT NOTICE TO: Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline 386 Stonehedge Lane Mechanicsburg, PA 17055 DATE OF NOTICE: 10/30/2014 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) days from the date of this notice, a -judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. Carol E. Harling as Executrix of the Estate of Isabella • Cline, a/k/a Isabella Krater Cline; Defendant. NO.: 14 -3251 -CIVIL AVISO IMPORTANTE TO: Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline 386 Stonehedge Lane Mechanicsburg, PA 17055 FECHA DEL AVISO:10/30/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXIMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS INIPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDJA.TAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR. UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 ZUCKER GOLDBERG & ACKERMAN BY: Scoff- A. Di e4 e-ri,c k. Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 189044 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. Carol E. Harling as Executrix of the Estate of Isabella Cline, a/kla Isabella Krater Cline; Defendant. NO.: 14 -3251 -CIVIL IMPORTANT NOTICE TO: Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline 12 Highland Drive Camp Hill, PA 17011 DATE OF NOTICE: 10/30/2014 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline; Defendant. NO.: 14 -3251 -CIVIL AVISO IMPORTANTE TO: Carol E. Harling as Executrix of the Estate of Isabella Cline, a/k/a Isabella Krater Cline 12 Highland Drive Camp Hill, PA 17011 FECHA DEL AVISO:10/30/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMkR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CAB O UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE ASU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE ]NFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE T O DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 ZUCKER GOLDBERG & ACKERMAN BY: Scot(- A. D i.e�Fteri,r.k, Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 189044