HomeMy WebLinkAbout14-4043 Supreme Court-of_Pennsylvania
CourAof.CornlafiTleas
, . For Prothonotary Use Only:ziv '1GWv-eP)91" 1A
Uet
Ci71VlBE AND0* County Docket No: Sri;
The information collected on this form is used solely for court administration purposes. This form does not
supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court.
S Commencement of Action:
x❑Complaint ❑Writ of Summons ❑Petition
E ❑Transfer from Another Jurisdiction ❑Declaration of Taking
C Lead Plaintiff s Name: WELLS FARGO BANK,NA Lead Defendant's Name: RANDY E.BURCH
T
I Dollar Amount Requested: ❑ within arbitration limits
Are money damages requested? ElYes 9 No
0 (Check one) ❑D outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ❑x No Is this an MDJ Appeal? ❑ Yes ❑x No
A Name of Plaintiff/Appellant's Attorney: Jonathan Lobb,Esq.,Id.No.312174,Phelan Hallinan,LLP
❑ Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant)
Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS
❑ Intentional ❑Buyer Plaintiff Administrative Agencies
❑Malicious Prosecution ❑Debt Collection: Credit Card ❑Board of Assessment
❑Motor Vehicle ❑Debt Collection: Other ❑Board of Elections
❑Nuisance ❑Dept. of Transportation
❑Premises Liability ❑ Statutory Appeal: Other
❑Product Liability(does not
S include mass tort) ❑Employment Dispute:
❑ Slander/Libel/Defamation Discrimination
E ❑Other: ❑Employment Dispute: Other ❑Zoning Board
C ❑Other:
T
I MASS TORT ❑Other:
O ❑Asbestos
N ❑Tobacco
❑Toxic Tort-DES
❑Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS
❑Toxic Waste ❑Ejectment ❑ Common Law/Statutory Arbitration
B ❑Other: ❑Eminent Domain/Condemnation ❑Declaratory Judgment
❑Ground Rent ❑Mandamus
❑Landlord/Tenant Dispute ❑Non-Domestic Relations
®Mortgage Foreclosure:Residential Restraining Order
PROFESSIONAL LIABILITY ❑Mortgage Foreclosure:Commercial ❑ Quo Warranto
❑Dental ❑Partition ❑Replevin
❑Legal ❑Quiet Title ❑Other:
❑Medical ❑Other:
❑ Other Professional:
Pa.R.C.P. 205.5 Updated 0110-112011
i l
NOTICE
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty(20) days after this Complaint and Notice
are served by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so,the case may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE,PA 17013
(717)249-3166
(800)990-9108
File#: 947223
y� s
J41t ,.
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PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF
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
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK,NA _
3476 STATEVIEW BOULEVARD CIVIL DIVISION
FORT MILL, SC 29715 r ,� �O(,f 3 fill
Plaintiff, NO.:
VS.
RANDY E. BURCH
1316 STRAFFORD ROAD
CAMP HILL, PA 17011-6206
TAMMI L. SORKIN A/K/A TAMMI BURCH
1316 STRAFFORD ROAD
CAMP HILL, PA 17011-6206
Defendants.
CIVIL ACTION- COMPLAINT IN MORTGAGE FORECLOSURE
And now comes WELLS FARGO BANK,NA, by its attorneys, Phelan Hallinan, LLP
and files this Complaint in Mortgage Foreclosure as follows:
062-PA-V4 /V,3&r, a?
/2* 26 P 3 0s
1. The Plaintiff is WELLS FARGO BANK, NA, 3476 STATEVIEW
BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff').
2. The Defendants are, RANDY E. BURCH and TAMMI L. SORKIN A/K/A
TAMMI BURCH, with a last known address of 1316 STRAFFORD ROAD, CAMP HILL, PA
17011-6206.
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 March 30, 2012, RANDY E. BURCH and TAMMI L. SORKIN made,
executed and delivered to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS
NOMINEE FOR COLE TAYLOR BANK, AN ILLINOIS CHARTERED BANK a Mortgage in
the original principal amount of$146,099.00 on the premises described in the legal description
marked Exhibit "B", attached hereto and made a part hereof. Said Mortgage being recorded in the
Office of the Recorder of CUMBERLAND County on April 13, 2012, in Instrument No.
201210742. 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.
062-PA-V4
6. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded March 14,
2014, the mortgage was assigned to WELLS FARGO BANK, NA which Assignment is
recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 201405333.
The Assignment is a matter of public record and is incorporated herein by reference in
accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach
documents to pleadings if those documents are of public record.
7. RANDY E. BURCH and TAMMI L. SORKIN A/K/A TAMMI BURCH are the
record and real owners of the aforesaid mortgaged premises.
8. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the installments of principal and interest due January 1, 2014.
9. As of 06/25/2014,the amount due and owing Plaintiff on the mortgage is as
follows:
Principal Balance $141,008.80
Interest $3,091.32
From 12/01/2013 to 06/25/2014
Late Charges $130.41
Escrow Advance $1,295.88
Property Inspections $0.00
Property Preservation $0.00
BPO/Appraisals $0.00
Escrow Balance $0.00
Corporate Advance Credit $0.00 .
Total $145,526.41
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.
062-PA-V4
10. 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).
11. This action does not come under Act 91 of 1983 because the mortgage is FHA-
insured.
12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is
not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do
so in a separate legal action if such right exists. If Defendant(s) have received a discharge of
personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish
such liability.
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the
amount due of$145,526.41,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: AL&
Date: I Jon n Lo b, Esq., Id.No.312174
Attorney for Plaintiff
062-PA-V4
Exhibit "A"
NOTE
MARCH 30, 2012 ANN ARBOR MICHIGAN
[Date] icityl Istatcl
r
1316 Strafford Road, Camp Hill', Pennsylvania 17011
(Property Address)
1. PARTIES
'Borrower" means each person signing at the end of this Note, and the person's successors and assigns.
"Cruder"means COLE TAYLOR BANK, AN ILLINOIS CHARTERED BANK
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST t
In return for a loan received from Lender, Borrower promises to pay the principal 'sura of
ONE HUNDRED FORTY-SIX THOUSAND NINETY-NINE AND 00/100
Dollars(U.S. S 146, 099. 00
plus interest, to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of
the loan proceeds by Lender, at the rate of THREE AND 875/1000 percent
(
3 .875 %)per year until the,full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated
the same date as this Note and called the"Security Instrument." The Security Instrument protects the Lendcr from
losses which might result if Borrower defaults under this Note.
4. MANNER OF PAYMENT -
(A) Time
Borrower shall make a payment of principal and interest to Lender on the 1st day of each month beginning
on MAY 1, 2012 . Any.principal and interest remaining on the 1st day of
APRIL, 2042 , will be due on that date, which is called the"Maturity Date."
(B) Place
Payment shall be made at 2350 GREEN ROAD, SUITE 100, ANN ARBOR,
MICHIGAN 48105
or at such other place
as Lender may designate in writing by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. S 687 . 01
This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to
principal, interest and other items in the order described in the Security.]nstrument.
(D) Allonge to this Note for Payment Adjustments
If an allongc providing for payment adjustments is executed by Borrower together with this Note,the covenants
of the allongc shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge
were a part of(his Note.
MULTISTATE-FHA FIXED RATE NOTE Docdlagre dV9V e
USFHA.NTE 09125/09 Page 1 of 3 www.doamagk.com
(Check applicable box.)
❑ Growing Equity Allonge
❑ Graduated Payment Allonge
❑ Other[specify];.
5. BORROWER'S FUGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty,
on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest
on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations
of the Secretary. if Borrower makes a partial prepayment, there will be no changes in the due date or in the amount
of the monthly payment unless Lender agrees in writing to those changes.
6. BORROWERS FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security Instrument, as described in
Paragraph 4(C)of this Note, by the end of fifteen calendar days after the payment is due, Lender may colicet a late
charge in the amount of FOUR AND 000/1000 percent( 4 .000 %)
of the overdue amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by
regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance
remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in
the event of any subsequent default. In many circumstances,regulations issued by the Secretary will limit Lender's
rights to require immediate payment in full in the case of payment defaults. This Note does not authorize acceleration
when not permitted by HUD regulations. As used in this.Note, "Secretary" means the Secretary of Housing and
Urban Development or his or her designee.
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full,as described above,Lender may require Borrower to pay costs
and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited
by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the
principal of this Note.
7. WAIVER$
Borrower 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 Lender to demand payment of amounts due. "Notice of
Dishonor" means the right to require Lender to give notice to other persons that amounts due have not been paid.
8. GIVING OF NOTICES '
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note
will be given by delivering it or by mailing it by first class mail to Borrower at the Property Address above or at a
different address if Borrower has given Lender a notice of Borrower's different address.
Any notice that must be given to Lender under this Note will be given by delivering it or by mailing it by first
class mail to Lender at the address stated in Paragraph 4(B)or at a different address if borrower is given a notice of
that different address.
9. 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 Not(:, 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
MULTISTATE-FHA FIXED RATE NOTE 00cNl691e r
USFHA.NTE 0912$109 Page 2 of 3 www_dormagic.com
this Note. Lender may enforce its rights under this Note against each person individually or against all signatories
together. Any one person signing this Note may be required to pay all of the amounts owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the terms.and covenants contained in this Note.
4_z::vI4� L
{Seal} (Seal)
Rand Burch -Borrower -Borrower
(Scat) (Scat)
-Borrower -Borrower
(Sea 1) (Seal)
-Borrower -Borrower
Without recourse:
Pay to the_order of Is Fargo Bank, N.A.
Lisa G. Patterson, Sr.%Ace President
Cote Taylor Bank
021 PAY TO THE ORDER OF
WITHOUT RECOURSE
BY ,
C*I)e
Lod K.Venegonta
Vice President Loan Documentation
Wens Fargo Bank,N.A.
(Sign Original Only)
MULTISTATE-FHA FIX®RATE NOTE Docafeg/c 4ftow e
USFHA.NTE 09/25/09 Page 3 of 3 www.dacmagic,wm
Exhibit "B"
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of land situate in the Township of Lower Allen, County of
Cumberland and Commonwealth of Pennsylvania, bounded and described as follows:
BEGINNING at a point on the westerly line of Strafford Road 137.76 feet North of the
northwest corner of Strafford and Carlisle Roads, at the northerly line of Lot No. 33, Block U, on
the hereinafter mentioned Plan of Lots; THENCE along the latter Lot northwestwardly 120.28
feet to a point on line of other lands now or late of N. P. Ninneman, Incorporated; THENCE
along the latter lands northeastwardly 70.01 feet to a point on line of Lot No. 31, Block U;
THENCE along the latter Lot southeastwardly 111.20 feet to a point on the westerly line of
Strafford Road;THENCE along Strafford Road souhwestwardly by a curve to the South having
a radius of 439.65 feet, an arc distance of 55 feet to a point, the place of BEGINNING.
BEING Lot No. 32, Block U on the Plan of Lots of a portion of Highland Park, dated April 4,
1952, and recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 37.
HAVING THEREON erected a single frame dwelling house, BEING KNOWN and numbered as
1316 Strafford Road, Highland Park, Camp Hill, Pennsylvania.
Parcel# 13-23-0545-323
PROPERTY ADDRESS: 1316 STRAFFORD ROAD, CAMP HILL,PA 17011-6206
PARCEL#13-23-0545-323
File k 947223
VERIFICATION
Carol Swanson,hereby states that he6gis Vice President Loan Documentation
of WELLS FARGO BANK,N.A.,plaintiff in this matter, that he( s 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 hisdPt 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 Carol Swanson
Title: Vice President Loan Documentation
Company: Wells Fargo Bank,N.A.
Date: 06/27/2014
086-PAN2 File#947223
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson FILED-OFFICE
SheriffOE THE PROTHONOTARY
00, ciimber1/4,4)
Jody S Smith 21I 11 JUL 3 1 All 10+ 3 7
Chief Deputy�t
Richard W Stewart CUMBERLAND COUNTY
Solicitor OFFICE OF THE SHERIFF PENNSYLVANIA
Wells Fargo Bank, N.A.
vs.
Randy E Burch (et al.)
Case Number
2014-4043
SHERIFF'S RETURN OF SERVICE
07/11/2014 05:47 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: Randy E Burch, but was unable to locate the Defendant
in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as
"Not Found" at 1316 Strafford Road, Lower Allen, Camp Hill, PA 17011. Deputies were advised that the
defendant moved out and per the Camp Hill Postmaster mail is still delivered to the address provided.
07/11/2014 05:47 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Complaint in
Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the
Defendant, to wit: Tammi L Sorkin at 1316 Strafford Road, Lower Allen, Camp Hill, PA 17011.
SHERIFF COST: $65.95 SO ANSWERS,
July 28, 2014
(c) CountySuite Sheriff, Toleosolf. Inc.
RONNY R ANDERSON, SHERIFF
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
OF THE PRCTfCINU j-
1400
2O6i AUG 20 T.;';11: 0 i
CUMBERLAND COUNTY
PENHSYLVAHj,
WELLS FARGO BANK, NA•
Plaintiff
vs.
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI BURCH
Defendants
Attorney for Plaintiff
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 14 -4043 -CIVIL
MOTION FOR SERVICE PURSUANT TO
SPECIAL ORDER OF COURT
Plaintiff, by its counsel, Phelan Hallinan, LLP, moves this Honorable Court for an Order
directing service of the Complaint and the notice of Sheriff's Sale upon the above -captioned
Defendant, RANDY E. BURCH, by first class mail to RANDY E. BURCH at the mortgaged
premises, 1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206; posting of the mortgaged
premises, 1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206; and publication pursuant
to Pa. R.C.P. 430, and in support thereof avers the following:
1. Attempts to serve Defendant, RANDY E. BURCH, personally with the Complaint
have been unsuccessful. The Sheriff of CUMBERLAND County attempted to serve the
Defendant at the mortgaged premises, 1316 STRAFFORD ROAD, CAMP HILL, PA 17011-
6206. As indicated by the Return of Service, no service was made as the Defendant had moved,
and does not reside at said address. A true and correct copy of the Return of Service is attached
hereto, made part hereof, and marked as Exhibit "A".
2. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the
Defendant. A true and correct copy of an affidavit of due diligence setting forth the specific
inquiries as to the Defendant's whereabouts and the results thereof is attached hereto, made part
hereof, and marked as Exhibit "B".
3. Plaintiff contacted the Prothontary's Office and as of August 8, 2014, no Judge
has previously entered a ruling in this case.
4. In accordance with CUMBERLAND County Local Rule 208.2(d), Plaintiff sent a
copy of its Proposed Motion for Special Service and Order to the Defendant on August 10, 2014
and requested Defendant's concurrence. Plaintiff did not receive any written response from the
Defendant. A true and correct copy of Plaintiffs August 10, 2014 letter and postmarked
certificate of mailing pursuant to Local Rule 208.2(d) attached hereto, made part hereof, and
marked Exhibit "C".
5. Plaintiff has reviewed its internal records and has not been contacted by the
Defendant to bring loan current.
6. Plaintiff submits that it has made a good faith effort to locate the Defendant but
has been unable to do so.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
pursuant to Pa.R.C.P. 430 directing service of the Complaint and notice of Sheriff's Sale by first
class mail; posting; and by publication.
Date: ��%/(e
Respectfully submitted,
PHELAN HALLINAN, LLP
By:
Phelan Hallinan, LLP
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
PHELAN HALLINAN, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza, Philadelphia, PA 19103
215-563-7000
947223
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000 Attorney for Plaintiff
WELLS FARGO BANK, NA Court of Common Pleas
Plaintiff
Civil Division
vs.
CUMBERLAND County
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI BURCH No. 14 -4043 -CIVIL
Defendants
CERTIFICATION OF SERVICE
The undersigned hereby certifies that copies of the Motion for Service Pursuant to Special
Order of Court, Memorandum of Law, Proposed Order and attached exhibits have been sent to
the individual as indicated below by first class mail, postage prepaid, on the date listed below.
RANDY E. BURCH
1316 STRAFFORD ROAD
CAMP HILL, PA 17011-6206
TAMMI L. SORKIN A/K/A TAMMI BURCH
1316 STRAFFORD ROAD
CAMP HILL, PA 17011-6206
The undersigned understands that this statement is made subject to the penalties of 18 Pa.
C.S. §4904 relating to unsworn falsification to authorities.
Date:
1/(7me
Respectfully submitted,
PHELAN HALLINAN, LLP
By:.�C/` '�---
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
947223
Exhibit "A'
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
coo. of CnInLrr4ttio
•
OFFICE 4F THE £i.ERIFF
Wells Fargo Bank, N.A.
vs.
Randy E Burch (et al.)
Case Number
2014-4043
SHERIFF'S RETURN OF SERVICE
07/11/2014 05:47 PM - Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search
and inquiry for the within named Defendant to wit: Randy E Burch, but was unable to locate the Defendant
in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as
"Not Found" at 1316 Strafford Road, Lower Allen, Camp Hill, PA 17011. Deputies were advised that the
defendant moved out and per the Camp Hill Postmaster mail is still delivered to the address provided.
07/11/2014 05:47 PM - Deputy Jamie DiMartle, being duly swom according to law, served the requested Complaint in
Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the
Defendant, to wit: Tammi L Sorkin at 1316 Strafford Road, Lower Allen, Camp Hill, PA 17011.
SHERIFF COST: $65.95 SO ANSWERS,
July 28, 2014
(cl CounlySude Shend, Toleosoff Inc.
RONNY R ANDERSON, SHERIFF
Exhibit "B"
AFFIDAVIT OF GOOD FAITH INVESTIGATION
File Number: 947223
Attorney Firm: Phelan, Hallinan, LLP
Subject: Randy E. Burch & Tammi L. Sorkin
Current Address: 1316 Strafford Road, Camp Hill, PA 17011
Property Address: 1316 Strafford Road, Camp Hill, PA 17011
Mailing Address: 1316 Strafford Road, Camp Hill, PA 1701.1.
L CREDIT INFORMATION
A. SOCIAL SECURITY NUMBER
Our search verified the following information to be true and correct
Randy E. Burch - xxx-xx-8327
Tammi L. Sorkin - 087-56-xxxx
B. EMPLOYMENT SEARCH
Randy E. Burch & Tammi L. Sorkin - A review of the credit reporting agencies
provided no employment information.
C. INQUIRY OF CREDITORS
Our inquiry of creditors indicated that Randy E. Burch & Tammi L. Sorkin reside(s)
at: 1316 Strafford Road, Camp Hill, PA 17011.
II. INQUIRY OF TELEPHONE COMPANY
A. DIRECTORY ASSISTANCE SEARCH
Our office searched directory assistance databases, which indicated that Tammi L.
Sorkin reside(s) at: 1316 Strafford Road, Camp Hill, PA 17011, however had no listing
for Randy E. Burch. On 05-13-14 our office made several telephone calls to the
subject's phone number (717) 737-1268 and received the following information:
answering machine.
B. On 05-13-14 our office made a telephone call to a possible phone number of the
subject(s) (717) 713-5833 and received the following information: spoke with an
unidentified female who confirmed that Randy E. Burch & Tammi L. Sorkin reside(s)
at: 1316 Strafford Road, Camp Hill, PA 17011.
III. ADDRESS INQUIRY
A. NATIONAL ADDRESS UPDATE
On 05-13-14 we reviewed the National Address database and found the .following
information: Randy E. Burch & Tammi L. Sorkin -1.316 Strafford Road, Camp Hill,
PA 17011.
B. ADDITIONAL ACTIVE MAILING ADDRESSES
Per our inquiry of creditors, the following is a possible mailing address: no addresses
on file.
IV. OTHER INQUIRIES
A. DEATH RECORDS
As of 0543-14 Vital Records and all. public databases have no death record on file for
Randy E. Burch & Tammi L. Sorkin.
V. ADDITIONAL INFORMATION OF SUBJECT
A. YEAR OF BIRTH
Randy E. Burch -1979
Tammi L. Sorkin - not available
B. A.K.A.
Tammi L. Stamy; Tammi Burch
* Our accessible databases have been checked and cross-referenced for the above
named individual(s).
* Please be advised our database information indicates the subject resides at the
current address.
I hereby verify that the statements made herein are true and correct to the best of my
knowledge, information and belief and that this affidavit of investigation is made subject to
the penalties of 18 Pa C.S. Sec. 4904 relating to unsworn falsification to authorities.
The above information is obtained from available public records
and we are only liable for the cost of the affidavit.
Exhibit "C"
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
FAX#: 215-568-7616
Noeleen R. Urmson Ext. 1469 Representing Lenders in
Service Department Pennsylvania
August 10, 2014
RANDY E. BURCH
1316 STRAFFORD ROAD
CAMP HILL, PA 17011-6206
TAMMI L. SORKIN A/K/A TAMMI BURCH
.1316 STRAFFORD ROAD
CAMP HILL, PA 17011-6206
R.E. WELLS FARGO BANK, :NA v. RANDY E. BURCH and TAMMI L. SORKIN A/K/A
TAMMI BURCH
Premises Address: 1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206
CUMBERLAND County, No. 14 -4043 -CIVIL
Dear Defendants,
Enclosed please find a true and correct copy of my proposed Motion for Special Service
and Order. In accordance with CUMBERLAND County Local Rule 208.3(9), I am seeking
concurrence with the requested relief that is, service of the complaint by first class mail and
• postinpyithefflortgaged premises. Please respond to me within one week, by
//14014
Should you have any further questions or concerns, please do not hesitate to contact me.
Otherwise, please be guided accordingly.
Very truly yours,
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
947223
Name and
Address
Of Sender
Linc
2
Article Number
Total Number of
Pieces Listed by Sender
Form 3877 Facsimile
Phclan Hallinan, LLP
1617 3FK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103 NRU
Name of Addressee, Street, and Post Office Address
RANDY E. BURCH
1316 STRAFFORD ROAD
CAMP HILL, PA 17011-6206
TAMMI L. SORKIN A/K/A TAMMI BURCH
1316 STRAFFORD ROAD
CAMP HILL,PA 17011-6206
Postage
$0.48
RE: RANDY E. BURCH (CUMBERLAND) TEAM 4 PH # 947223/1021 Page 1 of 1
Total Number of Picccx
Received at Post Office
$0.48
$0.96
Postmaster, Per (Name of
Receiving Employee)
Thc full declaration of value is requircd nn all domestic and international registered mail. Thc ma;
for the reconstruction of nonnegotiable documents under Express Mail document reconstruction in
piece subject to a limit of SSO0,000 per occurrence. The maximum indemnity payable on Express
The maximum indemnity payable Lt 525.000 for registered mail, sent with optional insurance. Sec
R900 S913 and 5921 for limitations of coverage.
947223
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
WELLS FARGO BANK, NA
Plaintiff
vs.
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI BURCH
Defendants
Attorney for Plaintiff
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 14 -4043 -CIVIL
MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION
FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT
I. FACTUAL BACKGROUND
Attempts to serve Defendant, RANDY E. BURCH, with the Complaint have been
unsuccessful. The Sheriff of CUMBERLAND County attempted to serve the Defendant at the
mortgaged premises, 1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206. As indicated
by the Return of Service, no service was made. Pursuant to Pa.R.C.P. 430, Plaintiff has made a
good faith effort to discover the whereabouts of the Defendant as evidenced by the affidavit of
due diligence setting forth the specific inquiries as to the Defendant's whereabouts and the results
thereof. Further, Plaintiff's counsel has reviewed its internal records and has not been contacted
by the Defendant to bring loan current. Consequently, Plaintiff submits that it has made a good
faith effort to locate the Defendant but has been unable to do so.
II. LEGAL AUTHORITY
Pennsylvania Rule of Civil Procedure 430(a) specifically states:
947223
If service cannot be made under the applicable rule, the plaintiff may move the court
for a special order directing the method of service. The motion shall be
accompanied by an affidavit stating the nature and extent of the investigation which
has been made to determine the whereabouts of the defendant and the reasons why
service cannot be made.
Pa.R.C.P. 430(a) (2009).
In particular:
An illustration of a good faith effort to locate the defendant includes (1) inquiries
of postal authorities including inquiries pursuant to the Freedom of Information
Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends, and
employers of the defendant, and (3) examinations of local telephone directories,
voter registration records, local tax records, and motor vehicle records.
Id. at 430(a) n.
Similarly, the Pennsylvania Superior Court has gone on to explain that, "While by no
means exhaustive, this Note is at least indicative of the types of procedures contemplated by the
legislature when enacting Rule 430." Deer Park Lumber, Inc. v. Major, 384 Pa. Super. 625, 633,
559 A.2d 941, 946 (1989), appeal denied, 525 Pa. 582, 575 A.2d 113 (1990). Only after such
proof has been offered is the Court authorized to direct another method of substitute service. See
id.
In the instant case, as indicated by the Return of Service, the Sheriff has been unable to
serve the Complaint. Plaintiff has made a good faith effort to discover the whereabouts of the
Defendant as evidenced by the affidavit of due diligence. Therefore, Plaintiff respectfully
requests an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail,
posting, and publication.
Additionally, pursuant to Pennsylvania Rule of Civil Procedure Rule 3129.2, it is necessary
in a foreclosure action for the Sheriff or Process Server to serve upon the Defendant Notice of the
947223
Sale of the mortgaged premises. Specifically, Pa. R.C.P. Rule 3129.2(c) provides in applicable part
as follows:
The written notice shall be prepared by the plaintiff, shall contain the same information as
the hand bills or may consist of the handbill and shall be served at least thirty days before
the sale on all persons whose names and addresses are set forth in the affidavit required by
Rule 3129.1.
(1)
(i)
Service of the notice shall be made:
upon a defendant...
(A) by the sheriff or by a competent adult in the manner prescribed by
Rule 402(a) for the service of the original process upon a defendant,
or
(B) by the plaintiff mailing a copy in the manner prescribed by Rule
403 to the addresses set forth in the affidavit; or
(C) if the service cannot be made as provided in subparagraph (A) or (B),
the notice shall be served pursuant to special order of court as
prescribed by Rule 430, except that if original process was served
pursuant to special order of court under Rule 430 upon the defendant in
the judgment, the notice may be served upon that defendant in the
manner provided by the order for service of original process without
further application to the court.
Therefore, Plaintiff respectfully requests that the Court allow for service of the Notice of Sale
upon Defendant in accordance with Pa. R. C. P. Rule 430 by first class mail and posting.
III. CONCLUSION
As indicated by the Return of Service, the Sheriff has been unable to serve the Complaint
upon the Defendant. Plaintiff has made a good faith effort to discover the whereabouts of the
Defendant as evidenced by its affidavit of due diligence.
947223
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
pursuant to Pa.R.C.P. 430 directing service of the Complaint and Notice of Sheriff's Sale by first
class mail, posting, and publication.
Date: f7(?775r
Respectfully submitted,
PHELAN HALLINAN, LLP
By:
Adam H. Davis, Esq., Id. No.203034
Attorney for Plaintiff
947223
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, NA
Plaintiff
vs.
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI BURCH
Defendants
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 14 -4043 -CIVIL
ORDER
AND NOW, this Z/ a day of , 2014, upon consideration of Plaintiff s
motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED,
that said Motion is GRANTED.
It is further ORDERED and DECREED that Plaintiff may obtain service of the
Complaint and of the Notice of Sheriffs Sale as authorized by Pa.RCP. 3129.2 (c)(1)(i)(C)*, on
the above captioned Defendants, RANDY E. BURCH, by:
1. Posting of the premises: 1316 STRAFFORD ROAD, CAMP HILL, PA
17011-6206 by the Sheriff or a non-party competent adult; and
2. First class mail to RANDY E. BURCH at the mortgaged premises located
at 1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206. Service by mail is
complete upon the date of mailing.
C)
-n �' n
t`ern
72)
r— ' C7
s'
ce,) E,ri
PH # 947223/NRU
It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file
a certificate of service with the Prothonotary's office to ensure compliance with this Court Order.
BY THE COURT.
4
J.
*Prior to fulfilling the requirements of service of Notice of Sale as set forth this Order, Plaintiff must first
attempt service as set forth in Pa.RCP. 3129.2(c)(1)(i) (A) or (B). In the vent this attempted service is not
successful, Plaintiff may proceed with service of the Notice of Sale in conformity with this Order.
Cc:
i RANDY E. BURCH
1316 STRAFFORD ROAD,
CAMP HILL, PA 17011-6206
TAMMI L. SORKIN A/K/A TAMMI BURCH
1316 STRAFFORD ROAD
CAMP HILL, PA 17011-6206
Phelan 14d/ favi, LL -P
Coos ptadt'/ 5%'aal/y
PH # 947223/NRU
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, NA
Plaintiff
vs.
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI BURCH
FILED -OFFICE
X11=. PROTHON,OTARY
7.[11 SEP -3 0111: 1?
CUMBERLAND f
PENNSYLVANIA COUNTY
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: CUMBERLAND COUNTY
: No. 14 -4043 -CIVIL
Defendants
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.
Date:
/sdk, Svc Dept.
File# 947223
By:
Kenya dates, Esq., Id. No.203664
Attorney for Plaintiff
PHELAN HALLINAN, LLP
CD
iS 11.115 PA Air/
et 1450199
2,'3lo55y
FILED -OFFICE
Ur rHE PROTHONOTAf i•
Phelan Hallinan, LLP
Kenya Bates, Esq., Id. No.20364JSEP 1 1M JO; 5 OTTORNEYS FOR PLAINTIFF
kenya.bates@phelanhallinan.corn
1617 JFK Boulevard, Suite i406UMBERLAND COUNTY
One Penn Center Plaza PENNSYLVANIA
Philadelphia, PA 19103
215-563-7000
WELLS FARGO BANK, NA
Plaintiff
vs.
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI BURCH
Defendant(s)
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
No. 14 -4043 -CIVIL
A1-1-11.)AVIT OF SERVICE OF COMPLAINT
BY MAIL PURSUANT TO COURT ORDER
I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage
Foreclosure in the above captioned matter was sent by regular mail to the following persons,
RANDY E. BURCH at 1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206 on September
9, 2014, in accordance with the Order of Court dated August 21, 2014. The undersigned
understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to
unsworn falsification to authorities.
DA 1E: ,ii./// By:
PH # 947223
Phelan Hallinan, LLP
Kenya B es, Esq., Id. No.203664
Attorney for Plaintiff
Phelan Hallinan, LLP
AFFIDAVIT OF SERVICE BY POSTING
WELLS FARGO BANK, NA
Plaintiff
v.
RANDY E. BURCH
Defendant
Service Instructions: PLEASE POST BY: 10/03/2014
Serve RANDY E. BURCH at 1316 STRAFFORD ROAD, CAMP
HILL, PA 17011-6206 by posting the property in accordance with the
court Order.
Court of Common Pleas
Civil Division
CUMBERLAND County
No. 14 -4043 -CIVIL
Served 1
Po ted and made known to RANDY E. BURCH, Defendant on the I43 a day of Jer ' , 20Iat ha;r
M., at 1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206; in the manner described below:
Property Posted
Other:
e Property was noto ed bcause
o'clock,
wCt L , a coZpetlent adult, being duly sworn according to law, depose and state that I personally posted a true and correct
copy of the Complaint in Mortgage Foreclosure issued in the captioned case on the date and the address indicated above. I understand that this
statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating t. psworn falsification to authorities.
DATE:
PH # 947223
NAME:
PRINTEDE:
�'G
TITLE: Ce55 J; VtR�
b r .
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
OF THE i'i.t, 11i3HUTi-,i!,(
2C i 4 DEC t 9 ID: 37
Attorney for Plaintiff
CUNBERL/. D COUNTY
PENNSYLVANIA
WELLS FARGO BANK, NA : CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
vs.
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI
BURCH
: CIVIL DIVISION
: No. 14 -4043 -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 RANDY E. BURCH and TAMMI L. SORKIN A/K/A
TAMMI BURCH 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 RANDY E. BURCH is over 18 years of age and resides at
1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206.
(c) that defendant TAMMI L. SORKIN A/K/A TAMMI BURCH is over 18 years
of age and resides at 1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date
P n Hallinan, LLP
Jonathan 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
947223
Department of Defense Manpower Data Center
rs •
ceraeinbers Civil Relief Act
;Last Name,: SORKIN
FirstAame:.TAMMI
Middle,Name: L
"Active -Duty Status As Of:.Dec-18-2014
Results as of : Dec -18-2014 12:05:42 AM
SCRA 3.0
_h � M•� `. ,. ,;�
r `� On A e DP O A ee'DDtit Staffs Date uo
DPn
,. .,- yn z, � .v,4o t yDuty" o..r.1": .' #:'cf a '2 6u e�skDa y g
`3„�LeftA'' ve Duty W+thin 387 Days of Achve,Dul Status,Date x ,�
?`E-6Mer,No6ficat{on.Start0ate ^<.+'s'§�.,, �
Actlye D ty;S alt O te
.b'.' 'a
`a ..Activ E d Da°gute...Status
,;. . ":
. . Send
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.
.. _ _ ....._y.:.
3 '
NA
NA
i..w. d { t
., y-:
+w *M�".: M1 y.'A ii �
•..,. • ,,NA^a a . ,.� "«,t'...�=-'a'>
$YY.i .D "" r i Kilt Y . 4.(`.
"vN0*� ._
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73�, "`
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- • - ••- This response refle'cls>the ndwiduats',act,ve duty;statusybased on the,Active DUty,Status Date ';
-
. , M
--.7'4'".-1:-"*"
�„ ` �
-
,. .,- yn z, � .v,4o t yDuty" o..r.1": .' #:'cf a '2 6u e�skDa y g
`3„�LeftA'' ve Duty W+thin 387 Days of Achve,Dul Status,Date x ,�
?`E-6Mer,No6ficat{on.Start0ate ^<.+'s'§�.,, �
HAaiNe, Duiy„Startpate
�, S¢rvide;Gomponent•
'Active Duty.J nd;Date�
�� sista s �� a
,._«. '. ”- T..'Ha'1�t��'
Service Compon 51
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.— x., NA,
t.r
Ai -a...
...y.NA"Jiie'!t;cf'•s
73�, "`
.• ....:.NA ,_
.S
'This response reflects 4fieerre tlle�tndividual le aaet yedduty €te
.a,,:e•
us etitPon 367 day receding the Active„Duty Status Date
'
,The Member;or,H�{ys+l�vHer Unit,Was Notifledrof a Future Call-Upto.Acttve DutyJonfAchve Duty;,Status at
?`E-6Mer,No6ficat{on.Start0ate ^<.+'s'§�.,, �
,-„� ,tomQrder,AYott itatan,nd-Date r'...
, - ;+,#``�StatJS' -
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_ ivid. ter ... .. . 'i; '�'117tp k°5;'rife �,
response reflects wt5 th�he,,mdrviduat n`r tu�lhe ,unit has rece{vetl early tifiC'attat"Sto!repoR for active duty
... _..
:.
•
'ti" t nr L..sr+ Cr t k . �fm.'*^•�. 'Yi7 _ _
Upon searching the data banks of the Department of Defense Manpower Data Center bas dion.the information that you provtded the above -is the status of
the individual on the active duty status"date a§ to H branches of the' n formed„servtce Army, Navy.Marine Corps, Air Force, NOAA, Public'Health, and
•r, -
Coast Guard). This status includes information on`;a'Sefvicemember 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
4600 Mark Center Drive, Suite 04E25
Arlington, VA 22350
Department of Defense Manpower Data Center
Stat L. Report
Pursuant to Sery eernerbers Civil Relief Act
Last Name: BURCH
First Name: RANDY
Middle Name: E
Active Duty Status As Of: Dec -18-2014
Results as of : Dec -18-2014 12:05:41 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 i4` -
_ - - - 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
1 i NA . -
No =
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
1
ri
The Member or His7Her 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 '
Y.No -
NA
This response reflects whether the indroidual 0i -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 Servicemembers Civil Relief Act
Last Name: BURCH
First Name: TAMMI
Middle Name:
Active Duty Status As Of: Dec -18-2014
Results as of : Dec -18-2014 12:07:52 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 ", _ .
---- _ No •
NA
This response reflectsrthe 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
1 , . NA ti.~
- No - 1..
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 --
J. 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.
Mary M. Snavely -Dixon, Director
Department of Defense - Manpower Data Center
4800 Mark Center Drive, Suite 04E25
Arlington, VA 22350
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
if, Attorney for Plaintiff
WELLS FARGO BANK, NA : CUMBERLAND COUNTY
vs. : COURT OF COMMON PLEAS
RANDY E. BURCH : CIVIL DIVISION
TAMMI L. SORKIN A/K/A TAMMI
BURCH : No. 14 -4043 -CIVIL
PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY:
Kindly enter judgment in favor of the Plaintiff and against RANDY E. BURCH, and
TAMMI L. SORKIN A/K/A TAMMI BURCH, 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 $145,526.41
TOTAL
$145,526.41
I hereby certify that (1) the Defendants' last known address is 1316 STRAFFORD
ROAD, CAMP HILL, PA 17011-6206, and (2) that notice has been given in accordance with
Rule Pa.R.C.P 237.1.
Date )1061,
nathan Lobb, Esq., Id. No.312174
Attorney for plaintiff
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: - o�
PH # 947223
PROTHONOTARY
Gk Jet
947223 C
r\• k /V?2/63
-e / 4 lGil
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
Attorney for Plaintiff
WELLS FARGO BANK, NA : CUMBERLAND COUNTY
: COURT OF COMMON PLEAS
vs.
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI
BURCH
: CIVIL DIVISION
: No. 14 -4043 -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 defendant(s) RANDY E. BURCH and TAMMI L. SORKIN A/K/A
TAMMI BURCH 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 RANDY E. BURCH is over 18 years of age and resides at
1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206.
(c) that defendant TAMMI L. SORKIN A/K/A TAMMI BURCH is over 18 years
of age and resides at 1316 STRAFFORD ROAD, CAMP HILL, PA 17011-6206.
This statement is made subject to the penalties of 18 Pa. C.S. Section 4904
relating to unsworn falsification to authorities.
Date (7 l t ct' uy
PhelHallinan, LLP
Jonathan 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
947223
Department of Defense Manpower Data Center
Status .Report
Pursuant to Servicernembers Civil Relief Act
Last Name: SORKIN
First Name: TAMMI'
Middle Name: L
Active Duty Status As Of: Dec -19-2014
Results as of : Dec -19-2014 12:06:31 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• -
•- -- No .
NA
This response reflects the individuals' active duty status based on the Active Duty Status Date
5•
Left Active Duty Within 367 Das of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
+. ,NA �-.
tt
- No^ t
NA
5
This response reflects where the individual left active duly status within 367 days preceding the ActHe 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.
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 Servicemembers Civil Relief Act
Last Name: BURCH
First Name: RANDY
Middle Name: E
Active Duty Status As Of: Dec -19-2014
Results as of : Dec -19-2014 12:06:30 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 7-•
NA
This response reflects the individuals' active duty status based ()lithe 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 •••• *' t 1
NA
This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date
fJ
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 ' -
• ''%Nor ..
NA
This response reflects whether the individual or his/her unit has received early notification to report for active duty
-
1
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 Repoit
Pursuant to Servicemembers Civil. Relief Act.
Last Name: BURCH
First Name: TAMMI
Middle Name:
Active Duty Status As Of: Dec -19-2014
Results as of : Dec -19-2014 12:01:20 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 '.y
NA
This response reflects the individuals' active duty statusbasedon the Active Duty Status Date
•
Len Active Duty Within 367 Days of Active Duty Status Date
Active Duty Start Date
Active Duty End Date
Status
Service Component
NA
. NA
_' No :- t.
NA
This response reflects where theindividual leftactiveduty status within 367 days preceding theyActive 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
y
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
(Rule of Civil Procedure No. 236) - Revised
WELLS FARGO BANK, NA : CUMBERLAND COUNTY
vs.
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI
BURCH
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: No. 14 -4043 -CIVIL
Notice is given that a Judgment in the above captioned matter has been entered
against you on la\ca, lif .
B
If you have any questions concerning this matter please contact:
Phelan Hallinan, LLP
Jonathan Lobb, Esq., Id. No.312174
Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
** THIS FIRM ISA 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. * *
947223
WELLS FARGO BANK, NA
Plaintiff
v.
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI BURCH
Defendant(s)
TO: TAMMI L. SORKIN
A/K/A TAM MI BURCH
1316 STRAFFORD ROAD
CAMP HILL, PA 17011-6206
DATE OF NOTICE:
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 14 -4043 -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 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 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 01-1~'ER 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
B
PH # 947223
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
�/ (717) 249-3166 V V P
y:
PETER WAPNER, Esq., Id. No.31.8263
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
WELLS FARGO BANK, NA
Plaintiff
v.
RANDY E. BURCH
TAMM1 L. SORKIN A/K/A TAMMI BURCH
Defendant(s)
TO: RANDY E. BURCH
1316 STRAFFORD ROAD
CAMP HILL, PA 17011-6206
DATE OF NOTICE: V 114 16 I
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 14 -4043 -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 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 PILE 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
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6195
By:
PH # 947223
CUMBERLAND COUNTY BAR
ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
32 SOUTH BEDFORD STREET
CARLISLE, PA 1.70'13
(717) 249-3166
f
PETER APNER, Esq., Id. No. 8263
Attorney for Plaintiff
Phelan Hallinan, LLP
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
PRAECIPE FOR WRIT OF EXECUTION -(MORTGAGE FORECLOSURE)
P.R.C.P. 3180-3183
Wells Fargo Bank, NA
Plaintiff
V.
Randy E. Burch
Tammi L. Sorkin a/k/a Ta
Defendant(s)
i Burch
To the Prothonotary:
Issue writ of execution in the above matter:
Amount Due
Interest from 12/23/2014 to Date of Sale
($23.92 per diem)
TOTAL
Note: Please attach description of property.
PH # 947223
3/diVithzr
‘03,
: COURT OF COMMON PLEAS
: CIVIL DIVISION
: NO.: 14 -4043 -CIVIL
CUMBERLAND COUNTY
$145,526.41
$3,898.96
$149,425.37
Phel 7 allinan, LLP
Jonathan Lobb, Esq., Id. No.312174
Attorney for Plaintiff
as -tts d
4 50 6L..
NO°
/2 -if 9.6W0
re :1
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of land situate in the Township of Lower Allen, County of Cumberland
and Commonwealth of Pennsylvania, bounded and described as follows:
BEGINNING at a point on the westerly line of Strafford Road 137.76 feet North of the northwest
corner of Strafford and Carlisle Roads, at the northerly line of Lot No. 33, Block U, on the
hereinafter mentioned Plan of Lots; THENCE along the latter Lot northwestwardly 120.28 feet to a
point on line of other lands now or late of N. P. Ninneman, Incorporated; THENCE along the latter
lands northeastwardly 70.01 feet to a point on line of Lot No. 31, Block U; THENCE along the •
latter Lot southeastwardly 111.20 feet to a point on the westerly line of Strafford Road; THENCE
along Strafford Road southwestwardly by a curve to the South having a radius of 439.65 feet, an arc
distance of 55 feet to a point, the place of BEGINNING.
BEING Lot No. 32, Block U on the Plan of Lots of a portion of Highland Park, dated April 4, 1952,
and recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 37.
HAVING THEREON erected a single frame dwelling house.
TITLE TO SAID PREMISES IS VESTED IN Randy E. Burch, a single man and Tammi L.
Sorkin, a single woman, as joint tenants with right of survivorship; by Deed from Nathanael J.
Byerly and Alison N. Byerly, h/w, dated 03/27/2012, recorded 04/13/2012 in Instrument Number
201210741.
PREMISES BEING: 1316 Strafford Road, Camp Hill, PA 17011-6206
PARCEL NO. 13-23-.0545-323
Wells Fargo Bank, NA
fa
2
vs.
Randy E. Burch
Tammi L. Sorkin a/k/a Tammi Burch
: COURT OF COMMON PLEAS
Plaintiff : CIVIL DIVISION
: NO.: 14 -4043 -CIVIL
: CUMBERLAND County
Defendant(s) :
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Randy E. Burch
Tammi L. Sorkin a/k/a Tammi Burch
1316 Strafford Road
Camp Hill, PA 17011-6206
**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 1316 Strafford Road, Camp Hill, PA 17011-6206 is scheduled to be sold at the
Sheriffs 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 $145,526.41 obtained by Wells Fargo Bank, NA (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.
3. The sale will go through only if the buyer pays the Sheriff the full 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 -4043 -CIVIL
Wells Fargo Bank, NA
v.
Randy E. Burch
Tammi L. Sorkin a/k/a Tammi Burch
owner(s) of property situate in LOWER ALLEN TOWNSHIP, CUMBERLAND County,
Pennsylvania, being
1316 Strafford Road, Camp Hill, PA 17011-6206
Parcel No. 13-23-0545-323
(Acreage or street address)
Improvements thereon: RESIDENTIAL DWELLING
Judgment Amount: $145,526.41
Attorneys for Plaintiff
Phelan Hallinan, LLP
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of land situate in the Township of Lower Allen, County of Cumberland
and Commonwealth of Pennsylvania, bounded and described as follows:
BEGINNING at a point on the westerly line of Strafford Road 137.76 feet North of the northwest
corner of Strafford and Carlisle Roads, at the northerly line of Lot No. 33, Block U, on the
hereinafter mentioned Plan of Lots; THENCE along the latter Lot northwestwardly 120.28 feet to a
point on line of other lands now or late of N. P. Ninneman, Incorporated; THENCE along the latter
lands northeastwardly 70.01 feet to a point on line of Lot No. 31, Block U; THENCE along the
latter Lot southeastwardly 111.20 feet to a point on the westerly line of Strafford Road; THENCE
along Strafford Road southwestwardly by a curve to the South having a radius of 439.65 feet, an arc
distance of 55 feet to a point, the place of BEGINNING.
BEING Lot No. 32, Block U on the Plan of Lots of a portion of Highland Park, dated April 4, 1952,
and recorded in the Cumberland County Recorder's Office in Plan Book 5, Page 37.
HAVING THEREON erected a single frame dwelling house.
TITLE TO SAID PREMISES IS VESTED IN Randy E. Burch, a single man and Tammi L.
Sorkin, a single woman, as joint tenants with right of survivorship, by Deed from Nathanael J.
Byerly and Alison N. Byerly, h/w, dated 03/27/2012, recorded 04/13/2012 in Instrument Number
201210741.
PREMISES BEING: 1316 Strafford Road, Camp Hill, PA 17011-6206
PARCEL NO. 13-23-0545-323
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, NA
Vs.
NO 14-4043 Civil Term
CIVIL ACTION — LAW
RANDY E. BURCH
TAMMI L. SORKIN A/K/A TAMMI BURCH
WRIT OF EXECUTION
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: $145,526.41 L.L.: $.50
Interest FROM 12/23/2014 TO DATE OF SALE ($23.92 PER DIEM) - $3,898.96
Atty's Comm:
Atty Paid: $226.45
Plaintiff Paid:
Date: 12/22/14
(Seal)
REQUESTING PARTY:
Name: JONATHAN LOBB, ESQUIRE
Address: PHELAN HALLINAN, LLP
1617 JFK BLVD, SUITE 1400
ONE PENN CENTER PLAZA
PHILADELPHIA, PA 19103
Attorney for: PLAINTIFF
Telephone: 215-563-7000
Supreme Court ID No. 312174
Due Prothy: $2.25
Other Costs:
David D. Buell, Prothonotary _
Deputy