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HomeMy WebLinkAbout14-5390 Supreme Court f Pennsylvania Court of Connr"n Pleas -hil Cover Sleet For Prothonotary Use Only: CoWr Df' 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 El Transfer from Another Jurisdiction El Declaration of Taking E Lead Plaintiff's Name: Wells Fargo Bank,N.A. Lead Defendant's Name: Mina Mesic C T Are money damages requested?: ❑Yes ® No Dollar Amount Requested: within arbitration limits I (Check one) x outside arbitration limits O 7- N Is this a Class Action Suit? E:1 Yes ® No Is this an MDJ Appeal? ❑Yes ® No Name of Plaintiff/Appellant's Attorney: Scott A.Dietterick,Esq.c/o Zucker,Goldberg&Ackerman,LLC A ❑ 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 [1 Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card El Motor Vehicle F1 Board of Assessment ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance El Dept.of Transportation El Premises Liability El Product Liability(does not include ❑ Statutory Appeal: Other S mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination El Other: E] Employment Dispute: Other C El Zoning Board T El Other: I MASS TORT ElOther: O ❑ Asbestos ❑ Tobacco N ❑ Toxic Tort-DES ❑ Toxic Tort-Implant �,�,PROPERTY El Toxic Waste 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 El Legal El Replevin ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1//2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A., CIVIL DIVISION Plaintiff, NO.: )q— .5 ,3�3D �U� VS. TYPE OF PLEADING Mina Mesic; Mahmut Mesic; Unis Mesic; CIVIL ACTION -COMPLAINT Defendants. IN MORTGAGE FORECLOSURE TO: DEFENDANTS FILED ON BEHALF OF: YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY(20)DAYS FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE Wells Fargo Bank, N.A. ENTERED AGAINST YOU. Plaintiff I HEREBY CERTIFY THAT THE ADDRESS OFTHE PLAINTIFF IS: COUNSEL OF RECORD FOR THIS PARTY: 3476 Stateview Blvd. Ft.Mill,SC 29715 ZUCKER, GOLDBERG &ACKERMAN, LLC AND THE DEFENDANT: Scott A. DietteriCk, Esquire- Pa. I.D.#55650 106 June Drive Kimberly A. Bonner, Esquire- Pa. I.D.#89705 Camp Hill,PA 17011 Joel A.Ackerman, Esquire- Pa I.D.#202729 Ashleigh Levy Marin, Esquire- Pa I.D.#306799 CERTIFICATE OF LOCATION Ralph M.Salvia, Esquire- Pa I.D.#202946 1 HEREBY CERTIFY THAT THE LOCATION OF Jaime R.Ackerman, Esquire- Pa I.D. #311032-- THE REAL ESTATE AFFECTED BY THIS LIEN IS Jana Fridfinnsdottir, Esquire- Pa I.D.#315944 106 June Drive Cam Hill PA 17011 Municipality: Camp Hill Brian Nicholas, Esquire- Pa I.D.#317240 Denise Carlon, Esquire-Pa I.D.#317226 Roger Fay, Esquire; PA I.D.#315987 ATTORNE FO I 200 Sheffield Street, Suite 101 ATTY FILE NO.:XFP 192199 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-192199 r,- r St: C —{ y_ � aAj 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, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Mina Mesic; Mahmut Mesic; Unis Mesic; 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 (71.7) 249-3166 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Mina Mesic; Mahmut Mesic; Unis Mesic; Defendants. AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar accion dentro de los prdximos veinte (20) dias despues de la notificacion de esta Demanda y Aviso respondiendo personalmente o por medio de un abogado una comparecencia esc rita y radicando en la Corte por escrito sus defensas y objeciones a las demandas establecidas en su contra. Se le advierte de que si usted falla en tomar accion.como se describe anteriormente, el caso puede proceder sin usted sin previo aviso y un fallo por cualquier suma de dinero reclamada en la demanda 0 cua Iquier otra reclamacion o remedio solicitado por el demandante, puede ser dictado en contra suva por la Corte. Usted puede perder dinero o propiedades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR LINO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND& LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800) 990-9108 Phone (800) 990-9108 (717) 249-3166 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, l NO. VS. I Mina Mesic; Mahmut Mesic; Unis Mesic; • Defendants. • r Q C'.' ---r Cr, NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty(60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. Zucker,Goldberg&Ackerman, LLC XFP-192199 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 &ACK MAN, LLC By: Dated: September�� 2014 Scott A. Dietted . , squire; 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 Attorneys for Plaintiff XFP-192199/ns 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908)233-8500; (908)233-1390 FAX Email: Office@zuckergoldberg.com Zucker,Goldberg&Ackerman, LLC XFP-192199 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date: Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete•your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOMER/PRI 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 XFP-192199 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/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income& Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: Email: Zucker,Goldberg&Ackerman, LLC XFP-192199 1 1 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 XFP-192199 e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.. VS. Mina Mesic; Mahmut Mesic; Unis Mesic; 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 XFP-192199 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, NO.. VS. Mina Mesic; Mahmut Mesic; Unis Mesic; 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 resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the Zucker,Goldberg&Ackerman, LLC XFP-192199 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 XFP-192199 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION 3476 Stateview Blvd. Ft. Mill,SC 29715 NO.: Plaintiff, VS. Mina Mesic 106 June Drive Camp Hill, PA 17011; Mahmut Mesic 106 June Drive Camp Hill, PA 17011; Unis Mesic 1175 Shoreham Road Camp Hill, PA 17011; Defendants. CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, N.A., by its attorneys, Zucker, Goldberg&Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, N.A., 3476 Stateview Blvd., Ft. Mill, SC 29715 (hereinafter"plaintiff"). 2. The Defendant(s) is/are Mina Mesic, with a last known address of 106 June Drive, Camp Hill, PA 17011. 3. The Defendant(s) is/are Mahmut Mesic, with a last known address of 106 June Drive, Camp Hill, PA 17011. 4. The Defendants) is/are Unis Mesic, with a last known address of 1175 Shoreham Road, Camp Hill, PA 17011. 062-PA-V5 Zucker,Goldberg&Ackerman, LLC 5. 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. 6. Wells Fargo Bank, N.A., directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, N.A. is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A copy of said Promissory Note is marked Exhibit A, attached hereto and made a part hereof. 7. On or about March 31, 2009, Mina Mesic, Mahmut Mesic and Unis Mesic made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for MLD Mortgage, Inc. a Mortgage in the original principal amount of$204,888.00 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 April 20, 2009, Instrument #200912394. The mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 8. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded April 7, 2014, the mortgage was assigned to Wells Fargo Bank, N.A. which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument#201407067. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(8), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 9. Mina Mesic, Mahmut Mesic and Unis Mesic are the record and real owners of the aforesaid mortgaged premises. 10. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the installments of principal and interest due February 1, 2014. Zucker,Goldberg&Ackerman, LLC 062-PA-VS 11. As of 08/27/2014 the amount due and owing Plaintiff on the mortgage is as follows: Principal $187,093.40 Interest $5,204.74 From 01/01/2014 to 08/27/2014 Late Charges $0.00 Escrow Advance $2,155.64 Property Inspections $0.00 Property Preservation $0.00 BPO/Appraisals $0.00 Escrow Balance $0.00 Corporate Advance Credit $0.00 Total $194,453.78 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. 12. 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). 13. This action does not come under Act 91 of 1983 because the mortgage is FHA insured. 14. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding,this action is in no way an attempt to re-establish such liability. Zucker,Goldberg&Ackerman, LLC 062-PA-VS WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of $194,453.78 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 &A MAN, LL BY: Dated: n Scott A. Dietteric squire; PA I.D.#55650 `}l/1 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 Attorneys for Plaintiff XFP-192199/rbo 200 Sheffield Street,Suite 101 Mountainside, N1 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-VS EXHIBIT A Zucker,Goldberg&Ackerman, LLC 062-PA-V5 ML,irictalre NOTE MINMER ♦ �- MARCH 31,2009 @u,,itl 106 JUNE.DRIVE,CAMP i1,11LL.,PA 17019 - hh'rywov>4tRdr—1 - I. PARTIES 'Born cr"anaaal.en h#forAtan signits;•a€the Incl t>i"IhiA Notu.atnd ttti,purstxti'S succesaxrstatad a,_aigtt>. "L.ctachur"mean. Ml..D MORTGAGE INC. .and¢€x,tec4esx;,a1's xt'acd asAigus. 2, HORRO WEB'S PROMISE,TO PAY:1NTI?RI ST Ili rtaurn fuf':r taint TecCiPcd li"ttnl l cad(@,13}rastecrprterttimcs taa pm the vuhwipal Woi ul. TWO HUNDRED FOUR THOUSAND EIGHT HUNDRED EIGHTY EIGHT AND NOM00 X X X X X X X X X X X I $ 204,888.00 ? plats lnluru>i-to liar of dcr or!l,cmdri'. 'Intcrc,t st•il't be c4 afgcd On nralMid ti:4161'411, Iran)the dale of dkbilr titncnt o IIIc,haan prm"d;•:$t'Imitku',(0 ilre i'11tu of FOUR AND ONE QUARTER Itcrctititi q 4,250 %"'i per t'car milih 111tt ball lutial lit of p:nncipal lias'bccll p:li d. 3. PROMISE TO PAY SECURED 130rrimcr';protnise to pad'k secttrcd dn'as nmrlgapc,d'i'd of trtlxt 51;Aiulilar seclrrity immnimcol llttat is dated 0ic smoe da(c a5 this Iatric antt wallci,3 the"Scciirilt'IwIrmut',iil.'"'fliu tik-tarlt Intlromuni prolows 0w.Lend=er from los-sats whicli might roolt if Borrower Je iadts under this Now. 4. MANNER OF PAYMENT (A) Time. N1rrotiva I€ail i?ta ia"ti p'l,"m ll of tam" mwml 151 i.Clida oil tile first thy t f'chit mol'oll h9qinllin'g• on MAY,'2005 Any pritiolitil and intcrest roti n;ink on 9'he first dine of APRIL,2039 will be thm on thaal dole,t%Boli ie,,cattcd til::"\3aluritr Datc." (B) Ylacu 1'il4nlce?i,hail'I},'ti mic al, MLA MORTGAGE INC.ATTNh LOAN PAYMENT CFNTER 30-B VREB..ANO ROAD.rLORHANI PARK,NJ 04932 ar ai sut:h phauc lts l.,andcr titaar c1cmmnale its rcriting h+'iutxlicc lu-L3tarrtmcr. (C) Amount I'i:101 mortrllh-pilyll-ont ol'principal and imurcA will he in Iho amolml oFit.S. Y 1,007 93 Thix tan7ueint will be pat'l of n krt!cr mrnthlt'paylimil required by the Securtl4' lnsmllnlent, that Edi atl be,applied ICI princilX0. interest and wheT tl 3n.,in the of dr£sic ti'rillyd in the Vit.". ur'i1,v lmglumcllt. (D) Allungv to this Ntotc for patnIctit ad,jta.Utaenl5 Wan Ajolt"c Arottdililz is-r Inlymctat Id a tntalts is cyeeattcd lit 13orrotl'er tol2cthut tel h this Nutt, the covenants of II'le atk?ngC sll.al I'lie ipcorpu)mtcd inti)ttiij.:hall an,cttd:1110 ALgtlalliticill the cu4•cntnts of d i.€'Scats as 11'Stir t,illoragc ttusc to Ikul of lit;»N,tc.,�t:zlus;l;:,piiiz,tbtc lin+� Graduated Vm merat lilonpo C4ruscinp I; uit+ Alionpe 00ther 1slit:61%'i 5. BORROWER'S RIGHT TOPREPAY Borrower has the rigN iu pat the debt evidco-W I,)v ttai Now in whvIv.of€tit pan' withlllt cli.,rgr 5}r pelvills-;oll the first dery rad:Flit-Illonill, (.alder li't11:Ic:c„pl prt 1palink)ly ti tltlti.t tlijv:IS.t15'is}Ull Ib•l 13arrCtt�i'j13�'?'Init'•11-:Onkilt iltlls aEn€}YS 4-ItAi9d LUT Ilrc wilaindcaai lite ii)=-nnih n1 aha•a.eisalt ia:cluired is k;lldcr and surtaittcd lnr rugutitions of fl.e Sccrcd:an% 11''3znrraa• r m:ko,ri hraraal plcjiaylncla, thiafc iA i'c is'cl:mvou;in €tau data dale air sr 1h;;ariounl ani[lit;nly t}nc tirllhnm:at;mlal. s� u,idcr al;rc'cq in trrttia}};to[lisxptr ch;ulg,a. 11.`�yee11j�{�, J�� f&50.MwFiS:a3a�ise4 rfaae aim - - ____ aatd5 auu t rl i"so^Ido rUp4't!2 ,LEkCf?t St ispt,•5„^.Y:F;Ai u-INC k01t7tX,fi VA IOMW?ta41 (a. BORROWER'S FAILURE TO PAY (A) 'Ceti Cha€kr fur Orerdaac P�rmrnix b ^ If I,elttler has not rvccivcJ giro 1,411 tmoufblr p,tenitill,trghaimd t>y'ttac Svvuri'h'InMILMICnt, 0S&scribed in I�lmt In'ziplif 4(Ci of thus'N"ea bg 11te end of It ealendtir drays afrcr tale pa moot is due, LQndvt€im co kcct ii laic dnagc in it€e:arnotsnt pi FOUR pereant 4,000 %.),It(tic"A'cl-due allimmt of ciach Iiat'ttafttt. (B) Default If 13wraa%crr didaolr,by trait€tle to peay iu 1t1i3 an} ttlnnlhly paymcnt.Ihcn Lcatdci€»at'.eXCcpt as)itnitcct by rcgulaticnts of(Ile:Scmitarr In the cele;of pak'mcni del�aahS, ruiluily znmwdi(a.c.p yinvul.ill full of 1930 pa'btcip€i b atamcu rcnutitliree-date and all accrued interest. IxIidev ma.v choose not lea.ceraisr this op lion wilhout e.aii' i its righis in ttly c.cnt of t=_>;y,s ilm-,q atnt dd:aill, par a€aapr ciacullisttmccs rcgOationr.9ssocti by the scciclarc Brill limit I.crntcr's rights it)rtatpaatre imnacdiaate laaymcni in Cull ill lite case of,paymcrat deivaults.This Now dov, no otuth,3riz.t rcajel,ation wfivu Ilm perulined by 1IU9 t rcgtdulia*aas. M used iu this Now- nwaaae:ata karuU.irr tat He3(asitt(.aMl 1-Irhan Devc ImIcni or his or her dczil trite. (C) Paty€ncni of C4r;tts and Exiwa wit I:Lundcr park rcgml cd iaatmedmic"'w"I om ill ball, as dcscritwd abm C, tc vdarr mak.recIllir,BorroactX to pats cosis and cals:mt iN, inl;,kdinp raasiII €MC,load t;€€sto.mary nuorne s Xa.rs I'm c oreini this Nou En the I:Merit not prohibilvil by appl'ic bib law. Such piers ill)(]costa-,sh€€tt tear interest liean ilio date ul clis'burscuicaa€tat the sate rate,as the pritwap;iI tat this Nole- '.WAIVERS 13;u'rotcwer and ant• ul;tet per:ort at(R) Nis obliplions under this ;None mtiav the iiphts nt leresvrdtucla and nonce ol, disclotatir- "t'r eNi=stat-,"-,levans the!`i,It lea rucit€ire i.cnder iss do-,lurid pustnetit tai atneu-v,;dei."Nofic:o-'dispanYitr' teleaaus pica; right to ret circ kcndcc It,6irc nolicc to oilier pxrctsns ihat arlmin9s dve ts:€rc:not,tmcn paid. 8. GIVING OF NOTICES Uupass aprlictIIlv hnv legllites;a dillcleni molhotl. atl,v r09i cf timt wl:n(Lt'git'cn to I'$(uroeter i-m0cr,Itio Noic will bu given l;c ilctiver'ing, tt or In. €nttihng it by tits-, class trait it) 13atrrotecr :at the property a€(iciness a€l,ovu or r€t n tpit'Iuj-;cart ;€€.ttlr._as pi- Tt,r,ncwcr leers sire I LI.3113.;1a alone,,of 9ltrrmwr,dill"ercrd zjddirss. Am aaotiec IJKu.oat€sl hu ppiy cn it€Lunticr t[ndur this IN'ole b*ri91 he given bn I'iiSl class mad to Lender at ihc:utdtlr,.m stated iia: Parr rt;.,tshit 0031 u€ Z4 n tbiterew a.ddw—it K'nowcr is given a€x=tiec of ifiat u'ittcr,rnm uddres'� t).OBLIGATIONS OF PERSONS IINDEiR THIS NOTE li'mory thin-,ane perm)signs€lei,Ntttc_eadl person is sally ams pu solmliv oblig;0W to keels all:s#'thc promises Imide in -,leis Now, inchlkhog flic prolnava to pay lite felt a awn,mt caved,Any person wt's;?is a gar ,italuor,skuvlt or vn(lot-"cl of this Note'is al.)ohlip alcd ill do IlIc v thin{, Ali,v ptvsoat te$o'.takes cat%Lr thew ehlivatiuu s, indutling the ohliplioms ol'at guarantor, surett err endorser etf(9tis KcIfe. is n9-,,,oblig'atcd to Beep;all of Qu,pmrnt-ws mad,,in this'Nolc. I.titttar may enforce il_s rights und'a this Nww ap;a(ilm u€clt plrescnt indiVidl,i11V or 410inst'III si nt9nric4 togc9licr. Ane tun perSon stgn aag this Nole may he rccpuired to pay all of lite antou=.tis anvcd ander this Notre_ BY SIGNING iBELOW; Rlofl,m'Lranti ugmes€o the germs and rprca>ants contailled in this Now. AN-�n,.,,� \.` r 4np"S �e.'Fca'ta- Z�Y,s MINA MESiG (, MANMU7 MESta: ^'--__. (Seal) tiniresxae 41"tcrW" (SC,91a dSc^atp) - FAY TO E RDIER OF', t?rrra ecr a3urrR,.er Wal's Faigp Bank N.R. rift.3S t 0 m.. f O t3 R 5 1�iI.D M F INC. A NEW.1 RPORATION BY'PHILIP N , >G C,VICE PRESIDENT (�iUEI"} (Sc;d i -tfniY6tta' •iYrfi s,aa. .......... MA tiU M.1te PIMMN 6!d` YM1I?1 a(ir&aUt SEA WITHOUT RECOURSE PAYTO TME ORDER OF Weill Fgrgo Bank,NI X �p��l:ar9 K.Vatlega a Ypga PratddeAll Watt Gvmurn�t lalian EXHIBIT B Zucker,Goldberg&Ackerman, LLC 062-PA-V5 ��✓" kJS/ ALL THAT CERTAIN piece or parcel of land situate in the Borough of Camp Hill (formerly Hampden Township),Cumberland County,Pennsylvania,more particularly bounded and described as follows: BEGINNING at a point on the Western side of June Drive which point is two hundred forty-three and thirty-two- hundredths (243.32) feet South of the monument at the Southwest corner of Trindle Road and June Drive and at the division line of lots Nos. 45 and 46 on the hereinafter mentioned plan of lots; thence South sixty-five (65) degrees thirty-four(34)minutes West along said division line a distance of one hundred thirty(130)feet to a point at lands now or late of Camp Hill Realty Corporation; thence South twenty-four (24) degrees twenty-six (26) minutes East along lands now or formerly of Camp Hill Realty Corporation a distance of sixty-six and sixty-six (66.66) feet to a point at the division line of Lots Nos. 44 and 45 on said plan; thence North sixty-five (65) degrees thirty-four(34)minutes East along said division line a distance of one hundred thirty(130) feet to a point on the Western side of June Drive; thence North twenty-four (24) degrees twenty-six (26) minutes West along said June Drive a distance of sixty-six and sixty-six hundredths(66.66)feet to a point, the place of BEGINNING. BEING Lot No. 45, Block `B", on the Plan of Lots of Trindle Village, Section 1, recorded in the Recorder's Office in and for Cumberland County in Plan Book 8,Page 31. HAVING THEREON ERECTED a single brick and frame ranch house known as 106 June Drive, Camp Hill, Pennsylvania. i 1 . VERIFICATION Jasmin McLean, hereby states that he/bis 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 his 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. Nam :Jasmin McLean Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 08/28/2014 086-PA-V2 File#192199 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY , 01.`' /�� ���-/fQVJ CUMBERLAND - PENNSYLVANIA Wells Fargo BankN.A. Mina Mesic (et al.) Case Number 2014-5390 SHERIFF'S RETURN OF SERVICE 09/17/2014 11:24 AM - Deputy Shawn Gutshall, 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: Mina Mesic at 106 June Drive, Camp Hill Borough, Camp Hill, PA 17011. 09/17/2014 11:24 AM - Deputy Shawn Gutshall, 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: ,"_^_°,"__'__,,"" __�__ ,___',�__^ ,___''' PA^__~ v"="`�=����� /vn�x*,u/v�.�uxpnmovv�g/.�u,xpnm./'u/^n �llfier- 09/19/2014 04:06 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Unis Mesic at 1175 Shoreham Road, Lower Allen, Camp Hill, PA 17011. Vat.^ DAWN KELL, DEPUTY SHERIFF COST: $93.90 SO ANSWERS, September 22, 2014 (c) CountySuite Sheriff: Teieosoft inc. RONNYRANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIAc.), s._ Wells Fargo Bank, N.A., Plaintiff, vs. Mina Mesic; Mahmut Mesic; Unis Mesic; Defendants. Mortgaged Premises: 106 June Drive, Camp Hill, PA 17011 CIVIL DIVISION No.: 14 -5390 -CIVIL ISSUE NUMBER: TYPE OF PLEADING: -57 PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) FILED ON BEHALF OF: Wells Fargo Bank, N.A. 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.: XFP-192199 op-J-4140,s6p41 a�1 Old/ 7Wic Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, C — �) v iXFp 92 (• 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Mina Mesic; Mahmut Mesic; Unis Mesic; Defendants. NO.: 14 -5390 -CIVIL 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 Plaintiffs Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $194,453.78 plus interest on the judgment amount ($194,453.78) from August 28, 2014, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 106 June Drive address is: Dated: t 0 S l '( y DAMAGES ARE HEREBY Date r/ D BY: Camp Hill, PA 17011 ZUCKER, LBERG & ACKERM�.N 1175 Shoreham Road Camp Hill, PA 17011 , LLC ❑ Scott A. r,ietterick,, PA. I.D. #55650 ❑ Kim • rly A. Bonner, Esquire; PA. I.D. #89705 ❑ Ralph M. Salvia, Esquire; PA I.D. #202946 ❑ Joel A. Ackerman, Esquire; PA I.D. #202729 ❑ Ashleigh L. Marin, Esquire; PA I.D. #306799 ❑ Jaime R. Ackerman, Esquire; PA I.D. #311032 ❑ Jana Fridfinnsdottir, Esquire; PA I.D. #315944 ❑ Denise Carlon, Esquire; PA I.D. #317226 ❑ Brian Nicholas, Esquire; PA I.D. #317240 Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XFP-192199 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500(908) 233-1390 FAX Email: Office@z'cker SSESSED AS INDICATED Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Mina Mesic; Mahmut Mesic; Unis Mesic; Defendants. NO.: 14 -5390 -CIVIL 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 Defendants Mina Mesic, Mahmut Mesic, Unis Mesic are 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 Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. Dated: (0 - 3 d - / y Sworn to and subscribed before me This l0 day of 0 G --(0M , 20 (`( Nota Public My Commission Expires: ZUCKER, GOLBERG & ACKERMAJV, LLC BY: 1��� ❑ Scott A. D' tterick, Esquire; PA. I.D. #55650 ❑ Kimberly A. Bonner, Esquire; PA. I.D. #89705 ❑ Ralph M. Salvia, Esquire; PA I.D. #202946 ❑ Joel A. Ackerman, Esquire; PA I.D. #202729 ❑ Ashleigh L. Marin, Esquire; PA I.D. #306799 ❑ Jaime R. Ackerman, Esquire; PA I.D. #311032 ❑ Jana Fridfinnsdottir, Esquire; PA I.D. #315944 ❑ Denise Carlon, Esquire; PA I.D. #317226 ❑ Brian Nicholas, Esquire; PA I.D. #317240 15K1. Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XFP-192199 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com PAUL C. NADRATOWSKI Notary Public c of New Jersey 850 My Commission Expires 4/27/2016 Zucker, Goldberg & Ackerman, LLC YFD_10 )100 Department of Defense Manpower Data Center Status Report Pursuant to Servicernernbers Civil Relief Act Last Name: MESIC First Name: MINA Middle Name: Active Duty Status As Of: Oct -29-2014 Results as of : Oct -29-2014 03:32:36 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 Da a of Active Duty Status Date Active Duty Start Data Active Duty End Date Status Sence Component NA NA No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status . Service Component NA NA . ' No NA This response reflects whether the Individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Ya. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 dai:e"N- 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/PC09SLDR.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: 2FV1X2E0102FM10 Department of Defense Manpower Data Center Status Report Pursuant to Servicernernbers Civil Relief Act Last Name: MESIC First Name: MAHMUT Middle Name: Active Duty Status As Of: Oct -29-2014 Results as of : Oct -29-2014 03:32:29 PM SCRA 3.0 On Active Duty On Active Duty Status Date i 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 Lett Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. 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: DFECX250F02E650 Department of Defense Manpower Data Center Status Report Pursuant to Servicementhers Civil Relief Act Last Name: MESIC First Name: UNIS Middle Name: Active Duty Status As Of: Oct -29-2014 Results as of : Oct -29-2014 03:05:53 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 The Member or His/Her Unit Was Notified of a Future Cat -Up to Active Duty on Active Duty Status Date Left Active Duty within 367 Days of Active Duty Status Date Active Duty Start Date Status Active Duty End Date Status ' Service Component NA NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Cat -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 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/PC09SLDR.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: 5FSEW1COYOE7J80 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Mina Mesic; Mahmut Mesic; Unis Mesic; Defendants. NO.: 14 -5390 -CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT TO: Mina Mesic 106 June Drive Camp Hill, PA 17011 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decr a or Judgment was entered in the above captioned proceeding on I C 31 U [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $194,453.78 plus cost Prothonotji'^� Zucker, Goldberg & Ackerman, LLC XFP-192199 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Mina Mesic; Mahmut Mesic; Unis Mesic; Defendants. NO.: 14 -5390 -CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT TO: Mahmut Mesic 106 June Drive Camp Hill, PA 17011 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, D cree or Judgment was entered in the above captioned proceeding on 11) 1 g/ ) y [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $194,453.78 plus cost§§ Prothoriota Zucker, Goldberg & Ackerman, LLC XFP-192199 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Mina Mesic; Mahmut Mesic; Unis Mesic; Defendants. NO.: 14 -5390 -CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT TO: Unis Mesic 1175 Shoreham Road Camp Hill, PA 17011 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Ord r, Decree or Judgment was entered in the above captioned proceeding on D ?j1 t.1 [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $194,453.78 plus costs. Prothonotary Zucker, Goldberg & Ackerman, LLC XFP-192199 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY c.Ut'�ti, 01INilrrJ. Iib Wells Fargo Bank, N.A. vs. Mina Mesic (et at) Case Number 2014-5390 SHERIFF'S RETURN OF SERVICE 09/17/2014 11:24 AM - Deputy Shawn Gutshall, 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: Mina Mesic at 106 June Drive, Camp Hill Borough, Camp Hill, PA 17011. ."r,-DEPUTYS HAS GUT 09/17/2014 11:24 AM - Deputy Shawn Gutshall, 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: Mahmut Mesic at 106 June Drive, Camp Hill Borough, Camp Hill, PA 1701 TSHAD Ef —W 09/19/2014 04:06 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Unis Mesic at 1175 Shoreham Road, Lower Allen, Camp Hill, PA 17011. /1-t e n SHERIFF COST: $93.90 September 22, 2014 DAWN KELL, DEPUTY SO ANSWERS, RNNY R ANDERSON, SHERIFF (ci Coo r,(ySuiio Shonfl, I r•I::csoff Inc IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Mahmut Mesic Mina Mesic Unis Mesic Defendant. TO: Mina Mesic 106 June Drive Camp Hill, PA 17011 DATE OF NOTICE: 10/14/2014 NO.: 14 -5390 -CIVIL 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 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, N.A. CIVIL DIVISION Plaintiff, vs. Mahmut Mesic Mina Mesic Unis Mesic Defendant. TO: Mina Mesic 106 June Drive Camp Hill, PA 17011 NO.: 14 -5390 -CIVIL AVISO IMPORTANTE FECHA DEL AVISO:10/14/2014 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 IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE 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 &LAWYERREFERRAL 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: Scott A. DWttr-U 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 192199 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. NO.: 14 -5390 -CIVIL Mahmut Mesic Mina Mesic Unis Mesic Defendant. IMPORTANT NOTICE TO: Mahmut Mesic 106 June Drive Camp Hill, PA 17011 DATE OF NOTICE: 10/14/2014 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, N.A. CIVIL DIVISION Plaintiff, vs. Mahmut Mesic Mina Mesic Unis Mesic Defendant. TO: Mahmut Mesic 106 June Drive Camp Hill, PA 17011 NO.: 14 -5390 -CIVIL AVISO IMPORTANTE FECHA DEL AVISO:10/14/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERMA 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 IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INAr1EDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICftTA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LE GAL. NOTICE TD 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: Sco-H- A. D i eittcrizk, 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 192199 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Mahmut Mesic Mina Mesic Unis Mesic Defendant. TO: Unis Mesic 1175 Shoreham Road Camp Hill, PA 17011 DATE OF NOTICE: 10/14/2014 NO.: 14 -5390 -CIVIL 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 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, N.A. CIVIL DIVISION Plaintiff, vs. Mahmut Mesic Mina Mesic Unis Mesic Defendant. TO: Unis Mesic 1175 Shoreham Road Camp Hill, PA 17011 NO.: 14 -5390 -CIVIL AVISO IMPORTANTE FECHA DEL AVISO:10/14/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROMOS 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 IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICQNA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND &LAWYERREFERRAL 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: Sc,o-H- A. Di,Oterix,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 192199