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 —{
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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
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106 JUNE.DRIVE,CAMP i1,11LL.,PA 17019
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I. PARTIES
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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