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HomeMy WebLinkAbout14-6236 Supreme Court of Pennsylvania • Cor :of Co umn Pleas For Prothonotary Use Only: CivilzCovek,Sheet CUMBERLAND', A County Docket No: ,P The information collected on this form is used solely.for court administration purposes. This form does not supplement or replace thefiling and service ofpleadings or other papers as required by law or rules of court. S Commencement of Action: Complaint ❑Writ of Summons ❑Petition E ❑Transfer from Another Jurisdiction ❑Declaration of Taking C Lead Plaintiff s Name: WELLS FARGO BANK,NA Lead Defendant's Name: BRYAN J.GABNER T I Are money damages requested? ❑ Yes Z No Dollar Amount Requested: ❑ within arbitration limits Q (Check one) Z outside arbitration limits N Is this a Class Action Suit? ❑ Yes Z No Is this an MDJ Appeal? ❑ Yes Z No A Name of Plaintiff/Appellant's Attorney: Kenya Bates,Esq.,Id.No.203664,Phelan Hallinan.LLP ❑ Check here if you have no attorney(are a Self-Represented [Pro Sel Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim,check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑Intentional ❑Buyer Plaintiff Administrative Agencies ❑Malicious Prosecution ❑Debt Collection:Credit Card ❑ Board of Assessment ❑Motor Vehicle ❑Debt Collection:Other ❑Board of Elections Nuisance ❑Dept.of Transportation ❑Premises Liability ❑ Statutory Appeal: Other ❑Product Liability(does not S include mass tort) ❑Employment Dispute: ❑ Slander/Libel/Defamation Discrimination E ❑Other: ❑Employment Dispute: Other ❑Zoning Board C ❑ Other: T OMASS TORT ❑Other: ❑Asbestos N ❑Tobacco ❑Toxic Tort-DES ❑Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ❑Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration B ❑Other: ❑Eminent Domain/Condemnation ❑Declaratory Judgment ❑ Ground Rent ❑Mandamus ❑Landlord/Tenant Dispute ❑Non-Domestic Relations Z Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑Dental ❑Partition ❑Replevin ❑Legal ❑Quiet Title ❑Other: ❑Medical ❑Other: ❑Other Professional: Pa.R.C.P. 205.5 Updated 01/01/2011 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 32 SOUTH BEDFORD STREET CARLISLE,PA 17013 (717)249-3166 (800)990-9108 File#: 952871 ted.-^ 27 is�,ll tU`tl� r 0'r<�;yi :J `res1 PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF Kenya Bates, Esq., Id.No.203664 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 kenya.bates@phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA l 3476 STATEVIEW BOULEVARD CIVIL DIVISION FORT MILL, SC 29715 ` Plaintiff, NO.: VS. BRYAN J. GABNER 2900 SOCIETY HILL DRIVE, APARTMENT 6 CAMP HILL, PA 17011-8114 NINA GABNER 6 PLAINVIEW ROAD CAMP HILL, PA 17011-7928 Defendants. CIVIL ACTION- COMPLAINT IN MORTGAGE FORECLOSURE And now comes WELLS FARGO BANK,NA,by its attorneys, Phelan Hallinan, LLP _ and files this Complaint in Mortgage Foreclosure as follows: 062-PA-V5 / 1. The Plaintiff is WELLS FARGO BANK, NA, 3476 STATEVIEW BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff'). 2. The Defendant is, BRYAN J. GABNER, with a last known address of 2900 SOCIETY HILL DRIVE, APARTMENT 6, CAMP HILL, PA 17011-8114. 3. The Defendant is, NINA GABNER, with a last known address of 6 PLAINVIEW ROAD, CAMP HILL, PA 17011-7928. 4. 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. 5. WELLS FARGO BANK, NA, directly or through an agent, has possession of the Promissory Note. WELLS FARGO BANK, NA is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A copy of said Promissory Note is marked Exhibit "A", attached hereto and made a part hereof. 6. On or about November 25, 2008, BRYAN J. GABNER and NINA ,GABNER made, executed and delivered to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR PREMIUM CAPITAL FUNDING, LLC D/B/A TOROOT MORTGAGE, A NEW YORK LIMITED LIABILITY a Mortgage in the original principal amount of$144,993.00 on the premises described in the legal description marked Exhibit "B", attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the Recorder of CUMBERLAND County on December 15, 2008, in Instrument No. 200839610. The Mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 7. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded February 23, 2012, the mortgage was assigned to WELLS FARGO BANK, NA which Assignment is recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 201205400. The Assignment is a matter of public record and is incorporated herein by reference in 062-PA-VS accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 8. BRYAN J. GABNER and NINA GABNER are the record and real owners of the aforesaid mortgaged premises. 9. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the installments of principal and interest due January 1, 2013. 10. As of 10/16/2014, the amount due. and owing Plaintiff on the mortgage is as follows: Principal $ 146,628.24 Interest From 12/01/2012 to 10/16/2014 $ 13,055.03 Late Charges $ 71.06 Escrow Advance $ 4,963.37 Property Inspections $ 40.00 Property/Preservation $ 0.00 BPO/Appraisals $ 0.00 Escrow Balance $ 0.00 Corporate Advance Credit $ 0.00 Total $ 164,686.64 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 11. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have 062-PA-VS been sent to the Defendant(s). 12. This action does not come under Act 91 of 1983 because the mortgage is FHA- insured. 13. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so.in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of$ 164,686.64, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. By: Date: !d`?•��� Kenya' B tes, Esq., Id. No.203664 Attorney for Plaintiff 062-PA-VS EXHIBIT "A" MIN: NOTE Loan Number: ".eo. NOVEMBER 25, 2008 MELVILLE NEW YORK [Umel I01)•1 [Stoic] 6 PLAINVIEW ROAD, CAMP HILL, PENNSYLVANIA 11011 [Property Address] 1. PARTIES "Borrower"means each person signing at the end of this Note, and the person's successors and assigns. "Lender"means PREMIUM CAPITAL FUNDING, LLC D/B/A TOPDOT MORTGAGE, A NEW YORK LIMITED LIABILITY COMPANY and its successors and assigns. 2. BORROWER'S PROMISE TO PAY;INTEREST In return for a loan received from Lender, Borrower promises to pay the principal sum of ONE HUNDRED FORTY-FOUR THOUSAND NINE HUNDRED NINETY-THREE AND 00/100 Dollars(U.S.$ 144,993.00 ), plus interest,to the order of Lender. Interest will be charged on unpaid principal, from the date of disbursement of the loan proceeds by Lender,at the rate of SIX AND 125/1000 percent ( 6.125 %)per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage,deed of trust or similar security instrument that is dated the same date as this Note and called the"Security Instrument." The Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4. MANNER OF PAYMENT (A)Time Borrower shall make a payment of principal and interest to Lender on the 1St day of each month beginning on JANUARY 1, 2009 . Any principal and interest remaining on the 1st day of DECEMBER, 2038 will be due on that date,which is called the"Maturity Date." (B) Place Payment shall be made at P.O. BOX 9103, UNIONDALE, NEW YORK 11555-9103 ,or at such other place as Lender may designate in writing by notice to Borrower. (C)Amount Each monthly payment of principal and interest will be in the amount of U.S.$ 880.99 This amount will be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and other items in the order described in the Security Instrument. (D) Allonge to this Note for Payment Adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note,the covenants of the allonge shall he incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a part of this Note. Borrower Initials: MULTISTATE-FNA FIXED RATE NOTE f70CMagiePdaD 800.649-1.762USFHA.tJTE 05/01/08 Pegs t of 3 www.doemaglaeam IIIII 11111111111111111111 loll llll oil 111111111111111111111]11111111 itllfl111111111111111111111111 lilt 11111 (Check applicable box.) ❑ Growing Equity Allonge ❑ Graduated Payment Allonge ❑ Other[specify]: 5. BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Note,in whole or in part,without charge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment,there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in writing to those changes. 6. BORROWER'S FAILURE TO PAY (A) Late Charge for Overdue Payments If Lender has not received the full monthly payment required by the Security Instrument, as described in Paragraph 4(C)of this Note,by the end of fifteen calendar days after the payment is due,Lender may collect a late charge in the amount of FOUR AND 000/1000 percent( 4.000 %) of the overdue amount of each payment. (B) Default If Borrower defaults by failing to pay in full any monthly payment, then Lender may,except as limited by regulations of the Secretary in the case ofpayment defaults,require immediate payment in full ofihe principal balance remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances,regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case ofpayment defaults. This Note does not authorize acceleration when not permitted by HUD regulations. As used in this Note, "Secretary"means the Secretary of Housing and Urban Development or his or her designee. (C)Payment of Costs and Expenses I f Lender has required immediate payment in full,as described above,Lender may require Borrower io pay costs and expenses including reasonable and customary attorney~ fees for enforcing this-Note to the extent not prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7. WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" means the right to require Lender to demand payment of amounts due. "Notice of Dishonor"means the right to require Lender to give notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law requires a different method,any notice that must he given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the Property Address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by delivering it or by mailing it by first class mail to Lender at the address stated in Paragraph 4(B)or at a different address if Borrower is given a notice of that different address. 9. OBLIGATIONS OF PERSONS UNDER THIS NOTE If more than one person signs this Note,each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor,surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor,surety or endorser of this Note,is also obligated to keep all of the promises made in Borrower Initials: MULTISTATE-FHA FIXED RATE NOTE DocMagic CF=,w 800-649a362 USFHA.NTE 05/01/08 Page 2 o1 3 www.domnagte.eom 111NI IIIIIIQ 11111 IIII 11111111 Ilnl 111111111111111 1111111N1 lli 11111111111111f1 VIII Ili11111111111111i this Note. Lender may enforce its rights under this Note against each person individually or against all signatories together. Anyone person signing this Note maybe required to pay all of the amounts owed under this Note. BY SIGNING BELOW,Borrower accepts and agrees to the terms and covenants contained in this Note. (Seal) (Seal) BR>& J GABNER -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower ALLONGE ATTACHED FOR THE PURPOSE OF ENDORSING THE NOTE [Sign Original Only] MULTISTATE-FHA FIXED RATE NOTE USFHA.NTE 05101/08 Pae 3 of 3 OtxMagic t'aF" .&eao•s�s• 9 www.docmagk.c=om /III{VIII I II 11111 1111 111111/III VIII III 1111111 I I III VIII Illi l 111111111/III I VIII VIII VIII VIII 1111 Ipl i Loan Number: - ALLONGE TO PROMISSORY NOTE Without recourse pay to the order of: wellsFa�9oBank,�•A• By: Name: JOSEPH MANSI Title: DIRECTOR OF OPERATIONS Company: PREMIUM CAPITAL FUNDING, LLC D/B/A TOPDOT MORTGAGE, A NEW YORK LIMITED LIABILITY COMPANY 125 JERICHO TURNPIKE, SUITE 500 JERICHO, NEW YORK 11753 Borrower Name: BRYAN J. GABNER Property Address: 6 PLAINVIEW ROAD CAMP HILL, PENNSYLVANIA 17011 �iS� Loan Amount: S 144,993.00 PAY TO THE ORDER OF Closing Date: NOVEMBER 25, 2006 Wells Fargo Bank,N.A. ayLori. Vice President Loan Documentafwn I ALLONGE TO PROMISSORY NOTE DoeMagb6Antgz 800-649-1362 08/05/03 aww.docmaglc.eom EXHIBIT "B" LEGAL DESCRIPTION All that certain piece or parcel of land, situate in the lower Allen Township, County of Cumberland, Commonwealth of Pennsylvania,more particularly bounded and described in accordance with a survey by Roy M. Benjamin P.E. dated June 1, 1971 as follows, to wit: BEGINNING at a point on the easterly line of Plainview Road which point is 204.98 feet south of the southeasterly corner of Scarsdale Drive and Plainview Road and at the dividing line between Lots No. 18 and 19, Block K on the hereinafter mentioned plan of lots; THENCE along said dividing line north 47 degrees 40 minutes east, 125 feet to a point; THENCE along the westerly line of Lots Nos. 3 and 4, Block K on said plan, south 42 degrees 20 minutes east 75 feet to a point at the dividing line between Lots Nos. 17 and 18, Block K on said plan; THENCE along said dividing line south 47 degrees 40 minutes west, 125 feet to a point on the easterly line of Plainview Road of foresaid; THENCE along same north 42 degrees 20 minutes west, 75 feet to a point, the place of Beginning. PARCEL ID#: 13-25-0022-214 Premises known as: 6 Plainview Road, Camp Hill,PA File#: 952871 PROPERTY ADDRESS: 6 PLAINVIEW ROAD, CAMP HILL,PA 17011-7928 PARCEL#13-25-0022-214. File#: 952871 r VERIFICATION Darren Britt, hereby states that ie she is.Vice President Loan Documentation of WELLS FARGO BANK, N.A.,plaintiff in this matter, that h this Verification, and verifythat �e she is authorized to make , at the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of0her information and belief. The undersigned understands that this statement is made'sub•e C.S. Sec. 4904 relating to unsworn falsification to authorities.� ct to the penalties of 18 Pa, Name: Darren Britt Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 10/17/2014 086-PA-V2 File#952871 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY rJ OFFIC,.c P L:=ire—I: i F VHF PiWTH 2 1 Et DEC -Li Ail 3; 5 CUMBERLAND COUN i PENNSYLVANIA Wells Fargo Bank, N.A. vs. Bryan J. Gabner (et al.) Case Number 2014-6236 SHERIFF'S RETURN OF SERVICE 10/28/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Bryan J. Gabner, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 6 Plainview Road, Lower Allen Township, Camp Hill, PA 17011. Residence is vacant. 10/28/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Nina Gabner, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 6 Plainview Road, Lower Allen Township, Camp Hill, PA 17011. Residence is vacant. 11/19/2014 07:46 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Nina Gabner, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at 2900 Society Hill Drive, Apt. 6, Lower Allen, Camp Hill, PA 17011. Deputies were advised by the defendant's ex-husband that the defendant is now resideing at 101 Coblestone Way, Dillsburg, PA 17019 which is located in York County. 11/19/2014 07:46 PM - Deputy Shawn Gutshall, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Bryan J. Gabner at 2900 Society Hill Drive, Apt. 6, Lower Allen Township, Camp Hill, PA 17011. GUT DEPUTY SHERIFF COST: $121.80 SO ANSWERS, November 26, 2014 RONNS' R ANDERSON, SHERIFF (c) CountySuito Sheriff, Teleosoft. Inc. PHELAN HALLINAN, LLP • PETER WAPNER, Esq., Id. No.318263 1617 JFK Boulevard, Suite.1400 One Penn Center Plaza Philadelphia, PA 19103 peter.wapner@phelanhallinan.com 215-563-7000 WELLS FARGO BANK, NA Plaintiff vs. BRYAN J. GABNER NINA GABNER THF, Zel t: DEC 12 /11O: 23 CU';',F.3ERLALD COWiTY • PEiL4LS YLVAMA : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : No. 14-6236 CIVIL Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. By: Date: /alg, Svc Dept. File# 952871 PHELAN HALLINAN, LLP PETE WAPNER, Esq., Id. No.318263 Attorney for Plaintiff 1 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFbE OF THE ,St4EE;IFF t1E. ,.0.1 114 P1'i 1: it PE S1Lui•Wi Wells Fargo Bank, N.A. vs. Bryan J. Gabner (et al.) Case Number 2014-6236 SHERIFF'S RETURN OF SERVICE 12/15/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Nina Gabner, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of York, Pennsylvania to serve the within Complaint in Mortgage Foreclosure according to law. 12/17/2014 09:45 AM - The requested Complaint in Mortgage Foreclosure returned by the Sheriff of York County, the within named Defendant Nina Gabner, not found. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. 01/02/2015 05:45 PM - The requested Complaint in Mortgage Foreclosure served by the Sheriff of York County upon Nina Gabner, personally, at 721 South Mountain Road, Apt. 105, Dillsburg, PA 17019. Richard Keuerleber, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $37.00 SO ANSWERS, January 02, 2015 (.c) CountySuite She Sherr, Teieosoft, inc. RONKS' R ANDERSON, SHERIFF Richard P Keuerleber Sheriff Michael S. Hose Chief Deputy, Operations WELLS FARGO BANK, NA vs. NINA GABNER SHERIFF'S OFFICE OF YORK COUNTY PETER J. MANGAN, ESQ. Solicitor Richard E Rice, I1 Chief Deputy, Administration Case Number 2014-6236 12/17/2014 12/22/2014 SHERIFF'S RETURN OF SERVICE 09:45 AM - DEPUTY TAYLOR ECK, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: NINA GABNER AT 101 COBLESTONE WAY, DILLSBURG, PA 17019. THE DEFENDANT WAS FOUND TO HAVE MOVED. 05:45 PM - DEPUTY COREY STRINE, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE (CIMF) BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: NINA GABNER AT 721 SOUTH MOUNTAIN ROAD, APT 105, DILLSBURG, PA 17019. REY STRINE, DEPUTY SHERIFF COST: $120.44 SO ' , December 30, 2014 RICHARD P KEUERLEBER, SHERIFF COMMONWEALTH OF PENNSYLVANIA Notarial Seal Lisa L. Thorpe, Notary Public City of York, York County My Commission Expires Aug. 12, 2017 MEMEER, PENNSYLVANIA ASSOCIATION OF NOTARIES Affirmed and subscribed to before me this 30TH day of DECEMBER NOTARY 2014 (c) CountySuite Sheriff. Teieosoft, Inc. p