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Home My WebLink About14-6308 Supreme Court'of Pennsylvania ,4 s'. Court Common Pleas t ,j ;. i::\ For Prothonotary Use Only: Civil'C0e�r;Sheet f CUM,IRER[,`ANIvI't County Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace thefiling and service ofpleadiqgs or other papers as required by law or rules of court. S Commencement of Action: O Complaint ❑Writ of Summons ❑Petition E+ ❑Transfer from Another Jurisdiction ❑Declaration of Taking C Lead Plaintiffs Name: WELLS FARGO BANK,NA Lead Defendant's Name: BONNIE BLOUNT T I 'Are money damages requested? ❑Yes 0 No Dollar Amount Requested: ❑ within arbitration limits 0 (Check one) 0 outside arbitration limits N Is this a Class Action Suit? ❑Yes 0 No Is this an MDJ Appeal? ❑Yes 0 No A Name of Plaintiff/Appellant's Attorney: Meredith Wooters,Esq.,Id.No.307207 Phelan Hallinan,LLP ❑ Check here if you have no attorney(are a Self-Represented [Pro Sej Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑Intentional ❑Buyer Plaintiff Administrative Agencies ❑Malicious Prosecution ❑Debt Collection: Credit Card ❑Board of Assessment ❑Motor Vehicle ❑Debt Collection:Other ❑Board of Elections ❑Nuisance ❑Dept. of Transportation ❑Premises Liability ❑Statutory Appeal:Other ❑Product Liability(does not S include mass tort) ❑Employment Dispute: ❑Slander/Libel/Defamation Discrimination E ❑Other: ❑Employment Dispute:Other ❑Zoning Board C ❑Other: T I MASS TORT ❑Other: 0 ❑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 0110112011 • - i ISA`y vitt �' [7.; f.,i. i� .i •.1�'`! l PHELAN HALLINAN, LLP ATTORNEY FOR PLAINTIFF Meredith Wooters, Esq., Id. No.307207 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Meredith.Wooters@phelanhallinan.com 215-563-7000 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK,NA 3476 STATEVIEW BOULEVARD CIVIL DIVISION FORT MILL, SC 29715 /7 g 1 Plaintiff, NO.: ll/J� vs. BONNIE BLOUNT 103 FARM ROAD NEWVILLE, PA 17241-9508 JON M. BLOUNT, SR 103 FARM ROAD NEWVILLE, PA 17241-9508 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: C$ Com , �ub"1 C\ 062-PA-v5 1. The Plaintiff is WELLS FARGO BANK, NA, 3476 STATEVIEW BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff'). 2. The Defendants are, BONNIE BLOUNT and JON M. BLOUNT, SR, with a last known address of 103 FARM ROAD, NEWVILLE, PA 17241-9508. 3. In order to protect the borrower's privacy, certain personal information of the borrower (such as loan account, Social Security numbers and birth dates), may have been partially or completely redacted on the exhibits to this Complaint. 4. WELLS FARGO BANK, NA, directly or through an agent, has possession of the Promissory Note. WELLS FARGO BANK, NA is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A copy of said Promissory Note is marked Exhibit "A", attached hereto and made a part hereof. 5. On or about July 26, 2010, BONNIE BLOUNT and JON M. BLOUNT, SR made, executed and delivered to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR PRIMELENDING, A PLAINSCAPITAL COMPANY a Mortgage in the original principal amount of$145,706.00 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 August 5, 2010, in Instrument No. 201021575. 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. 6. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded February 28, 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. 201205840. The Assignment is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 062-PA-VS 7. BONNIE BLOUNT and JON M. BLOUNT, SR are the record and real owners of the aforesaid mortgaged premises. 8. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the installments of principal and interest due October 1, 2013. 9. As of 09/26/2014, the amount due and owing Plaintiff on the mortgage is as follows: Principal $157,287.73 Interest $5,672.03 From 09/01/2013 to 09/26/2014 Late Charges $41.67 , Escrow Advance $2,173.87 Property Inspections $0.00 Property Preservation $0.00 BPO/Appraisals $0.00 Escrow Balance $0.00 Corporate Advance Credit $0.00 Total $165,175.30 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. 10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 062-PA-V5 11. This action does not come under Act 91 of 1983 because the mortgage is FHA- insured. 12. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish such liability. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of$165,175.30, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale.of the mortgaged premises. I I y. Date: (� By Wooters, Esq., Id. No.307207 Attorney for Plaintiff 062-PA-VS Exhibit "A" U ORIGINAL NOTE arovaa Waath. MIN; Quo N., JULY 26, 2010 SAINT PETERSBURG RARIDA [Date] [City] LStatej 103 PARK ROAD, NEwvzLLE, PA 17241-9508 jProperty,Addressj 1.PARTUES "Borrower"means each person signing at the end of this Notc,and the person's successors and assigns."Lender'frtcuns PRDISLENDING, A PLAINSCAPITAL ComPAu r 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 FIVE Tatouu RD SEVEN RUNDRED SIX Dollars(U.S.S145,706.00).plus interest,to the order of Lender.Interest will be charged on unpaid principal,from the dale of disbursement of the loan prteculx by Leader,at lite rate of PIPE percent(5.000%)per year until the full amount of principal has been paid. 3,PROMISE TO PAY SECURED Borrower's promise to pay is secured by u murtgagc,deet]Of trust Of similar security instnlment that is dated the same datnas this Note and called rile"Security Instrument."That Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4.MANNER OF PAYMENT (A)rum Borrower shall make a payment of principal and imerest to Lender on the first day of each month beginning an SEPTEMEER 1, 2010.Any principal and interest remaining on the first day of AUGUST, 2060,wilt be due on that date,which is culled the 'Maturity Date." (R)Plate Payment shall be madc ut 18111 PRESTON ROAD, SUITE 900, DALLAS, TX 75252 or at such 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.5782.18.This amount will be purl of a larger monthly payment required by the Security Instrument,that shall be applied to principal,interesl and other items in the order described in the S"Wity lnstrumem. (D)Allonge to this Note for payment adjustments If un allonge providing for payment adjustments is executed by Borrower together with this Note,the covenants of the ullungc shall be incorporated into and shall umcnd and supplement tlx:txlvcnants of this Note as if the allonge were a part of this Note. [Check applicable box.] ❑Graduated Payment Allonge ❑Growl ng Equity Allonge OOther[Specify] 5.BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt evidenced by this Mote,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 ® 30,23 Page I of 3 FHA Marllsrale tired Rate Noir-0"+A9 IIII � IIIIE ORIGIN,4L remainder of the month to the extent required by Lender and pemtitted by regulations of the Secretary.If Burrower snakes a parliat prepayment,there will be no changes in the due date or in the amount of the monthly payment unless Lender agrees in%,filing to th•ase changes. 6.BORROWER'S FAILURE TO PAY (A)Late Charge for Overdue Payments If Lender has not received the full mumhly payment required by the Security Instrument,us described in Paragraph 4(C i of this Note,by the end of 15 calendar days after the payment is due,Lender may collect a late charge in the amount of POM percent (4.000%)of the overdue amount of cath payment. (B)fiefaull If Borrower defaults by fuiling to pay in full any monthly payment,then Lender may,except as Limited by regulations of the Secretary in the cure of paymert defaults,require immediate payment in full of the principal balance remaining due and all accrled 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 Lenders rights to require immediate payment in full in the cast:of payment defauhs.This Note does not authorize acceleration when not permitted by HUD regulations.As used in this Note, "Secretary" means the Secretary of Housing and Urban Development or his or her designee. (C)Payment of Costs and Expenses If Lender has required immediate payment in full,as described above,Lender may require Borrower to pay costs and expenses including reasonable and customary attorneys'fees for enforcing this Note to the extent not prohihited by applicable law. Stich fees and costs shall bear inrem;i: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 ol'dishonor. "Prescnunent"means the right to require Lender to demand payment of amounts due."Notiec of dishonor'means the right to require Lender to give notice to other persons that amounts due have not been paid. S.GIVING OF NO'T'ICES Unless applicable law requires a different methrrd,any notice that must be given to Borrower under this Note will be given by delivering it or by mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notiw that must be given to Lender under this Note will be given by first class instil to Lender at the addrass states in Paragraph 4(B)or at a different address if Borrower is given a notice of that different address. 9.OBLIGATIONS ON PENSONS UNDER THIS NOTE If more than one person signs this Note,each person is fully and personally obligated to keep all of the promites 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 endc•rser of this Note,is also obligated to keep all of the promise.&trade in this Note.Lender may enforce its right%under this Note against each person individually or against all signatories together.Any one person signing this Note may he required to pay all of The amounts owed under this Note. 36.23 Page 2 of 3 FHA Mallislalr Fixtd Rate Nile-17/09 ORIGINAL BY SIGNING BELOW,Borrower accepts and agrees to flit terms and covenants calloined in this Nutc. F)2"'A'j j-'Q -ro RROWER - f3 Mag BLOUM - PATS - — (Sign Origlnai Only) PAID•1U THE ORDER OF F"61 624 6/ N'A Wfl'HOUT RECOURSE PRIMELENDING,A PLAINSCvA I' COMPANY BY: �/ y a PRINTED NAME: M art TITLE: up �1N WITHOUT RECOURSE .y PAY TO THE ORDER OF W ELO FAAaGO ANK'N.A`r. By Scott m,.Swanson , Aspistant vico•Prooldent ® 36.23 Page 3 of 3 FHA Multistate Fixed Rate Nd,-07819 Exhibit "B" LEGAL DESCRIPTION THE land referred to herein below is situated in the county of Cumberland, state of Pennsylvania, and is described as follows: ALL THAT CERTAIN tract of land situate in Penn township, Cumberlard county, Pennsylvania, bounded and described as follows: BEGINNING at a point in the center of township road no. 344,also known as farm, road on the dividing line between lots nos. 18 and 19 on the hereinafter mentioned plan of lots thence by said dividing line, south 54 degrees 14 minutes 20 seconds west, 200 feet to a point; thence by land now or formerly of Wilbert L. Diehl and Shryle M. Diehl,husband and wife, north 36 degrees 17 minutes 40 seconds west, 100 feet to a point thence by the dividing line between lots nos. 19 and 20 on said plan of lots. north 54 degrees 14 minutes 20 seconds east, 200 feet to a point in the center of township road no. 344 aforesaid; thence by the center of said road, south 36 degrees 17 minutes 40 seconds east, 100 feet to the place of beginning. Parcel ID: 31-11-0300-060 Commonly known as 103 Farm Road,Newville, PA 17241 However, by showing this address no additional coverage is provided PROPERTY ADDRESS: 103 FARM ROAD, NEW VILLE,PA 17241-9508 PARCEL#31-11-0300-060. File#: 945180 VERIFICATION Jasmin McLean, hereby states that he he is Vice President Loan Documentation of WELLS FARGO BANK, N.A.,plaintiff in this matter, that he/e)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 hie i er 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. Na . Jasmin McLean Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 09/29/2014 086-PA-V2 File#945180 WELLS FARGO BANK,NA IN THE COURT OF COMMON 3476 STATEVIEW BOULEVARD PLEAS FORT MILL, SC 29715 OF CUMBERLAND COUNTY, PENNSTLVANIA Plaintiff(s) vs. ., BONNIE BLOUNT JON M. BLOUNT, SR Defendants) .- Civil'•;-:`• - - NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM f F f 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 an attorney,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 not charge to you. Once you have been appointed a legal representative,you must promptly meet with the legal representative within twenty(20)days of the appointment date. During that meeting,you must provide the legal representative with all the 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 attempt to work out a 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 the 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 our reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward, IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Io a� Date Signature of Counsel for Plaintiff Cumberland County Residential Mortgage Foreclosure Diversion Program Date Financial Worksheet Cumberland County Court of Common Please 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: CIJSTOM ER/PRI MARV APPLICANT Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? 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: 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: Other transportation (automobiles boats motorcycles • 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 nd 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: 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 you know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, named , authorize the above 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 page along with the following information to lender: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) 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#: 945180 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY CT.THE PROTHONOTA-`l' CUMBERLAND COUNT,I ?814 NOV 17 PM 2/ 59PENNSYLVANIA Wells Fargo Bank, N.A. vs. Bonnie Blount (et al.)2014-6308 Case Number SHERIFF'S RETURN OF SERVICE 1104/2014 09:04 PM - Deputy Christopher Sharpe, 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: Jon M. Blount, Sr. at1O3Farm Road, Penn Township, NavmiUe.PA1T241. R|STOP R SHARPE, DEPUTY 11x00/2014 09:03 PM - 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 handing a true copy to a person representing themselves to be Jon M. Blount Sr.. Dwnor, who accepted as "Adult Person in Charge" for Bonnie Blount at 103 Farm Road, Penn Township, ,'wwiUe.PA17241. 47# = N GU ALL, DEPUTY SHERIFF COST: $57.56 SO ANSWERS, November 07, 2014 RONR ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson r !LED -Or F{(, Sheriff H PRO THONO Jody S Smith v ? j it DEC wI Chief DeputyA�` 9: r �r ,, Richard W Stewart Solicitor 6,)FP,CE OF THE V1:R.IFF *AMENDED* CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Bonnie Blount (et al.) Case Number 2014-6308 SHERIFF'S RETURN OF SERVICE 11/04/2014 09:04 PM - Deputy Christopher Sharpe, 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: Jon M. Blount, Sr. at 103 Farm Road, Penn Township, Newville, PA 17241. CHRIS IR SHARPE, DEPUTY 11/06/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Bonnie Blount, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure ' Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 103 Farm Road, Penn Township, Newville, PA 17241. Deputies were advised by Jon M. Blount, Sr. that the defendant is thought to be residing somewhere in Carlisle. This office contacted the defendant by phone and she advised that is is residing at 4820 Orrstown Road, Orrstown, PA 17244. 11/06/2014 09:03 PM - 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 handing a true copy to a person representing themselves to be Jon M. Blount, Sr., who accepted as "Adult Person in Charge" for Occupant at 103 Farm Road, Penn Township, Newville, PA 17241. fr AWN G A , DEPUTY SHERIFF COST: $57.56 SO A RS, November 07, 2014 RONN Y' R ANDERSON, SHERIFF (c CountySulle Sheriff, Tel€ osoft. I!'.,. PHELAN PIALLINAN, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 One Penn Censer Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 WELLS FARGO BANK, NA Plaintiff vs. : COURT OF COMMON PLEAS . : CIVIL DIVISION : CUMBERLAND COUNTY BONNIE BLOUNT : No. 14-6308 CIVIL JON M. BLOUNT, SR 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: 1112010( /sdk, Svc Dept. File# 945180 PHELAN HALLINA , LLP Jonath Lobb, Esq., Id. No.312174 Attor ey for Plaintiff awk 6\1 iSptk CLA V-nlbg 3) p 0-)cl Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF THE SHERIFF Pi i 2: L a Is Wells Fargo Bank, N.A. vs. Bonnie Blount (et al.) Case Number 2014-6308 SHERIFF'S RETURN OF SERVICE 11/04/2014 09:04 PM - Deputy Christopher Sharpe, 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: Jon M. Blount, Sr. at 103 Farm Road, Penn Township, Newville, PA 17241. RIST HER SHARPE, DEPUTY 11/06/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Bonnie Blount, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 103 Farm Road, Penn Township, Newville, PA 17241. Deputies were advised by Jon M. Blount, Sr. that the defendant is thought to be residing somewhere in Carlisle. This office contacted the defendant by phone and she advised that is is residing at 4820 Orrstown Road, Orrstown, PA 17244. 11/06/2014 09:03 PM - 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 handing a true copy to a person representing themselves to be Jon M. Blount, Sr., who accepted as "Adult Person in Charge" for Occupant at 103 Farm Road, Penn Township, Newville PA 241. - 1/01r'' GUTSHA , IEPUTY 12/02/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Bonnie Blount, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Franklin, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 12/15/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Franklin County, the within named Defendant Bonnie Blount, not found. Dane Anthony, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $57.56 SO ANSWERS, December 29, 2014 (.c) CcuntySuite Shenfl, Teleosoft Inc. RONNY R ANDERSON, SHERIFF EXP: 11/28/2014 4820 ORRSTOWN ROAD, ORRSTOWN, PA 17244 CO 0 0 N BLOUNT, BONNIE Ronny R Anderson Sheriff Jody S Smith Chief Deputy SHERIFF'S OFFICECF CUMBERLAND COUNTY OFFICE OF THE SRERIFF Wells Fargo Bank, N.A. vs. Blount, Bonnie (et al.) Richard W Stewart 8_i-1,0 7-- Solicitor Case Number 2014-6308 [Service Details: SERVICE COVER SHEET Category: Manner: Notes: [Serve To: Name: Civil Action - Notice of Residential Mortgage Foreclosure Diversion Progr Deputize Expires: 1 tot Zone: Warrant: Primary Address: Phone: Alternate Address: Phone: Bonnie Blount 4820 Orrstown Road Orrstown, PA 17244 DOB: [Attorney / Originator: Name: [Final Service:, Served: Personally • Adult In Charge • Posted • Other Adult In Charge: Relation: Date: Deputy: Time: Mileage: Joseph Schalk [Service Attempts: Date: Time: Mileage: Deputy: Phone: /„2/4,11 [Notes / Special /Instructions: l/ 11614— cLJ c�444 `t�P.� W - 4e( PA -- 1 5 6 ECElVED DEC 'x:2014 FRANKLIN COUNTY. SHERIEE'S.OFFICE Now, December 02, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Franklin County to execute service of the documents herewith and make return thereof according to law. Return To: Cumberland County Sheriffs Office One Courthouse Square Carlisle, PA 17013 Sc) CountySuEte Sheriff Teleosoft. Inc Ronny R Anderson, Sheriff SHERIFF'S RETURN - NOT FOUND CASE NO: 2014-00410 T COMMONTWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN WELLS FARGO BANK NA VS BONNIE BLOUNT BENJAMIN SITES , Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: BLOUNT BONNIE but was unable to locate Her in his bailiwick. He therefore returns the COMP MORT FORE the within named DEFENDANT , BLOUNT BONNIE 4820 ORRSTOWN ROAD , NOT FOUND , as to ORRSTOWN, PA 17244 DEF LIVES IN CARLISLE; GAVE NOTIFICATION CARD TO FATHER WHO IS TO TELL DEF TO GO TO SHERIFF'S OFFICE TO PICK UP; NO RESPONSE FROM DEF Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 BENJAMIN/.ITES DANE M THONY, Sheriff .00 PHELAN HALLINAN LLP 12/23/2014 Sworn and subscribed to before me this eZ3 44 day of 06614.441u01,44,..) OttW At ft OFFENNSYLVANIA NQ't t1AL f , Q`,. McCARIY Notary Public .Born., Franklin County ,empires Jan. 29, 2015 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. BONNIE BLOUNT JON M. BLOUNT, SR Defendants . • : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY : No. 14-6308 CIVIL 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. • PHELAN HALLINAN, LLP By: Date: 1 01 /nru, Svc Dept. File# 945180 fC� PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff �� 13 II,.iSatl--71 PHELAN HALL1NAN, 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. BONNIE BLOUNT JON M. BLOUNT, SR Defendants -t:Lrit11- •„`"' 110-1"i .1\rti a, 21 :_nr,SYLVA. til A. : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY No. 14-6308 CIVIL 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. • PHELAN HALLINAN, LLP By: Date: 1) /nru, Svc Dept. File# 945180 PETER WAPNER, Esq., Id. No.318263 Attorney for Plaintiff 1I.7 Sf- orthi -4- I tos 111- 3) i