Loading...
HomeMy WebLinkAbout14-6486 Supreme Court of Pennsylvania Cour.C+M Common Pleas t ., y...` For Prothonotary Use Only: CIVWCovelf,Sheet CIABE"�ANII'i � County14 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 ofpleadings or other a ers as required by law or rules of court. S Commencement of Action: D Complaint ❑Writ of Summons ❑Petition E+ ❑Transfer from Another Jurisdiction ❑Declaration of Taking C Lead Plaintiffs Name: WELLS FARGO BANK,N.A. Lead Defendant's Name: ABDUL AKHTER A/K/A ABDUL G. T AKHTER I Are money damages requested? El Yes Z No Dollar Amount Requested: Elwithin arbitration limits O (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 I MASS 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#: 952980 f ii' F {ii tw ! 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,N.A. 1 3476 STATEVIEW BOULEVARD CIVIL DIVISION FORT MILL, SC 29715 LOH Plaintiff, NO.: Ili VS. ABDUL AKHTER A/K/A ABDUL G. AKHTER 307 KAY ROAD MECHANICSBURG, PA 17050-3048 THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA 228 WALNUT STREET, PO BOX 11754 HARRISBURG, PA 17108-1754 Defendants. CIVIL ACTION- COMPLAINT IN MORTGAGE FORECLOSURE And now comes WELLS FARGO BANK,N.A.,by its attorneys, Phelan Hallinan, LLP s and files this Complaint in Mortgage Foreclosure as follows: 1 IS,J ,74� Q 062-PA-V5 1. The Plaintiff is WELLS FARGO BANK, N.A., 3476 STATEVIEW BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff'). 2. The Defendant is, ABDUL AKHTER A/K/A ABDUL G. AKHTER, with a last known address of 307 KAY ROAD, MECHANICSBURG, PA 17050-3048. 3. The Defendant is, THE UNITED STATES OF AMERICA C/O THE UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA, with a last known address of 228 WALNUT STREET, PO BOX 11754, HARRISBURG, PA 17108-1754. 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, 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. 6. On or about September 19, 2007, ABDUL AKHTER made, executed and delivered to WELLS FARGO BANK, N.A. a Mortgage in the original principal amount of $125,000.00 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 October 4, 2007, in Instrument No. 200738324. 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. 8. ABDUL AKHTER A/K/A ABDUL G. AKHTER is the record and real owner of the aforesaid mortgaged premises. 062-PA-VS 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 April 1, 2014. 10. As of 10/30/2014, the amount due and owing Plaintiff on the mortgage is as follows: Principal $112,873.01 Interest $5,049.71 From 03/01/2014 to 10/30/2014 Late Charges $121.62 Escrow Advance $908.65 Property Inspections $0.00 Property Preservation $0.00 .BPO/Appraisals $0.00 Escrow Balance $0.00 Corporate Advance Credit $0.00 Total $118,952.99 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 been sent to the Defendant(s). 12. 062-PA-VS 13. The United States of America is made a Defendant herein pursuant to 28 U.S.C. 2410, because of federal tax liens that have been filed with the Prothonotary of CUMBERLAND County in the Judgment Index Unit as follows: US TREASURY DEPARTMENT VS. ABDUL G. AKHTER DOCKET NO. 2012-02757, FILED: 05/04/2012,IN THE AMOUNT OF$26,960.63. 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. WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the amount due of$118,952.99, 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: �/ ,/CKenya Ve�s, Escqj., Id. N�o203�664 �� Attorney for Plaintiff 062-PA-V5 Exhibit "A" Vol\ )n NOTE SEPTEMBER 19, 2007 Illatc) ICityl [State] 307 KAY ROAD, MECHANICSBURG, PA 17050 ]Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S. $*****125,000.00 (this amount is called "Principal"), plus interest, to the order of the Lender. The Lender is WELLS FARGO BANK, N.A. I will make all payments under this Note in the form of cash, check or money order. I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is entitled to receive payments under this Note is called the "Note Holder." 2. INTEREST Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a yearly rate of 6.750 ga. The interest rate required by this Section 2 is the rate 1 will pay both before and after any default described in Section 6(13) of this Note. 3. PAYMENTS (A) Time and Place of Payments I will pay principal and interest by making a payment every month. 1 will make my monthly payment on the FIRST day of each month beginning on NOVEMBER 01, 2007 1 will make these payments every month until I have paid all of the principal and interest and any other charges described below that I may owe under this Note. Each monthly payment will he applied as of its scheduled due date and will be applied to interest before Principal. If, on OCTOBER 01, 2037 I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." 1 will make my monthly payments at WELLS FARGO HOME MORTGAGE, P.O. BOX 11701, NEWARK, NJ 071014701 or at a different place if required by the Note Holder. (B)Amount of Monthly Payments My monthly payment will be in the amount of U.S. $ ****810.75 4. BORROWER'S RIGHT TO PREPAY I have the right to make payments of Principal at any time before they are due. A payment of Principal only is known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note. 1 may snake a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Prepayment to the accrued and unpaid interest on the Prepayment-amount, before applying my Prepayment to reduce the Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes. 0078678349 MULTISTATE FIXED RATE NOTE-Single Family-Fannie Mee/Freddie Mac UNIFORM INSTRUMENT (M 5N boos) Form 3200 1/01 VMP MORTGAGE FORMS-1800)621-7281 Pape 1 of 3 Irrilials:-KV-/ I 1 5. LOAN CHARGES If a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a)any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct payment to me. If a refund reduces Principal, the reduction will be treated as a partial Prepayment. 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A) Late Charge for Overdue Payments If the Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after the date it is due, 1 will pay a late charge to the Note Holder. The amount of the charge will be 5.000 %of my overdue payment of principal and interest. 1 will pay this late charge promptly but only once on each late payment. (B) Default If I do not pay the full amount of each monthly payment on the date it is due, I will be in default. (C) Notice of Default If 1 am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a certain date, the Note Holder may require me to pay immediately'the full amount of Principal which has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or delivered by other means. (D)No Waiver By Note Holder Even if, at a time when 1 am in default, the Note Holder does not require me to pay immediately in full as described above, the Note Holder will still have the right to do so if 1 am in default at a later time. (E) Payment of Note Holder's Costs and Expenses If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be paid back by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law, Those expenses include, for example, reasonable attorneys' fees. 7. GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to me under this Note will he given by delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if 1 give the Note Holder a notice of my different address. Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class mail to the Note Holder at the address stated in Section 3(A)above or at a different address if I am given a notice of that different address. 8. 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 this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of us together. This means that any one of us may be required to pay all of the amounts owed under this Note. 9. WAIVERS I 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 the Note Holder to demand payment of amounts due. "Notice of Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been paid. " Form 3 0 110 �O 5N t000s) Pape 2 of 3 orm 10. UNIFORM SECURED NOTE This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the Note Holder under this Note, a Mortgage, Deed of Trust, or Security Deed (the "Security Instrument"), dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of all amounts I owe under this Note. Some of those conditions are described as follows: If all or any part of the Property or any Interest in the Property is sold or transferred (or if Borrower is not a natural person and a beneficial interest in Borrower is sold or transferred)without Lender's prior written consent, Lender may require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by Lender if such exercise is prohibited by Applicable Law. If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is given in accordance with Section 15 within which Borrower must pay all sums secured by this Security Instrument. If Borrower fails to pay these sums prior to the expiration of this period, Lender may invoke any remedies permitted by this Security Instrument w'thout further notice or demand on Borrower. WITNESS THE HA ( ) AL(S)OF THE UNDERSIGNED. (Seal) (Sea]) ABDUL AKHTER -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower AYTTO THE tJT RECOURSE ROS OF (Seal) (Sea]) Borrower8Y ,/� -Borrower n M.MI118,rVlce Presids (Seal) (Seal) -Borrower -Borrower [Sign Original Only] Z •1 -5N l000sl Pape 3 of 3 Form 3200 1/01 i � :J:�stt.�. � �� t �` 4 ,�h�� s $rtm�ir,4'1"3 a�r�:'d .��4;TJE ,lvi n;"�ti�l. Exhibit `B" LEGAL DESCRIPTION ALL THAT CERTAIN tract or parcel of land situate in Hampden Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the east side of Kay Road, 50 feet wide, as shown on the hereinafter mentioned Plan of Lots, at the dividing line between Lots Nos. 42 and 43 on said Plan; thence along said dividing line, North 82 degrees 13 minutes East, a distance of 133.02 feet to a point; thence South 18 degrees 21 minutes West, a distance of 96.27 feet to a point thence South 82 degrees 13 minutes West, a distance of 90.59 feet to a point; thence North 07 degrees 47 minutes i West, a distance of 86.43 feet to Lot No. 43, the place of BEGINNING. BEING Lot No. 42 on Plan of St. Marks Place, said Plan recorded in Plan Book 8, Page 8, Cumberland County records. HAVING THEREON ERECTED a dwelling known and numbered as 307 Kay Road. PROPERTY ADDRESS: 307 KAY ROAD,MECHANICSBURG,PA 17050-3048 PARCEL#10-22-0527-047. File#: 952980 s ' 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/6)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 er nfon-nation and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Jasmin McLean Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 10/31/2014 086-PA-V2 File#952980 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF!C' F TH2 y_ c.u('}-UFt-i 'IL PRTH.ONG ii;: 20140V 26 fiiHiII: 21 CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Abdul Akhter Case Number 2014-6486 SHERIFF'S RETURN OF SERVICE 11/19/2014 05:57 PM - Deputy Shawn Harrison, 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 themselve b he I -ndant, to wit: Abdul Akhter at 307 Kay Road, Hampden Township, Mechanicsburg, PA 17 S AWN H R: • N. DEPUTY SHERIFF COST: $39.30 SO ANSWERS, November 21, 2014 RONM R ANDERSON, SHERIFF (c) CountySuite Shentt, Toleoso; . Inc. PLAINTIFF WELLS FARGO BANK, N.A. DEFENDANT ABDUL AKHTER A/K/A ABDUL G. AKHTER; ET. AL. SERVE UNITED STATES OF AMERICA CIO UNITED STATES ATTORNEY FOR THE MIDDLE 950 PENNSYLVANIA AVENUE, N.W., MAIN JUSTICE BUILDING, WASHINGTON, DC 20530 Affidavit of Service CUMBERLAND COUNTY PHS # 952980 SERVICE TEAM COURT NO.:14-6486 TYPE OF ACTION CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE WITH EXHIBITS; CIVIL COVER SHEET; NOTICE SERVED Served and made known to United States of America c/o United States Attorney for ,Defendant on the 21 of November , 20 14, at 11:19 AM , at 950 Pennsylvania Avenue, N.W., Main Justice Building, Washington, DC 20530 in the manner described below: Defendant personally served. Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). X Agent or person in charge of Defendant's office or usual place of business. Dale Von Whitmore as Contract Director an officer of said Defendant's company. Other: Description: Age 30 - 40 Yrs. Height 5ft 4in - 5ft Weight 161-190 Race Black Sex Male Other 1 Marcus Murga , a competent adult being duly sworn according to law, depose and state that I personally handed a true and correct copy of the CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE WITH EXHIBITS; CIV.IL COVER' SHEET; NOTICE in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above =.1, Sworn to and subscribed before `�e<<<I 11 h I "it/ ,/ me this 24th day.%� - A C < �� Q� . of November , 2014 . Q'' •GOtt'MOAiki,. Q :*.94,O ,_f41A S. o Rt�zO• O.p :al NO key"" : hl `/L `�`.. �'tj dc, -A.•.. II �'f-G t Z. NOT S ED iie'''90•_RC;II.... NO �0_, at e. On the oiy ei ��� `� hereby state that Defendant NOT %Dj j Vacant No answer on Service Refused 11 Does Not Exist 00. Other: Sworn to and subscribed before me this 24th day of November 2014 By: Notary: Martha L. Lazo Ruiz at c • r o'clock .M., 1, , a competent adult Moved Does Not Reside ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg Esq., Id No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, Esq., Id. No. 86657 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Courtenay R. Dunn, Esq., Id. No. 206779 Allison F. Zuckerman, Esq., Id. No. 309519 Melissa J, Cantwell, Esq., Id. No. 308912 Mario J. Hanyon, Esq., Id. No. 203993 John M. Kolesnik, Esq., Id. No. 308877 Matthew G. Brushwood, Esq., Id. No. 310592 Zachary J. Jones, Esq., Id. No. 310721 Justin F. Kobeski, Esq., Id. No. 200392 Adam Davis, Esq., Id. No. 203034 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff vs. ABDUL AKHTER A/K/A ABDUL G. AKHTER 307 KAY ROAD MECHANICSBURG, PA 17050-3048 : : Docket No.: 2014 -6486 -CV : CIVIL ACTION - LAW • THE UNITED STATES OF AMERICA : In care of UNITED STATES ATTORNEY : FOR THE MIDDLE DISTRICT OF PENNSYLVANIA 228 WALNUT STREET P.O. BOX 11754 HARRISBURG, PA 17108-1754 Defendants I CERTIFICATE OF SERVICE �.a E=D r ri CD CFI tv ca cry c' --.4 ri ('-., CD CD n Irr I, Michael O. Palermo, Jr., Esquire, counsel for Plaintiff, do hereby certify that I this day served a copy of this E ,TRY OF APPEARANCE upon the following by FIRST CLASS MAIL addressed as follows: PHELAN HALLINAN, LLP Kenya Bates, Esquire 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Date: Az -414y United States Attorney Middle District of Pennsylvania 228 Walnut Street P.O. Box 11754 Harrisburg, PA 17108-1754 Respectfully submitted, PALERMO LAW OFFICES rvv/l t) Michael O. Palermo, Jr. Esquire Counsel for Defendant Akhter IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK, N.A. 3476 STATEVIEW BOULEVARD FORT MILL, SC 29715 Plaintiff : Docket No.: 2014 -6486 -CV vs. : CIVIL ACTION - LAW ABDUL AKHTER A/K/A ABDUL G. AKHTER 307 KAY ROAD MECHANICSBURG, PA 17050-3048 THE UNITED STATES OF AMERICA : In care of UNITED STATES ATTORNEY : FOR THE MIDDLE DISTRICT OF PENNSYLVANIA 228 WALNUT STREET P.O. BOX 11754 HARRISBURG, PA 1 71 08-1 754 Defendants ENTRY OF APPEARANCE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Kindly enter my appearance as counsel of record for ABDUL AKHTER a/k/a ABDUL G. AKHTER in the above captioned case. Respectfully submitted, PALERMO LA 1 FF C S Date: /)- /49) '/Y Michael O. Palermo, Jr., G squire 3300 Trindle Road Camp Hill, PA 17011 (717) 635-9591 (717) 635-9725 (fax) Supreme Court ID # 93334 mop@palermolawoffices.com