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HomeMy WebLinkAbout14-6590 Supreme Court of Pennsylvania Coulrtof Com n Pleas C�vilyCoyei-,Sheet For Prothonotary Use Only. Cl lilBf RL:AIVD 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 ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E Lead Plaintiffs Name: Wells Fargo Bank,N.A. Lead Defendant's Name: Tracy E.Raymond C T Are money damages requested?: ❑Yes ® No Dollar Amount Requested: within arbitration limits I (Check one) X outside arbitration limits I O N Is this a Class Action Suit? ❑Yes ® No Is this an MDJ AppeaR ❑Yes ® No Name of Plaintiff/Appellant's Attorney: Scott A.Dietterick,Esq.c/o Zucker,Goldberg&Ackerman,LLC LA ❑ 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 ❑ 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 S El Product Liability(does not include mass tort) ❑ Employment Dispute: E ❑ Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I MASS TORT ❑ Other: O El Asbestos ❑ Tobacco N ❑ Toxic Tort-DES ❑ Toxic Tort-Implant REAP,PROPERTY MISCELLANEOUS E] Toxic Waste El Other: El Ejectment [:1 Common Law/Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment B El Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations PROFESSIONAL LIABILITY ® Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ 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.. 1 1 VC l vs. Tracy E. Raymond;William H.Whittaker,Jr.; TYPE OF PLEADING cn Defendants. C -:� CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE TO: DEFENDANTS YOU ARE HEREBY NOTIFIED TO PLEAD TO THE . ENCLOSED COMPLAINT WITHIN TWENTY(20)DAYS FILED ON BEHALF OF: FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE ENTERED AGAINST YOU. > A' Wells Fargo Bank, N.A. I HEREBY CERTIFY THAT THE ADDRESS Plaintiff OF THE PLAINTIFF IS: 3476Stateview Blvd. COUNSEL OF RECORD FOR THIS PARTY: Ft.Mill,SC 29715 AND THE DEFENDANT: ZUCKER' GOLDBERG &ACKERMAN, LLC 625 North West street Scott A. Dietterick, Esquire-Pa. I.D.#55650 Carlisle,PA 17013-1967 Kimberly A. Bonner, Esquire- Pa. I.D.#89.705 Joel A.Ackerman, Esquire- Pa I.D.#202729 CERTIFICATE OF LOCATION Ashleigh Levy Marin, Esquire- Pa I.D.#306799 1 HEREBY CERTIFY THATTHE LOCATION OF Ralph M.Salvia, Esquire- Pa I.D.#202946 THE REAL ESTATE AFFECTED BY THIS LIEN IS Jaime R.Ackerman, Esquire- Pa I.D. #311032 625 North West Street,Carlisle PA 17013-1967 Municipality: Carlisle Jana Fridfinnsdottir, Esquire- Pa I.D.#315944 Brian Nicholas, Esquire-Pa I.D.#317240 MCI I Denise Carlon, Esquire=Pa I.D.#317226 A F P I Roger Fay, Esquire; PA I.D.#315987 ATTY FILE NO.:XRP 190310 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XRP-190310 C� _ 3�s3 r 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.. Tracy E. Raymond;William H. Whittaker,Jr.; 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 (717) 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.. Tracy E. Raymond; William H.Whittaker,Jr.; Defendants. AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de la demanda establecida en las siguientes paginas, debe tomar acci6n dentro de los pr6ximos veinte (20) dias despues de la notificaci6n 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 reclamaci6n 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 LISTED 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 3476 Stateview Blvd. Ft. Mill,SC 29715 NO.: Plaintiff, vs. Tracy E. Raymond 625 North West Street Carlisle, PA 17013-1967; William H.Whittaker,Jr. 625 North West Street Carlisle, PA 17013-1967; 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 Tracy E. Raymond, with a last`known address of 625 North West Street, Carlisle, PA 17013-1967. 3. The Defendants) is/are William H. Whittaker, Jr., with a last known address of 625 North West Street, Carlisle, PA 17013-1967. 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 21, 2007, William H. Whittaker, Jr. and Tracy E. Raymond r made, executed and delivered to Mortgage Electronic Registration Systems, Inc. as nominee for Zucker,Goldberg&Ackerman, LLC 062-PA-V5 AmTrust Bank a Mortgage in the original principal amount of$152,749.29 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 September 27, 2007, Instrument #200737432. 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 April 9, 2012,the mortgage was assigned to Wells Fargo Bank, NA which assignment is recorded in the Office of the Recorder of Deeds for Cumberland County, Instrument #201210072. 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. 8. William H. Whittaker,Jr. and Tracy E. Raymond, husband and wife, as tenants by the entireties 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 1,2014. 10. As of 10/31/2014 the amount due and owing Plaintiff on the mortgage is as follows: Principal Balance $143,295.42 Interest from 12/01/2013 to 10/31/2014 $5,575.55 Late Charges $0.00 Escrow Advance $4,074.26 Property Inspections $0.00 Property Preservations $0.00 BPO/Appraisals $0.00 Escrow Balance $0.00 Corporate Advance Credit $0.00 TOTAL $152,945.23 Zucker,Goldberg&Ackerman, LLC 062-PA-VS 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 sl ms 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. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is Lot 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 $152,945.23 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 &ACKERMAN, LLC BY: C 1A A�Im a R�4 Dated: �� '� I(� Scott A. Diet erick, 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 Attorneys for Plaintiff XRP-190310/rbo 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@ZuckergoIdberg.com Zucker,Goldberg&Ackerman, LLC 062-PA-V5 Loan Numbert / NOTE MIN.: September 21,2007 Carlisle Pennsylvania [Date] f09'] [State] 625 N West Street,Carlisle,PA 17013 [Property Address] 1. BORROWER'S PROMISE TO PAY In return for a loan that I have received, I promise to pay U.S.$152,749.29 (this amount is called"Principal"),plus interest,to the order of the Lender. The Lender is AmTrust Bank. 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 6.375%. The interest rate required by this Section 2 is the rate I 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. I will make my monthly payment on the 1st day of each month beginning on November,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 be applied as of its scheduled due date and will be applied to interest before Principal. If,on October 1,2027,I still owe amounts under this Note,I will pay those amounts in full on that date,which is called the`;Maturity Date." I will make my monthly payments at P.O Box 790376, St. Louis, MO 63179-0376 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.$1,127.64 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. I may make 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. Multistate Fixed Rate Note—Single Family—Fannie Mae/Freddie Mac UNIFORM INSTRUMENT Form 3200 01/01 —Tim CO MPLIANCESOURCE,I\C: Page I of tisotxu 0&00 o..w.wmptianawuroamm =00.The Compliane Sm=,rM 5. LOAN CHARGES x 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 chopse 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,l 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. I 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 I 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 I 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 be 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 I 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. 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 Multistate Fixed Rate Note—Singie Family—Fannie,Mae/Freddie Jlne UNIFORM INSTRUMENT Form 3200 01/01 —TuE COMPLIANCE SOURCE,INC: Page 2 of 3 12601Nu WOO wxw.CompliitlCCSaluOt.tOm 12000.iix Complimoe Soiaee,ine 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 without further notice or demand on Borrower. WITNESS THE HAND(S)AND SEAL(S)OF THE UNDERSIGNED. (Seal). Seal) WILL AM H.WHITTAKER,Jr -Borrower TRACY E RAY ND -Borrower (Seal) (Seal) -Borrower -Borrower (Sign Original Only) cu.fond,Ci>;o 20�._ PAi 0 THE 0 F D R 0 without1 ecotne Oili S is Qg.3 al; BY: ROS Ind JOrI s Authorized Agent Multistate Fixed Rate Note—Single Family—Fannie Mne1Freddie Xfae UNIFORM INSTRUMENT Form 3200 01101 —TUE COMPLIANCE SOURCE,INC.— Page 3 of rzeontu osroa uwv.tomplianeesoutce.wm 02003,The Compha,c Source-I— EXHIBIT B Zucker,Goldberg&Ackerman, LLC 062-PA-V5 09/11,(2,007 11:14 7176719676 HOMESALE SETTLEMENT PAGE 09'/11 Commitment forritle insurance EXhibit A THE SECURITY TITLE GUARANTEE CORPORATION OF BALTIMORE Commitment No. Agent File No. LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in the Fifth Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a spike at the intersecdon of the Eastem line of sixty (60) feet wide North West Street with the Northern line of a sixteen'(16)feet wide public alley; thence-along the Eastern tine of said sixty(60)fleet wide North-West Street; North 16 degrees East,a distance of thirty-five(35) feet to a spike, thence along line of land formerly of the heirs of David Lesher, deceased, later of Samuel Heberling, and now or formerly of Forrest E Nousbaum, South.74 degrees East a distance of one hundred ninety (190) feet to a stake on the Western line of a sixteen (16) feet Wide public alley; thence along the Western line of said sixteen (16)feet wide public alley,South 18 degrees West, a distance of thirty-five(35)feet to a stake on the Northern line of a sixteen(16) feel 'wide public alley; thence along the Northern One of said sixteen (16) feet wide public alley, North 74 degrees West, a distance of one hundred ninety(190)feet to a spike on the Eastem line of said sixty(60)feet wide North West Street, the Place of BEGINNING, CONTAINING-thirty-five(35) feet in front along the Eastern line of said sixty(60)feet wide North West Street and extending Eastwardly therefrom At an even width a distance of one hundred ninety(190) feet to the Western line of sixteen (16) feet wide public alley, and having thereon erected a two and one-half story brick and frame dwelling house known as and numbered 625 North West Street. UNDER AND SUBJECT as aforesaid. BEING the same premises which,JACK E.BROWNAWELL and BARBARA A. REASY n/b/m BARBARA A.BROWNAWELL,HUSBAND AND WIFE by Indenture bearing date September 16,2005 and recorded September 26,2005 in the Office of the Recorder of Deeds,In and for the County of CUMBERLAND Deed Book No;271, page 586 etc.,granted and conveyed unto JACK-E- BROWNAWELL and BARBARA A. BROWNAWELL,HUSBAND AND WIFE, In fee. + 4 ST-N-24 VERIFICATION Bryan Woodward, hereby states the she is Vice President Loan Documentation of WELLS FARGO BANK,N.A.,plaintiff in this matter, thaQ�she is 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 his 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. Name: Bryan Woodward Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 11/03/2014 086-PA-V2 File#XRP-190310 r , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.: Tracy E. Raymond;William H. Whittaker,Jr.; Defendants. 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 XRP-190310 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 &ACKERMAN, LLC By: Dated: November , 2014 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 Attorneys for Plaintiff XRP-190310/emed 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908)233-1390 FAX Email: Office@zuckergoldberg.com Zucker,Goldberg&Ackerman, LLC XRP-190310 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 XRP-190310 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- Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Aut insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. 1 Spending Money Day/Child Care/Tuft. I 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 XRP-190310 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 XRP-190310 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Tracy E. Raymond;William H.Whittaker,Jr.; 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 XRP-190310 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, VS. NO.. Tracy E. Raymond;William H.Whittaker,Jr.; 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 XRP-190310 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 XRP-190310 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF NE WSRIFF (E R DEC 12 All 10; Cis; CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Case Number Tracy E. Raymond (et al.) 2014-6590 SHERIFF'S RETURN OF SERVICE 11/26/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: William H. Whittaker, Jr., 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 625 N. West Street, Carlisle Borough, Carlisle, PA 17013. Residence is vacant, per the Carlisle Postmaster mail is still delivered to the address provided. 11/26/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Tracy E. Raymond, 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 625 N. West Street, Carlisle Borough, Carlisle, PA 17013. Residence is vacant, per the Carlisle Postmaster mail is still delivered to the address provided. SHERIFF COST: $60.78 SO ANSWERS, December 09, 2014 (C) CountySuite Sheriff, Teleosoft, Inc RONIVR ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A., CIVIL DIVISION Plaintiff, vs. Tracy E. Raymond; William H. Whittaker, Jr.; Defendant(s). NO.: 14 -6590 -CIVIL MOTION FOR ALTERNATE SERVICE ON DEFENDANT PURSUANT TO Pa.R.C.P. 430 FILED ON BEHALF OF: Wells Fargo Bank, N.A. 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 Levy 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 (908) 233-1390 FAX office@zuckergoldberg.com File No.: XRP-190310/jfa Zucker, Goldberg & Ackerman, LLC XRP-190310 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Tracy E. Raymond; William H. Whittaker, Jr.; Defendants. NO.: 14 -6590 -CIVIL MOTION FOR ALTERNATE SERVICE PURSUANT TO Pa.R.C.P. 430 AND NOW, comes the Plaintiff, Wells Fargo Bank, N.A., by and through its attorneys, Zucker, Goldberg & Ackerman, LLC, and files the within Motion for Alternate Service pursuant to Pa.R.C.P. 430 as follows: 1. On or about November 13, 2014, Plaintiff filed its original Complaint in Mortgage Foreclosure ("Complaint") against the Defendants, William H. Whittaker, Jr. and Tracy E. Raymond, husband and wife, as tenants by the entireties ("Defendant(s)"), at the above - captioned number and term. 2. Plaintiff directed the Sheriff of Cumberland County to serve Defendant(s) with the Complaint in Mortgage Foreclosure at Defendants' last known address being 625 North West Street, Carlisle, PA 17013-1967, but service was returned property vacant. A true and correct copy of said Return of Service from the Cumberland County Sheriff's Office is marked Exhibit "A," attached hereto and made a part hereof. 3. A search of the U.S. Postmaster's records for 625 North West Street, Carlisle, PA 17013-1967 replied good as addressed. A true and correct copy of Plaintiff's U.S. Postmaster's Search is marked Exhibit "B," attached hereto and made apart hereof. 4. An internet person locator search provided no alternative address for Defendant(s). 5. Plaintiff conducted an investigation to determine the whereabouts of Defendant(s), Tracy E. Raymond and William H. Whittaker, Jr., but all sources indicated no alternative address other than that of the Mortgaged Premises. An affidavit of Plaintiff's counsel Zucker, Goldberg & Ackerman, LLC XRP-190310 regarding the investigation taken to determine the whereabouts of Defendant(s) is marked Exhibit "C," attached hereto and made a part hereof. 6. Plaintiff attempted to obtain concurrence of Defendant(s) Tracy E. Raymond and William H. Whittaker, Jr. with the Motion, but Defendant(s) cannot be located, therefore no concurrence was obtained. 7. There has been no other motion filed in this case. 8. This motion can be ruled on without a hearing or argument and no discovery is necessary. WHEREFORE, Plaintiff respectfully requests that this Honorable Court to permit Plaintiff to serve Defendant(s), Tracy E. Raymond and William H. Whittaker, Jr., with the Complaint and Notice of Sale, if necessary, by instructing the Cumberland County Sheriff's Office to POST a copy of same on the Mortgaged Premises, being 625 North West Street, Carlisle, PA 17013-1967 and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 625 North West Street, Carlisle, PA 17013-1967, with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 430. Dated: 12/23/2-o I� ZUCKE' GOLDBERG & ACK_ , LLC lazihuja A. Dietterick, Esquire; PI .D #55650 erly A. Bonner, Esquire; °'A.I.D. #89705 A. Ackerman, Esquire; PA I.D. #202729 shleigh Levy 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 File No.: XRP-190310 (908) 233-8500; (908) 233-1390 FAX E-mail: Office@zuckergoldberg.com Scott Kim Jo Zucker, Goldberg & Ackerman, LLC XRP-190310 EXHIBIT "A„ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson /�! Sheriff ' ' - ' ,•,� �iLL.:i Vii �.:,... ��t�ti1.,„.0cgoo i,, i.i+' THE P F W T �� O II O TAW., Jody S Smith t Chief Deputy Vit } 5: 7v 2O R OEC 12. AM ID: Oh Richard W Stewart ,i•''. Solicitor OFICEOFtKESHERIFF CUMBERLAND D COUNTY t'E•HNSYLVAN:1 A Wells Fargo Bank, N.A. Case Number vs. Tracy E. Raymond (et al.) 2014-6590 SHERIFF'S RETURN OF SERVICE 11/26/2014 Ronny R Anderson, Sheriff, being duly swom according to law, states he made diligent search and inquiry for the within named Defendant to wit: William H. Whittaker, Jr., but was unable to locate the Defendant in his bailiwick. The Sheriff therefore retums the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as "Not Found" at 625 N. West Street, Carlisle Borough, Carlisle, PA 17013. Residence is vacant, per the Carlisle Postmaster mail is still delivered to the address provided. 11/26/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Tracy E. Raymond, 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 625 N. West Street, Carlisle_ Borough, Carlisle, PA 17013. Residence is vacant, per the Carlisle Postmaster mail is still delivered to the address provided. SHERIFF COST: $60.78 SOANSWERS, December 09,22014 (c3 Ccurr[ySuiio Shcdff, ThIrosoft. Inc: RONNY R ANDERSON, SHERIFF EXHIBIT ur • LEONARD B. ZUCKER MICHAEL 5. ACKERMAN JOEL ACKERMAN • FRANCES GAMBARDELLA BRIAN C. NICHOLAS •• SCOTT A. DIETTERICK •!• KIMBERLY A. BONNER •t• STEVEN 0. KROL CHRISTOPHER G. FORD DENISE CARLON ••" CHRISTINE E. POTTER •8•• RYAN 5. MALC STEPHANIE WOLCHOK ASHLEIGH LEVY MARIN •F DOUGLAS). MCDONOUGH TIMOTHY J. ZIEGLER RALPH M. SALVIA '8S' ROBERT D. DAILY JAIME R. ACKERMAN •• KACIE W. BROWN MONIKA S. PUNDAL]K TODD MARKS ••"• JANA FRIDFINNSOOTTIR '8' DENNIS P. UHLMANN, M. BRIAN M. GILBERT JAMAR BENJAMIN ZUCKER, GOLDBERG & ACKERMAN, LLC ATTORNEYS AT LAW 200 SHEFFIELD STREET - SUITE 301 P.O. BOX 1024 MOUNTAINSIDE, N) 07092-0024 TELEPHONE : 908-233-8500 FACIMILE : 908-233-1390 E-MAIL : OFFICEOZUCKERGOLDBERG.COM FOR PAYOFF/REINSTATEMENT FIGURES PLEASE SEND YOUR REQUEST TO : ZUCKERGOLOBERG.COM/PR REPLY TO NEW JERSEY ADDRESS FOUNDED IN 1923 AS ZUCKER R GOLDBERG MAURICE J. ZUCKER (1918-.1979) LOUIS 1). GOLDBERG (1923- 1967) LEONARD H. GOLDBERG (1929 - 1979) BENJAMIN WEISS (1949 • 1981) PENNSYLVANIA OFFICE : The Unlon Hotel Office ButMing 240 Gettysburg Pike Medienkstnng, PA 17055 • ALSO MEMBER OF NY, PA AND CA BAR • • 01.50 MEMBER OF NY, PA AND ME BAR "" ALSO MEMBER OF NY AND PA BAR ""'• ALSO MEMBER OF NY BAR '9 ALSO MEMBER OF PA BAR 'I' MEMBER OF PA BAR ONLY "i" 01.50 MEMBER OF FL BAR Postmaster C_190310PD021X1 C CARLISLE, PA 17013-1967 June 03, 2014 RE: Request for Change of Address or Boxholder Information Needed for' Service of Process Please furnish the new address or the name and street address (if a boxholder) for the following: TRACY RAYMOND --625 N W ST The following information is provided in accordance with 39 CFR 265.6(d)(6Xii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester. ATTORNEYS FOR PLAINTIFF 2. Statute or regulation that empowers me to serve process: NOT APPLICABLE 3. The names of all known parties to the litigation: Wells Fargo Bank, N.A. v. TRACY RAYMOND 4. The court in which the case has been or will be heard: SUPERIOR COURT OF PENNSYLVANIA; CHANCERY DIVISION; COUNTY CUMBERLAND 5. The docket number is: F-00000-07 6. The capacity in which this individual is to bo served (e.g. defendant or witness): DEFENDANT THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE •`OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO 510,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS. OR BOTH (TITLE 18 U.S,C. SECTION 1001)• 1 certify that the above information is tme and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. LBZ/T Enclosures No Change of Address Order on file. ,Not known at address given. Moved Left no forwarding address No such address - ' ' • • / MOO A� ra y C 190310PD021X1 C Very truly yours, By: SCOTT DIETTERICK SCOTT DIETTERICK FOR POST OFFICE USE ONLY NAME AND STREET ADDRESS 1,9 STAMP HERE LEONARD B. ZUCKER MICHAEL S. ACKERMAN JOEL ACKERMAN • FRANCES GAMBAROELLA BRIAN C. NICHOLAS •• SCOTT A. DIETTERICK •1• KIMBERLY A. BONNER •4' STEVEN D. KROL CHRISTOPHER G. FORD DENISE CARLON ••• CHRISTINE E. POTTER •••• RYAN S. MALL STEPHANIE WOLCHOK ASHLEIGH LEVY MARIN •! DOUGLAS J. McDONOUGH TIMOTHY J. ZIEGLER RALPH M. SALVIA •12• ROBERT D. GAILY JAIME R. ACKERMAN •• KACIE W. BROWN MONIKA S. PUNDAUK TODD MARKS •••• JANA FRIDFINNSDOTTIR •t• DENNIS P. UHLMANN, JR. BRIAN M. G LBERT JAMAR BENJAMIN ZUCKER, GOLDBERG & ACKERMAN, LLC ATTORNEYS AT LAW 200 SHEFFIELD STREET - SUITE 301 P.O. BOX 1024 MOUNTAINSIDE, NJ 07092-0024 TELEPHONE : 908-233-8500 FACTMJLE : 908-233-1390 E-MAIL : OFFICECZUCKERGOLOBERG.COM FOR PAYOFF/REINSTATEMENT FIGURES PLEASE SEND YOUR REQUEST TO : ZUCKERGOLDBERG.COM/PR REPLY TO NEW 3ERSEY ADDRESS FOUNDED 1N 1923 AS ZUCKER a GOLDBERG MAVRICE J. ZUCKER (1918. 1979) LOUIS D. GOLDBERG (1923. 1967) LEONARD N. GOLDBERG (1929 - 1979) BENJAMIN WEISS (1949 - 1981) PENNSYLVANIA OFFICE: The Union Hotel Office Bullding 240 Gettysburg Plke Mechanicsburg, PA 17055 • ALSO MEMBER OF NY, PA AND CA BAR ALSO MEMBER OF NY, PA AND ME BAR ••• ALSO MEMBER OF NY AND PA BAR •••• ALSO MEMBER OF NY BAR •! ALSO MEMBER OF PA BAR •f• MEMBER OF PA BAR ONLY • !•• ALSO MEMBER OF FL BAR Postmaster C_190310PD011XI_C Carlisle, PA 17013-1967 June 03, 2014 RE: Request for Change.of Address or Boxholder Information Needed for Service of Process Please furnish the new address or the name and street address (if a boxholder) for the following: JR WILLIAM WHITTAKER--625 North West Street The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: ATTORNEYS FOR PLAINTIFF 2. Statute or regulation that empowers me to serve process: NOT APPLICABLE 3. The names of all known parties to the litigation: Welts Fargo Bank, N.A. v. JR WILLIAM WHITTAKER 4. The court in which the case has been or will be heard: SUPERIOR COURT OF PENNSYLVANIA; CHANCERY DIVISION; COUNTY CUMBERLAND 5. The docket number is: F-00000-07 6. The capacity in which this individual is to be served (c.g. defendant or witness): DEFENDANT THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND 'USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL Olt PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO 510,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. LEVI Enclosures No Change of Address Order on file. Not known at address given. Moved Left no forwarding address IJo.such address 0vlt9 dpi tv2 d(144/1 C 190310PD011X1 C • Very truly yours, By: SCOTT DIETTERICK SCOTT DIETTERICK FOR POST OFFICE USE ONLY NAME AND STREET ADDRESS STAMP HERE : : • . . • • • O. . • • . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Tracy E. Raymond; William H. Whittaker, Jr.; Defendants. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN NO.: 14 -6590 -CIVIL Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Jana Fridfinnsdottir, Esquire, attorney for and authorized representative of Plaintiff, who being duly sworn according to law, deposes and says that Plaintiff, or counsel for Plaintiff, conducted an investigation to determine the whereabouts of Defendant(s), which included, but was not limited to searches of the following records: (X) Records of the U.S. Postmaster with results of same attached to the foregoing Motion. (X) Internet Person Locator Records (X) Credit Report Agency. (X) Telephone Directory (X) Records of the County Recorder of Deeds and Prothonotary Zucker, Goldberg & Ackerman, LLC XRP-190310 Finally, Affidavit deposes and says that if Defendant(s) is/are not located at the address uncovered by this investigation, the whereabouts of Defendant(s) is/are unknown to Plaintiff. Dated: 12.123A0 (1. Bv: ZU . ER, GOLDBERG MAN, LLC Sworn o and ubscribed before me this Itj..4104,1t:_ ,2014 1 A 0111411111EL ,V4 ay of Notary Pub!' My Commission Expires: COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL ELIZABETH ANNE FAIRCHOK Notary Public SWATARA TWR,DAUPHIN COUNTY My Commission Expires Jul 23, 2017 Fridfinnsdottir, Esq., ty File No.: XRP-190310 00 Sheffield Street, Suite 101 Mountainside, NJ 07092 Email: Office@zuckergoldberg.com (908) 233-8500; (908) 233-1390 FAX .ID#315944 Zucker, Goldberg & Ackerman, LLC XRP-190310 Legis a*IS' Accurin for Cai#ections Person Search Plus Results - Contact & Locate Search Terms Used - SSN: 1. Subject Results 2. Household Results Full Name SSN TRACEY E RAYMOND TRACY ELLEN RAYMOND TRACY E RAYMOND TRACY E RAYMOND SR TRACY RAYMOND PRANCY E WITTAKER TRACY E WHITTAKER TRACY E WHITTAKER SR DOB: 6/28/1967 Age: 47 DOB: 1968 Age: 46 'View Sources (-4) 40 Setup Alert Address Phone Page 1 of 2 Records: 1 to 2 of 2 Next Ste.s mor-xx-8703 vIt 55N %ISSN potentially randomlyissued by the SSA, but invalid when first associated with the consumer. ISSN not recently reported for subject. LexID: 2085884102 ,625 N WEST ST CARLISLE PA 17013-1967 2005 - Nov 2014 717-379-1090 - EST Jun 01 Possible Cell Phone TRACEY E RAYMOND 717-258-1999 - EST 2005 - 2014 ROTZ E (Current Listing Name) We Also Found: ❑ Email Address 960 W TRINDLE RD MECHANICSBURG PA 17055-4081 Apr 1998 - Apr 2008 118 SUMMIT HILL RD APT G PARADISE PA 17562-9700 Apr 1989 -Jan 2003 1350 MICHELLE CT APT 0 COLORADO SPRINGS CO 80916-1912 Apr 1989 -Jan 2003 21 FERNWOOD DR PARADISE PA 17562-9709 Mar 1991 -Jan 1999 1350 MICHELLE CT APT P COLORADO SPRINGS CO 80916-1985 May 1994 118G SUMMIT HILL RD PARADISE PA 17562-9700 Jan 1993 1186 SUMMIT HILL DR PARADISE PA 17562 Oct 1990 - Jan 1993 14A E 3RD ST FREDERICK MD 21701-5311 Jul 1990 - Dec 1991 1136 SUMMIT HILL DR PARADISE PA 17562 Nov 1990 - Dec 1990 https://secure.accurint.com/app/bps/misc 717-766-4291- EST Oct 02 - Dec 07 phone number may be disconnected. 766-4291 766-4291 687-7887 Learn how Contact & Locate Reports can assist you:See Examples 12/15/2014 (air LexlisNexis• 1 Accurint for Coliections . Person Search Plus Results - Contact & Locate Search Terms Used - SSN: 1. Subject Results 2. Household Results Full Name SSN WILLIAM HAROLD WHITTAKER WILLIAM HAROLD WHITTAKER JR WILLIAM H WHITTAKER WILLIAM H WHITTAKER JR WILLIAM WHITTAKER DOB: 10/20/1966 Age: 48 Gender - Male *View Sources (-6) Setup Alert Address Phone LexID: 2702341577 625 N WEST ST CARLISLE PA 17013-1967 2005- Nov 2014 717-258-1999 - EST Oct 07 - Jul 09 ROTZ E (Current Listing Name) We Also Found: ❑ Email Address 960 W TRINDLE RD MECHANICSBURG PA 17055-4081 Apr 1998 -Aug 2012 625 W NORTH ST CARLISLE PA 17013-2225 Sep 2007 - 2008 960 W TRINDLE RD SILVER SPRING PA 17055-4081 Oct 2002 - Dec 2007 960 W TRINDLE RD SILVER SPRING PA 17575 Apr 2006 - May 2006 1350 MICHELLE CT APT 0 COLORADO SPRINGS CO 80916-1912 May 1994 - Jan 2003 960 W TINDAL RD • MECHANICSBURG PA 17055 Apr 2000 21 FERNWOOD DR PARADISE PA 17562-9709 Jul 1995 -Jan 1999 https://secure.accurint.com/app/bps/misc 717-379-9090 - EST Jun 06 -Jun 14 Possible Cell Phone WHITTAKER, WILLIAM 717-766-4291 - EST May 98 - Dec 07 . phone number may be disconnected. 717-258-1999 - EST ROTZ E (Current Listing Name) 717-379-9090 - EST Jun 06 -Jun 14 Possible Cell Phone WHITTAKER, WILLIAM 717-766-4291 - EST Oct 02 - Dec 07 111 phone number may be disconnected. 717379-9090 - EST Jun 06 - Jun 14 Possible Cell Phone WHITTAKER, WILLIAM Page 1 of 2 Records: 1 to 2 of 2 Next Ste.s Learn how Contact & Locate Reports can assist you:See Examples 717-766-4291 - EST Apr 06 - May 06 phone number may be disconnected. 717-379-9090 - EST Jun 06 -Jun 14 Possible Cell Phone WHITTAKER, WILLIAM 717-766-4291 - EST '4r phone number may be disconnected. 111 phone number and zip code combination is invalid. 12/15/2014 14 E 3RD ST FREDERICK MD 21701-5311 Jul 1990 PO BOX 72 PARADISE PA 17562-0072 Jul 1989 504 N MARKET ST FREDERICK MD 21701-5243 Jun 1989 118 SUMMIT DRI G PARADISE PA 17562 766-4291 Page 2 of 2 2. WILLIAM WHITTAKER Gender - Male 'View Sources (-1) *u Setup Alert S not recently 1350 MICHELLE CT APT reported for COLORADO SPRINGS CO 80916-1912 subject. Sep 4004- Jan 2005 LexID: 57107750609 Your DPPA Permissible Use: Civil, Criminal, Administrative or Arbitral Proceedings Your GLBA Permissible Use: Persons Acting in a Fiduciary Capacity on Behalf of the Consumer Your DMF Permissible Use: No Permissible Purpose Learn how Contact & Locate Reports can assist you:See Examples Records: 1 to 2 of 2 Copyright © 2014 LexisNexis. All rights Reserved. Terms & Conditions 1 Privacy & Security https://secure.accurint.com/app/bps/misc 12/15/2014 Page 2 of 2 le phone and address are geographically distant (greater than 10 miles). USA MODDAC FORT CARSON CO 80913 Dec 1992 1350 MICHELLE US ARMY COLORADO SPRINGS CO 80916 2. VICTORIAN° ORTIZ AGUIRRE VICTORIAN° 0 AGUIRRE VICTORIAN° AGUIRRE VICTORIANOO AGUIRRE VICTOR OAGUIRRE VICTORIANOA ORTIZ VICTORIAN° ORTIZ VICTOR ORTIZ DOB: 5/6/1965 Age: 49 Gender - Male *View Sources (-5) Setup Alert xxx-xx-5772 asN \ SSN potentially randomly issued by the SSA. LexID: 9470988084 19436 SATICOY ST RESEDA CA 91335-2342 Jul 2002 - Sep 2014 19436 SATICOY ST RESEDA CA 91311-2342 Jun 2008 - Oct 2008 NORTHRIDGE CA 91311 Aug 2009 - Feb 2014 19758 STAGG ST WINNETKA CA 91306.2667 Oct 1995 - Mar 2011 CANOGA PARK CA 91306 Sep 2002 - May 2006 7545 HASKELL AVE VAN NUYS CA 91406.3220 Apr 2003 -Aug 2005 442 SAN ANDREAS RD BANNING CA 92220-2210 Jun 2004 1212 VISTA SERENA AVE BANNING CA 92220-2576 Feb 2004 818-8864047 - PST Nov 02 - Dec 14 RIVERA VICTORINA Active Phone 818-775.5800 - PST Feb 14 Possible non DA AGUIRRE VICTORIAN° 0 818-882-7378 - PST EZ PEST CONTROL (Current Listing Name) Your DPPA Permissible Use: Civil, Criminal, Administrative or Arbitral Proceedings Your GLBA Permissible Use: Persons Acting in a Fiduciary Capacity on Behalf of the Consumer Your DMF Permissible Use: No Permissible Purpose Learn how Contact & Locate Reports can assist you:See Examples Records: 1 to 2 of 2 Copyright © 2014 LexisNexis. All rights Reserved. Terms & Conditions I Privacy & Security https://secure.accurint.com/app/bps/misc 1')/1GJ'1A1 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, N.A. CIVIL DIVISION Plaintiff, vs. Tracy E. Raymond; William H. Whittaker, Jr.; Defendants. AND NOW, this 4 day of NO.: 14 -6590 -CIVIL ORDER OF COURT 4-7 , 2014, upon consideration of Plaintiff's Motion for Alternate Service, it is hereby ORDERED, ADJUDGED AND DECREED that Plaintiff shall serve its Complaint in Mortgage Foreclosure and Notice of Sale, if necessary, on Defendant(s) Tracy E. Raymond and William H. Whittaker, Jr., by instructing the Sheriff of Cumberland County to POST a copy of same on the Mortgaged Premises, being 625 North West Street, Carlisle PA 17013-1967, and by mailing a copy, via Certified Mail, no signature required and First Class U.S. Mail, Postage Prepaid to 625 North West Street, Carlisle PA 17013-1967, with said service being valid and complete upon such posting and mailing in accordance with Pa.R.C.P. 430. CO ty2.1.Leck Py ./ J .dz. __s 4; .7 C -7i Zucker, Goldberg & Ackerman, LLC XRP-190310