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Home My WebLink About14-6591 Supreme Court-o.f Pennsylvania Couilt�vf Com !lon Pleas � 1. r' � For Prothonotary Use Only: vi "Coye>t�S eet CIIVIBtI'AND, County Docket No: The information collected on this form is used solely far court administration purposes. This form does not supplement or replace the filing and service ofpleadings or otherpopers 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 iLead Plaintiff's Name: Wells Fargo Bank,NA Lead Defendant's Name: Theodore Hamal,a/kla Theodore R. C Hamal T I Are money damages requested?: ❑Yes ® No Dollar Amount Requested: within arbitration limits {check one} Q x outside arbitration limits N Is this a Class Action Suit? ❑Yes ® No Is this an MDJ Appeal? ❑Yes ® No Name of Plaintiff/Appellant's Attorney: Scott A.Dietterick,Esq.c/o Zucker,Goldberg&Ackerman,LLC Id- ❑ 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 ElSlander/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 REAL PROPERTY MISCELLANEOUS ❑ Toxic Waste El Other: El Ejectment ❑ Common Law/Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment B E] Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ® Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure:Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 111112011 s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, NA, CIVIL DIVISION v j l Plaintiff, NO.. H_�P 9 VS. \ TYPE OF PLEADING Theodore Hamal,a/k/a Theodore R. Hamal; Anne M. Hamal; CIVIL ACTION -COMPLAINTS IN MORTGAGE FORECLOSURE Defendants. FILED ON BEHALF OF: TO: DEFENDANTS ' - O YOU ARE HEREBY NOTIFIED TO PLEAD TO THE ENCLOSED COMPLAINT WITHIN TWENTY(20)DAYS Wells Fargo Bank, NA FROM SERVICE HEREOF OR A DEFAULT JUDGMENT MAY BE Plaintiff ENTERED AGAINST YOU. I HEREBY CERTIFY THAT THE ADDRESS COUNSEL OF RECORD FOR THIS PARTY: OF THE PLAINTIFF IS: 3476 Stateview Blvd. ZUCKER,GOLDBERG &ACKERMAN, LLC Ft.Mill,SC 29715 Scott A. Dietterick, Esquire-Pa. I.D.#55650 AND THE DEFENDANT: Kimberly A. Bonner, Esquire- Pa. I.D.#89705 97 old state Road Joel A.Ackerman, Esquire-Pa I.D.#202729. Gardners,PA 17324 Ashleigh Levy Marin, Esquire- Pa I.D.#306799 Ralph M.Salvia, Esquire-Pa I.D.#202946 Jaime R.Ackerman, Esquire- Pa I.D.#311032 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF Jana Fridfinnsdottir, Esquire- Pa I.D.#315944 THE REAL ESTATE AFFECTED BY THIS LIEN IS Brian Nicholas, Esquire- Pa I.D.#317240 97 Old State Road(f/k/a T-522) Gardners PA 17324 Denise Carlon, Esquire-Pa I.D.#317226 Municipality: Dickinson C9� Roger Fay, Esquire; PA I.D.#315987 200 Sheffield Street,Suite 101 ATT R Y FOR P6W4T TFF Mountainside, NJ 07092 ATTY FILE NO.:XFP 190337 (908) 233-8500 Atty File No.: XFP-190337 L -7 V�s'?� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, NO.. VS. Theodore Hamal, a/k/a Theodore R. Hamal; Anne M. Hamal; Defendants. s'2 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 Zucker,Goldberg&Ackerman,LLC XFP-190337 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. 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: �.. J (� ScottA. ietterick, Esquire; PA I.D.#55650 Kimb ly A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M.Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D.#317226 Roger Fay, Esquire; PA I.D.#315987 Attorneys for Plaintiff XFP-190337/mti 200 Sheffield Street,Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908)233-1390 FAX Email: Office@zuckergoldberg.com Zucker,Goldberg&Ackerman, LLC XFP-190337 ' 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: CUSTOM Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ . Listing date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? CO-BORROWER Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date you closed your loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes& Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court,case number&attorney: Zucker,Goldberg&Ackerman,LLC XFP-190337 Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. Additional Income Description (not wages): 1. Monthly amount: 2. Monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2"d Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: Email: Zucker,Goldberg&Ackerman, LLC XFP-190337 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 d Proof of any expected income for the last 45 days Copy of current utility bill d Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement(if property is currently on the market) Zucker,Goldberg&Ackerman, LLC XFP-190337 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, VS. NO.. Theodore Hamal, a/k/a Theodore R. Hamal; Anne M. Hamal; Defendants. REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program,the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 1. Defendant lives in the subject real property, which is defendant's primary residence; 2. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program"and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. Signature of Defendant's Counsel/Appointed Date Legal Representative Signature of Defendant Date Signature of Defendant Date Zucker,Goldberg&Ackerman, LLC XFP-190337 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, NO.. VS. Theodore Hamal, a/k/a Theodore R. Hamal; Anne M. Hamal; 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 Zucker,Goldberg&Ackerman,LLC XFP-190337 resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference,the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 3. At the Conciliation Conference,the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure;entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 4. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Zucker,Goldberg&Ackerman, LLC XFP-190337 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, NA CIVIL DIVISION Plaintiff, NO.. VS. Theodore Hamal, a/k/a Theodore R. Hamal; Anne M. Hamal; 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, NA CIVIL DIVISION Plaintiff, VS. NO.. Theodore Hamal,a/k/a Theodore R. Hamal; Anne M. Hama[; 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 vaso 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. Sl USTED NO TIENE UN ABOGADO 0 NO PUEDE PAGAR LINO, LLAME 0 VAVA A LA SIGUEINTE OFICINA PARA AVERIGUAR DONDE PUEDE ENCONTRAR ASISTENCIA LEGAL. NOTICE TO DEFEND&LAWYER REFERRAL SERVICE NOTICE TO DEFEND LAWYER REFERRAL Cumberland County Bar Association Cumberland County Bar Association 32 S. Bedford Street 32 S. Bedford Street Carlisle, PA 17013 Carlisle, PA 17013 Phone (800)990-9108 Phone (800) 990-9108 (717) 249-3166 (717)249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION 3476 Stateview Blvd. Ft. Mill, SC 29715. NO.: Plaintiff, VS. Theodore Hamal, a/k/a Theodore R. Hamal 97 Old State Road Gardners, PA 17324; Anne M. Hamal 97 Old State Road Gardners, PA 17324; Defendants. CIVIL ACTION -COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank, NA, by its attorneys,Zucker, Goldberg&Ackerman, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank, NA, 3476 Stateview Blvd., Ft. Mill, SC 29715 (hereinafter"plaintiff"). 2. The Defendants) is/are Theodore Hamal, a/k/a Theodore R. Hamal, with a last known address of 97 Old State Road, Gardners, PA 17324. 3. The Defendant(s) is/are Anne M. Hamal, with a last known address of 97 Old State Road, Gardners, PA 17324. 4. In order to protect the borrower's privacy, certain personal information of the borrower(such as loan account, Social Security numbers and birth dates), may have been partially or completely redacted on the exhibits to this complaint. 5. Wells Fargo Bank, NA, directly or through an agent, has possession of the Promissory Note. Wells Fargo Bank, NA is either the original payee of the Promissory Note or the Promissory Note has been duly indorsed. A copy of said Promissory Note is marked Exhibit A, attached hereto and made a part hereof. 6. On or about January 13, 2010, Theodore Hamal and Anne M. Hamal made, executed and delivered to Homepromise Corporation a Mortgage in the original principal amount of 062-PA-V5 Zucker,Goldberg&Ackerman, LLC $99,460.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on January 22, 2010, Instrument#201001938.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. The aforesaid Note and/or Mortgage was modified pursuant to a Loan Modification Agreement dated February 20, 2013. A copy of said Modification Agreement is marked Exhibit C, attached hereto and made a part hereof 8. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded March 19, 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 #201207827. 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. 9. Theodore Hamal and Anne M. Hamal are the record and real owners of the aforesaid mortgaged premises. 10. Defendants are in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the installments of principal and interest due December 1,2013. Zucker,Goldberg&Ackerman, LLC 062-PA-VS 11. As of 10/31/2014 the amount due and owing Plaintiff on the mortgage is as follows: Principal $102,571.69 Interest $3,329.79 From 11/01/2013 to 10/31/2014 Late Charges $140.65 Escrow Advance $2,025.91 Property Inspections $0.00 Property Preservation $0.00 BPO/Appraisals $0.00 Escrow Balance $0.00 Corporate Advance Credit $0.00 Total $108,068.04 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). 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 Zucker,Goldberg&Ackerman, LLC 062-PA-VS a separate legal action if such right exists. If Defendants) 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 $108,068.04 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 &ACKEERMA/N, LLC CSS BY: Dated: i f ..( y Scott A. Di erick, Esquire; PA I.D.#55650 Kimber[A. Bonner, Esquire; PA I.D.#89705 Joel A.Ackerman, Esquire; PA I.D.#202729 Ashleigh L. Marin, Esquire; PA I.D.#306799 Ralph M. Salvia, Esquire; PA I.D.#202946 Jaime R.Ackerman, Esquire; PA I.D.#311032 Jana Fridfinnsdottir, Esquire; PA I.D.#315944 Brian Nicholas, Esquire; PA I.D.#317240 Denise Carlon, Esquire; PA I.D.#317226 Roger Fay, Esquire; PA I.D.#315987 Attorneys for Plaintiff XFP-190337/rbo 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908)233-1390 FAX Email: Office@zuckergoldberg.com THIS/SAN ATTEMPT TO COLLECT A DEBT,AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. Zucker,Goldberg&Ackerman, LLC 062-PA-V5 NOTE IFHA Case No: MW App January 13,2010 GARDNERS PENNSYLVANIA [Date] [City] [State] 97 OLD STATE RD,GARDNERS,PA 17324 [Property Address] 1.PARTIES "Borrower"means each person signing at the end of this Note,and the person's successors and assigns."Lender"means HOMEPROMISE CORPORATION 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 Ninety Nine Thousand Four Hundred Sixty Dollars and No Cents (U.S. $99,460.00 ), plus interest,to the order of Lender. Interest will`.be Charged on unpaid principal,from the date of disbursement of the loan proceeds by Lender,at the rate of FIVE AND ONE HALF PERCENT(5.500%) per year until the full amount of principal has been paid. 3. PROMISE TO PAY SECURED Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date as this Note and called the"Security Instrument."That Security Instrument protects the Lender from losses which might result if Borrower defaults under this Note. 4.MANNER OF PAYMENT ' (A)Time Borrower shall make a payment'of principal and interest to Lender on the first day of each month beginning on 03/01/2010 .Any principal and interest remaining on the first day of 02/01/2040 , will be due on that date,which is called the"Maturity Date." (B) Place Payment shall be made at 60 S.WASHINGTON ST,SUITE 106 GREENCASTLE, PA 17225 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 $564.72 This amount will a part of a larger monthly payment required by the Security Instrument,that shall be applied to principal, interest and other items to the order described in the Security Instrument. (D)Allonge to this Note for payment adjustments If an allonge providing for payment adjustments is executed by Borrower together with this Note,the covenants of the allonge shall be incorporated into and shall amend and supplement the covenant's of this,.-Note as if the allonge were a part of this Note. [Check applicable box] ❑ Graduated Payment Allonge ❑ Growing Equity Allonge ❑ Other[specify] (Page 1 of 3) Management Systems Development,Inc. (310)519.3111 Loan Energizer!" &nt_pa_fh (3/11/09VAFHA) Copyright(c)2003-2006 b , Y1 5.BORROWER'S RIGHT TO PREPAY Borrower has the right to pay the debt'evidenced by this Note, in wh?Ie or in part,without Lharge or penalty, on the first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the Secretary. If Borrower makes a partial prepayment,the�rre will be no changes in the due date or in the amount of the monthly payment unless Lender agrees itn d�riting to those changes. 6. BORROWER'S FAILURE TO PAY' (A) Late Charge for Overdue Payments 11.Lender has not received the full monthly payment required by the Security Instrument,as described in Paragraph 4(C)of this Note by the end.of 15 calendar days after the payment is due, Lender may collect a late charge in the amount of-;FOUR PERCENT(4.000%) of the overdue amount of each payment. (B)Default If Borrower defaults by failing to pay in full any monthly payment,then Lender may,except as limited by regulations of the Secretary in the case of payment defaults,require immediate payment in full of the principal balance remaining due and all-accrued interest. Lender may choose not to exercise this option without waiving its rights in the event of any subsequent default. In many circumstances regulations issued by the Secretary will limit Lender's rights to require immediate payment in full in the case of payment defaults.This Note does not authorize acceleration when not permitted by HUD regulations.As used in this Note, "Secretary"means the Secretary of Housing and Urban Development or his or her designee. (C)Payment of Costs and Expenses IfI 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 prohibited by applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of this Note. 7.WAIVERS Borrower and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment"means the right to require Lender to demand payment of amounts due. "Notice of dishonor"means the right to require Lender to give notice to other persons that amounts due have not been paid. 8.GIVING OF NOTICES Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or mailing it by first class mail to Borrower at the property address above or at a different address if Borrower has given Lender a notice of Borrower's different address. Any notice that must be given to Lender under this Note will be given by first class mail to Lender at the address stated in Paragraph 4(B)or at a different address if Borrower is given a notice of that different address. 9.OBLIGATIONS OF PERSONS UNDER THIS NOTE If,more than one person signs this'Note,each person is fully and personally obligated to keep all of the promises made in this Note, including the promise to pay the full amount owed.Any person who is a guarantor,surety or endorser of this Note is also obligated to do these things.Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in this Note.Lender may enforce its rights under this Note against each person individually or against all signatories together.Any one person signing this Note may be required to pay;all of the amounts owed under this Note. (Page 2 of 3) management systems Development,Inc. (310)519.311.1 Loan Energlzedr" &d1_va th (3111109VAFHA) Copyright(c)2003.2006 s• i ,y• ,1;4r: BY SIGNING BELOW, Borrower accepts and agrees to the terms and covenants contained in this Note. Jr eal} (Seal) THEODORE R RAMAL -Borrower -Borrower (Seal) (Seal) -Borrower -Borrower [Sign Original Only] ' 1 AI LONGE ATTACKED FOR,�E PURPOSE OF ENDORSING VE (Page 3 of 3) Management Systems Development,Ino. (310)519.3111 Loan Energizer?i° &dt va_fh (3111/09VAFHA) copyright(c)2003-2006 i • Allonge To Note Description 97 Old State Road Gardners, PA 17324 Maker: Theodore IHam , Co-Maker(s): Note Amount: $99,460.00 Note Date: 01/13/2010 Payee: HomePromise Corporation Loan Number: Pay To The Order Of: Sun West Mortgage Company,Inc Without Recourse Name: Nicole Mavero,AVP Texas Capital Bank,N.A. Attorney-In-Fact For: HomePromise Corporation i i Allonge To Note . I Description 07 Old State Road = Gardners, PA.,-7324 h � , Maker: Theodore(Hamal Co-Maker(s): Note Amount: $99,460.00 Note Date: 01113/2010 Payee. Sun West Mortgage Company,Inc. Loan Number: Pay To The Order Of: Wilt 8190 Bank,NA. Without Recourse Name: Nicole Mavero,AVP Texas Capital Bank,N.A. Attorney-In-Fact For: Sun West Mortgage Company,Inc. WITHOUT RECOURSE PAYTO THE ORDER OF Wells Fargo Bank, NA. BysL�s� A4Lori K.Venego Vice President Loan Documentation oRDF . EXHIBIT A ALL THAT PARCEL OF LAND IN TOWNSHIP OF DICKINSON,CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA,AS MORE FULLY DESCRIBED IN DEED BOOK 279, BUNDLE 2391,IDN 08.40-2648-066,BEING KNOWN AND DESIGNATED AS METES AND BOUNDS PROPERTV. CONTAINING.5233 ACRES AND BEING DESCRIBED ACCORDING TO A SURVEY BY EUGENE A HOCKENSMITH,R.E.DATED 8/11/1977 AND BEING IMPROVED WITH AN EXISTING HOUSE AND OUTBUILDINGS. DEED FROM BENEFICIAL CONSUMER DISCOUNT CO D/8/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA AS SET FORTH IN DEED BOOK 299,BUNDLE 2391 DATED 03/01/2007 AND RECORDED 04/05/2007,CUMBERLAND COUNTY RECORDS,COMMONWEALTH OF PENNSYLVANIA. Post 4 of 10 wells Fargo Home Mortgage MAC W0151-053 HOME 210 Wildwood Parkway MORTGAGEBirmingham,AL 35209 Tel: 877 913 3376 Toll Free LOAN MODIFICATION_ AGREEMENT LOAN NUMBER: PROPERTY ADDRESS 91 Old State Road Gardners PA 17324-9058 THIS LOAN MODIFICATION AGREEMENT ("Agreement") , made on February 20, 2013, by and between. Theodore R Hamal. (the "Borrower(s) ") and Wells Fargo Bank, N. A. (the "Lender"-, together with the Borrower(s) , the "Parties") . WITNESSETH WHEREAS, Borrower has requested and Lender has agreed, subject to the following terms and conditions, to a loan modification as follows : NOW THEREFORE, in consideration of the covenants hereinafter set forth and for other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged by the Parties, it is agreed as follows (notwithstanding anything to the contrary in the Note and Security Instrument dated 01%13/2010 . ) 1 . BALANCE. As of February 20, 2013, the amount payable under the Note and Security Instrument (the "Unpaid Balance" ) is •U.S . $ 96, 338. 71. . 2 . EXTENSION. This Agreement hereby modifies the following terms. of the Note and Security Instrument described herein above as follows: A. The current contractual due date has been extended from 06-01-12 to 05/01/2013. The first modified contractual due date is on 05/01/2013 . B. The maturity date has been extended from 02-40 (month/year) to 04/01/2043 . C. The amount of interest to be included (capitalized) will be U.S. $ 4, 857 .05 . The amount of the Escrow Advance to be capitalized will be U.S . $2, 747 . 99 . The amount of Recoverable Expenses* to be capitalized will be U.S. $0.00. The modified Unpaid Principal Balance is U.S. $ 103, 943 .75 . * Recoverable Expenses may include, but are not limited to: Title, Attorney fees/costs, BPO/Appraisal, and/or Property Preservation/ Property Inspections LM521/XSD/Pgl Together we'll go far %wtisiatgotlomeMmlgigokadMsiamMWMtfatgaaank,NAPwLSR*39MJ ;•. _,•. _ L` ?! Wells Fargo Home Mortgage MAC W0151-053 HOME ; 210 Wildwood Parkway • Simingham.AL 35209 Tel: 877 9133376 Toll Free D. The Borrower(s) promises to pay the Unpaid Principal Balance plus interest, to the order of the Lender. Interest will be charged on the Unpaid Principal Balance of U.S. $ 103, 943 . 75 . The Borrower(s) promises to make monthly payments of principal and interest of U.S . $ 452.37, at a yearly rate of 3 . 2500, not including any escrow deposit, if applicable. If on the'maturity date the Borrowerts) still owes an amount under the Note and Security Instrument, as amended by this Agreement, Borrower(s) . will pay this amount in full on thetmaturity date. E. Borrower agrees that certain amounts owed will not be capitalized, waived, or addressed as part of this Agreement, and will remain Owed until paid. These amounts owed are referenced in the Cover Letter to this Agreement, which is incorporated herein, and are to be paid with the return of this executed Agreement. If these amounts owed are not paid with the return of this executed Agreement, then Lender may deem this Agreement void. 3 . NOTE AND SECURITY INSTRUMENT. Nothing in this Agreement shall be understood or construed to- be a satisfaction or release, in whole or in part of the Borrower's obligations under the Note or Security Instrument. Further, except as otherwise specifically provided in this Agreement, the Note and Security Instrument will remain unchanged, and Borrower and Lender will be bound by, and shall comply with, all of the terms and provisions thereof, as amended by this Agreement . 4 . The undersigned Borrower(s) acknowledge receipt and acceptance of the Loan Modification Settlement Statement. Borrower(s) agree with the information disclosed in and understand that I/we am/are responsible for payment of any outstanding- balances outlined in the Loan Modification Settlement . S . The undersigned Borrower(s) acknowledge receipt and acceptance of the Borrower Acknowledgements, *Agreements, and Disclosures Document (BRAD) . 6 . If included, the undersigned Borrower(s) acknowledge receipt and acceptance of the Truth in Lending statement. 7. If included, the undersigned Borrower(s) acknowledge receipt and acceptance of the 1-4 Family Modification Agreement Rider Assignment of Rents. 8 . If included, the undersigned Borrower(s) acknowledge receipt and acceptance of the Notice of Special Flood Hazard disclosure. LM521/XSD/Pg2 Together we'll go far wells FatgottomeMcrtg»9elsad'Nfs7onatWNls6argnBank.N.&NN15RtU39980t Wells Fargo Home Mortgage • . MACW0151-053 FH210 wildwood Parkway • • • Birmingham,AL35209 Tel: 877 913 3376 Toll Free 9. This Agreement is conditioned upon the receipt of the 1-4 Family Modification Agreement Rider Assignment of Rents, if included, specified in the attached cover letter, which is incorporated herein by reference. 10 . That (he/she/they) (is/are) the Borrower(s) on. the above-referenced Mortgage Loan serviced by wells Fargo Bank, N. A. . That (he/she/they) have experienced a financial hardship or change in financial circumstances since the origination of (his/her/their) Mortgage Loan. That (he/she/they) did not intentionally or purposefully default on the Mortgage Loan in order to obtain a loan modification. CORRECTION AGREEMENT. The undersigned borrower(s) , for and in consideration of the approval, closing and funding of this Modification, hereby grants Wells Fargo Bank, N. A. , as lender, limited power of attorney to correct and/or initial all typographical or clerical errors discovered in the Modification Agreement required to be signed. In the event this limited power of attorney is exercised, the undersigned will be notified and .receive a copy of the document executed or initialed on their behalf . This provision may not be used to modify the interest rate, modify the term, modify the outstanding principal balance or modify the undersigned' s monthly principal and interest payments as modified by this Agreement . Any of these specified changes must be executed directly by the undersigned. This limited power of attorney shall automatically terminate in 120 days from the closing date of the undersigned' s modification:-7 ,#_�,r {Borrower(s) initial) 11 . CONSENT TO DISCLOSE PERSONAL INFORMATION I consent to the disclosure of my personal information, including the terms of this modification, to any investor, owner, servicer, insurer or guarantor who owns, services, insures or guarantees my first lien account for purposes related to the second mortgage Consumer Relief Program. I also consent to- the disclosure of my personal information to any entity that performs support services for the second mortgage Consumer Relief Program, including marketing, survey, research or other borrower outreach, data processing and technical systems consulting. IN WITNESS WHEREOF, the Parties hereto have executed this Agreement as the date first above written. By signing this Agreement I hereby consent to being contacted concerning this Loan at any cellular or mobile telephone number I may have. This includes text messages and telephone calls including the use of automated dialing systems to contact my cellular or mobile telephone . You will not be billed= by your cellular or mobile carrier for any text messages you may receive from Wells Fargo, however, any caj3AAh404&19r to your cellular or mobile phone will .incur no time char es assessed by your mobile carrier. 1 Webs Fatgo Home Mortgage 1s a dwWon or Wens forgo 9aM.N•0.MMLSA tp WMI Wells Fargo Home Mortgage MAC W0151.053 HOME 210 Wildwood Parkway MORTGAGE Birminghacn,AL35209 Tei: 877 913 3376 Toll Free Dated as of this a day of 4 GIgA4 20,,,•Za f Theodore R Hamal Signature Signature I q/l3 Wells targo Hank, N. A. Name: Marie Burr Vice President Loan Documentation Its : LM527/XSD/gg4 Together we'll go far We11s Forgo Havre Mortgage Is i dMrtiat of Vt'NIS Fargo sank,h,A.r7ML5q t0 3498011 9.7*- VERIFICATION Tiffany Watkins, hereby states that he he 's Vice President Loan Documentation of WELLS FARGO BANK,N.A.,plaintiff in this matter, that h 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 of his(Oinformation 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: Tiffany atkins Title: Vice President Loan Documentation Company: Wells Fargo Bank,N.A. Date: 11/03/2014 086-PA-V2 File# 190337 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ^ 9LEU-O F CE Sheriff ,F„ THE ?ROTHONOTA5 Jody S Smith Chief Deputy Richard W Stewart Solicitor of Cntnbt•rjtryd z OFFICE OF THE $HERIFF 21'iNOV 26 MIil:22 CUMBERLAND COUNTY PENNSYLVANIA Wells Fargo Bank, N.A. vs. Theodore R Hamal (et al.) Case Number 2014-6591 SHERIFF'S RETURN OF SERVICE 11/18/2014 07:09 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 Anne Hamal, wife, who accepted as "Adult Person in Charge" for Theodore R Hamal at 97 Old State Road, Dickinson Township�eardners, PA 17324. SHALL, DEPUTY 11/18/2014 07:09 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 "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Anne M Hamal at 97 Old State Road, Dickinson Township, Gardners, PA 17324 UTSHALL, DEPUTY SHERIFF COST: $56.43 SO ANSWERS, November 19, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA, Plaintiff, vs. Theodore Hamal, a/k/a Theodore R. Hamal; Anne M. Hamal; Defendants. Mortgaged Premises: 97 Old State Road (f/k/a T-522), Gardners, PA 17324 CIVIL DIVISION No.: 14 -6591 -CIVIL ISSUE NUMBER: TYPE OF PLEADING: tin co -,(II PRAECIPE FOR ENTRY OF JUDGMENT BY ' • DEFAULT (MORTGAGE FORECLOSURE)" : FILED ON BEHALF OF: Wells Fargo Bank, NA Plaintiff COUNSEL OF RECORD FOR THIS PARTY: ZUCKER, GOLDBERG & ACKERMAN, LLC Scott A. Dietterick, Esquire- Pa. I.D. #55650 Kimberly A. Bonner, Esquire- Pa. I.D. #89705 Joel A. Ackerman, Esquire- Pa I.D. #202729 Ashleigh Levy Marin, Esquire- Pa I.D. #306799 Ralph M. Salvia, Esquire- Pa I.D. #202946 Jaime R. Ackerman, Esquire- Pa I.D. #311032 Jana Fridfinnsdottir, Esquire- Pa I.D. #315944 Brian Nicholas, Esquire- Pa I.D. #317240 Denise Carlon, Esquire- Pa I.D. #317226 Roger Fay, Esquire; PA I.D. #315987 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500 Atty File No.: XFP-190337 • silostp-P a41(j- k771ff 3/sig$ Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, LLC XFP-190337 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. Theodore Hamal, a/k/a Theodore R. Hamal; Anne M. Hamal; Defendants. NO.: 14 -6591 -CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY DEFAULT (MORTGAGE FORECLOSURE) TO: PROTHONOTARY Please enter judgment, in mortgage foreclosure (in rem only), in the above -captioned case in favor of Plaintiff and against Defendant(s), for failure to file a response to Plaintiffs Complaint within the appropriate time limits from service thereof, and assess Plaintiff's damages as set forth in Complaint: Amount as set forth in Complaint $108,068.04 plus interest on the judgment amount ($108,068.04) from November 1, 2014, at the statutory rate and for foreclosure and sale of the mortgaged premises. I hereby certify that the defendant's last known 97 Old State Road address is: Gardners, PA 17324 Dated: / a i r BY: ZUCKER, GOLBERG &.9CKERN, LLC ❑ Sco t ietterick, Esquire; PA. I.D. #55650 ❑ Kim•erly A. Bonner, Esquire; PA. I.D. #89705 ❑ Ralph M. Salvia, Esquire; PA I.D. #202946 ❑ Joel A. Ackerman, Esquire; PA I.D. #202729 ❑ Ashleigh L. Marin, Esquire; PA I.D. #306799 ❑ Jaime R. Ackerman, Esquire; PA I.D. #311032 ❑ Jana Fridfinnsdottir, Esquire; PA I.D. #315944 ❑ Denise Carlon, Esquire; PA I.D. #317226 ❑ Brian Nicholas, Esquire; PA I.D. #317240 Roger Fay, Esquire; PA I.D. #315987 .5z. Attorneys for Plaintiff XFP-190337 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com DAMAGES ARE HEREBY ASSESSED AS INDICATED DateI 14S Prothonotary Praecipe for Entry of Judgment Zucker, Goldberg & Ackerman, LLC XFP-190337 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. Theodore Hamal, a/k/a Theodore R. Hamal; Anne M. Hamal; Defendants. NO.: 14 -6591 -CIVIL AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT STATE OF NEW JERSEY SS: COUNTY OF UNION I, the undersigned attorney for the plaintiff in the above action, being duly sworn according to law, do hereby depose and say that the statements made herein are true and correct to the best of my knowledge, information, and that: 1) The Defendants Theodore Hamal, a/k/a Theodore R. Hamal, Anne M. Hamal are not in the military service of the United States of America as evidenced by the attached copies; Zucker, Goldberg & Ackerman, LLC XFP-190337 2) The Notice of Intent to take Default Judgment was mailed in accordance with Pa. R.C.P. 237.1 and that the time limits provided for that notice have expired. Dated: / Sworn to and subscribed before me This c, day of.,J/}MOit q , 20 / ZUCKER GOLBERG & ACK_ ERM�N, LLC BY: ❑ Sco ' Dietterick, Se; PA. I.D. #55650 ❑ Kim .erly A. Bonner, Esquire; PA. I.D. #89705 ❑ Ralph M. Salvia, Esquire; PA I.D. #202946 ❑ Joel A. Ackerman, Esquire; PA I.D. #202729 ❑ Ashleigh L. Marin, Esquire; PA I.D. #306799 ❑ Jaime R. Ackerman, Esquire; PA I.D. #311032 ❑ Jana Fridfinnsdottir, Esquire; PA I.D. #315944 ❑ Denise Carlon, Esquire; PA I.D. #317226 ❑ Brian Nicholas, Esquire; PA I.D. #317240 • Roger Fay, Esquire; PA I.D. #315987 Attorneys for Plaintiff XFP-190337 200 Sheffield Street, Suite 101 Mountainside, NJ 07092 (908) 233-8500; (908) 233-1390 FAX Email: Office@zuckergoldberg.com Notary Public My Commission Expires: PAUL C. NADRATOWSKI Notary Public of New Jersey ID# 2407850 My Commission Expires 4/27/2016 Zucker, Goldberg & Ackerman, LLC XFP-190337 • Department of Defense Manpower Data Center Status Report Pursuant to Servieemerbers Civil Relief Act Last Name: HAMAL First Name: ANNE Middle Name: M Active Duty Status As Of: Dec -31-2014 Results as of : Dec -31-2014 08:19:09 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - . - - No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. v�. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty' responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: T13708A5111FE10 • Department of Defense Manpower Data Center Status Report Pursuant to Servicementhers Civil Relief Act Last Name: HAMAL First Name: THEODORE Middle Name: R Active Duty Status As Of: Dec -31-2014 Results as of : Dec -31-2014 08:14:29 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No . NA This response reflects the Individuals' active duty status based on the Active Duly Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or 1-lis/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA •No, NA This response reflects whether the lndMdual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 14;14:1, 1764...„ • The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(0 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: J1W8Q7B511F6810 • Department of Defense Manpower Data Center Status Report Pursuant to Sery cemembers Civil Relief Act Last Name: HAMAL First Name: THEODORE Middle Name: Active Duty Status As Of: Dec -31-2014 Results as of : Dec -31-2014 08:13:15 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the Individuals' active duty status based on the Active Duty Status Date Da Left Active Duty Within 367 Das of Active Duly Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the Individual left active duty status within 387 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No ' NA This response reflects whether the Indtdual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Yh. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 • The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SORA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: Q120L75511F6R90 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. Theodore Hamal, a/k/a Theodore R. Hamal; Anne M. Hamal; Defendants. NO.: 14 -6591 -CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT TO: Theodore Hamal, a/k/a Theodore R. Hamal 97 Old State Road Gardners, PA 17324 [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree r Judgment was entered in the above captioned proceeding on [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $108,068.04 plus osts. r Prothonotary Zucker, Goldberg & Ackerman, LLC XFP-190337 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA CIVIL DIVISION Plaintiff, vs. Theodore Hamal, a/k/a Theodore R. Hamal; Anne M. Hamal; TO: Anne M. Hamal 97 Old State Road Gardners, PA 17324 Defendants. NO.: 14 -6591 -CIVIL NOTICE OF ORDER, DECREE OR JUDGMENT [ ] Plaintiff [V] Defendant [ ] Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding onIS 1 IS [ ] A copy of the Order or Decree is enclosed, or [V] The judgment is as follows: $108,068.04 plus costs. Zucker, Goldberg & Ackerman, LLC XFP-190337 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA vs. Plaintiff, Theodore Hamal, a/k/a Theodore R. Hamal Defendant. TO: Anne M. Hamal 97 Old State Road Gardners, PA 17324 DATE OF NOTICE: 12/17/2014 CIVIL DIVISION NO.: 14 -6591 -CIVIL IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA vs. Plaintiff, Theodore Hamal, a/k/a Theodore R. Hamal Defendant. TO: Anne M. Hamal 97 Old State Road Gardners, PA 17324 CIVIL DIVISION NO.: 14 -6591 -CIVIL AVISO IMPORTANTE FECHA DEL AVISO:12/1 7/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXLMOS DIEZ (10) DIAS DE LA FECHA DE ESTE AVISO, SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENT° INMEDIATAMENTE A SU ABOGADO. SI USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 ZUCKER GOLDBERG & ACKERMAN BY: Scott A. Dietterick Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 190337 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA vs. Plaintiff, Theodore Hamal, a/k/a Theodore R. Hamal Defendant. CIVIL DIVISION NO.: 14 -6591 -CIVIL IMPORTANT NOTICE TO: Theodore Hamal, a/k/a Theodore R. Hamal 97 Old State Road Gardners, PA 17324 DATE OF NOTICE: 12/17/2014 You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth again you. Unless you act within Ten (10) days from the date of this notice, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal Help. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Wells Fargo Bank, NA vs. Plaintiff, Theodore Hamal, a/kla Theodore R. Hamal Defendant. CIVIL DIVISION NO.: 14 -6591 -CIVIL AVISO IMPORTANTE TO: Theodore Hamal, alk/a Theodore R. Hamal 97 Old State Road Gardners, PA 17324 FECHA DEL AVISO:12/17/2014 USTED ESTA EN REBELDIA PORQUE HA FALLADO DE TOMAR LA ACCION REQUERIDA EN ESTE CASO. A MENOS QUE USTED TOME ACCION DENTRO DE LOS PROXI?'VIOS DIEZ (10) DIAS DE LA FEMA DE ESTE AVISO: SE PUEDE DICTAR UN FALLO EN CONTRA SUYA SIN LLEVARSE A CABO UNA VISTA Y USTED PUEDE PERDER SU PROPIEDAD Y OTROS DERECHOS LM' PORTAI\TTES. USTED DEBE LLEVAR ESTE DOCUMENTO INMEDIATAMENTE A SU ABOGADO. Si USTED NO TIENTE UN ABOGADO 0 NO PUEDE PAGAR UNO, VAYA 0 LLAME LA OFICINA ABAJO INDICADA PARA QUE LE INFORMEN DONDE PUEDE CONSEQUIR AYUDA LEGAL. NOTICE TO DEFEND & LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone (800) 990-9108 (717) 249-3166 ZUCKER GOLDBERG & ACKERMAN BY: Scott A. Dietterick Scott A. Dietterick, Esquire Attorneys for Plaintiff PAID. # 55650 200 Sheffield Street, Suite 301 P.O. Box 1024 Mountainside, NJ 07092-0024 (717) 533-3560 FIRST CLASS U.S. MAIL, POSTAGE PREPAID 190337 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY v\ty ul ticuub rr Wells Fargo Bank, N.A. vs. Theodore R Hamal (et al.) Case Number 2014-6591 SHERIFF'S RETURN OF SERVICE 11/18/2014 07:09 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 Anne Hamal, wife, who accepted as "Adult Person in Charge" for Theodore R Hamal at 97 Old State Road, Dickinson Township Gardners, PA 17324, SHALL, DEPUTY 11/18/2014 07:09 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 "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Anne M Hamal at 97 Old State Road, Dickinson Township, Gardners, PA 17324 'UTSHALL, DEPUTY SHERIFF COST: $56.43 SO ANSWERS, November 19, 2014 RONNY R ANDERSON, SHERIFF na C:>iu1'yEwi;a >;h:'.;:;1 7Gi;;., :pR