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HomeMy WebLinkAbout14-7029 Supreme Cquu"rpt of Pennsylvania COu rt'-Of+COM m0 TIeas For Prothonotary Use Only: Civil Uv Sheet WW:�r- Docket No: CUMB�ERRLAND� County Slll�� � a The information collected on this firm is used solelv.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 Ix Complaint 0 Writ of Summons 0 Petition 0 Transfer from Another Jurisdiction M Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T WELLS FARGO BANK, N.A. JASON L. HEATH, SR. Dollar Amount Requested: 10within arbitration limits I Are money damages requested? 9 Yes `X, No (check one) !X outside arbitration limits O N Is this a Class Action Suit? Yes El No Is this an MDJAppeal? Yes No A Name of Plaintiff/Appellant's Attorney: POWERS, KIRN &ASSOCIATES, LLC. El Check here if you have no attorney-(are a Self-Represented (I'ro Sel Litigant) Nature of the Case: Place an "X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS El Intentional El Buyer Plaintiff Administrative Agencies Q Malicious Prosecution Debt Collection: Credit Card Board of Assessment 0 Motor Vehicle Debt Collection: Other Board of Elections E] Nuisance 0 Dept.of Transportation 0 Premises Liability 0 Statutory Appeal:Other S F1 Product Liability(does not include E mass torr) El Employment Dispute: Slander/Libel/Defamation Discrimination C 0 Other: Employment Dispute:Other 0 Zoning Board T E3Other: I C,' Other: O MASS TORT f] Asbestos N E3 Tobacco 'S Toxic Tort-DES E] Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS Toxic Waste El' Ejectment 0 Common Law/Statutory Arbitration B Eminent Domain/Condemnation E] Declaratory Judgment 0 Ground Rent 0 Mandamus I© Landlord/Tenant Dispute 0 Non-Domestic Relations Q Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY El Mortgage Foreclosure: Commercial 13 Quo Warranto 0 Dental 0 Partition El Replevin 0 Legal I_ Quiet Title 0 Other: E] Medical 0 Other: E] Other Professional: Updated 1/1/2011 'POWERS KlRN &ASSOCIATES, LLC Jill Manuel-Coughlin, ��S T�� �J0. ��7�� --- `—'-- lo}uu1aPcka}:k» Esquire Id. No. 307468 Harry B. Reese, Esquire Id. No. 310501 Daniel C. Fanaselle, Esquire Id. No. 312292 Matthew J. McDonnell, Esquire Id. No. 313549 �.�,.�[��-/\��.� ��!/��Y 8 Nesharniny Interplex Suite 215 PA ]QO53 (7]5) g42-20g0 ATTORNEYS FOR PLAINTIFF Wells Fargo Bank, N.A. IN THE COURT OF COMMON PLEAS OF 3476 Sta1evicvvBoulevard Fort Mill, SC 29715 CIVIL DIVISION Plaintiff CUMBERLAND COUNTY PENNSYLVANIA vs. Jason[ Heath, Sr. 554 Shed Road Nevvvi(}c, PA 17241 No . Defendant(s) COMPLAINT IN MORTGAGE FLORECLOSURE NOTICE You have been sued inCourt. If you wish to defend against the claims set forth in the following pages,you must take action within twenty(20) days after this Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defense 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 orproperty orother rights important toyou. YOU SHOULD TAKE THIS PAPER TOYOUR LAWYER ATONCE. IF YOU DO NOT HAVE ALAWYER,GOTOORTELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. ' IF YOU CANNOT AFFORD TO HIRE ALAW/ER, TBIB OFFICE MAYBE ABLE TO PROVIDE YOOWIIB INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELD3I0LE PERSONS AT A REDUCED FEE 0R NO FEE. Cumberland County Bar Association 328. Bedford Street Carlisle, PA17013 7l7Z493166 / ' ' � |^� 800'990'9188 � �] � r� �� � ^` 062-pA-, ~ 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.0§ 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. 062-PA-v5 'POWERS KIRN &ASSOCIATES, LLC Jill Manuel-Coughlin, Esquire Id. No. 63252 Jolanta Pekalska, Esquire Id. No. 307968 Harry B. Reese, Esquire Id. No. 310501 Daniel C. Fanaselle, Esquire Id. No. 312292 Matthew J. McDonnell, Esquire Id. No. 313549 8 Neshaminy Interplex Suite 215 Trevose, PA 19053 (215) 942-2090 ATTORNEYS FOR PLAINTIFF Wells Fargo Bank,N.A. IN THE COURT OF COMMON PLEAS OF 3476 Stateview Boulevard Fort Mill, SC 29715 CIVIL DIVISION Plaintiff CUMBERLAND COUNTY PENNSYLVANIA VS. Jason L. Heath, Sr. 554 Shed Road Newville, PA 17241 No. Defendant(s) COMPLAINT IN MORTGAGE FLORECLOSURE CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE And now comes Wells Fargo Bank,N.A., by its attorneys, Powers Kirn & Associates, LLC, and files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is Wells Fargo Bank,N.A., 3476 Stateview Boulevard, Fort Mill, SC 29715, (hereinafter"Plaintiff'). 2. The Defendant(s) is, Jason L. Heath, Sr., with a last known address of 554 Shed Road,Newville, PA 17241. 3. In order to protect the borrower's privacy, certain personal information of the borrower(such as .loan account, Social Security numbers, and birth dates), may have been partially or completely redacted on the exhibits to this Complaint. 4. Wells Fargo Bank,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. 062-PA-v5 5. On or about August 15, 2011, Jason L. Heath, Sr. made, executed and delivered to Homesale Lending, LLC, a Mortgage in the original principal amount of$91,800.00 on the premises described in the legal description marked Exhibit B, attached hereto and made a part hereof. Said Mortgage being recorded on August 17, 2011 in the Office of the Recorder of Deeds in Cumberland County, in Instrument Number: 201122802. The Mortgage is a matter of public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are of public record. 6. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded October 21, 2014,the mortgage was assigned to Wells Fargo Bank,N.A. which Assignment is recorded in the Office of the Recorder of Deeds of Cumberland County in Instrument Id. No: 201423939. 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. 7. Jason L. Heath, Sr. is the record and real owner of the aforesaid mortgaged premises. 8. Defendant(s) is in default under the terms of the aforesaid Mortgage for, inter alia, failure to pay the installments of principal and interest due November 1, 2013. 9. As of 11/20/2014, the amount due and owing Plaintiff on the mortgage is as follows: Principal $88,567.70 Interest from 10/1/2013 to 11/20/2014 $4,399.40 Late Charges $192.28 Escrow Advance $3,014.62 Property Inspections $0.00 Property Preservation $0.00 BPO/Appraisals $0.00 Escrow Balance $0.00 Corporate Advance Credit $0.00 Total $96,174.00 plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file a motion in the above-captioned action to add such additional sums authorized under the Mortgage and Pennsylvania Law to the above amount due and owing when incurred. 10. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). 062-PA-v5 11. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to do so in a separate legal action if such right exists. If Defendant(s) has 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 $96,174.00, with interest thereon plus additional costs (including additional escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the mortgaged premises. POWERS KIRN &ASSOCIATES, LLC BY: �---- ❑ Jill Manuel-Coughlin, Esquire Id. No. 63252 ❑ Jolanta Pekalska, Esquire Id. No. 307968 ❑ Harry B. Reese, Esquire Id. No. 310501 ,Daniel C. Fanaselle, Esquire Id. No. 312292 ❑ Matthew J. McDonnell, Esquire Id. No. 313549 Attorneys for Plaintiff 062-PA-v5 EXHIBIT `A' . u ti i, s J 4.r aa- REDACTED NOTE NOTICE- THIS LOAN IS NOT ASSUMABLE WITHOUT. THE APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUTHORIZED AGENT. AUGUST 15, 2011 {` ftrstcl [t+nl Maki 554 SHKD ROAD, NEWVILLE, PA 17241 ` I. BORROWER'S PROMISE TO PAY !n return for a lma that have tcecivcd.I promise to pay U.S S­­910* 91;too.00 ((hit amount is called"Principal"). 'y plots infmst,tit thv order of the Leader.The Lender is arwrsrtZS= LENDING, LLC u t, will orate all Inrymeni ander this Mile in the Lund of canh,t:h=k or money ord4. I understand shat the Gender may transfer this Nott The Lender or anyone alto takes this Mote by transfer and%vino is entitled to mccnvc paymcats under this Neote is celfed the"Note Hokler.' 2:''11rEREST ` inttresl will be ehargaf onunpaid principal until she full amount of Principal has h¢cn paid,l will pay interest at a yearly ,. ritcof ****4.375 X. It the 'the inicrest rate r%xp tired by this Section 2 it the rate 1 will pay both Before and afler any default describad in Section 6(B) ofrhi%Note_ PAYMENTS p- (A)Time and Puce of Payments. I will pay principal and intcnst by making a payment every month. I will make my monthly payment on lhcFERST day of each month beginning onGCTOBER 01, 2011 I will r nrakC dusc,puvmetnts.cwryrnonttr until 1 have paid and of the principal and interest and arty othcr charges deseribcd below that 1 itaty nuY uncfeY this&I ac. Each monthly payment will he applied as of its scheduled duc date and will Ire applied to intetchl hrlbrc principal.If,on SEPTEIEBEA 01,•2641 I still owe amounts uhxlar this Note F will pay tfwsc amounts in fall on that date,which iscallld the"Maturity mie I will makcmyMonthlypaythattsatWELLS FARGO 13th MORTGAGE, P.Q. BOX 11701, ItEiIAM, NS 071014701 or at a different place if required by the Note Holder. y, (8)Amount of NI-sthly Paymenm My monthly payment will be in the amount of U.S. S ****458.30 o, d. BORROU'l:R'S RIGHT TO PREPAY_ The.Borrower shall have Iry right to prepay al any time;ivilbout premium or lec.the Claire indebtedness or any part ALTOFnot icw than the amount of one installment,or S100.00,whichever is less.Any Prepayment in full of the indettleduess r skill be crudiluxt tm the date rcccivW,ani no inhered may he charged thereafter.Any partial Prgnymerd made on other than an insraihue nt duc date ncv:d not he credited until the nerd following installment due dote or 3D days after such Prepayment, whichCver is earlier. ' MULTI6TATEFQMDRATENOTE,SaFamh/_FatnteMaefFrddd1e8acUNFORMINWRUMENT.YowansAfbtrs tr MK MD(VU" Rw 71MI I j; Form 3200 tlpt Rad -atat om Khrwer Ftetal Serrioca Ar=dad tirOG VtP"�G deer! P1.0$w3 m tt i a- aa: 1 k 6 ' , tOf. r 5- Li1&V(.31ARGF,£r 11`2 law,which applies to this loan and which wi;masimum kion c1cisges;is finally interpreted so that the interest orother lrrn charges collected or to be collected in ctuntection with this loan exceed the permitted limits there:(aI any see h Ivan clrargc :diall he nxitrced by the amount.acct--sary to r ducc the charge In thepermitted limit;and(Il)any sums•alrcady collected from me which rsomcdedpermittedlimits will be refunded to me-The Note Holder may choose to make this refund by reducinge the n Princitwl I owe under this Note or by making a direct payment to me.If a refund reduces Principal,the reduction will be treated i as a partial Prz ymcnt. n k n_ r 6. BORROWER'S FAILURE TO PAY AS REQUIRED (A)Inte Charge for OverduePaytmats �. If the Nate Holder bus riot received.the full am nant of any monthly payment by the end nr 15 ctlerafarthiys aflcr Clic eats ii is duc.I will pay a kite charge W 111t:Note Holder.The amount otthe charge will be 4.000 °Sof tasy ovrdue payment.l will pay late aha+Cc promptly but only ouee on each late payment- (BI If f dor not pay the full amount ofmch monthlypayment on the date it is due,I will be in default: ' (C)Ahdiee 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 cexkein date,the Note Holder may require me to pay immediately the fall amount of Principal which has not been,paid tin d all the iso�T4it ibal I owe to that amount.That that mast heat least.30 days after the date an which the notice is mailed rte me or dcliverctl by other means. j (0)hio Walver By Nott Hodder wEvcm if. at'a firm when I am in default,the Note Holder does riot require me to pay immediately in f tj as described .i- aline.the Ntu,:Holder will still have the right to do so if I am in default at a later time. r �e (E}f'srtucntot�krte I7oldrr'st3osts and Expenses 4 li the%'#tie Holder has required enc to pay immediately in full is described above:,.dee Note Ifoldtr will have the right to jl .• he pa nt hack by mo Gtr all of its Costs and expeasese in uirnecing this Noic to the extent int(pmhihitc d by appikahl:law.Those cspem xs include,for=%niptc,ivasomeble utwfetes T. (WIN- G OF NOTICES s j Unless applicable law requires a difreiew method,any notice[hat must be given to me under this Note will be given by ` ddiriringe it or by mailing it by first efass.mail to me at the Property Address above or at a different address if i give the Note I lalJor a notice of my different addre-m _+ Any notice that must he given to the Note Holder under this Note will he given by dclivaing.it or by waiting i1.by Gist t tam mail to the Note Itoldct at the address stated in Section 3(A)above or at a ditTerrat address if t am given a'noliccmf that diffmnt uddrteas. 0' 6LIGATIONS OF PERS NS IJWDER THIS NOTE r- If more than one person signs this Note,each person is fully and perso—migy obligated to keep all of the promises matte in { this eNote.including the promise to pay the fudl amount owed..Any person who is guarantor,surey or endorser or this Note is also okigatcd to.do these things_Any person who takes over these obligations,including the obligations of a.gua=wr,surety tt ortaxMnicr of chi.Notc,is also obligated to keep all of.the promises made in this Note.The Note.ffolder may corarce its rights troller this Note against each person individually or against all of us together.Tbis meats that any one of us may be required to Pay all of tot:amounts owed under this Note. 9. WAIVEIt4 e pts 1 and any Other person who has obligations under this Note waive the tights.of Presentment and Notice of Dishonor. "Prexnemtart•mcam;the right to require the Noic Holder to demand payment of amounts due."Notice of Dishonor"means the riot to mquitr the Note Ihdder to give notice to other persons that amounts due have not been paid ct MULnST VMP A rnFIXED RATE MOT€9ttgta tamely-FanNs MaNFrtrAnte Nae UNIEORN MSTRtgUEMT-VMeiuni Afhlrb Firm � It01 vaat2or3 Weer =s ' rP t. 'ere „ K L eF •1 A r_ r, Ilk AI,Lf)NGE TO1111S.NOTE +c If an allangu pnwoding kr payment adjustments or fnr any other soppiemental infurmation is executed by the Iiomnscr tugcilt:rwith this Noic.tla:.covvmtttd of the attongc shall be incorporated into acid shalt atuctd and supplement the covenantsof this Iv4tte as if the atlonge were a part of this Note.[Check applicable boa) LJ Graduated Payment Atlotuge ❑(hher tSperafyl ❑01her[Specify) t [L GtNM)RM SECURED NOTE This Note is a unifom instrument with limited variations in some jurisdictions.In addition to the protections given to the Note tinldcr under this Note,a Mortgage;Deed of Truss,or Security Deed(the":xcurity lastrumcnt"),dated the some date as this Note;protects the Note HuWer from possible losses which might result if I do not keep the promises which I make in this ” Ncuc.That Scturily Instrument dcscribes.lww and under what conditions I may be inquired to make immediate payment in full F ol'all anicnmts I owe utalcr this.Nute.Some of thoseconditions are described as follows: i ReguF.rlinns(38 C.F.R. Part 36)issued:under the Department of Veterans Affairs("VA')Guaranteed Loan . Authority(38 U.S.C. .wpte{37Y.and in effect oil the date of loan closing shall eovem the rights,duties and liabilities of the panics to this loan and any provisions of this Nae which arc inconsistent ntith sixb regulations are hereby amcnifed and supplamented to con farm thereto, 4 a s� u = 9i'f1TIPS:ti•11.11?IIAND(S)AND IWAL.(S)t)F THE UNDERSIGNED. JASORI (- 1} (Seal , •;.roe' .. 'BOA •Aortmicr tt1 -trurrmue� - ..• - •norm", 7 : Rec 4- (Seal) (seal) 5 -Botrmw« •ilonxer J 4' .F R r t ) laical) ^•: 43wrov r •Flouroctir j., n ' [sign Orville/vary) aWLTtSTATE FWW RATE Nt3TE u.7�e Famiy.FannioMpWrodQN mac,UNFORM MSTWJMENT:Ystentru Att int Farm 72001101 sr vMa w.SM"W) Dees.s ax V Sir. ow c R h. P�►ElJ,8 FA p F WniiO#�' ti0 , � NA UIC ar PAY TO THE ORMOF WELa 6tFMBA1�A.8H/al •Pf�lf 0012 EXHIBIT ' B ' Exhibit "A" ALL those three (3) tracts of land situate in Lower Mifflin Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: TRACT NO. 1: BEGINNING at a point on Township Road on Lot No. 11, which point is 75 feet from the comer of Lots No. 10 and 11; thence South 26-1/4 degrees East 121 feet to a point in the Township Road and Lot No. 13, now or formerly of Charles E. Ickes, et ux; thence in a southerly direction 63-1/4 degrees West 200 feet to an iron pin to-the comer of lands now or formerly of John H. Clouse and Charles E. Ickes; thence in a northerly direction 26-1/4 degrees West 121 feet to an iron pin to the comer of lands of Lot No. 11 and the said John H. Clouse and wife; thence along the remaining portion of Lot No. 11 now or formerly of Duane L. Rolar, et ux. North 63-1/4 degrees East 200 feet.to the.place of BEGINNING-.- BEING. EGINNING.-BEING Lot No. 12 and the southern 25 feet of Lot No. 11 in the Plan of Lots as laid out by John H. Clouse, dated May 14, 1964. TRACT NO. 2: BEGINNING at a point on the Township Road and Lot No. 13; thence South 26- 1/4 degrees East 30 feet to a point in the Township Road and Lot No. 14; thence in a southerly direction 63-1/4 degrees West 200 feet to an iron pin to the corner of lands now or formerly of John H. Clouse, et ux.; thence in a northerly direction 26-1/4 degrees West 30 feet to an iron pin to the comer of Lot No. 13 and lands of John H. Clouse, et ux; thence along Lot No. 13 North 63- 1/4 degrees East 200 feet to the place of BEGINNING. BEING the northern 30 feet of Lot No. 14 in the Plan of Lots laid out by John H. Clouse, dated May 14, 1964. TRACT NO. 3: BEGINNING at a point on a Township Road 335 feet from the comer of land now or formerly of Charles L. Bear, thence in a northerly direction along said Township Road 85 feet and North 26 degrees 15 minutes West to a point in the Township Road; thence in a southwesterly direction 200 feet along a line South 63 degrees 40 minutes West to an iron pin; thence southerly 85 feet and South 26 degrees 15 minutes East to an iron pin; thence 200 feet along a line North 63 degrees 40 minutes East to the place of BEGINNING. This being the same property conveyed unto Jason L. Heath, Sr. by Deed fromFederal Home Loan Mortgage Corporation by Daniel A. McGovern, by Power of Attorney recorded 1/9/09, Inst# 200900685, dated 06/20/2011 and recorded 08/17/2011 in Instrument No. 201122801, in the Office of the Register of Deeds for CUMBERLAND County, Pennsylvania. PARCEL ID: 15-04-0391-014 VERIFICATION Cheri Dunston, hereby states that hshe ' Nice President Loan Documentation of CE WELLS FARGO BANK,N.A.,plaintiff in this matter, that he she is uthorized 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 hi sormation 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: Cheri Dunston Title: Vice President Loan Documentation Company: Wells Fargo Bank, N.A. Date: 11/21/2014 086-PA-V2 FILE# 14-0428 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson 1-HED-0 Sheriff E 1� 't'f(! i'+QhiJ ti': rtF p bt I: it irJil�!y�ls_ Jody S Smith , Chief Deputy . L I li ULU 15 Hi 3: 2 G Richard W Stewart CUf 1 rt�L A,(''J COUNT';' Solicitor °''F r" f€ i w p: NNSYLVAN!A Wells Fargo Bank, N.A. vs. Jason L Heath, Sr. Case Number 2014-7029 SHERIFF'S RETURN OF SERVICE 12/05/2014 06:02 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Leslie Eby, Mother-in-law, who accepted as "Adult Person in Charge" for Jason L Heath, r. _t 554 Shed Road, Lower Mifflin Township, Newville, PA 17241. ILLIA CLINE, DEPUTY SHERIFF COST: $41.56 SO ANSWERS, I December 08, 2014 RONNY R ANDERSON, SHERIFF (c) Cou-tySuiie Shen). Teleosoft, iCC.