Loading...
HomeMy WebLinkAbout06-0174 PHELAN HALLINAN & SCHMIEG, LLP LA WRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (2 IS) 563-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, INe. 3476 STATEVIEW BLVD FORT MILL, SC 29715 ATTORNEY FOR PLAINTIFF Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. 010 - I "l'f C'~I{ YElLh-'t v. CUMBERLAND COUNTY KAREN E. GEIDEL AfKJ A KAREN E. EIDEL VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, yon must take aetion within twenty (20) days after this complaint and notice are served, by entering a written appearance personally OT by attorney and filing in writing with the conrt 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 jndgment may be entered against you by the court without further notice for any money eIaimed 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 yon. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DONOTHAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, P A 17013 (800)990-9108 File #: 126578 File #: 126578 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. I. Plaintiff is WELLS FARGO FINANCIAL PENNSYLVANIA, INC. 3476 STATEVIEW BLVD FORT MILL, SC 29715 2. The name(s) and last known address(es) of the Defendant(s) are: KAREN E. GEIDEL AlKJA KAREN E. EIDEL VIRGIL E. GEIDEL 178 RED T ANI< ROAD BOILING SPRINGS, PA 17007 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 04/25/2005 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF whieh mortgage is recorded in the Office ofthe Recorder of CUMBERLAND Connty, in Mortgage Book No: 1906, Page: 41 IS. 4. The premises subjeet to said mortgage is deseribed as attached. 5. The mortgage is in default because monthly payments of principal and interest npon said mortgage due 07/29/2005 and each month thereafter are due and unpaid, and by the terms of said mortgage, npon failure of mortgagor to make such payments after a date specified by written notiee sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 126578 6. The following amounts are dne on the mortgage: Principal Balance Interest 06/29/2005 throngh 0 I /06/2006 (Per Diem $26.73) Attorney's Fees Cumulative Late Charges 04/25/2005 to 01106/2006 Cost of Suit and Title Search Subtotal $124,176.64 5,132.16 1,250.00 0.00 $ 550.00 $ 131,108.80 Escrow Credit Defieit Subtotal 0.00 0.00 $ 0.00 TOTAL $ 131,108.80 7. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. 8. Notice oflntention to Foreclose as set forth in Aet 6 of1974, Notice of Homeowner's Emergency Assistance Program pursnant to Act 91 of 1983, as amended in 1998, and/or Notice of Defanlt as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date( s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit eounseIing agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exeeeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 13 I, I 08.80, together with interest from 0 I /06/2006 at the rate of $26.73 per diem to the date of J ndgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP <' '-~. . ~ ~, ~ By: IsIFrancis S. Hallinan LAWRENCE T. PHELAN, ES IRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 126578 LEGAL DESCRIPTION ALL the following described real estate, together with the improvements thereon ereeted, lying and being situate in South Middleton Township, Cumberland Connty, Pennsylvania, bounded and limited as follows: BEGINNING at a steel pin set on the southernmost dedicated right-of-way line of Red Tank Road, also known as Township Road T -542, said pin marking the point of joinder ofthe line which extends between Lots No. ] and 2 on the hereinafter mentioned subdivision with said dedicated right-of-way line, and said pin also being located South 84 degrees 16 minntes 50 seeonds East for a distance of 240.89 feet from a concrete monument which marks the northwesternmost corner of the parcel of which this tract was once a part; thence extending in and along the southernmost dedicated right- of-way line of Red Tank Road by an arc or enrve to the left having a radins of337.37 feet, a chord bearing of North 77 degrees 8 minutes 20 seeonds East, for an are distance of218.82 feet to a pin on the southernmost dedicated right-of-way line of Red Tank Road, at Lot No.3 on the hereinafter mentioned Plan of Lots; thenee departing from the southernmost dedicated right-of-way line and extending along Lot No.3 on the hereinafter mentioned Plan of Lots, the following two courses and distances: South 8 degrees 29 minutes 10 seconds East for a distance of29I .25 feet to a steel pin; thence continning alottg Lot No.3, Sonth 81 degrees 30 minutes 50 seconds West for a distance of 171.09 feet to a steel pin at Lot No. I on the hereinafter mentioned Plan of Lots; thence continuing and extending along Lot No.1, North 17 degrees 26 minutes IS seconds West for a distance of278.24 feet to a steel pin on the southernmost dedicated right-of-way line of Red Tank Road, said pin marking the Place of BEGINNING. CONTAINING 1.198 Aeres, and BEING designated as Lot NO.2 on a Final Plan of Minor Snbdivision prepared by Kimba, Ine., by Rodney Lee Decker & Associates, dated July 31,1979, and reeorded in the Office of the Recorder of Deeds in and for Cumberland Connty, Pennsylvania, in Plan Book 36, Page 146. HA VING thereon erected a dwelling honse known and numbered as 178 Red Tank Road, Boiling Springs, Pennsylvania 17007. BEING the same premises which were conveyed by Paul R. Young, 11, and Kim R. Young, his wife, formerly Kim R. Mixell, to Paul R. Young, 11, and Kim R. Young, his wife, by deed dated Jannary 24,1986, and reeorded January 27, 1986, in Cumberland Connty Deed book S, Vol. 3 I, Page 20. File #: 126578 . VRRTFrCATTON FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the court and or the Verification could not be obtained within the time allowed for the filing on the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c) and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. Furthermore, it is counsel's intention to substitute a verification from Plaintiff as soon as it is received by counsel . 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. -i> ) An~ FRANCIS S. HALLINAN, ESQUIRE Attorney for Plaintiff DATE: I <n-00 p ~ G p ~ tn. '- V\ C), <;\ B -0 (---, c,.' -.t: .~ - ~ -4. ~ .- ~ W C:~I ~'.'.," ~ . ~ ~ - \!\ , ~ -+- c':', -L. -' .. SHERIFF'S RETURN - REGULAR CASE NO: 2006-00174 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO FINANCIAL PENNSYLV VS GEIDEL KAREN E ET AL VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GEIDEL KAREN E AKA KAREN E EIDEL the DEFENDANT , at 1435:00 HOURS, on the 23rd day of January 2006 at 178 RED TANK ROAD BOILING SPRINGS, PA 17007 by handing to KAREN E GEIDLE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 5.28 .00 10.00 .00 33.28 r~:{~-':"":<A~-~ . , R. Thomas Kline 01/24/2006 PHELAN HALLINAN SCHMIEG Sworn and Subscribed to before By: ft?, ~---.. eputy Sh ff me this ;u.,,'5 day of /" ..loVe.. A.D. . SHERIFF'S RETURN - REGULAR CASE NO: 2006-00174 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO FINANCIAL PENNSYLV VS GEIDEL KAREN E ET AL VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GEIDEL VIRGIL E the DEFENDANT at 1435:00 HOURS, on the 23rd day of January ,2006 at 178 RED TANK ROAD BOILING SPRINGS, PA 17007 by handing to KAREN E GEIDLE, WIFE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 .?"/~'/..f';/ i% ,,~>.;,:.. R. Thomas Kline ,;/~4 ~:(:~~.r~ 01/24/2006 PHELAN HALLINAN SCHMIEG Sworn and Subscribed to before By: It I!~' L< --- Deputy ~riff me this .:J.t,'e day of A.D. PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN ST AnON 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. 3476 STATEVIEW BLVD FORT MILL, SC 29715 CUMBERLAND COUNTY COURT 0)<- COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 06-174 KAREN E. GEIDEL AlKlA KAREN E. EIDEL VIRGIL E. GEIDEL Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against KAREN E. GEIDEL AlKJA KAREN E. EIDEL and VIRGIL E. GEIDEL, Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale ofthe mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 1/7/06 to 2/28/06 TOTAL $131,108,80 $1,416.69 $132,525.49 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. ~ ~~.V\\~~.~. -, G. SCH G, ESQ . Attorney for Plaintilf DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~/JI"t. It d_a:iD PHELAN HALLINAN AND SCHMIEG By: Lawrence T. Phelan, Esq., ld. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 One Penn Center Plaza, Suite 1400 Philadelphia, P A 19103 (21,) ,Ii,-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. : COURT OF COMMON PLEAS Plaintiff : CIVIL DIVISION Vs. : CUMBERLAND COUNTY KAREN E. GEIDEL AlK!A KAREN E. EIDEL VIRGIL E. GEIDEL : NO. 06-174 Defendants TO: KAREN E. GEIDEL AlKJA KAREN E. EIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 FILE COpy DATE OF NOnCE: FRRRITARV 14, 2001i THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NonCE 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 AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A WDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIA nON 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 ~h fia)AJ FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ATTORNEY FOR PLAINTIFF ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PIDLADELPIDA, PA 19103-1814 (215) 563-7000 WELLS FARGO FINANCIAL PENNSYL VANIA, INC. CUMBERlAND COUNTY 3476 STATEVIEW BLVD COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 06-174 KAREN E. GEIDEL AlKlA KAREN E. EIDEL VIRGIL E. GEIDEL Defendant(s). VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant KAREN E. GEIDEL AlKJA KAREN E. EIDEL is over l8 years of age and resides at, 178 RED TANK ROAD, BOILING SPRINGS, PA 17007. (c) that defendant VIRGIL E. GEIDEL is over l8 years of age, and resides at, 178 RED TANK ROAD, BOILING SPRINGS, PA 17007. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. <-- '--- G -p ~ ~ ~ ~ ~ ~ ~ cr- ~ ?= G 4+ ~ :-0 \t Q l:~ ~ ?- ..t:. -=P ~-1 (-) ,':J 1,i \ -,- :: ' . . - -,---~----- (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW WELLS FARGO FINANCIAL PENNSYLVANIA, INC. 3476 STATEVIEW BLVD CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff, v. NO. 06-174 KAREN E. GEIDEL AlKlA KAREN E. EIDEL VIRGIL E. GEIDEL Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on ('t?~_1 .~ /s! /LFL }!~ If you have any questions concerning this matter, please contact: ~ 200 in. ~~! ~. ~\IIM&' L G. SCH 100, ESQUIRE. Attorney for Plaintiff / ONE PENN CENTER AT SUBURB ST nON 1617 JOHNF. KENNEDY BLVD., S 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 :: "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMA nON OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.' CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P.3180-3183 WELLS FARGO FINANCIAL PENNSYL VANIA, INC. Plaintiff, v. No. 06-174 KAREN E. GEIDEL A!KIA KAREN E. EIDEL VIRGIL E. GEIDEL Defendant(s). TO THE DIRECTOR OF THE OFFICE OF THE PROTHONOTARY: Issue writ of execution in the above matter: Amount Due $132,525.49 Interest from 2/28/06 to JUNE 7, 2006 (per diem -$21.79) $2,] 57.21 and Costs TOTAL $134,682.70 -------- ~'- - b.~~ L G. SCHM SQUIRE One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Note: Please attach description of property.No. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. r-'b $Q r-r- '""''"'" ~~ ~~ <8<8 ~~ ~~ cC ~~ ';$~ ~ '8 0 ~ ,-' It:l ~ e '"'" ~ ~~ 'i-' ~ I..< G ~ ~'?: ~ \,..)\l;l oi '" ~ \~ ~~ ;o.'p i:'';t. (\} ~~ .-l:i P I..<g, 'a ~~ ~ ~'" ou - z,~ ~~ P-< e ~~ e '0 'i-''i-' '" ~~ ~~ ~~ ~~ ~ a$ ;r ~ . ,;, ~~ ~ p. o~ o~ (\} ;7 ~t, ~~ ~ c~ ~~ r-r- V? o~ '""''"'" 1 ~o I..<~ V ~'" e.- ~'6 VA ~~ ...z, 1..<.... ~ (\} ~~ c .:6; .JO ~~ ~ \ ~ VI ~~ (\} ~l J ~~ \ . I -- ...', ~~ ~G ,-' ~ -- ,,~ ~~ .c....- _~ ~ ~ ~ ~ ~ ';:; 0 -- .. q~ ~ a- ~ :::r '" ~ - - ~ - ~ 0", t" ~'0 - ':) '0 :::r - (?- \ () I I () 0) 1t - <) e:.- o 8 (J () ~ --:. -a rl <) 0 V:l ~ ~ d 0:- '" - Vt r') ~ ~ ("I') -- ('(\ - - //--------- ~ ~ WRlT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 06-174 Civil CIVIL ACTION - LA W TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO FINANCIAL PENNSYLVANIA, INC., Plaintiff (s) From KAREN E. GEIDEL A/KIA KAREN E. EIDEL AND VIRGIL E. GEIDEL (I) You are directed 10 levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as foIlows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that heishe has been added as a garnishee and is enjoined as above stated. Amount Due $132,525.49 LL $.50 Interest FROM 2/28/06 TO 617106 (PER DIEM - $21.79) - $2,157.21 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $131.28 Plaintiff Paid Date: MARCH I, 2006 Other Costs CURTIS R. LONG (Seal) Prothonotary c- ~~~~.2 17!007/~r-- Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court iD No, 62205 ALL the following described real estate, together with the improvements thereon erected, lying and being situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a steel pin set on the southernmost dedicated right-of-way line of Red Tank Road, also known as Township Road T-542, said pin marking the point of joinder of the line which extends between Lots No. I and 2 on the hereinafter mentioned subdivision with said dedicated right-of-way line, and said pin also being located South 84 degrees 16 minutes 50 seconds East for a distance of240.89 feet from a concrete monument which marks the northwesternmost corner of the parcel of which this tract was once a part; thence extending in and along the southernmost dedicated right-of-way line of Red Tank Road by an arc or curve to the left having a radius of337.37 feet, a chord bearing of North 77 degrees 8 minutes 20 seconds East, for an arc distance of 218.82 feet to a pin on the southernmost dedicated right-of-way line of Red Tank Road, at Lot No.3 on the hereinafter mentioned Plan of Lots; thence departing from the southernmost dedicated right-of-way line and extending along Lot No.3 on the hereinafter mentioned Plan of Lots, the following two courses and distances: South 8 degrees 29 minutes 10 seconds East for a distance of29L25 feet to a steel pin; thence continuing along Lot No.3, South 81 degrees 30 minutes 50 seconds West for a distance of 171.09 feet to a steel pin at Lot No. I on the hereinafter mentioned Plan of Lots; thence continuing and extending along Lot No. I, North 17 degrees 26 minutes 15 seconds West for a distance of 278.24 feet to a steel pin on the southernmost dedicated right-of-way lin" of Red Tank Road, said pin marking the Place of BEGINNING. CONTAINING 1.198 Acres, and BEING designated as Lot No. 2 on a Final Plan of Minor Subdivision prepared by Kimba, Inc., by Rodney Lee Decker & Associates, dated July 31, 1979, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 36, Page 146. HAVING thereon erected a dwelling house known and numbered as 178 Red Tank Road, Boling Springs, Pennsylvania 17007. BEING the same premises which were conveyed by Paul R. Young, II, and Kim R Young, his wife, formerly Kim R. Mixell, to Paul R. Young, II, and Kim R. Young, his wife, by deed dated January 24, 1986, and recorded January 27,1986, in Cumberland County Deed book S, Vol. 31, Page 20. Being Parcel # 40-12-0342-033B RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Virgil E Geidel and Karen E. Geidel, his wife, by Deed from Paul R. Young, II and Kim R. Young, his wife, dated 1-26-87, recorded 1-30-87 in Deed Book L-32, page 941. PRIOR DEED INFORMATION TITLE TO SAID PREMISES IS VESTED IN Paul R. Young, II and Kim R. Young, his wife, by Deed from Paul R. Young, II and Kim R. Young, his wife, formerly known as Kim R. Mixdl, dated 1-24-86, recorded 1-27-86 in Deed Book S-31, page 20. Premises: 178 Red Tank Road, Boiling Springs, P A 17007 PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 ATTORNEY FOR PLAINTIFF WELLS FARGO FINANCIAL PENNSYL VANIA, INC. CUMBERI,AND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION KAREN E. GEIDEL AlKlA KAREN E. EIDEL VIRGIL E. GEIDEL NO. 06-174 Defendant(s). CERTIFICATION DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that the premises are not subj ect to the provisions of Act 91 because it is: o an FHA mortgage () non-owner occupied () vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ------ -- ~, ,~~. SCH Attorney for Plaintiff ";1 J WELLS FARGO FINANCIAL PENNSYLVANIA, INC. CUMBERLAND COUNTY Plaintiff, COURT OF COMMON PLEAS v. CIVIL DIVISION KAREN E. GEIDEL AlKlA KAREN E. EIDEL VIRGIL E. GEIDEL NO. 06-174 Defendant(s). AFFIDA VIr PURSUANT TO RULE 3129 (Affidavit No. I) WELLS FARGO FINANCIAL PENNSYL VANIA, INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at ,178 RED TANK ROAD, BOILING SPRINGS, PA 17007. 1. Name and address ofOwner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) KAREN E. GEIDEL AlKJA KAREN E. EIDEL 178 RED TANK ROAD BOILING SPRINGS, P A 17007 VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) THE GAGE COMPANY C/O ROBERT KODAC 407 N. FRONT STREET P.O. BOX 11848 HARRISBURG, PA 17108 J. 4. Name and address of last recorded holder of every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address carmot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address carmot be reasonably ascertained, please indicate) Tenant/Occupant 178 RED TANK ROAD BOILING SPRINGS, PA 17007 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, PA 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties ofl8 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Februarv 28,2006 DATE ~ ~~) ~JrhY'^~ ~V\,/\J _ ~~\1 . '-. ~N L G. SCH G, ESQUIRE , Attorney for Plaintiff \. ... " .- WELLS FARGO FINANCIAL PENNSYL VANIA, INC. CUMBERLAND COUNTY Plaintiff, No. 06-174 v. KAREN E. GEIDEL A/KIA KAREN E. EIDEL VIRGIL E. GEIDEL Defendant(s). February 28, 2006 TO: KAREN E. GEIDEL A/KJA KAREN E. EIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THA T PURPOSE IF YOU HA VE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY" Your house (real estate) at .178 RED TANK ROAD. BOILING SPRINGS. PA 17007. is scheduled to be sold at the Sheriff's Sale on JUNE 7.2006 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A l70 l3, to enforce the court judgment of $132,525.49 obtained by WELLS FARGO FINANCIAL PENNSYL VANIA. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAYBE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: , 1. The sale will be cancellM if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. I. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only ifthe buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as ifthe sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share ofthe money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the distribution is filed. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE t I ALL the following described real estate, together with the improvements thereon erected, lying and being situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a steel pin set on the southernmost dedieated right-of-way line of Red Tank Road, also known as Township Road T -542, said pin marking the point of joinder of the line which extends between Lots No. I and 2 on the hereinafter mentioned subdivision with said dedicated right.-of-way line, and said pin also being located South 84 degrees 16 minutes 50 seconds East for a distance of240.89 feet from a concrete monument which marks the northwesternmost comer of the parcel of which this tract was once a part; thence extending in and along the southernmost dedicated right-of-way line of Red Tank Road by an arc or curve to the left having a radius of337.37 feet, a chord bearing of North 77 degrees 8 minutes 20 seconds East, for an arc distance of 218.82 feet to a pin on the southernmost dedicated right-of-way line of Red Tank Road, at Lot No.3 on the hereinafter mentioned Plan of Lots; thence departing from the southernmost dedicated right-of-way line and extending along Lot No.3 on the hereinafter mentioned Plan of Lots, the following two courses and distances: South 8 degrees 29 minutes 10 seconds East for a distance of291.25 feet to a steel pin; thence continuing along Lot No.3, South 81 degrees 30 minutes 50 seconds West for a distance of 171.09 feet to a steel pin at Lot No.1 on the hereinafter mentioned Plan of Lots; thence continuing and extending along Lot No. I, North 17 degrees 26 minutes 15 seconds West for a distance of278.24 feet to a steel pin on the southernmost dedicated right-of-way line of Red Tank Road, said pin marking the Place of BEGINNING. CONTAINING LI98 Acres, and BEING designated as Lot No.2 on a Final Plan of Minor Subdivision prepared by Kimba, Inc., by Rodney Lee Decker & Associates, dated July 31, 1979, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 36, Page 146. HAVING thereon erected a dwelling house known and numbered as 178 Red Tank Road, Boling Springs, Pennsylvania 17007. BEING the same premises which were conveyed by Paul R. Young, II, and Kim R. Young, his wife, formerly Kim R. Mixell, to Paul R. Young, II, and Kim R. Young, his wife, by deed dated January 24, 1986, and recorded January 27,1986, in Cumberland County Deed book S, VoL 31, Page 20. Being Parcel # 40-12-0342-033B RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Virgil E. Geidel and Karen E. Geidel, his wife, by Deed from Paul R. Young, II and KimR. Young, his wife, dated 1-26-87, recorded 1-30-87 in Deed Book L-32, page 941. PRIOR DEED INFORMATION TITLE TO SAID PREMISES IS VESTED IN Paul R. Young, II and Kim R. Young, his wife, by Deed from Paul R. Young, II and Kim R. Young, his wife, fOnDerly known as Kim R. Mixell, dated 1-24-86, recorded 1-27-86 in Deed Book S-31, page 20. Premises: 178 Red Tank Road, Boiling Springs, P A 17007 <--) '1-: - --- AFFIDAVIT OF SERVICE PLAINTIFF WELLS FARGO FINANCIAL PENNSYLVANIA, INC. CUMBERLAND COUNTY KIO No. 06-174 DEFENDANT(S) EIDEL KAREN E. GEIDEL AlK/A KAREN E. ACCT. #1180004452 VIRGIL E. GEIDEL Type of Action - Notice of Sheriffs Sale SERVE KAREN E. GEIDEL AlK/A KAREN E. EIDEL AT 178 RED TANK ROAD BOILING SPRINGS, PA 17007 Sale Date: JUNE 7, 2006 Served and made known to f< Cpr! t\ (:') L ,'J<) at S./J . o'c1ockL-m, at 17fr.e...J /c;"k SERVED . Defendant, on the ~ f)., 1",,1 ,G)",II'~J s,P('<\j' ?A dayof M~n~ .200L; I, 0 () 7 . Conunonwealtb of Pennsylvania, in the manner described below: __Y_Defendant personally served. Adult family member with wbom Defendant(s) reside(s). Name and Relationship is Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place oflodging in which Defendant(s) reside(s). Agent or person in charge of Defendant(s)'s office or usual place of bus mess. an officer of said Defendant(s)'s company. Other: Description: Age {S't(,- Height 5- 'Y' Weight.LdL- Race --0!.... Sex ---E- Other I, , j" {'. '^ E: II.' r , a competent adult, being duly sworn according to law, depose and state that I personally banded a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. \ ~ BY:~~'h~ CUe, AS 'i~~MfCT SERVICE AT LEAjiT 3 TIMES. INDICATE DATES & TIMES OF SERVICE ATTEMPTED. State of New Jersey PATRICIA E. HARRIS NOT SERVED Onr.oemmission EXP~eySoJune 16. 2008 .lli aa t . 200~ at o'clock _.m, Defendant NOT FOUND because: Moved Unknown No Answer Vacant 1st Attempt: 1 / Time: 2,d Attempt: I I Time: 3rd Attempt: I 1 Time: Sworn to and subscribed before me this _ day of .200_. Notary: By: Attornev for Plaintiff Daniel G. Schmieg, Esquire - LD. No. 62205 -z.- \ C) r<' C:;J C) C~ ,_.:,' 'T, ~~: :;.:) 1"'.) W ~,._~ 1') ..,,- t,.;, , AFFIDAVIT OF SERVICE CUMBERLAND COUNTY PLAINTIFF WELLS FARGO FINANCIAL PENNSYLVANIA, INC. KIO No. 06-174 DEFENDANT(S) EIDEL KAREN E. GEIDEL AIKJ A KAREN E. ACCT. #1180004452 VIRGIL E. GEIDEL Type of Action - Notice of Sheriff's Sale SERVE VIRGIL E. GEIDEL AT 178 RED TANK ROAD BOILING SPRINGS, PA 17007 Sale Date: JUNE 7, 2006 SERVED Served and made known to V,' v j ; I C'." i' ,'J < \ ,200fg,at ::;" /1 ,o'clock.l.m,at ,79' ,z...A -r;:,~k , Defendant, on the '? +- f" ,). 3"'(:"Ij S,pr,nj3 fA dayof i\lvch IlOOi , Couunonweahh of Pennsylvania, in the manner described below: Defendant personally served, . ) .X Adult family member with whom Defendant(s) reside(s). Name and Relationship is ( .J..f'! Adult in charge ofDefendant(s)'s residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant( s) reside( s). Agent or person in charge ofDefendant(s)'s office or usual place of bus mess. an officer of said Defendant(s)'s company. Other: Description: Age~ HeightCL... Weight /.JC Race--'='-Sex~ Other I, {, < /~ Fit. 'J . a competent adult, being duly sworn according to law, depose and state that! personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated aoove. NOT SERVED On the day of . 200~ at o'clock _.m, Defendant NOT FOUND because: Moved ~ Unknown _ No Answer Vacant 1" Attempt: 2Dd Attempt: 1 I Time: I / Time: 3rd Attempt: I 1 Time: Sworn to and subscribed before me this _ day of___.~ 200_. Notary: By: t Attornev for Plaintiff Daniel G~ Schmieg, Esquire I.D. No. 62205 \ ,...~ ,-) <"3 ~"rl (:J'"' - ~::::,',. :.-0 f".,) 'w T;;~ (..~ Wells Fargo Financial Pennsylvania, Inc. VS Karen E. Geidel alk/a Karen E Eidel And Virgil E. Geidel The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-174 Civil Kenneth E Gossert, Deputy Sheriff, who being duly sworn according to law, states that on March 09,2006 at 4:05 o'clock PM, he served a true copy of the within Real Estate Writ, Notice of Sheriffs Sale and Description, in the above entitled action, upon the within named defendants, to wit: Karen E. Geidel and Virgil E. Geidel, by making known unto Virgil Geidel, personally and husband of Karen Geidel, at 178 Red Tank Road, Boiling Springs, Cumberland County, Pennsylvania, its contents and at the same handing him the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 06, 2006 at 6:45 o'clock P.M., he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of Karen E. Geidel a/k/a Karen E. Eidel and Virgil E. Geidel located at 178 Red Tank Road, Boiling Springs, Pennsylvania, according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice ofthe pendency of the action to the within named defendants, to wit: Karen E. Geidel alk/a Karen E. Eidel and Virgil E. Geidel by regular mail to their last known address of 178 Red Tank Road, Boiling Springs, PA 17007. These letters were mailed under the date of April 06, 2006 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff who being duly sworn according to law, states this writ is returned stayed per instructions from attorney Daniel Schmieg. Sheriffs costs: Docketing Poundage Posting Bills Advertising Law Library Prothonotary Mileage Certified mail Levy Surcharge Law Journal Patriot News Share of Bills Total: 30.00 24.13 15.00 15.00 .50 1.00 12.32 4.88 15.00 30.00 653.00 410.00 19.57 1230.40 v' ~ ~/tJ5/b {. if> \, lJl.I&'7 (.:Je... 5" C\Lj.( (6.v. i '1 q So Answers: :(~:e~ ~,~t~ WELLS FARGO FINANCIAL PENNSYLVANIA, . INC. v CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, v. CIVIL DIVISION KAREN E. GEIDEL A/KJA KAREN E. EIDEL VIRGIL E. GEIDEL NO. 06-174 Defendant(s). AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) WELLS FARGO FINANCIAL PENNSYL VANIA. INC., Plaintiff in the above action, by its attorney, DANIEL G. SCHMIEG, ESQUIRE, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property located at .178 RED TANK ROAD. BOILING SPRINGS. PA 17007. 1. Name and address of Owner(s) or reputed Owner(s): Name Last Known Address (if address cannot be reasonably ascertained, please indicate) KAREN E. GEIDEL A/KJA KAREN E. EIDEL 178 RED TANK ROAD BOILING SPRINGS, P A 17007 VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 2. Name and address ofDefendant(s) in the judgment: Same as above 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) THE GAGE COMPANY C/O ROBERT KODAC 407 N. FRONT STREET P.O. BOX 11848 HARRISBURG, PA 17108 4. Name and address of last recorded holder,')f every mortgage of record: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 5. Name and address of every other person who has any record lien on the property: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Last Known Address (if address cannot be reasonably ascertained, please indicate) None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Last Known Address (if address cannot be reasonably ascertained, please indicate) Tenant/Occupant 178 RED TANK ROAD BOILING SPRINGS, PA 17007 Domestic Relations of Cumberland County 13 North Hanover Street Carlisle, P A 17013 Commonwealth of Pennsylvania Department of Welfare PO Box 2675 Harrisburg, P A 17105 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. February 28. 2006 DATE ==~s~~~ Attorney for Plaintiff JIRE \j , WELLS FARGO FINANCIAL PENNSYLVANIA, INC. CUMBERLAND COUNTY Plaintiff, No. 06-174 v. KAREN E. GEIDEL AIKIA KAREN E. EIDEL VIRGIL E. GEIDEL Defendant(s). February 28, 2006 TO: KAREN E. GEIDEL AIKIA KAREN E. EIDEL 178 RED TANK ROAD BOILING SPRINGS, P A 17007 VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, P A 17007 nTHIS FIRM IS A DEBT COLLECTOR AITEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN AITEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at .178 RED TANK ROAD. BOILING SPRINGS. PA 17007. is scheduled to be sold at the Sheriffs Sale on JUNE 7.2006 at 10:00 a.m. in the Cumberland County Courthouse, South Hanover Street, Carlisle, P A 17013, to enforce the court judgment of $132.525.49 obtained by WELLS FARGO FINANCIAL PENNSYLVANIA. INC. (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P., Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT TIllS SHERIFF'S SALE To prevent this Sheriffs Sale, you must take immediate action: 1. The sale will be cancelled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: (215) 563-7000. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. )' , You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU BA VE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling (215) 563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call (717) 240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriffwithin 30 days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriffwithin ten (10) days after the distribution is filed. 7 . You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE TmS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT BA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CUMBERLAND COUNTY COURTHOUSE . , ALL the following described real estate, together with the improvements thereon erected, lying and being situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a steel pin set on the southernmost dedieated right-of-way line of Red Tank Road, also known as Township Road T -542, said pin marking the point of joinder of the line which extends between Lots No. 1 and 2 on the hereinafter mentioned subdivision with said dedicated right-of-way line, and said pin also being located South 84 degrees 16 minutes 50 seconds East for a distance of240.89 feet from a concrete monument which marks the northwestemmost comer of the parcel of which this tract was once a part; thence extending in and along the southernmost dedicated right-of-way line of Red Tank Road by an arc or curve to the left having a radius of337.37 feet, a chord bearing of North 77 degrees 8 minutes 20 seconds East, for an arc distance of218.82 feet to a pin on the southernmost dedicated right-of-way line of Red Tank Road, at Lot No.3 on the hereinafter mentioned Plan of Lots; thence departing from the southernmost dedicated right-of-way line and extending ~ong Lot No.3 on the hereinafter mentioned Plan of Lots, the following two courses and distances: South 8 degrees 29 minutes 10 seconds East for a distance of 291.25 feet to a steel pin; thence continuing along Lot No.3, South 81 degrees 30 minutes 50 seconds West for a distance of 171.09 feet to a steel pin at Lot No. 1 on the hereinafter mentioned Plan of Lots; thence continuing and extending along Lot No.1, North 17 degrees 26 minutes 15 seconds West for a distance of 278.24 feet to a steel pin on the southernmost dedicated right-of-way line of Red Tank Road, said pin marking the Place of BEGINNING. CONTAINING 1.198 Acres, and BEING designated as Lot No.2 on a Final Plan of Minor Subdivision prepared by Kimba, Inc., by Rodney Lee Decker & Associates, dated July 31, 1979, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 36, Page 146. HAVING thereon erected a dwelling house known and numbered as 178 Red Tank Road, Boling Springs, Pennsylvania 17007. BEING the same premises which were conveyed by Paul R Young, IT, and Kim R Young, his wife, fonnerly Kim R Mixell, to Paul R Young, IT, and Kim R Young, his wife, by deed dated January 24, 1986, and recorded January 27, 1986, in Cumberland County Deed book S, Vol. 31, Page 20. Being Parcel # 40-12-0342-033B RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN Virgil E. Geidel and Karen E. Geidel, his wife, by Deed from Paul R Young, IT and KimR Young, his wife, dated 1-26-87, recorded 1-30-87 in Deed Book L-32, page 941. 'NORDEED INFORMATION TITLE TO SAID PREMISES IS VESTED IN Paul R yoouilg, IT and Kim R Young, his wife, by Deed from Paul R Young, IT and Kim R Young, his wife, formerly known as Kim R Mixell, dated 1-24-86, recorded 1-27-86 in Deed Book S-31, page 20. Premises: 178 Red Tank Road, Boiling Springs, P A 17007 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-174 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO FINANCIAL PENNSYLVANIA, INC., Plaintiff (s) From KAREN E. GEIDEL A/K1A KAREN E. EIDEL AND VIRGIL E. GEIDEL (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) Ifproperty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify himlher that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $132,525.49 1.1. $.50 Interest FROM 2/28/06 TO 6/7/06 (PER DIEM - $21.79) - $2,157.21 AND COSTS Atty's Comm % Due Prothy $1.00 Atty Paid $131.28 Other Costs Plaintiff Paid Date: MARCH 1,2006 CURTIS R. LONG (Seal) Prothonotary ,--By ~Ch-<.J} .7fOZ/YLJ Deputy REQUESTING PARTY: Name DANIEL G. SCHMIEG, ESQUIRE Address: ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103-1814 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 62205 Real Estate Sale # 75 On March 06, 2006 the Sheriff levied upon the defendant's interest in the real property situated in South Middleton Township, Cumberland County, PA Known and numbered as 178 Red Tank Road, Boiling Springs, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 06, 2006 By: ~~~~t ~ eB ~ ~ (u:!J I f) :01 "V Z - HVH qaal 'd ' v~~~.~iU~UiH'f~~o' jj1/~~BJ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16,1929), P. L.1784 COMMONWEAL TH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, VIZ: April 7,14,21,2006 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. --' o AND SUBSCRIBED before me this day of April. 2006 NOT AAI L SEAL LOIS E. SNYDER, Notary Public Carlisle Boro, Cumberland County My Commission Expires March 5. 2009 REAL ESTATE SALE NO. 75 Writ No. 2006-174 Civil Wells Fargo Financial Pennsylvania, Inc. vs. Karen E. Geidel a/k/ a Karen E. Eidel and Virgil E. Geidel Atty.: Daniel Schmieg ALL the following described real estate, together with the improve- ments thereon erected, lying and being situate In South Middleton Township, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING at a steel pin set on the southernmost dedicated right- of-way line of Red Tank Road, also known as Township Road T-542, said pin marking the point of joIn- der of the line which extends be- tween Lots No. 1 and 2 on the hereinafter mentioned subdivision with said dedicated right-of-way line and said pin also being located Sou'th 84 degrees 16 minutes 50 seconds East for a distance of 240.89 feet from a concrete monu- ment which marks the northwest- ernmost corner of the parcel of which this tract was once a part; thence extending in and along the southernmost dedicated right-of- way line of Red Tank Roa,d by an arc or curve to the left havmg a ra- dius of 337.37 feet, a chord bear- ing of North 77 degrees 8 minutes 20 seconds East, for an arc distance of 218.82 feet to a pin on the south- ernmost dedicated right-of-way line of Red Tank Road, at Lot No. 3 on the hereinafter mentioned Plan of Lots; thence departing from the southernmost dedicated right-of- way line and extending along Lot No. 3 on the hereinafter mentioned Plan of Lots, the following two courses and distances: South 8 degrees 29 minutes 10 seconds East for a dIs- tance of 291.25 feet to a steel pin; thence continuing along Lot No.3, South 81 degrees 30 minutes 50 seconds West for a distance of 171.09 feet to a steel pin at Lot No. 1 on the hereinafter mentioned Plan of Lots; thence continuing and ex- tending along Lot No.1, North 17 degrees 26 minutes 15 seconds West for a distance of 278.24 feet to a steel pin on the southernmost dedicated right-of-way line of Red Tank Road, said pin marking the Place of BEGINNING. CONTAINING 1.198 Acres, and BEING designated as Lot No: 2.on a Final Plan of Minor SubdIviSiOn prepared by Kimba, Inc., by Rodney Lee Decker & Associates, dated July 31, 1979, and recorded in the Of- fice of the Recorder of Deeds in and for Cumberland County, Pennsylva- nia, In Plan Book 36, Page 146. HAVING thereon erected a dwelling house known and numbered as 178 Red Tank Road, Boling Springs, PennsylvanIa 17007. BEING the same premIses which were cOnveyed by Paul R. Young. II, and Kim R. Young, his wife, for- merly Kim R. Mixell, to Paul R. Young, II, and Kim R. Young, hIs wIfe, by deed dated January 24, 1986, and recorded January 27, 1986, in Cumberland County Deed book S, Vol. 31, Page 20. Being Parcel # 40-12-0342-033B RECORD OWNER TITLE TO SAID PREMISES IS VESTED IN VIrgil E. Geidel and Karen E. Geidel, his wife, by Deed from Paul R. Young, II and Kim R. Young, his wife, dated 1-26-87, re- corded 1-30-87 in Deed Book L-32, page 941. PRIOR DEED INFORMATION TITLE TO SAID PREMISES IS VESTED IN Paul R. Young, II and Kim R. Young, his wife, by Deed from Paul R. Young, II and Kim R. Young, his wife. formerly known as Kim R. MixeII, dated 1-24-86, re- corded 1-27-86 in Deed Book S-31, page 20. Premises: 178 Red Tank Road, Boiling Springs, PA 17007. -"..;--~,,>--_...__o<> . . ",. THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot- News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever smce; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared in the 19th and 26th day(s) of April and the 3rd day(s) of May 2006. That neither he nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY S ALE #75 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, PA. 17013 REAL wr.la SALE.... 7S ....... ...,......-- W.,FarIIP P1nMcI8I . . ~,tnc. VB' Karen E. o.kIeI aIkIa,~ E. :=-== DESCRIP110N AlL tile following described real estate, togeda with tile improvemeBtS dleRoo crectrd, lyiDg aIIlI bciDg sitDaIe. in Soulh Middleton Thwafihip,' CoiDlJedlmd Coooty, PamsyIvaDia, bounded aIIlIlimite4 as follows: BBGOOlJNG at a steel pin set 0Ji tile ~ ~ ript-of..way tiDe Ii Red 1'aJlk Road, aJso );Down as lbWlllbip Rllad T-S42, said . 'lJlIIkjug . point of joiOar.r of ddne J~ betmB, Lots No.1 _ 2 011 !be ~ ~,SQbdMsionWilhsaid ~, _,_~pin also ''c " ....16.....50 ..."'Z40...~ a '. '- .' ....' '" "I 'i' ,it '!'f, a '~77deglm8' 2O~ i .. distance of 2~eet toa pin tij. ; Soulhemmost dedicated ~-of-way Iiue ct. Tant Road, at Lot No: 3 on !be hereinafter ~ PIaD of Lots; 1heil:e departing froo1 tbe Soulhemmost dedicated right-of.way line aIIlI eI.teIIl!iDg aiOllg Lot No. r 011 !be hereiJIaftel IIleIltiooaI PIaD of Lots, !be following two oourses ani! ~; -Sooth ,8 degrees 29 miDnti:s 10 litCOOds East fir a distance of 291.25 feet to a steel pin; thence contiDuing aIoog Lot No.3, SilUlh 81 degrees 30 IIIim11es SO secoods West fir a distance elf 171.1)9 feet to a steel pin at Lot No.1 011 tbe ~ IIII9IIiooed plan Ii Lots; tbence COIIlimIilIg llIIII exreading aloog Lot No.1, Nmh 17 degrees 26 minutes 15 seconds West f~ a distaoceol 27824 feet m., a steel pin 00 !be Soulhemmost dedicate4 ~.way tiDe of Red Tank Rood, said pin matting.!be place of BEGINNJNG. CONTAINING 1.198 ~, and BEING desigutlld IS Lot No. 2 011 a Filial PIaD of Minor SubcIivisilm }Il.1lIIelIld by Kimba, Inc., by Roduey lee Decker &;~,dlfedJuly 31, 1979,8Dd recmIed in !be Office of tbe RecooIet of Deeds in 8Dd 1'<< CuIDbedaIld CowIty, Peousylvania, in Plan Boci: 36 ,Page 146. HAVJNG tImoo erected' a dwelliDg house kDown,8Dd IIlIJIIbered as 178 Red Tank Road, ",__,~ania 17007; ~'dle II\IlC premises which were COI.I\'ll)'Cld by Paul It YOlIIIg, n, 8Dd Kim R. ~l!i$~, f!lmafy,1jm R. Mixell, to Paul 1.~.n,~KimR. YOIIIIg.his wife. by deed 4Ii!!l.....,. 24.I986.8Dd recmledJl\1DIIIIY 27, 1986, in CUmIlcIIaDll'CouIIty DeIld boot S. 'M. 3J,Page20. ~, ',' ,."."ARCFJ... ' .,,#40-12-034, z.o~3P 'fi'ft.,Bro ~.PREMt5ES is ~ m VilP E. ~ IIIldKanm.E. ~,his 1rik. by DeIld , flwD" Paull. YOIIIIg, Ii.. Kim R,'YOUIJI. his wife, ~,lI26lr1, recmIed 1/30N7 in Deed. ~lr32.Ne941. ' l'IQllUD~' , ' ~ TO SAJJ).~is vesttld in Paul I., n~KiIalIt.YOllIltI,his wife,byDelld R..~ n _Jinlll. YOIIIIg, his , . ",as~R.;~.~ 1/ 24116, ~ rJt1Itj ill Deed. Bclci: 5-31. p.ge 20. ' PltEMJSES: 178 Red 'Iaat Road, BoiIiag SpriIgs;PA 17007 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 Attorney For Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, I : ( Court of Common Pleas INC. Plaintiff vs KAREN E. GEIDEL A/K/A KAREN E. EIDEL VIRGIL E. GEIDEL Defendant : I Civil Division : CUMBERLAND County : I No. 06-174 TO THE PROTHONOTARY: PRAECIPE Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. Please mark the above referenced case Settled, Discontinued and Ended. X Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. Please mark the in rem judgment Satisfied and the action Date: PHELAN LIN & SCHMIEG, LLP B r*tiD -y Lawrence T. Phelan, Esq. P` sq., Id. No. 62695 r Daniel G. Schmieg, Esq., Id. No. 62205 ?? tip pC7 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Cl) p'?1 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 { Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 a(y Courtenay R. Dunn, Esq., Id. No. 206779 ?' vd P Andrew C. Bramblett, Esq., Id. No. 208375 J??6ay/ --IATison F. Wells, Esq., Id. No. 309519 CAL William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 PHS# 126578 Attorneys for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station ATTORNEY FOR PLAINTIFF 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 WELLS FARGO FINANCIAL PENNSYLVANIA, INC. Court of Common Pleas Plaintiff vs Civil Division CUMBERLAND County KAREN E. GEIDEL AWA KAREN E. EIDEL No. 06-174 VIRGIL E. GEIDEL Defendant CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiff s Praecipe was served by regular mail to the person(s) on the date listed below: KAREN E. GEIDEL A/K/A KAREN E. EIDEL VIRGIL E. GEIDEL 178 RED TANK ROAD BOILING SPRINGS, PA 17007 Date: Lawrenci T. Phelan, E No. 32227 Francis S. Hallin sq., Id. No. 62695 "Ha?iefi 6 -6c ieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Apdre* C. Bramblett, Esq., Id. No. 208375 llison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 308912 Attorney for Plaintiff