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HomeMy WebLinkAbout06-0758 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL Division Case Number: 0(.. - '7st VS Type of Pleading JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANT Complaint in Mortgage Foreclosure Code and Classification: CERTIFICATE OF LOCATION Filed on Behalf Of: Plaintiff 93 PARSONAGE STREET NEWVILLE, PA 17241 Counsel of Record: BOROUGH OF NEWVILLE Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 ~ y: DANIEL J. MANCINI, ESQ. PA LD. No. 39353 PARCEL No: 27-20-1754-016D C!.,'u~L~E'R..h1 G Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar LD: 39353 20 I A Fairview Drive Monaca, PA J 5061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LA W CASE NO VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE THIS FIRM IS A DEBT COLLECTOR ATTEMPTING 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 CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days aller 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 ajudgment may be entered against you by the court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE A LA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Services, 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LA W CASE NO VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS IF THIS IS THE FIRST NOTICE TIIA T YOU IIA VE RECEIVED FROM TillS OFFICE. BE ADVISED TIIA T: PURSUANT TO TilE FAIR DEBT COLLECTION PRACTICES ACT, IS U.S.c. * 1692 ET SEQ. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF TilE 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 AN D 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 DfFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTI 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) DA YS 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 - TIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOU CONSUL AN ATTORNEY FOR ADV1CE CONCERNING YOUR RIGHTS AND OBLlG TIONS IN TH ' SUIT. Daniel J. Mancini, Esq. Daniel Mancini & Associates Daniel J. Mancini, Esq., P A Bar fD: 39353 20 I A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancini lawfirm(@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LA W CASE NO 01- - 7 Sf Q,'oL'TE/LWl VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS COMPLAINT IN MORTGAGE FORECLOSURE I. Plaintiff is: WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE, whose address is c/o Mancini & Associates, 201 A Fairview Drive, Monaca, P A 15061. 2. Defendants are JEFF J. SALISBURY and ELIZABETH A. GARVIN, whose last known address is 93 PARSONAGE STREET, NEWVILLE, PA 17241. JEFF J. SALISBURY and ELIZABETH A. GARVIN are the mortgagors and the recorded owner of the mortgaged property hereinafter described. 3. On or about, April 29, 2005, JEFF 1. SALISBURY and ELIZABETH A. GARVIN executed and delivered a mortgage upon the premises hereinafter described to MERS AS NOMINEE FOR DECISION ONE MORTGAGE CO. LLC, which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County in Mortgage Record Book 1905, Page 1897. This mortgage is incorporated herein by reference in accordance with Pa. R.C.P. 1019 (g).Yourplaintiff, WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE is now the current owner of said mortgage, and the assignment evidencing this ownership will be sent for recording at a later date. 4. The land subject to the Mortgage is 93 PARSONAGE STREET, NEWVILLE, PA 17241, and is more particularly described in Exhibit "A", which is attached hereof and part of this Complaint. 5, The Mortgage is in default because monthly payments of principal and interest upon said mortgage due September 1,2005, and each month thereafter are due and unpaid, and by the terms of said Mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. Unpaid Principal Balance $ 93,162.18 Delinquent Balance, including Interest at $16.50 per diem From 09/01105 to 02/02/06 (based on contract rate of 6.465 %) $ 2,915.42 Rec. Corp, Adv. Total $ 000.00 $ 000,00 $ 147.25 $ 000.00 $ 0.00 $ 0.00 $ 0.00 $ 25.00 $ 151.68 $ 500.00 $ 4.658.11 $ 101,559.64 Escrow Advance Accrued Late Charges Suspense Inspection Fees Recording Fees L/C Amt Bad CK Fees Other Fees Cost of Suit and Title Search Attorney's Fee ** Together with interest at the per diem rate noted above after September 1,2005 and other charges and costs to date of Sheriffs Sale. The Attorney's Fees set forth above are in conformity with the Mortgage documents and Pennsylvania law, and will be collected in the event ofa third party purchaser at Sheriffs Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable, or that are actually incurred by Plaintiff. 6. No judgment has been entered upon said Mortgage in any jurisdiction. 7. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 or 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant on November 4,2005, via certified and regular mail, in accordance with the requirements of those acts. 8. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring them within the Soldiers and Sailors Relief Act of 1940, as amended. 9. The Defendant has either failed to meet the time limitations as set forth under the Combined Act 6/91 Notice or have been determined by the Pennsylvania Housing Finance Agency not to qualify for Mortgage Assistance. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure 'IN REM' for the aforementioned total amount due together with interest at the rate of 6.465 % ($16.50per diem), together with other charges and costs including escrow advances incidental thereto to the date ofSherifPs Sale and for foreclosure and sale of the property withi" d~,ri""" Q Danie J. Mancini, Esq. Attorney Bar: PA 39353 (OO:SO-lWS) WdSO", 900'~,f/I0 J....II-Ul6 11:11 F,...P\ElIIER IllllbCT .21111I8 HIS '.lMlIIDII F-m ExlliJllIA ALL THAT CERTAIN 1IlIClof PClllllyhull, _ fully BllOlNNING II.. m1bo otway otW..Mnp S~ w_ 191.0 =IIl. pDiDl....1bo _okq'-"P""""Oumlh thcac. aloDg 1ho d;v;ding liIIe minula l!aat 191.0 JeoI; tboaae <1_ OOlDDlula WCIl40.0 1i1uIlc..1IIo BoIVUib ofN..mllc. 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Davi4 p, ~ IIDlIllalbtta /1,1#....., InuiJoDlI 0IIll BIllNG tile...... pzomioa dood dllOd W=b 30.1995 and P>,e429.lItlIIIled lKIlI.....e)'Ild wife, ~ baoin. . to be fe.cDfdc:d , cert\\)' thl~d CountY p!'- In Curtloen I' ~ ~ ~ ~e1: of peed>> BlI91l5PGI9H 922-0 81/0,d 2vg-l . -WO[j 2,:219B.-18-,0 Daniel Mancini & Associates Daniel J. Mancini, Esq., P A Bar 10: 39353 201 A Fairview Drive Monaca, PA \5061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LA W CASE NO VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS VERIFICATION Daniel J. Mancini, Esq., hereby states that he is the attorney for Plaintiff in this matter, that He is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Further, counsel submits that Plaintiff is outside the court's jurisdiction and verification cannot be obtained with the time allowed for filing the pleading. It is counsel's intention to substitute a verification from Plaintitf. Dated this 2nd Day of February, 2006 ~~d";. E~ Attorney Bar: Pa 39353 i 0 ~ l' tr- III ........ .J:::: tI1 B ~ .r;: C7 t.v ~ ~ -U c~ '" c:" 0 F C::l '';-' .\ --" :7 rq l- eu h1:::r.J r"-- \ ,~Ti c', ~rl -.. I,.,,) , :~-, () C..'l ~(n , .. :~ .. :D C) -< , SHERIFF'S RETURN - REGULAR CASE NO: 2006-00758 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL ASSN VS SALISBURY JEFF J ET AL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SALISBURY JEFF J the DEFENDANT , at 1405:00 HOURS, on the 8th day of February 2006 at 93 PARSONAGE STREET NEWVILLE, PA 17241 by handing to JEFF J SALISBURY me this /oC~ Is BY:4 J a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 10.56 ,00 10.00 .00 38.56 So Answers: ~.,.....,/..'>" ." '- T ......~~~:r~'..'!:.,,(' .",;.-.'~';;:,:~>-~. ~....." -4;...;..?--:;.-'~ R. Thomas Kline # 02/09/2006 DANIEL MANCINI Sworn and Subscribed to before day of :1 SHERIFF'S RETURN - REGULAR CASE NO: 2006-00758 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL ASSN VS SALISBURY JEFF J ET AL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GARVIN ELIZABETH A the DEFENDANT , at 1405:00 HOURS, on the 8th day of February 2006 at 93 PARSONAGE STREET NEWVILLE, PA 17241 by handing to JEFF J SALISBURY, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 r'~~~ R. Thomas Kline Sworn and Subscribed to before me this jc;'f! day of j4'''~;~iD 02/09/2006 DANIEL MAN~ / ~/ / By: . >/' .. ,c, Depu~f .) ,/ , .... IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE, CIVIL DIVISION Plaintiff Case No.: 06-758 Civil Term vs. JEFF J. SALISBURY and ELIZABETH A. GARVIN, Defendant( s) ANSWER TO COMPLAINT IN MORTGAGE FORECLOSURE AND NOW come(s) the defendant(s) by and through attorney, Frank E. Y ourick, Jr., Esquire, and makes the following Answer to Complaint in Mortgage Foreclosure: I. Paragraph 5 of the complaint is denied. Specifically, it is denied that the alleged amounts due on the principal balance, interest, court costs, escrow overdraft, late charges, and attorney's fees are accurate. The debtor cannot verifY the actual amounts due as this information is exclusively within the control of the plaintiff and strict proofthereof is demanded at time of trial. NEW MATTER - AFFIRMATIVE DEFENSES The answering Defendant(s) will rely upon all ofthe following defenses: I. Plaintiffs cause of action is in violation ofthe Fair Debt Collection Practices Act, 15 USC 1692-1692a. 2. Plaintiff s cause of action is barred in whole or in part by the doctrines of waiver and estoppel. 3. Plaintiff s cause of action has not been processed in a timely manner and is barred in whole or in part by the doctrine of laches. ~ '" WHEREFORE, the defendant(s) pray(s) that plaintiffs complaint be dismissed or, in the alternative, this action be delayed for ninety (90) days until the defendanCs) can bring the mortgage current. " B"",,, ~ , Frank E. Yourick, Pa. ID # 00245 P.O. Box 644 Murrysville, PA 15668 C 412) 243-5698 CERTIFICATE OF SERVICE I certify that on the 27th day of March, 2006, 1 served a copy of the Answer to Plaintiffs Complaint upon the following by US first class mail, postage prepaid: Daniel J. Mancini, Esquire 161 Linko A venue Aliquippa, PA 15001 fJk~ Frank E. Y ourick, J , Attorney for Defend P.O. Box 644 Murrysville, PA 15668 C 412) 243-5698 PA ID No.: 00245 (.:; ~,"j r,~) -.J - j.......) (.::- C'.., IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION - LAW WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL Division Case Number: 06-758 civil term Type of Pleading VS JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANT Mortgage Foreclosure Praecipe for Default Judgment Code and Classification: CERTIFICATE OF LOCATION Filed on Behalf Of: Plaintiff 93 PARSONAGE STREET NEWVILLE, P A 17241 Counsel of Record: BOROUGH OF NEWVILLE Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive 05061 (1 728- 233 , By: DANIEL J. MANCINI, ESQ. PA LD. No. 39353 PARCEL No: 27-20-1754-016D \ \ Daniel Mancini & Associates Daniel 1. Mancini, Esq., P A Bar 10: 39353 201 A Fairview Drive Monaca, PA \506\ (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LA W CASE NO: 06-758 civil tenn VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff, WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE, c/o Daniel J. Mancini, Esquire, 201 A Fairview Drive, Monaca, PA 17241, and against Defendants JEFF J. SALISBURY and ELIZABETH A. GARVIN, whose last known address is 93 PARSONAGE STREET, NEWVILLE, PA 17241 for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: Unpaid Principal Balance $ 93,162.18 Delinquent Balance, including Interest at $ I 6.50 per diem From 09/0 I /05 to 03/1 6/06 (based on contract rate of6.465 %) $ 3,765.70 Rec. Corp. Adv. Total $ 129.68 $ 000.00 $ 176.70 $ 0.00 $ 0.00 $ 0.00 $ 25.00 $ 151.68 $ 600.00 $ 4,658.\1 $ 102,669.05 Escrow Advance Accrued Late Charges Inspection Fees Recording Fees L1C Amt Bad CK Fees Other Fees Cost of Suit and Title Search Attorney's Fee 01.02 I hereby certify the (I) the addresses of the Plaintiff a been given in accordance with Rule 237.1, copy attached. are as shown above, and (2) notice has Daniel J. Mancini, Esq. Attorney Bar No.: 39353 DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: (f2';::)/? r 1.. ac> :loa , { **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 ONL Y ENFORCEMENT OF A LIEN AGAINST PROPERTY. ** 01.02 Daniel Mancini & Associates Daniel 1. Mancini, Esq.. PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION ~ LA W CASE NO: 06-758 civil term VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS AFFIDAVIT OF ACT 91 OF 1983 I, Daniel J. Mancini, Esquire, hereby affirm that I hll,ye complied with Act 6 and Ao< 91 of 1983, o",;c, re<j"'~mm" '0 "', "'o~~r 1, Daniel 1. Mancini, Esquire . Daniel Mancini & Associates Daniel J. Mancini, Esq., P A Bar 10: 39353 201 A Fairvicw Drive Monaca, PA 15061 (724) 7284233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LA W CASE NO: 06-758 civil tenn VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS AFFIDAVIT OF NAMES AND ADDRESSES OF OWNERS AND DEFENDANTS COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DANIEL J. MANCINI, Esq., being duly authorized to make this affidavit on behalf of the Plaintiff in the above action WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE, being duly sworn according to law deposes and says that to the best of his knowledge, infonnation and belief the owner of93 PARSONAGE STREET, NEWVILLE, PA 17241, the real property to be sold in the within execution and the defendants in the judgment are JEFF J. SALISBURY DATE: March 16.2006 STREET, NEWVILLE, PA 17241. and ELIZABETH A. GARVIN, whose last known address 93 PA DANIEL J. MANCINI, ESQUIRE Attorney for Plaintiff Daniel Mancini & Associates Daniel 1. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LA W CASE NO: 06-758 civil term VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss: Daniel J. Mancini, being duly swom according to law, deposes and says that he is the attorney of record, for the above-named Plaintiff, that he makes this Affidavit on Plaintiffs behalf, and that the statements in this Affidavit are true to the best of his knowledge, information and belief. Defendants JEFF J. SALISBURY and ELIZABETH A. GARVIN are over 21 years of age. Defendants are not in the military service of the United States as contemplated by the Soldier's and Sailor's Civil Relief Act, as amended. This affidavit is made in connection with the judgment n a note and mortgage secured upon Daniel J. Mancini, Esq. CASE NO: 2006-00758 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL ASSN VS SALISBURY JEFF J ET AL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SALISBURY JEFF J the DEFENDANT , at 1405:00 HOURS, on the 8th day of February, 2006 at 93 PARSONAGE STREET NEWVILLE, PA 17241 by handing to JEFF J SALISBURY a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.56 .00 10.00 .00 38.56 ~~~~ R. Thomas Kline Deputy Sh riff 02/09/2006 DANIEL MANCINI Sworn and Subscribed to before By: me this day of A.D. Prothonotary U.l-.l-.L.:J.l-\...J....l-....- U .l-\..J,..:j..LUlU'\I - L'\..c..\..J'U.LJ~ CASE NO: 2006-00758 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NATIONAL ASSN VS SALISBURY JEFF J ET AL MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon GARVIN ELIZABETH A the at 1405:00 HOURS, on the 8th day of February, 2006 at 93 PARSONAGE STREET DEFENDANT NEWVILLE, PA 17241 by handing to JEFF J SALISBURY, ADULT IN CHARGE a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 r-~<#-P R. Thomas Kline . 02/0'/2006 ~. //;7 DANmL MAN~ By' . Deput~f ' Sworn and Subscribed to before me this day of A.D. Prothonotary Daniel Mancini & Associates Daniel J. Mancini, Esq., P A Bar ID: 39353 20 I A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LA W CASE NO: 06-758 Civil Term VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS TO: JEFF J. SALISBURY 93 PARSONAGE STREET NEWVILLE, PA 17241 DATE OF NOTICE: March 2, 2006 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 '" n a'VOl TD'W'V THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE IE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS RCEMENT OF LIEN AGAINST PROPERTY. P0.~,'. ",,/,< "'("" .-,' ~r::-~-~~~~~~~-' IMPORTANT NOTICE .~ Cl z :J 0 C( ~. ::;; ~ u. 0 o 0 w .... <0: <J u: ;:: '" W <J ;e you have failed to enter a written appearance personally or by attorney .our defenses or objections to the claims set forth against you. Unless you late of this notice, a Judgment may be entered against you without a 'perty or other important rights. You should take this notice to a lawyer er or cannot afford one, go to or telephone the following office to find J ;;: ~ ~ ~ z o co ~ .~ ffiffi.S C'j ~~ u<,::: ~~~_~o ~'" 0 !:!2 N w tn~ u Wo ~z ~ 8~ UJ ~" '" 0'" ..J I.l..~ ." o~ f- wo '" "'~ o "w a. wo ui Ill:;: ::) ~~ ~~ Lawyer Referral Services, ,or, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Daniel J. Mancini, Esquire Attorney for Plaintiff " o N e- o " c . ~ ,..: ~ '" '" E " u. <f) a. 8..... ;: ."~~ "1ii~'6" .-. ./~'f"!!l~': ",:: F;1f1RJ~ ~..;~~! ~. ~,':'X'~', ~ 'f~l} ;... Daniel Mancini & Associates Daniel 1. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfinn@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYL VANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF VS CIVIL ACTION - LA W CASE NO: 06-758 Civil Tenn MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS TO: ELIZABETH A. GARVIN 93 PARSONAGE STREET NEWVILLE, PA 17241 OA TE OF NOnCE: March 2, 2006 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 INFORMA nON OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN RA NKRI JPTCY THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS JRCEMENT OF LIEN AGAINST PROPERTY. .< ,r;,:.- ;.~, Cl z ::i b :;;: z :; :z o o -1 ;;' " ~ ~. u: 5 " ~ ~ .~ W ffiffi.$ cd u !Z~ C) ~ o~~..... 0 ~t;; o~ ~2 N~ ~'" Wo g~ ~~ E u..~ e O~ ~ wo u ~~ ~ IlJO '8 105 III >-0 ~ <~ ,,~ \ s ~ . Ii .. 16 . " o IMPORTANT NOTICE use you have failed to enter a written appearance personally or by attorney your defenses or objections to the claims set forth against you. Unless you date of this notice, a Judgment may be entered against you without a roperty or other important rights. You should take this notice to a lawyer yer or cannot afford one, go to or telephone the following office to find ~ ~ " Lawyer Referral Services, oor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 Daniel J. Mancini, Esquire Attorney for Plaintiff o o N ~ . , c . , ,..: ~ '" '" E o u. "' a. c p GO 14- \l:- I: ....0 n ....., ~ It ,::::::) 0 C ~-~ ,~:"':'> -1) <:.:;'.... ::'C -1 .J:: G ),'" :L-n (' :;;cJ 1'11 ~~ e- rn ~ r-..) .'() I,"'''' -~ C> ,~ ",,0) '.~~; ':') ~ C P- ..", ,-;"'1, -- ;(~ W' <...-.) ':5r'n ~ \ ~ ~~~ .- [: t.) .;J G, ....:::: ;- -- Daniel Mancini & Associates Daniel 1. Mancini, Esq., P A Bar ID: 39353 20 I A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYL VANIA WELLS FARGO BANK NA TlONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LAW CASE NO: 06-758 civil term VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS RULE 236 NOTICE OF DEFAULT To: JEFF J. SALISBURY 93 PARSONAGE STREET NEWVILLE, PA 17241 You are hereby notified that the following Order, Decree or Judgment has been entered against you on fY2::l/l r.J... d ,) .:i 'Xl&' , A Judgment of Default in the amount of$ 102,669.05 plus costs. If you have any questions concerning the above, please contact: DANIEL J. MANCINI, ESQUIRE MANCINI & ASSOCIATES 201 A FA1RVIEW DRIVE MONACA, PA 15061 724-728-4233 Daniel Mancini & Associates Daniel 1. Mancini, Esq., P A Bar LD: 39353 201 A Fairview Drive Monaca, P A 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NA TIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LAW CASE NO: 06-758 civil term VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS RULE 236 NOTICE OF DEFAULT To: ELIZABETH A. GARVIN 93 PARSONAGE STREET NEWVILLE, PA 17241 You are hereby notified that the following Order, Decree or Judgment has been entered against you on 07. 'ail r J... ;;) f) do oot,;, , A Judgment of Default in the amount of$ 102,669.05 plus costs. (.~ If you have any questions concerning the above, please contact: DANIEL J. MANCINI, ESQUIRE MANCINI & ASSOCIATES 201 A FAIRVIEW DRIVE MONACA, PA 15061 724-728-4233 q , C-., ~ = <., .;;;;. / ~I'" I~ S;"; / nl Fry :I~j (rj ;))) -.J>~ N U) ... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYL VANIA CIVIL ACTION - LAW WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL Division Case Number: 06-758 civil term Type of Pleading VS JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANT Mortgage Foreclosure Praecipe for Writ of Execution Code and Classification: CERTIFICATE OF LOCATION Filed on Behalf Of: Plaintiff 93 PARSONAGE STREET NEWVILLE, P A 17241 Counsel of Record: BOROUGH OF NEWVILLE Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive Monac 15061 (7 728-423 PARCEL No: 27-20-1754-016D 2' By: DANIEL J. MANCINI, ESQ. P A I.D. No. 39353 .. Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, P A 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LAW CASE NO: 06-758 civil term VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) p.R.e.p.3180-3183 To the Director of the Office of Prothonotary Issue writ of execution in the above matter: Amount Due From 09/01/05 to 03/16/06 (based on contract rate of 6.465 %) $ 102,669.05 $ Dated this 16th day of March, 2006 an . ancini, Esq. Attorney Bar No.: 39353 Note: Property Description Attached 01-02 7\:J C r (J 1- ~ ~ ~ 5? , Cr) () .l::: (; D M- --- ~ 6'- ....() l' ~ ...... ()- ~. ~ ( +- ~ L -GQ.. - ~ RJ -:-0 ~ V) C, 0 ~ f' oC'v ~ ... ~ -UJ......... !~~ D vt () () 6' \) , I 1:-tJ ~ ~ ~ ~ ?F .. ' ~ E--I- ... ... '4!.. .. .. ...... .... o g ~ ~ ~ :1.,., ;,;;... mp -< -0 r:q -,.,0 ~ ..::,~ (:) =:2~ ~ '~~ CO _.._\ .. 1) N -< (J1 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-758 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE, Plaintiff (s) From JEFF J. SALISBURY AND ELIZABETH A. GARVIN (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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $102,669.05 L.L. $.50 Interest FROM 9/1/05 TO 3/16/06 (BASED ON CONTRACT RATE OF 6.465%) Arty's Comm % Due Prothy $1.00 Arty Paid $136.56 Other Costs Plaintiff Paid Date: MAY 19, 2006 ( Seal) Prothonotary By: Deputy REQUESTING PARTY: Name DANIEL J. MANCINI, ESQillRE Address: 201 A FAlRVIEW DRIVE MONACA, P A 15061 Attorney for: PLAINTIFF Telephone: 724-728-4233 Supreme Court ID No. 39353 t Daniel Mancini & Associates Daniel J. Mancini, Esq., P A Bar 10: 39353 201 A Fairview Drive Monaca, P A 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LAW CASE NO: 06-758 civil term VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS AFFIDAVIT PURSUANT TO RULE 3129 (Affidavit No.1) WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE, Plaintiff in the above action, by its attorney, Daniel 1. Mancini, 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 93 PARSONAGE STREET, NEWVILLE, PA 17241. 1. Name and address of Owner(s) or reputed Owner(s): JEFF J. SALISBURY and ELIZABETH A. GARVIN 93 PARSONAGE STREET NEWVILLE, P A 17241 2. Name and address ofDefendant(s) in the judgment: JEFF J. SALISBURY and ELIZABETH A. GARVIN 93 PARSONAGE STREET NEWVILLE, P A 17241 3. Name and address of every judgment creditor whose judgment is a record lien on the real property to be sold: t<<>RTGAGE/DEED OF TRUST 1st: Mortgagor: MERS NOMINEE FOR DECISION ONE MORTGAGE CO LLC** JEFF J SALISBURY AND ELIZABETH A GARVIN Trustee: M.B. Vol So Page: Dated: Amount: 1905-1897 04/29/2005 $93,520.00 Recorded: 05/02/2005 Future Advance: No **ADDRESS: 6060 J.A. JONES DR, SUITE 1000, CHARLOTTE, HC 28287 C/O Mancini & Associates, 201A Fairview Drive, Monaca, PA 15061 06-02 r 4. Name and address of the last recorded holder of every mortgage of record: I<<>R7GAGE/DEED OF mus~ 1st: Mortgagor: MERS NOMINEE FOR DECISION ONE MORTGAGE CO LLCH JEFF J SALISBURY AND ELIZABETH A GARVIN Trustee : K.B. Vol" Page: Dated: Amount: ~~ADDRESS: 6060 J.A. JONES DR, SUITE 1000, CHARLOTTE, NC 28287 c/o Mancini & Associates, 201A Fairview Drive, Monaca, PA 15061 1905-1897 04/29/2005 $93,520.00 Recorded: 05/02/2005 Future Advance: No MORTGAGE/DEED OF mUST 2nd: Kortgagor: MERS NOMINEE FOR DECISION ONE MORTGAGE CO LLC.. JEFF J SALISBURY AND ELIZABETH A GARVIN Trustee: M.B. Vol" Page: Dated: Amount: 1905-1915 04/29/2005 $23,380.00 Recorded: 05/02/2005 Future Advance: No ..ADDRESS: 6060 J.A. JONES DR, SUITE 1000, CHARLOTTE, NC 28287 5. Name and address of every other person who has any record lien on the property: UNKNOWN 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: 2005 REAL ESTATE TAXES ARE DELINQUENT IN THE AMOUNT OF $1,184.48, PLUS PENALTY AND INTEREST Tax Claim Bureau, 1 Courthouse Square, Carlisle, P A 17013 7. Name and address of every other person whom the Plaintiff has knowledge who has any interest in the property which may be affected by the Sale: UNKNOWN I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. '4904 relating to unsworn falsification to authorities. Dated this 15th day of May, 2006 fA- Daniel J. Mancini, Esq. Attorney Bar No.: 39353 06-02 (") ~::- L-;~ -~ -( '" <::::;) <::::;) ""'" ~ 3! rn :n r- -om :;99 '.2~ 1,21-" :/"C) dm ,.._/ )::>: :0 -< ::n: ~>> -<: \.0 :boo -".. -..... co .. N c.n . Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar ID: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LAW CASE NO: 06-758 civil term VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CML PROCEDURE 3129 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: September 6, 2006 TIME: 10:00 a.m. LOCATION: Cumberland County Courthouse 1 Courthouse Square Carlisle, P A 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. DWELLING KNOWN AS 93 PARSONAGE STREET, NEWVILLE, PA 17241. Legal Descriptions: All that certain property situated in the BOROUGH OF NEWVILLE in the county of CUMBERLAND, and the Commonwealth of PENNSYLVANIA, being described as follows: PARCEL 27-20-1754-0160 and being more fully described in a deed dated 04/29/2005, and recorded 05/02/2005, among the land records of the county and state set forth above, in Deed Book 268, page 3250 THE LOCATION of your property to be sold is: 93 PARSONAGE STREET NEWVILLE, P A 17241 ,- , THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 06-758 civil term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS ofthis property JEFF J. SALISBURY and ELIZABETH A. GARVIN A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (l0) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Pennsylvania, Cumberland County Courthouse. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Lawyer Referral Services, 4th Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: l. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the . . County Court House before presentation to the Court. Daniel Mancini, Esq. , (") I'-.l r- = 0 '-, c..-::> 0,", 11 :J: ~ > -< n1 ::n r- -om \.0 :tJ~ C) :J:::o ,~~:B :r ,~o ,. 9? ?5rn ::;l ;fd .... N _n U1 -< (oo=SC)-..ncn Wd!iO=ZIo geOU~U~O I . " _al-_ l1:SI FnrPBla AIS1IJCT +20_ r.f1S '.11III12 F-m BzIIlIlk A ALL'IHAI CER.TAlN1Iact of ~--fu1I,r .... "iIclIwIb.~ Cami:lcdaDl&CoIaay, ........... BEING ~r.....ot-4asJ.ocHo., ~m".. ~.:lIowid&a 21, 1-. BBGDINING. a___ af...,.af'w.....___ Sbec::l; WCIll91.o:li:cl1o."_. 1bcIoce ... .......,.,wI c::IIiIIIIb tbeace .... dJo cIividiDc iIIe mimlaaEal& 191.0 i'd; Ibr:aaa ~OO~WClt4Q.O _afwar_oa... .. s.r.;1MIceaIaBglipt ....-liIMfIlW/liIe..2CS...OO__ .. tiakf1ll'RJ ..0(.....,..1U_ o-m.AJJey. NcdtM___CIOmi8IlaBllt40.0ktD all__ .taeI1b.I_' _1IIiII MW#J Sodl2fi ...... DO *....,...of.,_~Sa=Soudl" 1D &JlliI!r. "PIIoo~, dw..,~a....._,....boc8led_ pICflMd 1IJ...A. &"' .,J.S.... A1.lpllt '. TOGBbd& __...... iD 15 ...........lIIil...............d..,. <<Lots ....iD..i__....Pc.. If SINer II..... on . . BBlNGdIoamcpmailel ~....r.:.,.~~~eo..-&o..by"'" deed GatcdMaa:il30.1995 _ .. 0-. .....1liI eo.,. ~lftIIiaDccdBoclk 120. ,.429. ....._tlIlm8jllld DailP.~~w.A. ~.~_ wife. <inIDroD.... w.cc.cotdc;d cCrtif1 this to vw P A- t ~-"-"~And CoUnt) . ll\~~t' :rr m ~ ~of1)eeds a190'5" J 9f1 gzz-n ~I/01j ZP9-1 -~ Zt:ZI98,-U:-U DanieI Mancini & Associates Daniel J. Mancini, Esq., PA Bar ill: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LAW CASE NO: 06-758 civil term VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS EXHmIT A LONG PROPERTY DESCRIPTION AU.. 'l'lIAT CBllTAIN'1IaCt of ~--tbIIy II1urc Ill"'" ofNIN\'I1lc. CaderJadOHay. ... ~.. tJUvwt: rilbtofwayU.ofP--..... .... allm&DI1R ..,lIIiI1liibt of1'll)' BIle NOIdl2t1..... 00-_ . d&k ofway lime ofllDapaae416.6 _ Cburda ~ Ncd&M.... Go ...;.~ a..-o.Or... _ _pia; LotINOI.I_' GIlIIId 111M)' SouIb 26 ..... 00 1bc: 8GI11ma riPt of.., IiDc oIPUIODIIC 8Cn:a Scn6 " 1Da~1DI"'gf~. llIe lUM'.YofM8IJ a 11.......... ~__dcd IIId prepared by2apDc ~. B...~ &8. dIIIlDd ADpIt ", Bl!OINNINO. a po. em._ alway DlW.....~ .s.er. WCltl'l.oAeuo.,.__ ........ UIIOIMII8d CIaavh tMael!l .... fU diYi&1ia81iM -~But l'l.O r..t;.... d..-. OO~...,.. Welt 40.0 BBlNG4011... IS LaINo. 9 dcIa:lbad. _au. .dtu...xl willi . 2t.1*. TOOBTHBR. wiIh ad 11.l1Ij_ tD lIS faat~___ ~"lOudMm~oftGts '. B. - 9 iIr...., 'peI. rtp11110 _ ftoID I8id tot... PCICUIII- StreIt u tIIawD. on. tho 8UBehal Plan. ; .1DJG1bume pzaai_ 40c441tCCl1ladl 30, 1'" _ '.-43........ amvayed .,., Ona-.blnia. ~ HoIuI, -11- ~aia CIIIpIJI1IIiau, by'" ooidcIdiD ~laa4 Coam;y. P~DccdBook 120" DAi4 P. 0Rs0Uv~Jlad)1IIA. ~pUcl buibad at DWELLING KNOWN AS 93 PARSONAGE STREET, NEWVILLE, PA 17241 IDENTIFIED as TAX/PARCEL ID#: 27-20-1754-016D in the Deed RnegiS Ice OfCUIn.. berland County, Pennsylvania. / <-- ~ Daniel J. Mancini, Esquire Attorney for Plaintiff ~. Daniel Mancini & Associates Daniel 1. Mancini, Esq., PA Bar 10: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfinn@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIA nON AS TRUSTEE PLAINTIFF CIVIL ACTION - LAW CASE NO: 06-758 civil tenn VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS RETURN OF SERVICE I hereby certify that I have deposited in the U.S. Mails at Monaca, Pennsylvania on July 20,2006, a true and correct copy of Notice of Sale of Real Estate pursuantto PA R.C.P. 3129.1 to all lien holders of record by regular first class mail (Certificate of Mailing fonn in compliance with U.S. Postal Fonn 3817 is attached hereto as evidence), which mailing receipts are attached. Service addresses are as follows: Decision One Mortgage Company 6060 J.A. Jones Drive Suite 1000 Charlotte, NC 28287 Tax Claim Bureau 1 Courthouse Square Carlisle, P A 17013 By Daniel J. Mancini, Esq. Attorney for Plaintiff {L ,- U.S. POSTAL SERVICE MAY BE USED FOR DOMESTIC AND INlERNATIONAL MAil. DOES NOT PROVIDE FOR INSURANCE-POSTMASTER =. . & AsSOCl.ates Received From: , . Fairview Drive . MOO9ca. PA 15061. .. ''", . \. . . ~ 00 \,),aTEoS ?:gt,) ~ ~A ~t;:u ~~~ ~ 1J~* ltl & O".J:>. .fi1 j ~:~ 'Q">>~ , aco:!! 0. ... O~O~"-' "1 <.0" CD 0; h.) to ~ o 0 ..... M\.. ',..,. {.J)o'V1U'J ~ _, ,;n <0 One piece of ordll\8lY maU sddlll888ll to: 'iA~ &A \ 1tV\ '&let-All ~~~~ ~~U~~" 'Ll~\..:t .A 10' '~~ ~-:;'( ;i:~:;~~/f PS Fann 3817, January 2001 R8c8Ived From: One piece of ordinary man addlll888lllo: D<-:t tSibJJ fu~ (V\oiTI~Aht lLUoD J'.A, Tc~ bll.\vt ~llln: l bo u rl ATGlolTc N<':"- ~ ~E-l PS Fann 3817, January 2001 ~o ~ g ~ uNITED.r~ hi~'1f ~ ~ .0 (0 " ^" ~')" Ul ~.jO.l'" ." o"'~ '~l ~ ~ ~~~~!~ 'II~ ,,?~-4"Y OC ... g: 00 ~I n1 (j) -< g~ ~ i " 0) (:) ..... en '.'0) 0 - '. Daniel Mancini & Associates Daniel 1. Mancini, Esq., PA Bar 10: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LAW CASE NO: 06-758 civil tenn VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS NOTICE PURSUANT TO PA. R.C.P. 3129 Notice is hereby given to the following parties who hold one or more mortgage, judgment or tax liens or any claim against the real estate of 93 PARSONAGE STREET, NEWVILLE, P A 17241 N:>RTGAGE/DEED OF TRUS'l' 2nd: IIortgagor: DECISION ONE MORTGAGE COMPANY JEFF J SALISBURY ELIZABETH A GARVIN 'l'rustee: M.B. Vol fr Paqe: Dated: Aaount: 1905-1915 04/29/2005 $23,380.00 Recorded: 05/02/2005 Future Advance: No **ADDRESS: 6060 J.A. JONES DR, SUITE 1000, CHARLOTTE, NC 28287 TAX IDt 27-20-1754-016D TAX REMARKS: ALL TAXES PAID THROUGH 2004 2005 TAXES DELINQUENT IN THE AMOUNT OF $1,229.08, PLUS PENALTY AND INTEREST NEXT TAXES DOl!: 12131/2006, AMOUNT UNAVAILABLE 2005 REAL ESTATE TAXES ARE DELINQUENT IN THE AMOUNT OF $1,184.48, PLUS PENALTY AND INTEREST Tax Claim Bureau, 1 Courthouse Square, Carlisle, P A 17013 You are hereby notified that on Wednesday, September 6,2006 at 10:00 A.M. prevailing time, by virtue ofa Writ of Execution issued out of the Court of Common Pleas of Cumberland County, Pennsylvania, on the judgment of, WELLS FARGO BANK NA TIONAL ASSOCIATION AS TRUSTEE, the Sheriff of Cumberland County, ...- ...~ Pennsylvania will expose at Public Sale at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, P A 17013, the real estate of JEFF J . SALISBURY and ELIZABETH A. GARVIN, known and numbered as 93 PARSONAGE STREET, NEWVILLE, P A 17241, Cumberland County. A description of said real estate is hereto attached. You are further notified that a Schedule of Distribution of Proposed Distribution will be filed by the Sheriff of Cumberland County within thirty (30) days, and distribution will be made in accordance with the Schedule unless exceptions are filed thereto within ten (10) days thereafter. You are further notified that the lien you hold agai the said real estate will be divested by the sale and that you have an opportunity to protect our in erest, if any, by being notified of said Sheriff's Sale. DATE: July 19,2006 By: Daniel J. Mancini, Esq. Attorney for Plaintiff ..,- .., AlL T.IIAT caTAIN'1IKt 01 ..... fa tltllolnJII o:f'N....... a.....n..~ ec.Q. ,. ~11. U[Wr.. __ &I;J .. 4110I..,. ....: _of'wayJlaeof.P-.-" -1IIm&$ ..,... datil of.",... NoId12llS ....... 00 -' 1 L I . .01...., llaaet"...,.tll4.'" a.rts~ NaltlaM..... 00 M1"~" 8M....0... CD _..pia; LotIN.. ...,........., Soat1I26 ~I"- 00 .. ....... nptOr"., IiAc on........8Irca 9cnd!l" ...,..., _...ar~. BBlNG4111p1ted IS LoI No. 9 the lUMl)'ofMIo E..:&.:ri* 1IIIl1ia1her1M.NDded.. cs.cdbId. ill __...,aa wida. lI~braw.O A. Bar.ll---..itIt. :a.S. ..... A1IpIt 2t.1_. ., TOOB'l'JIIk with... ~ aD a15 ..... ___ ......ID~ w...........afLo1a 1. B.1IId' ..... IJI, ..... ~ 1D -.i.ftrcIID I8i4 .... ..p...... sa.r U __ 011 .. ~ Plan. ~ . BDlOdIe__~ DwI.-1IoIuI, -. .~... C.....Idaa. "'... -.a4atlClMatcb 30. 1'" .... ClCltdIIIfD Camllarl1Dll Coaa\Y. rc~ Deal... 120. .....G. ~... GaaWl)1lll DAi4 ,. ~~DldJaraA. ~I ~ at wi:L'It, Oh.u_....a. Q , tr .--. ~..." C.::l :: 1 :.-,... Ii :.-.:J 0i (,!-; j In The Court of Common Pleas of Cumberland County, Pennsylvania Writ No. 2006-758 Civil Term Wells Fargo Bank National Association as Trustee VS Jeff J. Salisbury and Elizabeth A. Garvin R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned STAYED per instructions from Attorney Daniel J. Mancini. Sheriffs Costs: Docketing Surcharge Prothonotary Law Library Poundage Advertising Levy Posting Handbills Mileage Share of Bills Patriot News Law Journal 30.00 30.00 1.00 .50 17.08 15.00 15.00 15.00 31.68 19.31 308.00 389.00 $ 871.57 .; '1/11 {tJ~ c;.-. <~.~ ~ R. Thomas Kline, Sheriff f /"> _ BY\} C ~ II1A I l-iA Real Esta Sergeant ) .:So Ck...{53~ <::) ~J~'.{4'{lf I ~" f" Daniel Mancini & Associates Daniel J, Mancini, Esq" P A Bar ID: 39353 201 A Fairview Drive Monaca, P A 15061 (724) 728-4233 mancinilawfirm@comcast,net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LAW CASE NO: 06-758 civil term VS MORTGAGE FORECLOSURE JEFF 1. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS NOTICE OF SHERIFF'S SALE OF REAL ESTATE PURSUANT TO PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129 TAKE NOTICE: That the Sheriffs Sale of Real Property (real estate) will be held: DATE: September 6,2006 TIME: 10:00 a.m. LOCATION: Cumberland County Courthouse 1 Courthouse Square Carlisle, P A 17013 THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a statement of the measured boundaries of the property, together with a brief mention of the buildings and any other major improvements erected on the land. DWELLING KNOWN AS 93 PARSONAGE STREET, NEWVILLE, PA 17241. Legal Descriptions: ~~l that certain property situated in the BOROUGH OF NEWVILLE in the county of CUMBERLAND, and the Commonwealth of PENNSYLVANIA, being described as follows: PARCEL 27-20-1754-016D and being more fully described in a deed dated 04/29/2005, and recorded 05/02/2005, among the land records of the county and state set forth above, in Deed Book 268, page 3250 THE LOCATION of your property to be sold is: 93 PARSONAGE STREET NEWVILLE, PA 17241 ., ... THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within Commonwealth and County to: NO. 06-758 civil term THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property JEFF J. SALISBURY and ELIZABETH A. GARVIN A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is filed. Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common Pleas of Cumberland County, Pennsylvania, Cumberland County Courthouse. THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY. IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU. IT MAY CAUSE YOUR PROPERTY TO BE HELD. TO BE SOLD OR TAKEN TO PAY THE JUDGMENT. You may have legal rights to prevent your property from being taken away. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE: Lawyer Referral Services, 4th Floor, Cumberland County Courthouse Carlisle, P A 17013 (717) 240-6200 THE LEGAL RIGHTS YOU MAY HAVE ARE: 1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if you have a meritorious defense against the person or company that has entered judgment against you. You may also file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against you. 2. After the Sheriffs Sale you may file a petition with the Court of Common Pleas of the within County to set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED BEFORE THE SHERIFF'S DEED IS DELIVERED. 3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the petition. If a specific return date is desired, such date must be obtained from the within County Court House before presentation to the Court. D .<-. Daniel Mancini, Esq. WRIT OF EXECUTION and/or ATTACHMENT ~ . COMMONWEALTH OF PENNSYL VANIA) COUNTY OF CUMBERLAND) NO 06-758 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE, Plaintiff (s) From JEFF J. SALISBURY AND ELIZABETH A. GARVIN (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 him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $102,669.05 L.L. $.50 Interest FROM 9/1/05 TO 3/16/06 (BASED ON CONTRACT RATE OF 6.465%) Arty's Comm % Due Prothy $1.00 Atty Paid $136.56 Other Costs Plaintiff Paid Date: MAY 19, 2006 (Seal) Prothonotary By: Deputy REQUESTING PARTY: Name DANIEL J. MANCINI, ESQUIRE Address: 201 A FAIRVIEW DRIVE MONACA, PA 15061 Attorney for: PLAINTIFF Telephone: 724-728-4233 Supreme Court ID No. 39353 Real Estate Sale # 68 On June 2, 2006 the Sheriff levied upon the defendant's interest in the real property situated in Borough of Newville, Cumberland County, P A Known and numbered as 93 Parsonage Street, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: June 2, 2006 By: , "lock ( SVVtLt+l Real Estate Sergeant , ~3: ~j ~~i1 ~.:; ~ ;.~==---- . ,F1J Z 0 :01 'V [Z ^ VN qDOl \/.J ') , \iO /\.lit . . .,I.:JltJ'W' .., '.Jill 'lei ; -' .::i,,) .::i 1-11 j 0 ::D IJ j cl ~ ~ .~ -=.:::::::,.. <.... dJ ;~. 'J tJ U 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 July and the 2nd day(s) of August 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 #68 4 CUMBERLAND COUNTY SHERIFF'S OFFICE CUMBERLAND COUNTY COURTHOUSE CARLISLE, P A. 17013 ,.,'1 ) 1\ . . ,,'!f.l~~,-'. . '"'. ,',. ::t'...:.'....::.::'.' ,. . ~~':: PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYL VANIA 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: July 21, July 28, and August 4,2006 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. SWORN TO AND SUBSCRIBED before me this 4 day of August. 2006 NOT A AL SEAL LOIS E. SNYDER. Notary Public \ ,.. Carlis.le Boro, cun:berland County ~ My COfT1rniSsiO~es M,3;ch 5,;~~,. L,w-III......~ REAL ESTATE SALE NO. 68 Writ No. 2006-758 Civil Wells Fargo Bank National Association as Trustee vs. Jeff J. Salisbury and Elizabeth A.. GaIVin Atty.: Daniel J. Mancini EXHIBIT A LONG PROPERTY DESCRIPTION ALL THAT CERTAIN tract of land situate in the Borough of Newville, Cumberland County, Pennsylvania. more fully bounded and described as follows: BEGINNING at a point on the northern right of way line of Par- sonage Street; thence along right of way of Washington Street; thence along said right of way line North 26 degrees 00 minutes West 191.0 feet to a point on the southern right of way line of unopened 16.6 feet Church Alley, thence along un- opened Church Alley North 64 de- grees 00 minutes East 40.0 feet to an iron pin; thence along the dMd- ing line between Lots Nos. 8 and 9 on said survey South 26 degrees 00 minutes East 191.0 feet; thence along the northern right of way line of Parsonage Street South 64 de- grees 00 minutes West 40.0 feet to a point, the Place of BEGINNING, BEING designated as Lot No. 9 on the survey of Mary E. Barrick and further bounded and described in accordance with a survey pre- pared by Eugene A. Hockensmith. R.S. dated August 21, 1986. TOGETIIER with and subject to a 15 foot wide easement along the southern boundaries of Lots 7, 8, and 9 for ingress, egress, and re- gress to and from said lots and Par- sonage Street as shown on the at- tached Plan, BEING the same premises which Durham Homes, Inc., a pennsylva. nia Corporation, by their deed dated March 30, 1995 recorded in Cumberland County, Pennsylvania Deed Book 120, Page 429, granted and conveyed unto David P. Gregoire and Barbara A. Gregoire, husband and wife, Grantors herein. DWELLING KNOWN AS 93 Par- sonage Street, Newville, PA 1724 I. IDENTIFIED as TAX/PARCEL ID#: 27-20-1754-0160 in the Deed Registry Office of Cumberland County. Pennsylvania. ~ """ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYL VANIA CIVIL ACTION - LA W WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL Division Case Number: 06-758 civil term VS Type of Pleading Praecipe to Satisfy Judgment And Settle Case in Mortgage Foreclosure JEFF 1. SALISBURY and ELIZABETH A. GARVIN DEFENDANT Code and Classification: CERTIFICATE OF LOCA nON Filed on Behalf Of: Plaintiff 93 PARSONAGE STREET NEWVILLE, P A 17241 Counsel of Record: BOROUGH OF NEWVILLE Daniel J. Mancini, Esquire Attorney at Law 201 A Fairview Drive Monaca, P A 15061 (72/-4233 Lc By: DANIEL J. MANCINI, ESQ. PA I.D. No. 39353 PARCEL No: 27-20-1754-016D -I. " Daniel Mancini & Associates Daniel J. Mancini, Esq., PA Bar 10: 39353 201 A Fairview Drive Monaca, PA 15061 (724) 728-4233 mancinilawfirm@comcast.net IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA WELLS FARGO BANK NATIONAL ASSOCIATION AS TRUSTEE PLAINTIFF CIVIL ACTION - LAW CASE NO: 06-758 civil term VS MORTGAGE FORECLOSURE JEFF J. SALISBURY and ELIZABETH A. GARVIN DEFENDANTS PRAECIPE AND POWER OF ATTORNEY FOR SATISFACTION AND/OR TERMINATION TO THE PROTHONOTARY OF SAID COURT: You are hereby authorized, empowered, and directed to enter, as indicated, the following on the records thereof: A.1. ---- The within suit is Settled, Discontinued, Ended and costs paid. 2. ---- The within suit is Settled, Discontinued, Ended WITH Prejudice and costs paid. 3. --X-- the within suit is Settled, Discontinued, Ended WITHOUT Prejudice and costs paid. B.1. ---- Satisfaction of the Award in the within suit is acknowledged. 'I 2. -X-- Satisfaction of Judgment with interest and costs, in e withih matter is acknowledged. Date: December 5. 2006 WITNESS {if signer is other than a registered attorney}: ~. Daniel J. Mancini. ESQ. l~ Notary Type or print name of above signer -. COST PAYMENT VERIFICATION I UNDERSTAND THAT THE ABOVE ACTION CANNOT BE FILED AND DOCKETED UNTIL ALL COSTS HAVE BEEN PAID. INCLUDING SHERIFF'S COSTS: AND HEREBY VERIFY ALL COSTS HAVE BEEN PAID. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S.A. 4904--2ELATING TO UNSWORN FALSIFICATION TO AUTHORITIES L Signature ,....., c::> C:::J cr" CJ r'l '"' "',,~ C~ -.z. _-I -< ~ - - ~--l\ ::f;- l i c:. -~l!...!-:, :0,,2;\ '~ii~ t;c3\ -....~ ')) :.< "'f"';P- S: - - o ~