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Home My WebLink About06-1064 MILSTEAD & ASSOCIATES, LLC BY: Pina S. Wertzberger, Esquire ID No. 77274 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Wells Fargo Bank, NA as Trustee 1100 Corporate Center Drive Raleigh, NC 27607, Plaintiff, Vs. Diane M. Schall 520 Salmon Road Mechanicsburg, PA 17050, Defendant. Attorney for Plaintiff File No.: 5-04750 COURT OF COMMON PLEAS CUMBERLAND COUNTY i I No.: Oto - /OLV et u ?(? 1 CIVIL ACTION MORTGAGE FORECLOSURE NOTICE 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 after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Notice to Defend 32 S. Bedford Street Carlisle, PA 17013 717-249-3166 ?. NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT 1. This communication is from a debt collector. This is an attempt to collect a debt and any information obtained will be used for that purpose. 2. Unless you dispute the validity of this debt, or any portion thereof, within 30 days after receipt of this notice, the debt will be assumed to be valid by our offices. 3. If you notify our offices in writing within 30 days of receipt of this notice that the debt, or any portion thereof, is disputed, our offices will provide you with verification of the debt or copy of the Judgment against you, and a copy of such verification or judgment will be mailed to you by our offices. MILSTEAD & ASSOCIATES, LLC BY:Pina S. Wertzberger, Esquire ID No. 77274 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff Wells Fargo Bank, NA as Trustee, 1100 Corporate Center Drive Raleigh, NC 27607 Plaintiff, Vs. Diane M. Schall 520 Salmon Road Mechanicsburg, PA 17050, COURT OF COMMON PLEAS CUMBERLAND COUNTY No.: D(o - /any a I u Z-7e,/Z-? CIVIL ACTION MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff, Wells Fargo Bank, NA as Trustee (the "Plaintiff'), is a corporation registered to conduct business in the Commonwealth of Pennsylvania and having an office and place of business at 1100 Corporate Center Drive, Raleigh, NC 27607. 2. Defendant, Diane M. Schall, (the "Defendant"), is an adult individual and is the real owner of the premises hereinafter described. 3. Diane M. Schall, Defendant, resides at 520 Salmon Road, Mechanicsburg, PA 17050. 4. On December 1, 2004, in consideration of a loan in the principal amount of $157,000.00, the Defendant executed and delivered to Argent Mortgage Company, LLC a note (the "Note") with interest thereon at 8.100 percent per annum, payable as to the principal and interest in equal monthly installments of $1162.98 commencing February 1, 2005. 5. To secure the obligations under the Note, the Defendant executed and delivered to Argent Mortgage Company, LLC a mortgage (the "Mortgage") dated December 1, 2004, recorded on December 21, 2004 in the Department of Records in and for the County of Cumberland under Mortgage Book 1891, Page 4970. Pursuant to Pa.R.C.P. 1019 (g) the mortgage is incorporated herein by reference. Plaintiff is the proper party Plaintiff herein by way of an assignment to be recorded. 6. The Mortgage secures the following real property (the "Mortgaged Premises"): 520 Salmon Road, Mechanicsburg, PA 17050. A legal description of the Mortgaged Premises is attached hereto as Exhibit "A" and made a part hereof. 7. The Defendant is in default of his/her obligations pursuant to the Note and Mortgage because payments of principal and interest due January 1, 2035, and monthly thereafter are due and have not been paid, whereby the whole balance of principal and all interest due thereon have become due and payable forthwith together with late charges, escrow deficit (if any) and costs of collection including title search fees and reasonable attorney's fees. 8. The following amounts are due on the Mortgage and Note: Balance ofPrincipal $156,154.38 Accrued but Unpaid Interest from 10/1105 to 2/21/06 @ 8.100% per annum ($34.84 per diem) $6,026.82 Accrued Late Charges $767.58 Title Search Fees $350.00 Reasonable Attorney's Fees $1,250.00 TOTAL as of 02/21/2006 $164,548.78 Plus, the following amounts accrued after February 21, 2006: Interest at the Rate of 8.100 per cent per annum ($34.84 per diem); Late Charges of $58.15 per month. 9. Plaintiff has complied fully with Act No. 91 (35 P.SA680.401(c) of the 1983 Session of the General Assembly ("Act 91") of the Commonwealth of Pennsylvania, by mailing to the Defendant at 520 Salmon Road, Mechanicsburg, PA 17050 as well as to address of residences as listed in paragraph 3 of this document on November 8, 2005, the notice pursuant to '403-C of Act 91, and the applicable time periods therein have expired. True and correct copies of such notices are attached hereto as Exhibit "B" and made apart hereof. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant for foreclosure and sale of the Mortgaged Premises in the amount due as set forth in paragraph 8, namely, $164,548.78, plus the following amounts accruing after February 21, 2006, to the date of judgment: (a) interest of $34.84 per day, (b) late charges of $58.15 per month, (c) plus interest at the legal rate allowed on judgments after the date of judgment, (d) additional attorney's fees (if any) hereafter incurred, (e) and costs of suit. VERIFICATION I, Pina S. Wertzberger, hereby certify that I am an Attorney for Plaintiff and am authorized to make this verification on Plaintiff s behalf. I verify that the facts and statements set forth in the forgoing Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge, information and belief. This verification is made subject to the penalties of 18 Pa. C.S. ' 4404, relating to unswom falsification to authorities. Name: Pina S.'WIzl}efger, Esquire Title: Attorney ?'" SCHEDULE "A" . 90-01453413 THE LAND RRFERRED TO IN TRIG COM4171UNT IS DMW=SD 116 FOLLOWS: ALL TROD TWO CERTAIN PIECEe OR PAM= OR TRACTS OF LAND SITOATE IN TIE r011NSSir or EANPDEN, cm= Or COMBIxt-W, C01"NNEAL" OF PENNSYLVANIA, MOPH PA6T=LxmLY POUNDED Am OBSCR2HED AS TOLiOWS, TO WIT: TRACT W0, 11 BEGINNZW AT A POINT AT THE NORTHWEST 0ORNOR OF LOT NO. 6, PLAN Of WDRMt COTTAGES, AG LAID OUT By PANDER REALTY CoNPANY, SALl9Dv ROTS PLOT, SAID PLAN MIND RECOPDID IN MAR BOOS W. 2, FACE 61, CUNDERLAMm COUNTY REOORD6; TffiSR IN AN EASTERLY DIRECTION ALONG TH6 DIVISION LINE RETM= LOTS NOS, 6 AND 7 IN SAID PLAN, 151 FEET TO A POINT IN THE PUBLIC ROAD; THENCE IN SAID PUBLIC ROAD, SOUTH 12 DEGREES 30 MINUTES EAST, 50 FEET, NDRI OR 1ESS, To A P02M IN TNZ DIMINO LINE RETWEEN WIN NOT 5 AND 6 IV SAID PLAN; THENCE IN A WESTERLY DIRECTION ALONG SID DIVIDING LIM, BOOTH 74 DEGREES 45 MINUTES MIT, 150 PEST, WO ME OR LESS, TO A POINT: TEEMCE ALONU LAND RE9SAVSD FOR. PARE PURPOBEG AND 2=66 AND IHMSS TO LOTS AS BROWN ON BALD PLAN, NORTH 14 DEGREES 13 1@mTES REST, 50 FEET TO A POINT, THE PLACE OF BEGINNING. BEING LOT NO. 6 ON PLAN Or LOTS ABOVE HVNI'IORED- TRACT No. 2: BEG2NNING AT A POINT IN m CENTER OF A PUBLIC ROAD LEADING TO OAR'S BR1'DOL AT LINE Or LOT NO. 6 ON THE EEAZZ106TER MENTIONED PLAN OF LOTS, rom ERLY ONNED BY ENANOER REALTY CMWANY: THENCE NON MMUDLY ALONO THE CANTER LIMB Or PAID PUBLIC Am. 50 FEET, MORE OR LESS, TO A POINT AT LIM Or LOT NO. 6 ON SAID PLAN OF LOTS, NOR OR rOPMFZT OWNED BY EARN. STONER AM IPA RREm11 TEENCE WROTRANDLY ALONG LIRE OF LOT NO. 6, 152 FRIT, MORE OR LESS, TO AN IRON PIN: TNENCE BOOTMMWLY AT RIORT ANGLES NITS SAID LINE, AMONG TWE CONOGUINET CREW AND ABOUT PAPALLRL TWJMTN, 50 FEB? TO AN IBM Pilo AT LINS OF SAID LOT NO. 6; TBCNCE EASTWARDLY ALONG LAST NENTIONEO LINE, 151 FEET NONE OR LESS, TO TIE PLACE Or BRGINNING. BEING LOT NO. 7 ON THE PLAN OF LOTS ABOVE MENTIONED. BEING THE EAts PEOPERTY CONVEYED TO DIANE M. SC'NALL, SINGLE WOMAN BY Dm PEON RICE LEA RorrnAR AND STEPRANIE A. ROMOM, RIB WIFE RSCORDED 06/05/1996 IN DEED BOOR 170 PAGE 194, IN TIE OFFICE OF TEE RECONDER Or DEEDS Or CLDIDERmm COMM, PENNSYLVANIA. sCHMULE "A" TAX IDO 10-16-1314-058 HOMEQ SERVICING DF795 November 8, 2005 DIANE M SCHALL 520 SALMON ROAD MECHANICSBURG, PA 17050 HOMEOWNERS NAME(S): DIANE M SCHALL PROPERTY ADDRESS: 520 SALMON RD MECHANICSBURG, PA 17050 LOAN ACCOUNT NUMBER: 0323106633 CURRENT LENDER/SERVICER: HomEq Servicing Corporation ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER EMERGENCY MORTGAGE ASSISTANCE PROGR AM (HEMAP) maybe able to help to save your home. This notice explains how the program works. To see if HEMAP can help you, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the counseling agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your county are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call 717-780-1869) This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICAION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PAPA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. HomEq Servicing Corporation is a debt collector. HomEq is attempting to collect a debt and any information obtained will be used for that purpose. THIS NOTICE CONTINUES ON THE NEXT PAGE M WACHOVIA HOMEOWNERNMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNERE MERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT") YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, • YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE Under the Act, you are entitled to a temporary stay of the foreclosure on your mortgage for thirty (30) days from the date of this notice. During that time you must arrange for and attend a "face-to-face" meeting with one of the consumer counseling agencies listed at the end of this notice. THIS MEETING MUST OCCUR WITHIN THE NEXT THIRTY (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES If you attend a face-to-face meeting with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take further action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer counseling agencies for the county in which your property is located are set forth at the end of this notice. It is necessary to schedule only one face-to-face meeting. Advise this lender/servicer immediately only your intentions. APPLICATION FOR MORTGAGE ASSISTANCE Your mortgage is in default for the reasons set forth later in this notice (see the following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender/servicer, you have the right to apply for financial assistance from the HomeownarEmergency M ortgage Assistance Program. To do so, you must fill out, sign and file a completed HomeownsrEmergency Assi stance Program Application with one of the designated consumer credit counseling agencies listed at the end of this notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a completed application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION Available funds for emergency mortgage assistance are very limited. Funds will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency (The Agency) has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Agency of its decision on your application. THIS NOTICE CONTINUES ON THE NEXT PAGE Page 3 NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIONAL PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date) NATURE OF THE DEFAULT The MORTGAGE debt secured by your property located at: 520 SALMON RD MECHANICSBURG, PA 17050 IS SERIOUSLY IN DEFAULT because: 1. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: a) Number of Payments Delinquent: 3 b) Delinquent Amount Due: $4,243.53 c) Late Charges: $20934 d) Recoverable Corporate Advances: $106.44 e) Other Charges and Advances: $0.0 I) Less funds in Suspense: $585.25 g) Total amount past due as of (due date): $3,974.06 2. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: (Do not use if not applicable) HOW TO CURE THE DEFAULT You may cure this default within THIRTY (30) day s from the date of this letter BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDERlSERVICER, WHICH IS $3,974.06 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier check, certified check, or money order made payable to HomEa and sent to: Regular Mail HomEq Servicing Corporation P. O. Box 70829 Charlotte, NC 28272 - 0829 Overnight Attn: Cash Central NC 4726 1100 Corporate Center Drive Raleigh, NC 27607-5066 You can cure any other default by takine the followine action within THIRTY (30) DAYS of the date of this notice (Do not use if not applicable) THIS NOTICE CONTINUES ON THE NEXT PAGE Page 4 IF YOU DO NOT CURE THE DEFAULT If you do not cure the default within THIRTY (30) days of the date of this notice, the lenderlservicer intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the opportunity to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS OF THE DATE OF THIS LETTER, HomEq Servicing Corporation also intends to instruct its attorneys to start a legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender/servicer refers your case to its attorneys, but you cure the delinquency before the attorney begins legal proceedings against you, you will still be required to pay the reasonable attorneys fees actually incurred up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attomey£ees actually incurred by the servicer even if they are over $50.00. Any attomey£ees will be added to the amount you owe the lender/servicer, which may also include other reasonable costs. If you cure the default within the THIRTY (301 DAY period, You will not be required to pav attornevs' fees. OTHER LENDER/SERVICER REMEDIES The lender/servicer may also sue you personally for the unpaid principal balance and all other sums due under the Mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE If you have not cured the default within the THIRTY (30) day period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriffsale You may do so by paving the total amount then past due plus any late charees other charges then due reasonable attomevs' fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff ale as specified in writing by the lender/servicer and by performing any other requirements under the mortgage Curing your default in the manner set forth in this Notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE It is estimated that the earliest date that such Sheriffsale of the mortgaged property could be hel d would be approximately five (5) months from the date of this notice. A notice of the actual date of the Sheri£fSal e will be sent to you before the sale. The amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender/servicer. HOW TO CONTACT THE LENDER/SERVICER BY TELEPHONE OR MAIL: Name of Lender/Servicer HomEq Servicing Corporation Contact Name PA Housing Response Specialist Address 4837 Watt Avenue, North Highlands, CA 95660-5170 Attn: PA Housing Response Team Telephone Number: 1-800-795-5125 FAX Number (916) 339-6940 for use by local counse ling agency to notify HomEq that the homeowner met with the agency. EFFECT OF SHERIFF'S SALE You should realize that a Sheriffsale will end y our ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffsale, a lawsuit to remove you and you r furnishings and other belongings could be started by the lender/servicer at any time. ASSUMPTION OF MORTGAGE You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt. THIS NOTICE CONTINUES ON THE NEXT PAGE Page 5 YOU MAY ALSO HAVE THE RIGHT • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT, OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT; • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF; • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THE RIGHT TO CURE YOUR DEFAULTS ANY MORE THAN THREE TIMES IN A CALENDAR YEAR;) • TO ASSERT THE NON-EXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS; • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER/SERVICER; AND/OR • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. THE CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED TO THIS LETTER If you received a discharge of the account through the Bankruptcy Court and if your account has not been reaffirmed, the acceleration and sale will not result in your being held personally liable for the debt and this letter is not an attempt to collect a personal debt. However, failure to pay the delinquent balance is necessary to avoid foreclosure. You are notified that this default, and any other legal action that may occur as a result thereof, may be reported by HomEq to one or more credit reporting agencies. Please take appropriate action with respect to the important matters discussed herein. Sincerely, HomEq Servicing Corporation Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Effective 8/18/2005 at 10:05:07 AM Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 1 (888) 511-2227 Community Action Commission of Capital Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17110 1 (800) 342-2397 19- SHERIFF'S RETURN - REGULAR CASE NO: 2006-01064 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WELLS FARGO BANK NA VS SCHALL DIANE M WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SCHALL DIANE M the DEFENDANT , at 1629:00 HOURS, on the 23rd day of February , 2006 at 520 SALMON MECHANICSBURG, PA 17050 by handing to DIANE SCHALL 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 18.00 Service 11.44 Affidavit .00 Surcharge 10.00 .00 39.44 Sworn and Subscribed to before me this !,,,,e- day of A. D. Proth ry/ So Answers: R. Thomas Kline 02/24/2006 MILSTEAD & ASSOCIATES By: Deput Sheriff MILSTEAD & ASSOCIATES, LLC BY: Chrisovalante P. Fliakos, Esquire ID No. 94620 220 Lake Drive East, Suite 301 Cherry Hill, NJ 08002 (856) 482-1400 Attorney for Plaintiff File No. 5.04750 Wells Fargo Bank, NA as Trustee, COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, Vs. ' No.: 06-1064 CIVIL TERM Diane M. Schall, Praecive to Dismiss the Mortgage Defendant. Foreclosure Action without Preiudice TO THE PROTHONOTARY: Kindly dismiss the above captioned Mortgage Foreclosure Complaint without Prejudice. MI TEAD & ASSOCIATES, LLC C 's an liakos, Esquire Attorney ID No. 94620 -?a "t7? r .? ??r z tG ??: ??. ?, C? ?C