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HomeMy WebLinkAbout07-0966RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) BRADLEY D. SISLEY, ESQUIRE STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 410 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY NovaStar Mortgage, Inc. 8140 Ward Parkway Kansas City, MO 64114 V. Jo A. Reichard Civil Action Number: 0"" - 96L 11-? U.L 5510 Silver Creek Drive Mechanisburg, PA 17050 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE CIVIL ACTION - MORTGAGE FORECLOSURE This is an attempt to collect a debt and any information obtained will be used for that purpose. NOTICE You have been sued in Court. If you wish to defend the claims set forth in the following pages, you must take action within twenty (20) days after this Civil Action and notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defense or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Civil Action or for any other claim or relief requested by the plaintiff. You may lose money or property of other rights important to you. YOU SHOULD TAKE THIS PAPER TO A 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. J:\Diane\COMPLAIN\NOVASTAR-REICHARD CUMBERLAND 2-07.doe IF YOU CANNOT AFFORD TO HIRE A LAWYER THIS OFFICE MAY BE 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 Bar Association 32 South Bedford Street Carlisle, PA 17013 800-990-9108 717-249-3166 J:\Diane\COMPLAIN\NOVASTAR-REICHARD CUMBERLAND 2-07.doe NOTICE PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. §1692 ET SEQ., YOU MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF YOU DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE YOU WITH WRITTEN VERIFICATION OF THE DEBT, AS WELL AS THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM THE CURRENT CREDITOR. OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. IF YOU DO NOT DISPUTE THE DEBT, IT IS NOT AN ADMISSION OF LIABILITY BY YOU. IF YOU NOTIFY US IN WRITING WITHIN THE THIRTY (30) DAY PERIOD, WE WILL CEASE COLLECTION OF THIS DEBT, OR ANY DISPUTED PORTION OF IT, UNTIL WE HAVE OBTAINED THE REQUIRED INFORMATION AND MAILED IT TO YOU. ONCE WE HAVE MAILED YOU THE REQUIRED INFORMATION, WE WILL CONTINUE THE COLLECTION OF THIS DEBT. THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR. THIS ACTION IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. J:\Diane\COMPLAIN\NOVASTAR-REICHARD CUMBERLAND 2-07.doc RICHARD F. STERN, ESQUIRE (03315) STEVEN K. EISENBERG, ESQUIRE (75736) BRADLEY D. SISLEY, ESQUIRE STERN AND EISENBERG, LLP THE PAVILION 261 OLD YORK ROAD, SUITE 4 f0 JENKINTOWN, PENNSYLVANIA 19046 TELEPHONE: (215) 572-8111 FACSIMILE: (215) 572-5025 (COUNSEL FOR PLAINTIFF) IN THE COURT OF COMMON PLEAS OF PENNSYLVANIA FOR CUMBERLAND COUNTY NovaStar Mortgage, Inc. 8140 Ward Parkway Kansas City, MO 64114 V. Jo A. Reichard 5510 Silver Creek Drive Mechanisburg, PA 17050 Civil Action Number: 67 Ql.lo COMPLAINT IN MORTGAGE FORECLOSURE Defendant(s) COMPLAINT CIVIL ACTION - MORTGAGE FORECLOSURE 1. Plaintiff is NovaStar Mortgage, Inc. (hereinafter referred to as "NovaStar")with offices located at 8140 Ward Parkway, Kansas City, MO 64114. 2. Defendant is Jo A. Reichard, an adult individual with a last-known address of 5510 Silver Creek Drive, Mechanisburg, PA 17050. 3. Under date of 08/17/2004, defendant executed and delivered to The CIT Group/Consumer Finance, Inc. a mortgage upon the premises 5510 Silver Creek Drive, Mechanicsburg, PA (the "Property")to secure the payment of the sum of $168,400.00 . The said mortgage is recorded in the Office for the Recording of Deeds in and for Cumberland County on May 31, 2005 at Bk. 1908, P. 4532 and is incorporated herein by reference as though set forth at length herein. A copy of the legal description of the premises is attached hereto and made a part hereof as Exhibit "A". J:\Diane\COMPLAIN\NOVASTAR-REICHARD CUMBERLAND 2-07.doc 4. By Assignment of Mortgage which has been sent for recording, and which is incorporated herein by reference, the loan was assigned to NovaStar Mortgage, Inc., the within Plaintiff 5. Said Defendant is the real owner of premises 5510 Silver Creek Drive, Mechanicsburg, PA 17050. 6. In accordance with Act 91 of 1983, as amended, a combined notice providing the information required by §403 of Act No. 6 of 1974, and Act 91, aforesaid, was sent to the defendant and no response was made in the appropriate period of time. A true and correct copy of the aforesaid notice is attached hereto and made a part hereof as Exhibit "B". 7. The said loan is in default as a result of the failure to pay the monthly installments of $1,790.16 due on November 1, 2006 and on the same day of each month thereafter. 8. The following is due on the loan: PRINCIPAL BALANCE .......................................................$164,695.35 INTEREST accrued thru 02/07/2007 of ...............................$5,697.75 Interest after 02/07/2007 shall accrue at the per diem rate of $44.57.) LATE CHARGES accrued thru 02/07/2007 of .....................$1,153.51 Late charges after 02/07/2007 shall accrue at the monthly rate of $72.56.) ESCROW ADVANCES ........................................................$1,316.90 OTHER CHARGES .............................................................. $56.50 NSF/BANK FEES ................................................................. $60.00 FEES BILLED .......................................................................$52.50 COSTS ...................................................................................300.00 ATTORNEY'S FEE .............................................................. $7,000.00 TOTAL .................................................................................. $180,332.51 The attorney 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 Sale, reasonable attorney fees will be charged based on work actually performed. WHEREFORE, Plaintiff, NovaStar requests this Court to enter judgment for foreclosure of the mortgaged property for the sum of $164,695.35 plus interest thereon of $5,697.75 plus $44.57 J:\Diane\COMPLAIN\NOVASTAR-REICHARD CUMBERLAND 2-07.doc . per day from 02/07/2007 until judgment is paid in full, late charges of $1,153.51, plus late charges of $72.56 per month from 02/07/2007 until judgment is paid in full, escrow advances of $1,316.90, fees billed of $52.50, costs of $300.00, attorney's fees of $7,000.00 and all other amounts set forth above, less any suspense as set forth above, together with record costs and any other amounts to which Plaintiff is entitled to recover. STERN AND EISENBERG LLP BY: EI BERG, ESQUIRE Attorney for Plaintiff J:\Diane\COMPLAIN\NOVASTAR-REICHARD CUMBERLAND 2-07.doc VERIFICATION Nicole Taylor is the Foreclosure Specialist of NovaStar Mortgage, Inc. and is authorized to sign this Verification on behalf of same, and states that he verifies the foregoing Civil Action-Mortgage Foreclosure against Jo A. Reichard and avers the _ statements of fact therein contained are made subject to the penalties of 18 PA C.S. §4904 relating to the unworn falsification to authorities, and that same are true upon the signer's personal knowledge or information and belief. NICE TAYLOR Foreclosure Specialist DATE: It I L4 -1 OM 2, ALL THAT CERTAIN tract of land situate in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the Northern right-of-way line of Silvercreek Drive, said point being located a distance of 551.86 feet West of the dedicated right-of-way line of Jerusalem Road and at the dividing line between Lot No. 5 and Lot No. 6; thence by the Northern right-of-way line of Silvercreek Drive, South 61 degrees 00 minutes 00 seconds East a distance of 100.00 feet to a point at the dividing line between Lot No. 6 and Lot No. 7; thence by said dividing line, North 29 degrees 00 minutes 00 seconds West a distance of 150.00 feet to a point at lands now or formerly of Horner; thence by the same, North 61 degrees 00 minutes 00 seconds East a distance of 100.00 feet to a point at the dividing line between Lot No. 5 and Lot No. 6; thence by said dividing line, South 29 degrees 00 minutes 00 seconds East a distance of 150.00 feet to a point, the place of BEGINNING. BEING Lot No. 6, Block A and CONTAINING 15,000.00 square feet as shown on Final Subdivision Plan #4, Creekview, recorded in Plan Book 35, Page 92. HAVING thereon erected a brick and aluminum two-story dwelling house known and numbered as 5510 Silvercreek Drive, Mechanicsburg, Pennsylvania. BEING the same premises which Steven R. Snyder and Jo A. Snyder, now known as Jo A. Reichard, former husband and wife, by Deed dated July 14, 2004 and recorded August 13, 2004 in Deed Book 264 Page 3452, granted and conveyed unto Jo A. Reichard, in fee. E O"BR A y:r Jaaaary 4, 2007 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Tics b an official ROM that the mortgage on Your 112102 is in default, and the lender 131aft to fendam Speeitie lnforasatioa about the nature of the debnlt is provided in Me-Rig ched panes. The HOMLOW=S MORTGAGE ASSISTANCE PROGRAM (HEM[Af) may be abk to help to save vozr home. This Notice a _ bm the nroeram works. T Wn R HEMAP can help. you must MEET WrM A CONSUMER CREDIT BIN 30 DAYS OF THE DkTE OF THIS NOTICE. CcxnaSELING AGENCY WIT Take this Ngft with you when von mad with the Counseling Agency. The carm address and phone aunber of Conmmer Credit Counseling Agencies serving your Comty are listed at the end of this Notice. If von have any auesdons, you may call the Psansylyania Housing Finance Amoy toll- fee at 1-84Q-342_2397. tPersoas with impaired hearing can call 717-7WA8119) This Notice contains i10portant legal information. If you have any questions, representatives at the Consnaer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney In your area. The local bar associntion may be able to help you find a lawyer. LA NOTWICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA? (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERIDA DEL DERECHO A REDBMR SU HIPOTECA. 8 HOMEOWNER'S NAME: PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: JO REICHARD 5510 SILVER CREEK DR MECHANICSBURG, PA 17050 1470392 NOVASTAR MORTGAGE INC. NOVASTAR MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE W_ RICH CAN SAYE YOUR HOME FROM AND KELP YOU MAKE M= M GE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S LMERGENCV MORTGAGE ASSISTANCE ACT OF 190 (M "ACT") YOU MAY BE EI.IGEBL19 FOR EMERGENCY MORTGAGE ASSISTANCE: # IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, 0 IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND + IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a tenarporary stay of forecloscme on your mortgage for thirty (30) days from the date of this Notice- During that time you must arrange rod a#cnd a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS NEE" MM MUST OCCUR W1TH1N THE NEXT Q0 DAYS IF YOU DO NOT APPLY FOR EMERGENCY MORTUAGE ASSISTANCE. YOU MUST MM YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO $ JJMORTGAGE UP TO ATE. CONsumg CREDIT COU14SELING AM If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The nama addresses and telcnhone members ofNiga carmumer c m& oounwJms arteaoies for the county in which the PE%M y is located are set fortb at the end of this Notice. It is only necessary to scbcdnle one fact-to-face meeting. Advise your lender immediately of your intentions. APPLIC QN FOR MORTGAGE ASSISTANCE Your mortgage is in default for the reasons set forth later m this Notice (see following pages for specific mformation about the nature of your defauh.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Assistance Mortgage Assistance Program To do so, you must fill out, sign and file a completed Homaownc s Emergency Assistance 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 complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-facx meeting. YOU 1401ST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW TSE OTBER THYME PERIODS SET FORTH Hai THIS LETTER, FORZCLOSURZ MAY PR OCE1m AGAINST YOUR HOME IIIIIYIEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENUM AGENCY AMOON-Availsbie fiends for emaSeacy mortgage ours mm are very hmft& They will be disbursed by the Agency wider the ehgMty criteria establid ed by the Act The Peansyhmma housing Fkmw Agency has sixty (60) days to mobs a decision alter it receives your application. Daring that &ae, no forecloaa:e proceedings will be pmmwd spioat you if you have met the time tequironcuu set forth above. You wilt be notified dirocdy by the Pa wsylvania Beasigg F'manoe Agency of its decision on your tpp NOTE: IF YOU ARE CURRII gTLY PROTECTED BY TEE FILING OF A PETITION IN SANKRUPI'CY, THZ FOLLOW11NG PART OF THIS NOTICE IS FOR INFORMATION PURPOSFS ONLY AND SHOULD NOT BE CONS1DEUD AS AN ATTEMPT TO COLLzC'T TIM DEBT. (if you have filed bankruptcy you an still apply for Emergency Mortgage AuWance.) How TO CURE YOUR MORTGAGE DEFAULT (Bdntt it stn to date )w NATURE OF THE DEFAULT-The MORTGAGE debt held by the above lender on your property located at 5510 SELVER CREEK DR MECHAMCSBURC% PA 17050 IS SERIOUSLY IN DEFAULT bw we of NONPAYMENT YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following am w to are now past due: 1110UM6 tlrougb 01MM9 Odter charges (exp]ainlitemixa): 6611.83 Corporate advitiva: MS TOTAL AMOUNT PAST DUE: 666633 HOW TO OM THE DEFAULT_You may cane the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO TEE LENDER, WHICH IS $6668.33, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DUMG THE THIRTY (30) DAY PERIOD. ftmo?ts imust be made tither by ashwes clieck certified check or money order made =Mbk and aces W. Attn lei vi : Cash wil tas Mami l e BI D Wad ParimL Spite 300 KLuM Ot L MO 6 4114 IF YOU DO NOT CURE THE DEFAULT-If you do not cum the default within THIRTY (30) DAYS of the date of this Notice, the kder intends to exmiw its dit to accclerate the mattttue- debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly inssllmews. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the leader also intends to instruct its attorneys to start legal action to foL=kse open your mott¢aned trroyerty. 1Z = MORTGAGE is FORR+CL(MM ETION The mortgaged property will be sold by the Sberiff to pay off the mortgage debt. H the lender refers your case to As attorneys. but yon cage the dchmqucwY before the lender begins kgal proeeediop against you, you wall stall be requited to pay the tmsooable at uoy'a fees do were a kany incurred, up to 150.00. However. if legal prooadnegs are stated against you, ym win have to pay all reasonable attorney's fees actually incurred by the katder eves if they a mead 550.00. Any attorney's fees wM be added to the amount you owe the leader, which may ahw include other reaeooame, costs. if nq come the tiefauk aikYim the THMW 1301 DAY tteriod. vow will mot be reataind toatbsrmev's fm Ord I.F.NDIIM RE -Yw lends may ab o sue you personally for the unpaid prmcgW balance and ail other sums doe under Go mortgage. RIGHT TO CURE THE DLFAULT PRIOR TO SHERBF'S SALE-If you have not cured the default within the TH RTY (30) DAY period and fareclorme proceedings have begum, you still ve the riafit to cum the ,tt:.,,tr - me 5>a at atav time um m one borax before the Sherift Sale. You MU do m by FFARLEST SHERIFF'S SALK DAIZ-h is estimated that the earliest date that such a Mw i$s Sale of the mortgaged p Wmty cotdd be bold woaW be appraoiv ? 4s tb firm the date of tbk Nwke. A notice of Ow actual date of the Sha f s Sale wall be seat to you before the sak. Of course, the amount neWed to case the def hilt will increase the longer you wait. You may find out at any tune exactly what the required payment or action will be by contacting the leader. HOW TO CONTACT THL LENDER: Name of Lender. NovaStar Mortgage, Inc. Address: 8140 Wand Partway, Suite 200 Kansas City, MO 64114 Phone Number: (888) 289-1208 Fax Number: (816) 627-5854 Contact Person: Collections EFFECT OF SHRHr-6 SAIL-You should teali= that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you coubnw to live in the property after the Sheriff's Safe, a lawsuit to remove you and your famishings and other belongings could be slatted by the larder at any time. ASSUMPTION OF MORTGAGE-You array not sell or transfer your home to a buyer or transferee who will assume the mortgage debt provided that alt the outatand- payments, charges and attorney's foes and costs are paid prior to or at the sale and that rho other rcqukcn" of the mortgage are saddled. ' Y E MAY ALSO HAVE THERIGHT d TO SELL TIRE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOT=R LENDING IIrTMl U 11ON TO PAY OFF THIS DEBT. O TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. a TO HAVE THE MORTGAGE RESTORED TO THE SAME POSMON AS IF NO DEFAULT HAD OCCURRIA IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN TIDIES TIMES IN ANY CALENDAR YEAR) O TO ASSERT THE NONEXISTXNCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. $ TO ASSERT ANY OTEM DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER 41 TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY (plmu see atbwhed docamest) PREVIOUS CHARM AJ DAMRU!'7+CY: In the event that dte undslyft debt bu been dWcbwpd as a mnk of a prier bwkm"p L NouStw Mw- bm" admw4 dps that it is not miesging pon aW liability for da: debt to the borrowe*) aid dart its reoornte in coAeetim ma0m AM be United to dre cousin g de wiW in &c seaaity butr ommit. If you bsve previously roxived a dit pl a in bo*rupicy, 0& cmrcq m&we is not and dmH not be comomd b be si auunpt to colleet a debt, but only ado- mt of a lien wing property Ws lefts is vuitlen u ere sLtm4t to ceNed a debt sod sly b&nmfim obteioed wwll be awed for drt purpose skocrelys NovaStw Mortgage, Inc HEMAP Consumer Credit Counseling Agencies CUMERLAND County pAWk d upd . llAGWW3:48:15 PIA Adwm County kftrfS tl? Nash MMwlltr 40 E Hib SWd G*Mpbu% PA 17325 717,384.1518 CCC8 of MwMdm PA 2000 Lkgkd m Raid HmMmW PA 17102 8!8.511.2227 Cam malty AcOmCcawnWim at COP" PAO= 1514 0MY SNd Hwddm& PA 17104 717232MV Lorwl,w kw- 2.920 NoM Sh StrMt HwdWx rp, PA 17110 717232.2207 Me M-" 43 KkAdpMa Arno +w V%pwboro. PA 4'1268 717.782.3286 PHFA 211 NcM Find Stroel Hwdtbwy. PA 17110 717.7GM3W0 800.342.2397 r^ n y rv a N O 47- w ? 3? `71'f'1 c'°ta. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION-LAW STEVEN K. EISENBERG, ESQUIRE STERN AND EISENBERG The Pavilion 261 Old York Road, Suite 410 Jenkintown, PA 19046 (215) 572-8111 I.D. #75736 NovaStar Mortgage, Inc. 8140 Ward Parkway Kansas City, MO 64114 VS. NO.07-966 Civil Term Jo A. Reichard ORDER TO SETTLE, DISCONTINUE AND END To the Prothonotary: Kindly mark the above captioned matter as settled, discontinued and ended, upon payment of your costs only. STERN AND EISENBERG BY: STEV K. ISENBERG Attorney for Plaintiff ` ? t r x x r CIO / SHERIFF'S RETURN - REGULAR CASE NO: 2007-00966 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NOVASTAR MORTGAGE INC VS REICHARD JO A BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE REICHARD JO A DEFENDANT the at 1725:00 HOURS, on the 22nd day of March , 2007 at 6314 SALEM PARK CIRCLE MECHANICSBURG, PA 17050 JO REICHARD was served upon by handing to 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 21.12 Affidavit .00 Surcharge 10.00 .00 ?f ??4Ip? 49.12 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 03/27/2007 STERN & EISENBE r" By: y _. / Deputy Sheriff A. D.