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HomeMy WebLinkAbout02-6064WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO HOMESIDE LENDING, INC. Plaintiff vs. DALE L. STILES AND N1COLE L. STILES Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~'~ CIVIL ACTION- LAW ACTION OF MORTGAGE FORECLOSURE THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE You have been sued in court, l£you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the 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 claim in the Complaint o£ 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 AV1SO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECC1ON CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DEC1DIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE- S1 NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERV1CIO DE REFERENCIA DE ABOGADOS), (215) 238-6300. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER HOMESIDE LENDING, INC, Plaintiff VS. DALE L. STILES AND NICOLE L. STILES, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE THE FOLLOWING NOTICE IS BEING PROVIDED PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. 1601 The undersigned attorney is attempting to collect a debt owed to the Plaintiff, and any information obtained will be used for that purpose. The amount of the debt is stated in this Complaint. Plaintiff is the creditor to whom the debt is owed. Unless the Debtor, within thirty (30) days after your receipt of this notice disputes the validity of the aforesaid debt or any portion thereof owing to the Plaintiff, the undersigned attorney will assume that said debt is valid. If the Debtor notifies the undersigned attorney in writing with the said thirty (30) day period that the aforesaid debt, or any portion thereof, is disputed, the undersigned attorney shall obtain written verification of the said debt from the Plaintiff and mail same to Debtor. Upon written request by Debtor to the undersigned attorney within said thirty (30) day period, the undersigned attorney will provide debtor with the name and address of the original creditor if different from the current creditor. PURCELL, KRUG & HALLER 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney I.D.# 15700 Attorney for Plaintiff WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO HOMESIDE LENDING, INC., Plaintiff VS. DALE L. STILES AND NICOLE L. STILES, Defendants : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, WASHINGTON MUTUAL BANK, FA SUCCESSOR BY MERGER TO HOMESIDE LENDING, 1NC., is a Corporation, with an address of P.O. BOX 1169, DEPT. 2665 MILWAUKEE, WISCONSIN 53201. Defendant, DALE L. STILES, is an adult individual, whose last known address is 15 BELLMORE ROAD, CAMP HILL, PENNSYLVANIA 17011. Defendant, NICOLE L. STILES, is an adult individual, whose last known address is 15 BELLMORE ROAD, CAMP HILL, PENNSYLVANIA 17011. On or about, December 23, 1996, the said Defendants, executed and delivered a Mortgage Note in the sum of $86,800.00 payable to LONG ISLAND SAINGS BANK, FSB. The Said Note is not accessible to Plaintiff and is believed to have been lost. In further answer thereto, a copy is believed to be in the possession of Defendants. Plaintiff also avers that the within Mortgage foreclosure complaint is based upon the Mortgage and that the attachment of a copy of the Note is unnecessary pursuant to Rules 1019(h) and 1141(a) of the Pennsylvania Rules of Civil Procedure. Contemporaneously ~vith and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendants made, executed, and delivered to original Mortgagee, a certain real estate Mortgage which is recorded in the Recorder of Deeds Office of the within County and Commonwealth in Mortgage Book 1359, Page 453 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to HOMESIDE LEND1NG, INC. and recorded in the aforesaid County in Mortgage Book 541, Page 9. Washington Mutual Bank, FA is Successor by Merger to Homeside Lending, Inc. The Said Mortgage is attached hereto and marked Exhibit "A". The land subject to the Mortgage is: 15 BELLMORE ROAD, CAMP HILL, PENNSYLVANIA 17011 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendants are the real owners of the property. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on August 01, 2002 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE Interest at $17.34 per day From 07/01/2002 To 01/01/2003 ( based on contract rate of 7.750%) Accumulated Late Charges Late Charges $31.65 From 08/01/2002 to 01/01/2003 Escrow Balance Attorney' s Fee at 5% of Principal Balance TOTAL $81,683.13 $3,728.09 $284.71 $221.54 $122.98 $4,084.16 $90,124.61 ** Together with interest at the per diem rate noted above after January 01, 2003 and other charges and costs to date of Sheriff's 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 of a third party purchaser at Sheriff' s Sale. If the Mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged that are actually incurred by Plaintiff. 8. No judgment has been entered upon said Mortgage in any jurisdiction. 9. Notice of intention to foreclose and accelerate the loan balance pursuant to Pennsylvania Act No. 6 of 1974 is not required in that the original principal balance exceeds $50,000.00. 10. Defendants are not members 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. 11. The within Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act and, as such, is not subject to the provisions of Pennsylvania Act No. 91 of 1983. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned total amount due together with interest at the rate of 7.750% ($17.34 per diem), together with other charges and costs including escrow advances incidental thereto to,ate of Sheriff's Sale and for foreclosure and sale ,of the property within described. /~///~ ~/J~. By: ~' R Leo~P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) Oec-I?-Z00Z 1O:4Eam From-PPE}JIE~ ^D~TF^CT +TIT54~E163 T-51G p GI1/OI4 ~-55T When Recordsd Mall To: ONE #0965810 '97 jiti~ L~ E:~ i 53 ........... THE LONG ISLAND SAVINGS BANK, FSB ~ ~-- · /~ . -- .' ., , ~ PUflCHASE ltOftEy ~ ~ Cose ~o. Slale °f Pennsylvania ~ORT~AGE 441-5325917 DALE L ST~LES A~D NiCOLE L ST]LES, HUSBAND AND N]FE ~Bo~mwer').ThlsSecurll~ln~l~me~l~olvenlo THE LONG [SLAND SAV[MG5 BATIK, FSB whtc~lso~gsnlze~an~exJsan~unOorlhelsws~f THE UN[TED STATES OF AMERICA andwho:c~ddlec=l~ 201 OLD COUNTRY ROAD, NELV]LLE, NE~ YORK []747 [Le~der'l'B°rJo~r°'~es~n~mlheDrlnclp3lcumOI E]GHTY SEX THOUSArlD E[GtlT HUNDRED DOLLARS AND 00/100 Dollarst~.S $86,800.00 JThl~debllse~dence~ For ]ega] desc~p[ion see schedu]e "A" a[tached hereto and made a per[ hereof. Page 10I 4 pl~or to a IoreolOsU~C sale et the PIopa~ty or it:; acqu~Sllion by Lcflder, Borlo','.'er'~ account shall be credited with any batance remalfllflg 3, Application el paymentm All pa,/mcnls unde~ parag~Phs 1 ~n~ 2 shall be Bpplled by Lendcl as follow~: First. to thc mortgage Insurance premium to be paid by Lender ~o lbo Secrm~y or to the monlhiy charge by the Secretary instead el the ~ premiums, monthly morlgege Insurance premium; , special ascessments leasehold payment= or ground rent~, end fire flood and other hazard Insurance SC~ond. Io any taxes, ' Th~ ~o interest due under the Nole: ~ Id amortization el th~ principal el the Note; 9ub~equently e~eCted, against any hazards, casualties, 3nd conYngcncte~, Including fire, fDr whlch Lender requires In~ur~ncO. This insurance ~hall be malntamed m the amounts and Io~ the periods thaf Lender requtre~. ~orro~or $haIl atto insure ~1 Improvements on the Property. whether now In existence or ~ub.;equentty crcc~ed. Bgalnsl loss by IIood~ to the exlenl required by the S~cml~ry. All Insurance ~1~11 be carried whh companies ~pprovcd by Lender. The Insurance pollcle~ and any rencw~ls shall be held by Lendcr and shell ~nc[uda loss p~yeble clauses In laver el, and m a Iorm accDptab~e to, Lender. Io~= II not made p~ompt¥ by make p~ymcnt Io~ ;uch [ess d~mctly 1o Lends[, instead In the event el los~, Borrower ;holl gWe Lender imme~iale nollce by mail. Lender may m~ke prod[ el Borrower. E~ch Insurance company concerned ~ hereby aulhorlzed and directed to clm Borrowe~ 3nd to Lender Iolmly. All of any pO~[ el Ibc Insurance proceeds may be applied by Lander. at Ils o~tlon, either (a) to the reduction el Ihc Indebtedness under ~he Hotc ~nd this Securlly Instrument, first ~o ~ny dellnouent amount~ Bppfled In the ordB~ In paragraph - ' r re a r el he damaged Property. Any application el the proceed= ~ ..~ m.n o eteoevmem et plInclpal, or (b) to the ~e~torat~on ~ P .... ~hi~h ~fe re e red io In p~graph 2, or change such paymcms. Any cxce~s insurance p?oceeds over an amounl tequl~ed to pay all oUlstandln0 Indebtedness under 1he Note end this Security InsIrumCm ~hall be paid ~o 1he entlly legal¥ entitled thereto. I~lle and Imemst el Borrower In and to Insurance pollcio~ in Idms shall pass to thc purchaser, 5. Occu~n~, preservation. Maintenance ~nd ProteCtion el the properS; Botrower'~ Loon Appllcotlon; La.soho/ds. Borrower shaft occur, establish, and use the Property as Bo[rowe~ s principal residence within ~lxly day~ attar the exc~llon et Ibis Sec~ril/ Instrument and ~h~ll continue 1o occupy the Property e~ Borrower's pdncipa~ residence for ~t lea~l one yc~r oiler the data of o~pancy, untess the Secretary dctcrmlncs this requirement will cause undue he,al=hip Ior Borrower, or unless extcQuat[~0 circumstances e~Ist whld~ are beyond Bor~Owcr'~ control. Borrower shall ~ollly Lender= el any e~enuotlng circums[~ces. Bellower shall not commil wasle or destroy, d~age or substantially change the P~ope¢Iy or allow the Properly to deteri0rete, reasonable wear and tear ex~p~ed. ~nfl~ may mspact the Prepe~ ii the P~opcrty i~ v~cant or abandoned or thc Io~n I~ In doloult. Lender may ~ake reasonable adrien to ~rotect and preserve such vacant or ~bandoned Property. Borrower sh~l also be In dcIauIl II Borrower, during the Io~n appllcsUon p~oc~=, gave materially f~l~e Of Ina~Umte Inlormalion o~ statamenIs ~o Lender [or laiIcd to provide Lender with any maicdal Inlormation) In connection with thc lo~ evidenced by me Nom. Including. but not limited to, rcpresenlation~ concerning Borrower's occUpancY el ~he Property principal residence, II this Secu~I~ Instrument I~ on a leasahotd, Borrower sh~ll comply wlIh the provls~ons el ~he lease. II BorroWer acquires I~ ~ICe to the Property the Caseho[d ~nd Ice I~lla ~hB~I not ~ merged un~e~ Lender agrees to Ihs merger In wnl[ng, ' end proteCtion of Londer'~ Rights In the Propers- Bo~er ~hsIt pay all governmental or municipal 6. Charges to Borrower paragraph 2. Borrower shall pay ~hese obligations on time directly to the entity wh'ch charge~ ne= end impositlon~ that ~re not Include~ In Is owed the payment. I1 failure ~o pay wou'.d advecscly affect Lenders tntcres~ ~n the proper~, upon Lender's request Borrower promptly Iurni~h 1o Lender f~elpls evidencing these payments. - II Bonower I~lis to make these payments or the paymemS required by paragraph 2, or la~ls to parterre any other co~nant~ and agreements contained In this Security Instrument. of mere i~ ~ legal proceeding that may ~mgn~flc~ntly a1IccI Lender's ~lghls In Ihs Property [such as a preceding In b~nk,upmy. Ior condemnation or to enlorce laws or regulations], then LcRder may do and pay whatever ,. ., includln9 payment el taxC~, hazard Insurance and oth~r necessary Io protect the value el the property and Lender ~ fight~ m the Property, I~ems mentioned In peragraPh ~' Any amounl~ disbursed by Lende~ under thI~ paragraph shall become an additional debt el Borrower and ~ secured by this Security Instrument, These amount~ sha~l bear interest Item me d~te el dtsbu[se~enl, st the No~e rate, aQd ~t the optto~ el Lender, shaft be lmmedlote~ due and payable. - , ,~ ,~. dam~C$ direct or con~equemIol, In conncctloQ with any ~ndemn? place el condemna~on, ate hereby designed and shall be paid 7. Condemnation. Thc proceeds el any awa~o et c,a,.~ ,~. = or other tokln~ OI any pa~t o~ ~hc Property, or Io~ conveyance In Lendc~ that remains unpaid under thc Note and this Security Instrument, amounts ~ppllcd Ir, Note and this Secu~ny lns~ment, first ~o ~y delinquent proceeds t0 the reduction el thc Indcbtedn~c= under the application el the proceeds to the prln~p~l shall riel ~tend o~dsr provided ~n paragraph 3. and then to prcpaymen~ el prlnclpat. A~amgraph ~, or change the amount el such p~mentS. A~ postpone the due date el the monthly payments, which a~e rclerrCd ~o In and thio Security Instrument sha1[ ~ peld ~o thc proceed= eve, on amounl ~cqu~rcd Id pay ali ou~slanding Indebtedness under the Note Page 2 et 4 mail urlless applicable law requires use el anolher melhoO. The nollce shall be dlrocied to Ihe Property Address or a~y oIl~er a~ress Borrower deslgnale~ by notice Io Lender. ~y nallCa Io Lender shell be gl~an by lir~l cla~s mail Io LendeF~ address ~lale~ herein or any addre=s Lender deslgneles by nmlce ~ 8ortowet. ~y nollco provided lot In Ibis Security Ins[rumenl shall be deemeo Io have been given Borrower or Lender when ~lvon as prov~d~ In Ibis paragraph. 14. Governing ~w; 3e~erablJl~. This SecurlN Ins~tumenl shall be governed by leveret le,~ and I~e law el ~he jun~olcfion m which Ihe Pmper~ ~ located. Jn ~he even~ Ihat any p~ov~lon or cJau~e o~ Ih]~ Security Inat~umenl et Iha Nole confllcl~ wilh aPph~ble I~w, ~ucb con[Iici shell nol ellecl other provi~Jons el thl~ Secud~ I~sltume~l or Ihe Nole which can be given elJecl wilho~l ~he con/licking provIslo~. To {hi= en~ me provlsion~ el ~ls Securlly ln=trumont and {he Nole a~e decl3red to be severable. 15. Borrower'sCo~. B°rr°wer~halibeglvenoneconlotmed~p~oflhj~Securllyin~lrumem. 16. ~algnment et Rents. Borrower uncondlliona]ly ac=tgn~ and Ira~e/ere Io Lender alt fha rent~ and r~enu~ el the Propeny. Borrower eulhorlzes Le~da~ ~ Le~ar's egenls to collecl lhB te~l~ and revenue~ end hereby d~recl~ e~c~ len~RI el ~o Prope~ty Io ~y Ihe renla I~ Lender or [e~dar's 8ge~l~. Howe~er, pdor ~o Lendor'~ nollce lo Borrower o~ Borrower'= breach pi any cevenanl or agreemenl In lbo Security InSlfu~enl. Borrower ~haII conill a~ r~oJve ~11 ranis and revenu~ el Ihe P~opey~ ~ Ifu~l~e for Ihe beneilt of Lender and Bo~ro,..,er, This as,Jgnmenl el rents conSlllules an absalule asslgnmenl end riel a~ e~slgnmenl for Oddlllonal =ecudlv only. FHA Pennsylvania Mortgage. 5/95 __ 8910 Route 108, Columbia, Maryland 21045 ~IC~ELLE MYERS Agonl ~,.~CNWEALTH O F PEN NSYLVANIA. Cumb~rlan~ D~c-I?-lO§~ ID:4Fa~ Fram-PRE)~IER A~STR^CT +?17545~1~ T-516 P @14/0t4 F-55F Schedule A ALL T~L~T CERTAIn'! piece or parcel of land situate in Lower Allen Township,. Cu~rland County, Pennsylvania, bounded and described in accordance with a survey and plan thereof made by Gerrit J. Bets. R.$., dated June 19, 1974, as follows, to wit: BEGINMING at a point on the westerly line of Bellmore Rotd (50 feec wide) which said point is 159.76 feet north of the northwesterly corner of ~artzdale Drive and Belin%ore Road extended and at divising line between LOtS ~;OS. 8 and 9, BlocX K on ~he hereinafter mentioned Plan of Lots; thence along said dj.riding line South 47 degrees 40 minutes West 125.0 feet to a point; thence along the easterly line of Lots ~os. 13 and 14, Block }[, on said Plan North 42 degrees 10 minutes West 75.0 feet to a point at di-/iding line between Lots Nos. 7 and 8, Block K on said Plan; thence along safd dividing line !forth 47 degrees 40 minutes Bast 1~5.0 feet to a point on the westerly line of Bel!more Road aforesaid; thence along the westerly line of 3e!lmore Road Souch 42 degrees 20 minutes East 75.0 feet to a point, the place of Beginning. Eeing Lot ~;o. 8, Block K on the Plan of Country and Town Homes, Inc., recorded in Plan Book 7. page 41. ~eing known and numbered as 15 Beilmore Road. Under and Subject to restrictions, conditions and easements of prior record pertaining to said premises. Being she same premises which Robert A. Baldwin and Jean D. Baldwin, his wife, by their deed dated May 20th, 1987 and recorded Hay 21st, !987 in Cu~9~erland Councy Deed Rook R, Volume 32, page 225, grab%ted and conveyed unto Stanley E. Gipe and Betty ~. Gipe, ~is wife. And bein~ the same premises which Stanley E. Gipe and Betty E. Gipe, by her Attor~ey-!n-F~ct, Stanley E. Gipe, Husband & Wife by deed Deck.er 23rd, 1996 and which is intended =o be recorded herewish in the Cumberland County cfflce o~ the Recorder ot Deeds, ~ranted and conveyed onto Dale L. St~les and k?icole L. Stiles, Kusband & wife, Hortgagors 4,57 VERIFICATION I, the undersigned hereby verify that I am a representative of the plaintiff and I am authorized to make this Verification. I hereby verify that the facts set forth in the foregoing Complaint are true and correct to the best of my information and belief and that this statement is made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unswom falsification to the authorities. II~TE: Deos~13er 18, 2002 Name: Dean LaRocha Title: Asst. Secretary Company: Washington Mutual Bank FA - SHERIFF'S RETURN - REGULAR CASE NO: 2002-06064 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS STILES DALE L ET AL ROANLD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STILES NICOLE L the DEFENDANT , at 1818:00 HOURS, on the 30th day of December , 2002 at 15 BELLMORE ROAO CAMP HILL, PA 17011 DALE L. STILES, HUSBAND a true and attested copy of COMPLAINT - MORT FORE by handing to ADULT IN CHARGE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this /~ ~ day of  A.D. ! ~Prot~honotary So Answers: R. Thomas K~±ne ln/ 1/2oo2 PURCELL KRUG HALLER By: ~/ ~-- Deputy SheZriff SHERIFF'S RETURN - REGULAR CASE NO: 2002-06064 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS STILES DALE L ET AL RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon STILES DALE L the DEFENDANT , at 1818:00 HOURS, on the 30th day of December , 2002 at 15 BELLMORE ROAD CAMP HILL, PA 17011 by handing to DALE L STILES 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 18.00 Service 9.66 Affidavit .00 Surcharge 10.00 .00 37.66 Sworn and Subscribed to before me this ~ ~ day of j~ A.D. / ~rothonotary i / ~ So Answers: R. Thomas Kline 12/31/2002 PURCELL KRUG HALLER By: Deputy Sheriff WASHINGTON MUTUAL BANK, FA, Plaintiff VS. DALE L. STILES AND NICOLE L. STILES, Defendants IN THE CO~T OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-6064 Civil IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: P RA E C I P E Please mark the above matter Settled and Discontinued without prejudice. PURCELL, KRUG & HALLER By: DATE: February 5, 2003