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Home My WebLink About03-2167 MARK J. UDREN & ASSOCIATES BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 1040 N. KINGS HIGHWAY, SUITE 500 CHERRY HILL, NJ 08034 856-482-6900 ATTORNEY FOR PLAINTIFF GEMortgage Services, LLC, f/k/a GE Capital Mortgage Services, Inc. 3476 Stateview Blvd. Ft Mill, SC 29715 Plaintiff . . COURT OF COMMON PLEAS : CIVIL DIVISION . Cumberland County v. Jeffrey L. Frymoyer 312 Pinewood Drive Shiremanstown, PA 17011 Defendant(s) : NO, 03 - ~J(_ '1 CiCJll~Vll COMPLAINT IN MORTGAGE FORECLOSURE 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 wi thout 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 " AVISO Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta ascentar una comparencia escrita 0 en persona 0 con un abogado y entregar a la CQrte en for.ma escrita sus defensas 0 sus objeciones alas demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previa aviso 0 notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO o SI NO TIENE EL DlNERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 " NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom'the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. LAW OFFICES OF MARK J. UDREN /s/ Mark J. Udren, Esquire 1040 N. Kings Highway, Suite 500 Cherry Hill, NJ 08034 (856) 482-6900 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: United Savings Assn of Texas FSB Assignments of Record to: GE Mortgage Services, LLC, f/k/a GE Capital Mortgage Services, Inc. Recording Date: 08/17/92 Book: 424 Page: 1169 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant (s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R,C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 312 Pinewood Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Township of Lower Allen COUNTY: Cumberland DATE EXECUTED: 10/25/91 DATE RECORDED: 10/28/91 BOOK: 1032 PAGE: 1132 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortg~ge itemized below, shall be immediately due. 5. After demand, the Defendant (s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 04/26/03: Principal of debt due Unpaid Interest at 8.5% from 12/01/02 to 04/26/03 (the per diem interest accruing on this debt is $7.13 and that sum should be added each day after 04/26/03) $30,188.58 Title Report Court Costs (anticipated, excluding Sheriff's Sale costs) Escrow Overdraft/(Balance) (The monthly escrow on this account is $171.27 and that sum should be added on the first of each month after 04/26/03) 993.09 250.00 280.00 261. 74 Late Charges (monthly late charge of $39.39 should be added in accordance with the terms of the note each month after 04/26/03) Attorneys Fees (anticipated and actual to 5% of principal) TOTAL 118.17 1,509.43 $33,601.01 7. The attorney's fee 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 in accordance tith the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $33,601.01 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. ~ d . Mar J. U ren, Esqu1re, ESQUIRE MARK J. UDREN & ASSOCIATES Attorney for Plaintiff Attorney I.D. No. 04302 " ~L THAT CERTAIN PIECE OR PARCEL OF LAND SITUATE IN THE TOWNSHIP OF LOWER ALLEN, COUNTY OF CUMBERLAND AND STATE OF PENNSYLVANIA, BEING MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: BEGINNING AT A POINT ON THE SOUTHERN LINE OF Pl:NEWOOD DRIVE, SAID POINT BEING AT THE DIVIDING LiNE BETWEEN LOTS NOS. 7 AND 8 ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID DIVIDING LINE SOUTH 22 DEGREES 55 MINUl'ES EA,ST, ONE HUNDRED TWENTY-TWO AND SEVENTY-SEVEN HUNDREDTHS (122.77) FEET TO A POINT; THENCE NORTH 67 DEGREES 05 MINUTES EAST, NINETY (90) FEET TO A POINT AT THE DIVIDING LINE BETWEEN LOTS NOS. 8 AND 9 ON SAID PLAN; THENCE ALONG SAID DIVIDING LINE NORTH 22 DEGREES 55 MINUTES WEST, ONE HUNDRED TWENTY-TWO AND SEVENTY-FOUR HUNDREDTHS (122.74) FEET TO A POINT ON THE SOUTHERN LINE OF PINEWOOD PRIVE;THENCE CONTINUING ALONG THE SOUTHERN' LINE OP PINEWOOD DRIVE, SOUTH 67 DEGREES 05 MINUTES WEST, NINETY (90) FEET TO A POINT, .THE PLACE OF BEGINNING. BEING LOT NO.8, BLOCK liT" ON PLAN NO. 8 OF SHIREMAN MANOR EXTENSION, SAID PLAN BEING RECORDED IN THE CUMBERLAND COUNTY RECORDER I S OFFICE IN PLAN BOOK 23, PAGE 10.. '" UNDER AND SUBJECT, NEVERTHELESS, TO EASEMENTS APPEARNG ON RECORD IN SAID PLAN AND TO THE RESTRICTIONS AS SET PORTH IN CUMBERLAND COUNTY RECORDER'S OFFICE IN , MISCELLANEOUS RECORD BOOK 167, PAGE 435, AND TO AMENDED RESTRICTIONS AS SET FORTH IN MISCELLANEOUS RECORD BOOK 169, PAGE 685. " EXHIBIT A .Wells Fargo Home Mortgage, Inc. P.O. Box 1225 Charlotte, NC 28201-1225 111111111111111 ~ March 10, 2003 7100 4047 5100 2243 9b3b 0009069642/000 171/9311Ac'91 JEFFREY L fRY MOYER 312 PINEWOOD DR SI-llREMANSTOWN PA 17011 RE: Wells Fargo Home Mortgage, Inc. Loan Number 0009069642 Mortgagor(s): Mortgaged Premises: Jeffrey L. Frymoyer 312 Pillewood Dr. Shiremansto, PA 17011 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort2age 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 pae:es. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, 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 CounseHnr Agency. The name address and hone number of Consumer Credit Counse . A encies servo our County are listed at the end-of this Notice. vou have any Questions, yOU mav call the Pennsvlvania Housing Finance Ae:encv toll free at 1-800-342-2397. (Persons with impaired hearin$J can call (717) 780-1869). This Notice contains itnportant legal information. H 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 NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANClA, PUES AFECTA SU DERECHO " A CONTINUAR VIVlENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFlCACION OBTENGA UNA TRADUCCI0N INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYL VANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGmLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SAL V AR SU CASA DE LA PERDlDA DEL DERECHO A REDIMlR SU HIPOTECA. HOMEOWNER'S NAME(S): Jeffrey L. Frymoyer LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDERlSERVICER: ~~=~~~r17011 0009069642 PROPERTY ADDRESS: WELLS FARGO HOME MORTGAGE, INC. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE FA YMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE" ACT"), YOU MAY BE ELIGmLE FOR EMERGENCY MORTGAGE ASSISTANCE: · IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. · IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND · IF YOU MEET OTHER ELIGmILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEM RA YAY F F RE R -- Under the At.1:, you are entitled to a temporary stay o orec osure on your mortgage or t om' ( 0) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meetin with one of the consumer credit counse1in agencies listed at the end of this Notice. . .~~ DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MO~G.tiG~ ~~~j~~~~u 1. ST BRING YOUR MORTGAGE UP TO DATE. THE PART F HI "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINsHowro BRING YOUR MORTGAGE UP TO DATE. " AP~LI~nON F~R MORTG~ ASSISTANft;E - Your mortgage is in default for the reasons set ort ater in t is Notice (see 'onowing pages or specific information about the nature of your default.) If you have tried and are unable to rcsolve tliis problem with the lender, you have tlie right to apmY for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a comp'leted Homeowner's Emergency ASSistance Program Application with one of the desi~natea 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 submittinA..a complete applIcation to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of YOUT race-to-face mceting. . YOU MlISI FILE YOUR APPLICA nON PROMPTLY. IF YOU FAll. TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LElTER?!ORECLOSUm. MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICA lION FOR MORTGAGE ASSISTANCE WILL BE DENIED. 000171/936 9~CY ~~TI~N -- Available funds for emergency mortgage assistance are very limited. They will e 1S urse y t e Ageng under the eligibility criteria estabhshed by the Act. Tne Pennsylvania Housing Finance Agency nas sixty (60) days to make a decision after it receives your apphcation. 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 Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY.zJ'HE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES Ol"'lL Y AND SHOULD NOT BE CONSIDERED AS AN A ITEMPT TO COLLECT mE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage A~sistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (BrinK it up to date). ~ATURE OF THE DEFAULT.. The MORTGAGE debt held by the above lender on your property ocated at: 312 Pinewood Dr. Shiremansto,1:'1\ 17g11 IS SERIOUSLY IN DEFAULT ecause: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Tanl1ary 2D03 - March 2003 . $2,9 ~9 61 Other charges (explain/itemize\: Late Charges Other Fees (if applicable) Suspense AmOWlt TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION $78.78 $0.00 -JO.OO $3,0 8.39 ~OW TO CIJRP THE OF.FAIITT - - You may cure the default within THIRTY (30) DAYS ofthe ate of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER. WHICH IS $ 3,038.39, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Padments must be made either by cash, cashier's check, certified check or money order made payable an sent to: WELLS FARGO HOME MORTGAGE, INC. 1 HOME CAMPUS X2501-01H DES MOINES, IOWA 50328 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: IF YOU DO NOT CURE THE DEFAULT - - If you do not cure the default within THIRTY (30) DAYS at the date at thIS NotIce, the lender mtends to exercise its ri 18 to accelerate the mo e debt. This means that the entire outstan 109 a ance 0 t IS e t Wi e consI ere ue Imme ate y an you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made WIthin THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon vour mort2:ae:ed oropertv. IF THE MORTGAGE IS FORECLOSED UPON - - The mortgaged propertr will be sold by the Sheriff to pay aU the mortgage debt. it the Lender reters your case to Its attorneys, nut you cure the delinquency before the lender begins legal p'roceedings againstyoubyou will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50. o. However, if legal proceedings are started ap;ainst you, you will haveto pay all reasonable attorney's fees actually incurred by tne lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender.l.,which may al~o include oth~r reasonable costs. If you cure the default within the THIRTY (30) DA I oeriod, yOU wtll not be reauIred to pav attomev's tees. OTHER LENDER REMEDIES - - The lender may also sue you personally for the lmpaid principal balance and all other sums due under the mortgage. 000 171/936 EARLIEST POSSml.F, SHERIFF'S SALE DATE -- It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, 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. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Fax Number: Contact Person: Wells Fargo Home, Mortgage, Inc. 5024 Parkway Plaza Blvd. Charlotte, NC 28217 1-800-766-0987 704-423-4016 Tanisha Robinson EFFECT OF JHERIFF'S SALE -- You should realil.e that a Sheriff's Sale will end your ownership of the mortgage property and your right to occupy it. If you continue to live in the prope~ after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ mayor _ may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. 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 DEF AUL T flAg ~fb~D.f~6Dc&l~gS~iJklII~Ett~~\ltA~~'t~it\~ fI~~f&~~lHA VE CALENDAR YEAR.) · TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. · TO ASSERT ANY OTHER DEFENSE YOU BELIEVE Y~U MAY HAVE TO SUCH ACTION BY THE LENDER. · TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. . . APPENDIX C PENNSYL V ANlA HOUSING FINANCE AGENCY HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM CONSUMER CREDIT COUNSELING AGENCIES CUMBERLAND COUNTY CCCS of Western Pennsylvania, Inc. 2000 Linglestown Road Harrisburg, PA 17102 (717) 541-1757 FAX# (717) 541-4670 Financial Counseling Services of Franklin 31 West 3rd Street Waynesboro, PA 17268 (717) 762-3285 Urban League of Metropolitan Harrisburg N. 6th Street Harrisburg, PA 17101 (717) 234-5925 FAX# (717) 234-9459 YWCA of Carlisle 301 G Street Carlisle, PA 17013 (717)243-3818 FAX# (717) 731-9589 Community Action Conunission of the Capital Region 1514 Derry Street Harrisburg, P A 17104 (717) 232-9757 FAX# (717) 234-2227 Adams County Housing Authority 139-143 Carlisle St. Gettysburg, PA 17325 (717) 334-1518 FAX (717) 334-8326 It The Pennsylvania I-lousing Finance Agency can be reached TOLL FREE at 1 (800) 342-2397. V E R I F I CAT ION Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to.take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. H- Mark J. Udren, Esquire, ESQUIRE MARK J. UDREN & ASSOCIATES ~ !? '10. r '[ ~ _ Crt ~ ~ CY ~rr- t --< ~) ,....': ~ :~.. \. __..~ i . )>: .....; ... :~) .....~. :( ::::>- (r, ~ E I, " "I j SHERIFF'S RETURN - REGULAR CASE NO: 2003-02167 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GE MORTGAGE SERVICES LLC VS FRYMOYER JEFFREY L GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon FRYMOYER JEFFREY L the DEFENDANT , at 2100:00 HOURS, on the 14th day of May , 2003 at 312 PINEWOOD DRIVE SHIREMANSTOWN, PA 17011 by handing to JEFFREY L FRYMOYER 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 7.59 .00 10.00 .00 35.59 r~~ R. Thomas Kline 05/15/2003 MARK UDREN Sworn and Subscribed to before me this It ~ day of ~ /__ ~ A.D. *L- (j ~.~ othonotary By, ~ t)~ - Deputy S iff UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire, ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 ATTORNEY FOR PLAINTIFF GE Mortgage Services, LLC, f/k/a GE Capital Mortgage Services, Inc. COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County Plaintiff v. Jeffrey L. Frymoyer Defendant NO. 03-2167 Civil Term PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. Mark J. Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for Plaintiff DATED: Julv 26. 2006 '~' c')