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Home My WebLink About07-1943UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF 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 pleadings@udren.com Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas as Trustee by :CIVIL DIVISION Residential Funding Company LLC f/k/a Residential Funding :Cumberland County Corporation, Attorney in Fact 4828 Loop Central Drive Houston, TX 77081-2226 Plaintiff V. Kristy M. Bitting 205 Willow Mill Park Drive € NO. 67 `AG ??Vl? 4 / Mechanicsburg, PA 17050 Defendant(s) 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 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 GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. 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 quiere 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 o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las 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 previo aviso o notification. 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 o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO 0 SI NO TIENE EL DINERO 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. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 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: National City Mortgage Company d/b/a Accubank Mortgage Assignments of Record to: Deutsche Bank Trust Company Americas as Trustee by Residential Funding Company LLC f/k/a Residential Funding Corporation, Attorney in Fact Recording Date: LODGED FOR RECORDING 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: 205 Willow Mill Park Drive MUNICIPALITY/TOWNSHIP/BOROUGH: Silver Spring Township COUNTY: Cumberland DATE EXECUTED: 3/8/04 DATE RECORDED: 3/24/04 BOOK: 1857 PAGE: 4966 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 Mortgage 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 3/27/07: Principal of debt due $115,774.69 Unpaid Interest at 6.50 from 11/1/06 to 3/27/07 (the per diem interest accruing on this debt is $20.89 and that sum should be added each day after 3/27/07) 3,070.83 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $259.21 and that sum should be added on the first of each month after 3/27/07) (227 97) Late Charges (monthlyy late charge of $37.80 should be added in accordance with the terms of the note each month after 3/27/07) 151.20 Attorneys Fees (anticipated and actual to 50 of rinci 11 P Pa 5,788.73 TOTAL $125,162.48 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 with 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 $125,162.48 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. JNJ Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OF LAND WITH THE IMPROVEMENT THEREON ERECTED, SITUATE ON THE SOUTHEAST SIDE OF WILLOW MILL PARK DRIVE, SILVER SPRING TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, BEING LOT NO. 57 AND LOT NO. 58 "WILLOW MILL PARK" RECORDED IN PLAN BOOK 3, PAGE 7, BOUNDED AND DESCRIBED IN ACCORDANCE WITH A PLAN OF SURVEY BY WHITTOCK AND HARTMAN, DATED MAY 7,1981 AND BEARING FILE NO. WM-81-41 N. 8. NO. 686, AS FOLLOWS, TO WIT: BEGINNING AT AN IRON PIN ON THE SOUTHEAST SIDE OF WILLOW MILL PARK DRIVE (30 FOOT WIDE RIGHT OF WAY) AT A CORNER OF LOT NO. 59 OF THE ABOVE MENTIONED PLAN OF LOTS, SAID POINT BEING 51.71 FEET EAST OF THE SOUTHEAST CORNER OF WILLOW MILL PARK DRIVE AND A 20 FOOT WIDE RIGHT OF WAY; THENCE EXTENDING FROM SAID BEGINNING POINT AND ALONG WILLOW MILL PARK DRIVE, SOUTH 77 DEGREES 23 MINUTES 00 SECONDS EAST 103.42 FEET TO AN IRON PIN FOUND AT LOT NO. 56 OF THE ABOVE MENTIONED PLAN OF LOTS; THENCE EXTENDING ALONG SAME SOUTH 2 DEGREES 10 MINUTES 00 SECONDS EAST 96.67 FEET TO AN IRON PIN FOUND AT PROPERTY NOW OR FORMERLY OF ALDIE STIFLER; THENCE EXTENDING ALONG SAME AND ALONG LOT NO. 95, SOUTH 96 DEGREES 07 MINUTES 53 SECONDS WEST 100.04 FEET (SHOWN IN PRIOR DEED AS SOUTH 87 DEGREES 50 MINUTES 00 SECONDS WEST 100.00 FEET) TO AN IRON PIN AT LOT NO. 59 AFOREMENTIONED; THENCE EXTENDING ALONG SAME NORTH 2 DEGREES 10 MINUTES 00 SECONDS WEST 126.03 FEET TO THE FIRST MENTIONED IRON PIN AND PLACE OF BEGINNING. PARCEL #38-16-1072-008 Litton Loan Servicing LP P.O. Box 9010 Temecula, CA 92589-9010 Send Payments To: 2202793137 Litton Loan Servicing LP Attn: Cash Management Department P.O. Box 4387 Houston, TX 77210-4387 Send Correspondence To: Litton Loan Servicing LP Attn: Customer Assistance Response Team 4828 Loop Central Drive KRISTY BITTING Houston, TX 77081 205 WILLOW MILL PARK RD MECHANICSBURG, PA 17050 0"Es-, PRESORT First-Class Mail U.S. Postage and Fees Paid WSO 20070228-80 EXHIBIT A 0 Aitton Loan Servicing' 2/28/2007 KRISTY BITTING 205 WILLOW MILL. PARK RD MECHANICSBURG, PA 17050 4828 Loop Central Drive Houston, TX 77081 Telephone (800) 999-8501 Fax (713) 966-8906 www.littonloon.com ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an offldal Notice that the mor a on our home Is in default and the lender intends to foreclose. edfic information about the nature of the default is provided in the attached oases. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM may be able to help 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 on when ou meet with the Counseling Agency. The name, address, and phone number of Consumer Credit Counseling Agencies serving your County are lis ALrency ted at the end of the Notice. If on have a uestion von ma-v call the Penn lvania Housia Finance toll-free at (8001342-2397 Person with iu ) Aired head-no can n (73 7) 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 NOTIFICACION 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 11"MIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDS IIR SU HIPOTECA. M HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER Kristy Bitting 205 Willow Mill Park Rd Mechanicsburg, PA 17050 14504575 Contact Litton Loan Servicing LP CURRENT LENDERlSERVICER: Litton Loan Servicing LP 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 PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE 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 ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR W1THIII JTHE NEXT 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 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 names, addresses and telephone numbers of designated consumer credit counseling agencies for he county m which the propWy is located are set forth at the end of this schedule one `face-to-face meeting. Advise your lender immediately of your intentions. Notice. It is only necessary to APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see 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, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign, and file a completed Homeowner'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-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. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance 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 Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FMING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION 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 (Brim it un to date.) NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 205 Willow Mill Park Rd IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: 12/1/2006 through 2/1/2007 at $1,015.17 totaling $3,045.51 Other charges Late charges $113.40 Deferred late charges $196.81 NSF charges $0 .00 Deferred NSF charges $25.00 Suspense balance $390.32 TOTAL AMOUNT DUE AS OF THIS DATE $2,990.40 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION: Cure the default. HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $2,990.40 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check, or money order made payable and sent to: Litton Loan Servicing LP Attention: Cash Management Department P.O. Box 4387 Houston, TX 77210-4387 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 lender 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 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 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 refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fee that were actually R °,?1.r incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO C LM TAR DEF U- PRIOR TO cut RIFFS SALE - If you have not erred 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 Sheriffs Sale. You may do so by paying the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs connected with the foreclosure sale, and any other costs connected with the Sheriffs Sale as specified in writing by the lender 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 Sheriffs Sale of the mortgaged property could be held would be approximately 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: LITTON LOAN SERVICING LP Address: 4828 Loop Central Drive, Houston, TX 77081 Phone Number: (800) 999-8501 Fag Number: (713) 966-8906 Contact Person: Default Administration Department EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF - MORTGAGE - Under the terms of your mortgage and note, it may be possible to 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 ME-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 THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY 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 YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY CUMBERLAND COUNTY Acom Housing 14 S. 131h Street Adams County Interfaith Harrisburg, PA 17104 Housing Authority 40 E High Street 717.213.0150 Gettysburg, PA 17325 717.334.1518 Community Action Commission of Captial Loveship, Inc. Region 2320 North 51h Street 1514 Derry Street Harrisburg, PA 17110 717.232 2207 Harrisburg, PA 17104 . 717.232.9757 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 888.511.2227 Wranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 r.' .l It Fit ; 4: V E R I F I C A T I O N 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. Mark J. Udren, ESQUIRE UDREN LAW OFFICES, P.C. \J rv -r-? ; i 1 N i t'i I vi of-0 SHERIFF'S RETURN - REGULAR CASE NO: 2007-01943 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS BITTING KRISTY M 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 BITTING KRISTY M the DEFENDANT , at 1707:00 HOURS, on the 24th day of April 2007 at DUKE'S RIVERSIDE 313 FRONT STREET WORMLEYSBURGG, PA 17043 by handing to KRISTY BITTING 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 Service Affidavit Surcharge 5[a,3fo7 L?, 18.00 30.72 .00 10.00 .00 58.72 So Answers: R. Thomas Kline 04/26/2007 1 UDREN LAW OFFIC $ Sworn and Subscibed to By: A'1? /// before me this day ef of A.D. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF 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 Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas as Trustee by :CIVIL DIVISION Residential Funding Company ":.Cumberland County LLC f/k/a Residential Funding Corporation, Attorney in Fact Plaintiff NO. 07-1943 Civil Term V. Kristy M. Bitting Defendant PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. Mark Jren, Esquire UDREN SYOFFICES, P. C. Attorney for Plaintiff DATED:October 11. 2007 nvDIIi r-a C