HomeMy WebLinkAbout03-3142BANKERS TRUST COMPANY, AS CUSTODIAN IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CiVIL ACTION- LAW O,J J,.~l qJ,~
KENNWOOD LOSH A/K/A KENWOOD LOSH
AND SUSAN K. LOSH
Defendants
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. If 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
cl~trn in the Complaint of 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
AVISO
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 NECESSAPdO QUE USTED, O SU ABOGADO,
REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION
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, DECID1R 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 LIN ABOGADO IMMEDIATEAMENTE.
SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERV1CIO DE REFERENC1A
DE ABOGADOS), (215) 238-6300.
CUMBERLAND COUNTY LAWYER REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
BANKERS TRUST COMPANY, AS
CUSTODIAN,
Plaintiff
VS.
KENNWOOD LOSH A/K/A KENWOOD LOSH
AND SUSAN K. LOSH,
Defendants
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION- LAW
ACTION OF MORTGAGE FORECLOSURE
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff, BANKERS TRUST COMPANY, AS CUSTODIAN, is a Corporation, acting through its
servicing agent of Saxon Mortgage, Inc., with an address of P.O. Box 161489, Fort Worth, Texas 76161.
2. Defendant, KENNWOOD LOSH AfK/A KENWOOD LOSH, is an adult individual, whose last known
address is 43 SUBDIVISION ROAD, NEWVILLE, PENNSYLVANIA 17241. Defendant, SUSAN K.
LOSH, is an adult individual, whose last known address is 43 SUBDIVISION ROAD, NEWVILLE,
PENNSYLVANIA 17241.
3. On or about, August 2, 2001, the said Defendants, executed and delivered a Mortgage Note in the sum
of $121,100.00 payable to SAXON MORTGAGE, INC., which Note is attached hereto and marked
Exhibit "A".
Contemporaneously with 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 1729, Page 4806 conveying to original Mortgagee the subject
premises. The Mortgage was subsequently assigned to BANKERS TRUST COMPANY, AS
CUSTODIAN and recorded in the aforesaid County in Mortgage Book 680, Page 50. The Said
Mortgage and Assignment are incorporated herein by reference.
5. The land subject to the Mortgage is: 43 SUBDIVISION ROAD, NEWVILLE, PENNSYLVANIA
17241 and is more particularly described in Exhibit "B' attached hereto.
6. The said Defendants are the real owners of the property.
7. The Mortgage is in default due to the fact that Mortgagors have failed to pay the installment due on
February 01, 2002 and all subsequent installments thereon, and the following amounts are due on the
Mortgage:
UNPAID PRINCIPAL BALANCE
Interest at $42.29 per day
From 02/01/2002 To 08/01/2003
( based on contract rate of 12.750%)
Accumulated Late Charges
Late Charges $65.80
From 02/01/2002 to 08/01/2003
Escrow Balance
Attorney's Fee at 5% of Principal Balance
TOTAL
$120,980.91
$23,O90.34
$0.00
$1,184.40
$0.00
$6,049.05
$151,304.70
**Together with interest at the per diem rate noted above after August 1, 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. Plaintiff has complied with the procedures required by Pennsylvania Act 91 of 1983 (Homeowners'
Emergency Mortgage Assistance Payments Program) and Defendants have either failed to meet the time
limitations as set forth therein or have been determined by the Housing Finance Agency not to qualify
for assistance.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure "IN REM" for the aforementioned
total amount due together with interest at the rate of 12.750% ($42.29 per diem), together with other charges
and costs including escrow advances incidental thereto to the date of~heriff s Sale and for foreclosure and sale
of the property within described.
Leon P. Haller, lt~uire
Attorney for Plaintiff
I.D. # 15700
1719 N. Front Street
Harrisburg, PA 17102
(717-234-4178)
BANKERS TRUST COMPANY, AS
CUSTODIAN,
Plaintiff
VS.
KENNWOOD LOSH A/tCdA KENWOOD LOSH
KENNWOOD AND SUSAN K. LOSH,
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
11382937
ADJUSTABLE RATE NOTE
(LIBOR INDEX-RATE CAPS)
3-YEAR/6-MOi~TH LIBOR ARM
NON-CONFORMING
THIS NOTE CONTAINS PROVISIONS ALLOWING FOR CHANGES IN MY INTEREST RATE AND
MY MONTHLY PAYMENT. MY ADJUSTABLE INTEREST RATE CAN NEVER EXCEED OR BE LESS
THAN THE LIMITS STATED IN THIS NOTE.
August 21413 , 2001
42, Subdivision Road
Newville, Pennsylvania 17241
MaConnellsburg PA
[Cto,] [State]
[ProperO, ~4ddre.u]
I. BORROWER'S PROMISE TO PAY
In ~etum for a loan that I have received, I promise to pay U.S. $ 121,100.00 (this amount is called "principal"),
plus interest, to the order ofthe Lender· The Lender is
Saxon Mortgage, Inc.
I understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is
entitled to receive payments under this Note is called the "Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of principal has been paid. I will pay interest at a yearly
rate of 12.750 %. The interest rate I will pay may change in accordance with Section 4 of this Note.
The interest rate required by this Section 2 and Section 4 of this Note is the rate I will pay both before and alter any default
described in Section 7(B) of this Note.
3. PAYMEWfS
(A) Time and Place of Payments
I will pay principal and interest by making payra~nts every month.
I will make my monthly payments on the first day of each month b~ginning on O=tober 1ST ,2001
I will make these payments every month until I ha~e paid all of the principal and interest and any other charges described
below that I may owe under this Note. My monthly payments will be applied to interest before principal. If, on
September iST , 2031 I still owe amountS under this Note, I will pay those amounts in full on that date,
which is called the "Maturity Date."
I will make my monthly payments at 4880 Cox Road, Glen Alien, Virginia 23060, or at a different place if required by the
Note Holder.
(B) Amount of My Initial Monthly Payments
Each o f my in i rial monthly payments will be in th e amount of U.S. $ 1,315.99
· This amount may change.
(C) Monthly Payment Changes
Changes in my monthly payment will reflect changes in the unpaid principal of my loan and in the interest rate that I must
pay. The Note Holder will determine my new interest rate and thc changed amount of my monthly payment in accordance with
Section 4 of this Note.
4. ADJUSTABLE INTEREST RATE AND MONTHLY PAYMENT CHANGES
The interest rate I will.pay may change on the first day of $e.pt:e,mher .
, 2004 , and on the first day of every
(C) Calculation of Change
Before each Interest Rate Change Date, the Note Holder will calculate my new interest rate by adding
Seven end 375/1000 percentage point(s) ( 7. 375 %) to the
Current Index. The Note Holder will then round the result of this addition up to the nearest one-eighth of one percentage point
(,I25%). Subject to the limits stated in Section 4(D) below, this rounded amount wi[i be my new interest rate until the next
interest Rate Change Date.
The Note Holder will then determine the amount of the monthly payment that would be sufficient to repay the' UF. paid
principal that I am expected to owe at the Interest Rate Change Date in full on the Maturity Date at my new interest rate in
substantially equal payments. The result of this calculation will be the new amount ofmy monthly payment.
(D) Limits on Interest Rate Change
The interest rate I am required to pay at the first Interest Rate Change Date will not increase by more than 1% from the
initial interest rate, and will not decrease below the Minimum Rate stated below. Thereafter, my interest rate will never be
increased or decreased on any single Interest Rate Change Date by more than one percentage point (I %) from the rate of interest I
have been paying for the preceding six months, and in no event will be less than the Minimum Rate stated below,
My interest rate will never be greater than ~l.~.netema and 750/1000
percent ( 19. 750 %) which is called the "Maximum Rate." My interest rate will never be less than
Twelve and 750/1000 percent ( 12. 750 %) which is called the "Minimum Rate."
(E) Effective Date of Change
My new interest rate will become effective on each Interest Rate Change Date. I will pay the amount of my new monthly
payment beginning on the first monthly payment date after the Interest Rate Change Date until the amount of my monthly
payment changes again.
(F) Notice of Change
The Note Holder will deliver or mail to me a notice of any change in my interest rate and the amount of my monthly
payment before the effective date of any change. The notice will include information required by law to be given me and also the
title and telephone number of a person who will answer any question I may have regarding the notice.
5. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of principal at any time before they are due. A payment of prlncipal only is known as a
"prepayment." When I make a prepayment, I will tell the Note Holder in writing I am doing so.
I may make a full prepayment or partial prepayments without paying any prepayment charge. The Note Holder will use all
of my prepayments to reduce the amount of principal that I owe under this Note. Ill make a partial prepayment, there will be no
changes in the due dates of my monthly payments unless the Note Holder agrees in writing to those changes. My partial
prepaymem may reduce the amount of my monthly payments after the fa'st Interest Rate Change Date following my partial
prepayment. However, any reduction due to my partial prepayment may be offset by an interest rate increase.
6. LOAN CHARGES
Ifa law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the interest or other
loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (i) any such loan charge
shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (ii) any sums already collected from me
that exceeded permitted limits will be refunded m me. The Note Holder may choose to make this refund by reducing the principal
I owe under this Note or by making a direct payment to me. Ifa refund reduces principal, the reduction will be treated as a partial
prepayment.
7, BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charges for Overdue Payments
ffthe Note Holder has not received the full amount of any monthly payment by the end of 15 calendar days after
the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be $. 000 % of my
overdue payment of principal and interest. I will pay this charge promptly but only once on each late payment.
(B) Default
(E) Paymant of Note Holder'!
Expenses
if the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the right to be
paid back by me for ail of its costs and expenses in enforcing this Note to the extent not prohibited by applicable law. Those
expenses include, for example, reasonable attorneys' fees.
8. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by
delivering it or by mailing it by first class mail to me at the Properly Addres~ above or at a different address ifI give the Note
Holder a notice of my different address.
Unless the Note Holder requires a different method, any notice that must be given to the Note Holder under this Note will be
given by mailing it by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I
am given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
lfmore than one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this
Note, including the promise to pay the full amount owed. Any person who is a guarantor, surely or endorser of this Note is also
obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, surety or
endorser of this Note, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights
under this Note against each person individually or against all of us together. This means that any of one of us may be required to
pay all of the mounts owed under this Note.
In the event any provision of this Note is finally determined to be invalid or unenforceable by a court of competent
jurisdiction, such determination shall not affect the validity or enforceability of any other provision.
10. WAIVERS
I and any other person who has obligations under this Note waive the rights of presentment and notice of dishonor.
"Presentment" means the right to require the Note Holder to demand payment of amounts due. "Notice of dlshonor" means the
right to require the Note Holder to give notice to other persons that mounts due have not been paid.
I 1. UNIFORM SECURED NOTE
This Note is a uniform instrument with limited variations in some jurisdictions. In addition to the protections given to the
Note Holder under this Note, a Mortgage, Deed of Trust or Security Deed (the 'Security Instrument"), dated the same date as this
Note, protects the Note Holder from possible losses that might result if I do not keep the promises which I make in this Note.
That Security Instrument describes how and under what conditions I may be required to make immediate payment in full of ail
amounts I owe under this Note. Some of those conditions are described as follows:
Transfer of the Property. If all or any part of the Property or any interest in it is sold or ~ransferred without Note Holder's
prior written consent, Note Holder may, at its option, require immediate payment in full of all sums secured by this Security
Instrument. However, this option shall not be exercised by Note Holder if exereise is prohibited by federal law as of the date of
this Security Inslrument. Note Holder also shall not exercise this option if: (a) I submit to Note Holder information required by
Note Holder to evaluate the intended transferee as if a new loan were being made to the transferee; and 0a) Note Holder
reasonably determines that Note Holder's security will not be impaired by the loan assumption and that the risk of a breach of any
covenant or agreement in this Security Instrument is acceptable to Note Holder.
To the extent permitted by applicable law, Note Holder may charge a reasonable fee as a condition to Note Holder's consent
to the loan assumption. Note Holder may also require the transferee to sign an assumption agreement that is acceptable to Note
Holder and that obligates the transferee to keep all the promises and agreements made in the Note and in this Security Instrument.
I will continue to be obligated under the Note and this Security Instrument unless Note Holder releases me in writing.
If Note Holder exercises the option to require immediate payment in full, Note Holder shall give me notice of acceleration.
The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which ! must pay
all sums secured by this Security Instrument. If I fail to pay these sums prior to the expiration of this period, Note Holder may
invoke any remedies permitted by this Security Instrument without further notice or demand on me.
WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED.
Kennwood -L~sh ~
ALL THAT CERTAIN tra~t or parc'el ni'lmttt sliuGte, lyinJ~ m~d hrhlg in Upi~r Mit]lin Tuwi~hip,
Cm~hcrlnnd County. PennsylV~Snin, more parHcularly boufldud ami described ua follows, Itpv,,it;
IlPOINNINO nl n ~dnt }ri tile Intct',sectioA or tho Whtsk,~y Run Rnml will! u road leading Ia Whiskey
point iff ~M R~; I~ ~ t~ ~ ~ ~y of A, K, ~Gk, Noflh ron~zb~ (43)
Gu~lm[I, ~ forty~ O~ de~ W~, thifly~t (38) p~ IO n ~iflt; til~nce by ~lU~.
~U{h s~l=n 06) ~A~ ~, tWanty~t ~ ~U m, ~Jfll; t~ ~ ~d OOW or fomlcrly
n~ ~drk~r H~V~, ~h tklrly ~0) ~$~ W~t, ~[:ty-;~ (32} ~NIl~ ltv a point In ~hJskvy
R~; dWfl~ along ~ld r~, ~omh forly-four (~} ~ ~t, thbty~o~ O I) pe~it~ m t[~ ptttc~
[ff DEGINNINO. ~AININO ro~4h~ (4~) a~, mnm~
LEY,.~. iIOWEYER, a tre~t cfi land knmvn ~t l.at No. 2 of the &'uh~lv[siufl Pl.n fi)r Rh~,lull. Ellis
Lash, c4 al., p~ rccof~lcd I~ C~nih~,nod ~ounty Plan i~ok 4"). pa~o ?D, maJ cuntuinlnB S,00 ~cn.'s
· mvhh.'h pti:mi.mci was p-anted Dod conveyed unto Victor B. V/hi,an, l;r. lind VI~oe ti. V/hJtlcn, Jr. hy
demi doted O~.her 1. !~8~ cud tin,ordeal In ~{~A Oi1'~ of Ibm Re,.onlcr ui' Deeds {n nod for
CumherlMld Coonty, Panmylv#flh, in I~ ~ook 'X'. VAt. 29. paJ'.~ ~.
liP{NO lite tuldua{ .nm ol' 3~ me~, mom ur {c~4. desi{neU.'d as Lut Nu. l, off tile nforenlentkn]~'d
Certify this to be recorded
In Cumber/and County PA
VERIFICATION
I, Leon P. Haller, Esquire, hereby swear and affirm that the
facts contained in the foregoing COMPLAINT for Mortgage
Foreclosure are true and correct to the best of my knowledge,
information, and belief based upon information provided by
Plaintiff, BANKERS TRUST COMPANY, AS CUSTODIAN WITH A SERVICING
AGENT OF SAXON MORTGAGE, INC. Said facts contained herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to
unsworn falsification to authorities.
Date: June 23, 2003
SHERIFF'S RETURN -
CASE NO: 2003-03142 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CIYMBERLAND
BANKERS TRUST COMPANY
VS
LOSH KENNWOOD ET AL
REGULJtR
RICHARD SMITH ,
Cumberland County, Pennsylvania,
says, the within COMPLAINT - MORT FORE
LOSH KENNWOOD AKA KENWOOD LOSH
DEFENDANT , at 1425:00 HOURS,
at 43 SUBDIVISION ROAD
NEWVILLE, PA 17241
KENNWOOD LOSH
a true and attested copy of COMPLAINT - MORT FORE
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 9th day of July , 2003
by handing to
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 8.28
Affidavit .00
Surcharge 10.00
.00
36.28
Sworn and Subscribed to before
me this ;L~-~ day of
~ Prothonotary
So Answers:
R. Thomas Kline
07/09/2003
PURCELL KRUG HALLER
By: ~
/ ~eputy Sheriff
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-03142 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BANKERS TRUST COMPANY
VS
LOSH KENNWOOD ET AL
RICHARD SMITH ,
Cumberland County, Pennsylvania,
says, the within COMPLAINT - MORT FORE
LOSH SUSAN K
DEFENDANT , at 1425:00 HOURS, on the
at 43 SUBDIVISION ROAD
NEWVILLE, PA 17241
KENNWOOD LOSH, HUSBAND
a true and attested copy of COMPLAINT - MORT FORE
Sheriff or Deputy Sheriff of
who being duly sworn according to
was served upon
the
law,
9th day of July , 2003
together with
by handing to
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 /6 ~ day of
k3 A.D.
~r~thonotary
So Answers ."
R. Thomas Kline
07/09/2003
PUROELL HAL R¢
BANKERS TRUST COMPANY, AS
CUSTODIAN,
Plaintiff
VS.
KENNWOOD LOSH A/K/A KENWOOD
LOSH AND SUSAN K. LOSH,
Defendants
IN THE COURT OF COMMON
CUMBERLAND COUNTY, PENI~
CIVIL ACTION - LAW
NO. 2003 03142 Civil
IN MORTGAGE FORECLOSURE
P RAE C I p F,
PLEAS
SYLVANIA
Term
TO THE PROTHONOTARY:
Please mark the above action settled and discontinu(
prejudice.
PURCELL, KRUG & HALLER
By:
Le let ID
Attorne~ for Plai
Purcell, Krug & H
1719 North Front.
Harrisburg, PA 17
(717) 234-4178
DATE: Auqust 14, 200q
without
#15700
~tiff
~ller
~treet
202
MORTGAGE ELECTRONIC REGISTRA-
TION SYSTEMS, INC.,
Plaintiff
VS.
JAMES L. MILLER AND
STEPHANIE L. MILLER,
Defendants
IN THE COURT OF COMMON PL
CUMBERLAND cOUNTY, PENNS~
CIVIL ACTION - LAW
NO. 2003 - 3143 civil Te
IN MORTGAGE FORECLOSURE
p RAE C I P E
TO THE PROTHONOTARY:
Please mark the above action settled and discontinue
prejudice.
PURCELL, KRUG & HALLE~
By:~
Leon PJ Haller II
Attorney for Pla:
Purcell, Krug & ]
1719 North Front
Harrisburg, PA 1'
(717) 234-4178
SAS
~VANIA
cm
[, without
#15700
ntiff
aller
Street
102
DATE: Auqust 14, 2003