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Home My WebLink About03-4401MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC c/o Washington Mutual Bank, FA P.O. Box 1169 Milwaukee, WI 53224 Plaintiff VS. TRAVIS L. HURST Defendant 1N THE coURT OF COMMON PLEAS CU'MBERLAND 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, lfyou 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 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 NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FOR_MA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQU1ER 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, DECIDIR 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. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC c/o Washington Mutual Bank, FA P.O. Box 1169 Milwaukee, WI 53224 Plaintiff VS. TRAVIS L. HURST, Defendant : 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. Plaintiffis 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 Pla'mtiff, 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC c/o Washington Mutual Bank, FA P.O. Box 1169 Milwaukee, WI 53324 Plaintiff VS. TRAVIS L. HURST, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW 0,~ - q ~ o I ACTION OF MORTGAGE FORECLOSURE COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff, MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., herein after referred to a MERS, is the owner of legal title to the Mortgage subject to the Mortgage to this actin and nominee for Washington Mutual Bank, FA, which is the owner of the entire beneficial interest in the Mortgage, with an address of P.O. Box 1169, Milwaukee, Wisconsin 53224. 2. Defendant, TRAVIS L. HURST, is an adult individual, whose last known address is 1262 HUNTERS RIDGE DRIVE, MECHANICSBURG, PENNSYLVANIA 17055. On or about, May 25, 2000, the said Defendant, executed and delivered a Mortgage Note in the sum of $86,834.00 payable to NORTH AMERICAN MORTGAGE COMPANY. 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 Defendant. Plaintiff also avers that the within Mortgage foreclosure complaint is based upon the Mortgage and that the attachment ora copy of the Note is unnecessary pursuant to Rules 1019(h) and 1141(a) of the Pennsylvania Rules of Civil Procedure. Contemporaneously with and at the time of the execution of the aforesaid Mortgage Note, in order to secure payment of the same, Defendant, 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 1614, Page 727 conveying to original Mortgagee the subject premises. The Mortgage was subsequently assigned to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, 1NC., and recorded in the aforesaid County in Mortgage Book 699, Page 4278. Mortgage Electronic Registration Systems, Inc. is acting solely as nominee for Washington Mutual Bank, FA its Successors and Assigns. The Said Mortgage and Assignment are attached hereto as Exhibit "A". 5. The land subject to the Mortgage is: 1262 HUNTERS RIDGE DRIVE, MECHANICSBURG, PENNSYLVANIA 17055 and is more particularly described in Exhibit "B" attached hereto. 6. The said Defendant is the real owner of the property. 7. The Mortgage is in default due to the fact that Mortgagor has failed to pay the installment due on May 01, 2003 and all subsequent installments thereon, and the following amounts are due on the Mortgage: UNPAID PRINCIPAL BALANCE $84,774.62 Interest at $19.74 per day From 04/01/2003 To 10/01/2003 ( based on contract rate of 8.500%) $4,224.35 Accumulated Late Charges $177.29 Late Charges $35.89 From 05/01/2003 to 10/01/2003 $251.23 Escrow Balance $685.17 A~omey'sFeeat5% of PfincipalBalance TOTAL $4,238.73 $94,351.39 **Together with interest at the per diem rate noted above after October 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. Defendant is not a member of the Armed Forces of the United States of America, nor engaged in any way which would bring him within the Soldiers and Sailors Relief Act of 1940, as amended. 1 I. The within Mortgage is insured by the Federal Housing Administration under Title li 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 mount due together with interest at the rate of 8.500% ($19.74 per diem), together with other charges and costs including escrow advances incidental thereto to the~.cla~f Sheriff's Sale and for foreclosure and sale of the property within described. ~~~~/~ By: Leon P. Haller, Esquire Attorney for Plaintiff I.D. # 15700 1719 N. Front Street Harrisburg, PA 17102 (717-234-4178) WHEN RECORDED MAll. TO: NORTH AMERICAN MORTGAGE COMPANY P.O, BOX EDE031 PETALUMA, CA 94975-8031 Parcel Number: FINAL REVIEW AU 062 Commonwealth o! Pennsy]vanis a,o MORTGAGE THIS MORTGAGE ("~urity Instrument"} is glv;n on The Mortgagor is TRAVI$ L. HURST FHA C~w No. 441-6271004-734 MAY 2§THo 2000 5890302-702 ('Borrower*). This Security Instrument is given to NORTH AMER I CAN MORTGAGE COMPANY whlch ;s organized and esistlni under the laws of DELAWARE andwhoseaddrcs~is30E3 AIRIAY ~RIVE, SANTA ROSA, CA g5403 ('Lend~'}. ~wer owm ~ the pHnSpal sum of EIOHTY SlX TH~SAND EIGHT HUNDRED THIRTY F~R AND 001100 ~ll.~ (U.S. S se,eaa.~o ). ~is ~bt is evid~ by ~ormw~'s note ~t~ the ~me ~te ~ t~s ~flW l~trum~t ("Note }, which p~vld~ for monthly ~ym~. with the full debt, if ~t ~id ~llc~, due ~d ~ble dUNE 01. 2030" . ~is ~uNty I~t~m~t ~ ~ t~ ~bt ~id~ by ~e Note, wi~ in~ aM all ~newals, eg~o~ ~d m~i~tlo~ of ~ Note; (b} · e ~ym~t of all o~er sum~ with inter, advanc~ ~d~ ~aph 7 ~ ~t~ S~ty [n~m~nt; and (c} ~e ~o~ma~e of ~rmw~'s c~en~ and a~m~ und~ FHA Pennsylvania Me~gage - 4/96 "/MP MORTGAGE FORMS ' 5. Occupancy. Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Lea.~holds. 13orrower s~all occur.y, establish, and use the Property as Borrower's principal residence within sixty days after the execution of th,s Security Instrument (or within sixty days of a later sale or transfer of the Property ) and shall continue to occupy the Property as 13on'ower's prJecipal residence for at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower, or unless extenuating circumstance~e~ist which are beyond ]3orrower's control./3orrower shall notify Lenct~ of any extenuating circumstances. ]3orrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear nad~tear excepted. Lender may inspect the Pro~erty if the Property is vacant or abandoned or theloan is in default. [.~ndsr may take reasonable action to protect and @reserve such vacant or abandoned Property. ]~:~'rower shall also be in default if Borrower, during the loan application process, gave materially false or innccurete information or statements to Lender (or failed to provide Lender with any material information) in conncctlon with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a pr{ecipal residence, If this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the leue. If Borrower acquires fse title to the Property. the leaa~hold and fee tide*shall not be merged unless Lender agre~ to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct nc consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance !n place of condemnation, are hereby assigned nad shall be paid to Lender to the extent of the full amount of the md~btednaas that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the Note and this SeCurity Instrument, first to any delinquent amounts applied in the order provided in paragraph 3. and then to prepayment of principal, Any application of the pro..__~4_, to the principal shall not extend or postpone the due date of the mon'thly paym eats, which are referred to in paragraph 2, or change the amount of such payments..~.ny excess proceeds over an amount required to pay all outstandinglndebtedne~ under :he Note and this Security Instrumentshall be paid to ~e entltylegelly entltled thereto. 7. Charges to Borrow~r and Protection of Leader s Rights in the Property, ]~orrower shall pay governmental or munlcipa] cbarge~, fines and impnsltlona that are not included ~n paragraph 2. Borrower shall pay these obllgetlons on time directly to the entity which is owed the payment, If failure to pay we. uld adversely affect Lender's interest in the Property, upon Lender's request Borrower shall promptly fumtsh to Lender recelpta evidencing these payments, [f Borrower fails to make these Payments or. the pay, manta requited by paragraph 2, or fails to perform any other covenants and agreements contained in thts Security instrument, or them ia a legal proceeding that may sign~ ficantly affect Lender's rights in the Property (such aa a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do end pay whatever is nec.e~,,-y to protect the value of the ?ruperty and Lender's rights in the Property, including payment of taxes, bs~u'd insurance end other items mentionedin paragraph 2. . Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower and be s~cured by this Security Instrument. These amounts shall bear interest from the dateofdisbu~ment, at the Note rate. and at theoptionof Lender. shall be immedlatelydue and payable. Borrower shall promptly dlecherge any Ilea which has priority over this Security Instrument unless ~orrower: (a) ag~ea in wtltlng to the paymertt of the obligation secured by the Ilea i.n. a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the hen in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the Ilea; or (c) secures from the bolder of the Ilea an agreement sati~d'actory to Lender subordinating the l lea to thla Security Instrument. If Lender determlnes that any part of the Property is sub.~ct to a Ilea which may attain priority over this Security Instrument, Lender may give Burro wer a notice identifylng the lien. ~orrower shall satisfy +.he Ilea or' take one or more of the actions set forthabove within l 0days of the giving o fno, tlce. ~. Grounds for ~cceleration of Deb~ (a) Default, ~nd~ may, except ~ limi~ by r~latlo~ i~ by the ~tary, in the c~ of ~yment defsulm, r~ui~ imm~iam ~ym~t in f~l of all ~s ~u~ by t~s ~uHty ln~rument if: (i) ~wer ~faul= by Failing to ~y in full a~y m~ly ~ym=nt ~ui~ by this I~trument ~[or to ~ on the d~ date of the ~xt m~ly ~yment. or (il) Bormw~ ~fauIm by fa~ling, for a ~ri~ of thi~y ~ys, m ~m any other ob[l~tlo~ con~Jn~ in t~s ~urity I~rument, (b) Sale Without Credit Approval..~der s~l, if ~rmit~ by appli~bl~';law (including ~ion 341(d) o~ the Gain- SL O~main ~ttory Institu~o~ A~ of 19~ 12 U.S.C. l~]j-3(d)) and with the prior approval of the ~ry, r~uire imm~Jate ~yment in full of all sums ~ur~ by this ~uHty l~trum~df: (i) All ~ ~rt of t~ Pro~y, ~ ~ ~eficlal i~t in ~ ~t owning sit or ~rt of the Pro~rty ~ld o~ o~erwi~ trn~fe~ (o~her th~ by d~vi~ or d~ent), n~d (ii) ~e Pw~rty is no~ ~u~ bx ~ ~wh~r or gr~n~ ~ ~s or her ~lncip~ r~dence, or pusher or g~nt~ do~ ~ ~upy ~e Pw~r~y but ~s or ~r c~dit h~ not ~ n~wv~ accord~co with the r~u/~men~ of ~o ~. . (c) No Walv~r. If ciwum~n~ ~r t~t would ~rm~t ~n~ to r~oire immolate ~ym~t foil, hot ~nder do~ not ~q~i~ such paymen~ ~n~ d~ not w~iw i~ righ~ wi~h r~t to su~qu~t even~. (d) Regulations of HUD Sec~t~ry. in runny dwu~n~ ~la6o~ i~ by ~e ~t~ will limit ~'s righ~, in the c~ of ~ym~t ~faul~. m r~o/re imm~ ~ymem in full and fot~[~ if not paid. This ~d~y ~ment d~ not avthor/ze n~ti~ or fo~l~ if not ~rmltt~ by regulations of ~e ~retnry, (e) Mo~gng~ ~ot Insured. ~rmw~ ag~ ~nt if this S~u~ty ]~t~men~ nnd the Note ~ not determln~ to ~ eii~ble for insur~n~ under ~he National Ho~ing Act within ~ da~ [~m ~e her~f, ~ may, at [~ o~ion, ~oi~ im medin~ ~yment i~ foil of all sums ~ by ~is ~c~ ]n~m~t. A wdt~ s~tem~t of ~ny ~o~z~ a~nt of the S~ry ~ su~u~t lo ~ days from the dn~e he.f, d~llnlng to in~ t~s ~u~ [~ment and ~ Nole, ~hall ~ c~cl ~iv~ ~f of ~ch ineligibility. Notwit~tanding the f~ing, this o~]~ may not ~ by Lender wh~ the unnwila~lity of insora~ is ~]ely d~ to ~nd~'s failu~ to remit a mort~ i~urnn~ p~mium to ~ [ 0. Reinstatement. Bo~ow~ ~ ~ d~ht to ~ ~/nsmt~ if ~nder h~ ~oi~ immolate paym~t in full ~a~ of Borrower's f~ilu~ m ~y an ~mo~nt d~ und~ the No~ or this ~rity Instrument. This right ev~ aft~ fo~l~o~ pr~in~ ~ insti~ To ~te the ~ty I~wment, ~ow~ sh~ ~d~ in a lump sum all amo~ ~ui~ W bring Bo~ow~'~ ac~unt cu~t i~l~ing, W the o~ent they are o~llgatio~ of ~ww~ ~d~ thi~ ~ty l~t~mont, full.ore ~ and ~ble nnd c~tomary ~ttor~ys fe~ nnd ex~ ~o~ly ~nt~ wi~ ~he f~lo~ ~e~/ng. U~n ~t~t by ~wor, this ~y I~trum~t nad ~e oblign~ons t~t it ~u~ shall ~nin in offer ~ if ~der had not r~ui~ paymen~ in full. Hewers, ~er is not ~d~ W ~rmit ~ement if: (i) ~n~r h~ rei~tst~nt aft~ the ~mmen~mmt of fo~l~ore~i~ wi~n ~o y~ imm~intely ~ing commencement of n cu~t fo~l~ ~mg, (il) ~i~t w~ll ~IM~ fo~l~ on diffe~nt ~un~ in the fu:o~, or {iii) ~ntem~t will ~ve~ly ~f~ the p~o~ty of tho Ilea c~nt~ by ~is ~ty I~m~t. I I. Borrower Not Relish; F~rance By Lender Noi a Waiver. ~e~i~ of ~e ~me of ~ymont or m~i[icngon of ~mo~tion of th~ ~mn ~u~ by t~s ~ty l~m~t ~t~ by ~nd~ to any s~r in inter~t of ~rmwer s~ll not o~m ~ the Ii*~lity of t~ ~nnl ~rmw~r or Borrow~+s s~t in in~r~, l.~der s~I1 not ~ ~ui~ to commence p~in~ a~alnst any su~r in intent or BY SIGNING BELOW, Borrowor $ceepts and agr~ m the terms container in this $¢curity Instrument and in any rider(s} ex~cut~d by Borrower and res. ordeal with it. o' TRAVI$ k. HURST -Bm'rower (,~al) (Se,aD Certificate of Realdence thatthe~rr~taddr~oYthcwi~in-flam~d~i$ aosa ArnW~Y O~lVa, SANTA RO~A, CA 06403 Witness my hand this ~g day of /"r'~Zq , ,~CL'O COMMONWEALTH Q.~F PENNSylVANIA, C~ERL~O County $~ On t~s, t~ ~yor I~ , ~ , ~o~ me, ~e und~ officer, ~monsllya~ TRAVIS t. HURST O known to me (or satisfactorily ptovefl) to be the person whose n,ms ~bacril~l to th~ within instrument snd ncknowledl, d th~t executed tho same for th~ purposaa aereifl contained. ' IN WITNESS WHEREOF, I hereunto s~t my hand and o~f~cial seal. , 0 Mr Commi~on Expires:. / ~ [ NOTARIAL 8F. AL i [ M~gnrel A. FeflMennoehor. NoIn~' Publ;c I / Mechnnlc~burg, Ounfaed~md Oounty ! Title of Officer ALL that certain Unit, being Unit ~o. 1'~62 (the "Unit"). o~ Timber C~se Il. A Tow~ome Candom~nlum (the "Condominium"), Ioc~t~ in Hnmpdc~ Township, Cum~rla~d Counly, Pennsylvania, wl~lch Unit ia d~ignnted in the Declaration of Condemlnium o~Timber ~ase Il, A Townhome Condominium ({he "Decl=a{~on of Condom~n;um") and Declaration Hat~ Plans recorded in 0~e Off~ of the Cumberland County RecoVer o[ D~s Misc~llaneou= Eook 573, Page 35 and Right o~Way Plan Book 1 I, ~spectlvely, together w~th any and ali nmendmentl t~to. TOGETI-IER with the undivided percentage interest in the CommOn Elemcnta appu~t to the Unit n~ more pn~icularly ~e~ [o~ in the Declaral~on of Condominium, as I=~t amended. TOGETHER with the r~Eht to use ~l~e Limited Common Elemenl~ applicable to O~e Uni¢ being, conveyed herein, pu~uant ta the Declarntlon! of Condominium and Declaration Plats and Plans, as last amended. 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 MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. THROUGH WASHINGTON MUTUAL BANK, FA HOLDER OF THE ENTIRE BENEFICIAL INTEREST IN THE MORTGAGE. Said facts contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: September 4, 2003 Leon P. Hailer, Esquire SHERIFF'S RETURN - CASE NO: 2003-04401 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MORTGAGE ELECTRONIC REGISTRATI VS HURST Ti{AVIS L REGULAR DAVID MCKINNEY , Cumberland County, Pennsylvania, says, the within NOTICE HURST TRAVIS L DEFENDANT at 0019:24 HOURS, at 1262 HUNTERS RIDGE DRIVE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 16th day of September, 2003 MECHANICSBURG, PA 17055 by handing to NICOLE A. O'BRIEN (ADULT IN CHARGE OF RESIDENCE) a true and attested copy of NOTICE COMPLAINT IN MORTGAGE FORECLOSURE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.97 Affidavit ~00 Surcharge 10.00 .00 36.97 Sworn and Subscribed to before me this ~ day of · Prothonotary So Answers: R. Thomas Kline 09/17/2003 PURCELL, KRUG & HALLER Deputy Sheriff MORTGAGE ELECTRONIC REGIS- TRATION SYSTEMS, INC., Plaintiff VS. TRAVIS L. HURST, Defendants IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003 04401 IN MORTGAGE FORECLOSURE p RA E C I P E TO THE PROTHONOTARY: Please mark the prejudice. above action settled and discontinued, without PURCELL, By: KRUG & HALLER Leon P. Hatf~e~-I-D~i5700 Attorney for Plaintiff Purcell, Krug &Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 DATE: Noveraber 20, 2003