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HomeMy WebLinkAbout080-342PHELAN HALLINAN & SCHMIEG, LLP FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 MICHELE M. BRADFORD, ESQ., Id. No. 69849 SHEETAL R. SHAH-JANI, ESQ., Id. No. 81760 JUDITH T. ROMANO, ESQ., Id. No. 58745 JENINE R. DAVEY, ESQ., Id. No. 87077 MICHAEL E. CARLETON, ESQ., Id. No. 203009 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 169274 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff v. MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE PAUL J. HOLUBOWICZ, JR. 708 SIXTEENTH STREET NEW CUMBERLAND, PA 17070 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. ()g - 34a 0- i 1 Tervw CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 169274 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 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. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File #: 169274 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS File #: 169274 COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. File #: 169274 Plaintiff is COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE PAUL J. HOLUBOWICZ, JR. 708 SIXTEENTH STREET NEW CUMBERLAND, PA 17070 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/18/1999 mortgagor(s) made, executed, and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book: 1552, Page: 167. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 07/01/2007 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 169274 6. The following amounts are due on the mortgage: Principal Balance $84,097.02 Interest $4,195.20 06/01/2007 through 01/14/2008 (Per Diem $18.40) Attorney's Fees $1,250.00 Cumulative Late Charges $201.12 06/18/1999 to 01/14/2008 Cost of Suit and Title Search 550.00 Subtotal $90,293.34 Escrow Credit ($92.29) Deficit $0.00 Subtotal $92.29 TOTAL $90,201.05 7 If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 169274 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 10. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $90,201.05, together with interest from 01/14/2008 at the rate of $18.40 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELA ALLINAN & SCH G, LLP By: 1 FRANCIS S. HALLINAN, ESQUIRE °-1ANIEL G. SCHMIEG, ESQUIRE MICHELE M. BRADFORD, ESQUIRE SHEETAL R. SHAH-JANI, ESQUIRE JUDITH T. ROMANO, ESQUIRE JENINE R. DAVEY, ESQUIRE MICHAEL E. CARLETON, ESQUIRE Attorneys for Plaintiff File #: 169274 LEGAL DESCRIPTION ALL THAT CERTAIN piece, parcel or tract of land situate in the Borough of New Cumberland, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the southern line of Sixteenth Street at the dividing line between Lots Nos. 3 and 4 as shown on the Plan of Lots of George R. Moyer; thence in a southeasterly direction along said dividing line, 150 feet to Lot No. 7; thence in a northeasterly direction along said Lot No. 7, 75 feet to a point; thence in a northwesterly direction on a line parallel with the dividing line between Lots Nos. 4 and 5 on said Plan, 150 feet to the southerly side of Sixteenth Street as shown on said Plan; thence in a southwesterly direction along Sixteenth Street, 75 feet to Lot No. 3 on said Plan, the Place of BEGINNING. BEING all of Lot No. 4 and the westerly one-half of Lot No. 5 on the aforementioned Plan of Lots of George R. Moyer, recorded in the Cumberland County Recorder of Deeds Office in Carlisle, Plan Book 4, Page 65. HAVING THEREON ERECTED a one and one-half (1 1/2) story single brick dwelling house known as No. 708 Sixteenth Street, New Cumberland, Pennsylvania. PARCEL NO: 26-23-0543-552 PROPERTY BEING: 708 SIXTEENTH STREET File #: 169274 VERIFICATION I hereby state that I am the attorney for Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. W 407-6S- DATE: t - t 4; . D 8 ? . cy.L?w, d-e-p- 00 71% i .7 .. CID V jr, -% SHERIFF'S RETURN - REGULAR CASE NO: 2008-00342 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS HOLUBOWICZ MARY M ET AL JESSICA HERMANSEN , Sheriff or Deputy Cumberland County,Pennsylvania, who being duly swo says, the within COMPLAINT - MORT FORE was ser HOLUBOWICZ MARY M AKA MARY M SHOPE heriff of n according to law, ed upon the DEFENDANT , at 1658:00 HOURS, on the 22nd day of January , 2008 at 708 SIXTEENTH STREET NEW CUMBERLAND, PA 17070 by handn to MARY HOLUBOWICZ a true and attested copy of COMPLAINT - MORT FORS together with and at the same time directing Her attention to th? contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 17.28 Affidavit .00 Surcharge 10.00 R. Th mas Kline 00 n 45.28 01/23/2008 PHELAN HALLINAN SC, Sworn and Subscibed to By: ZI before me this day De u JAAO of A.D. [IEG &? r Sheri f i SHERIFF'S RETURN - REGULAR CASE NO: 2008-00342 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS HOLUBOWICZ MARY M ET AL JESSICA HERMANSEN , Sheriff or Deputy Cumberland County,Pennsylvania, who being duly sw says, the within COMPLAINT - MORT FORE was se HOLUBOWICZ PAUL J JR Sheriff of rn according to law, upon the DEFENDANT , at 2026:00 HOURS, on the 22nd d of January , 2008 at 9 PINETREE DRIVE MECHANICSBURG, PA 17055 by handing to PAUL HOLUBOWICZ JR a true and attested copy of COMPLAINT - MORT FOR together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 9.60 00 10.00 R. Thomas Kline 00 25.60 01/23/2008 PHELAN HALLINAN S( Sworn and Subscibed to By: before me this day D p? of A.D. ?- IEG Sheriff (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-342 CIVIL TERM MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE PAUL J. HOLUBOWICZ, JR. Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on Aa Z /C1 2009. By: If you have any questions concerning this matter, please contact: DANIEL G. SCHMIEG, ESQ I Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY AND THIS DEBT WAS NOT REAFFIRMED, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-342 CIVIL TERM MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE 708 SIXTEENTH STREET NEW CUMBERLAND, PA 17070 PAUL J. HOLUBOWICZ, JR. 9 PINETREE DRIVE MECHANICSBURG, PA 17055 Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against MARY M. HOLUBOWICZ A/K/A MARY M SHOPE and PAUL J. HOLUBOWICZ, JR., Defendant(s) for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 1/15/08 to 3/18/08 TOTAL $90,201.05 $1,177.60 $91,378.65 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. DANIEL G. SCHMIEG, ES Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PR ROTHY 169274 PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (9,15) 563-7000 COUNTRYWIDE HOME LOANS, INC. : COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION Vs. CUMBERLAND COUNTY MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE PAUL J. HOLUBOWICZ :NO. 08-342-CIVIL TERM Defendants TO: MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE 708 SIXTEENTH STREET NEW CUMBERLAND, PA 17070 DATE OF NOTICE: FEBRUARY 20, 2008 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET ^. CARLISLE, PA 17013 c?' 1 (800)990-9108 ( 1. Hainey, Legal Assistant PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 15) -561-7000 COUNTRYWIDE HOME LOANS, INC. Plaintiff Vs. MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE PAUL J. HOLUBOWICZ Defendants COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 08-342-CIVIL TERM TO: PAUL J. HOLUBOWICZ eT R. 9 PINETREE DRIVE MECHANICSBURG, PA 17055 DATE OF NOTICE: FERRIIARY 20, 2008 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST-YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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. CUMBERLAND COUNTY LAWYER REFERRAL SERVIC m CUMBERLAND COUNTY BAR ASS 32 SOUTH BEDFORD STREE CARLISLE, PA 17013 (800)990-9108 Lul; Py PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE Plaintiff, v. MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE PAUL J. HOLUBOWICZ, JR. Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-342 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE is over 18 years of age and resides at, 708 SIXTEENTH STREET, NEW CUMBERLAND, PA 17070. (c) that defendant PAUL J. HOLUBOWICZ, JR. is over 18 years of age, and resides at ,9 PINETREE DRIVE, MECHANICSBURG, PA 17055. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff 3 s-4"3 ?/ ? tiff ) ??? AD _ . C t Z4 PHELAN HALLINAN & SCHMIEG, LLP By: Francis S. Hallinan, Esquire IDENTIFICATION NO. 62695 1617 JFK Boulevard, Suite 1400 PHILADELPHIA, PA 19103 (915) 56:3-2000 COUNTRYWIDE HOME LOANS, INC. Plaintiff VS. MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE PAUL J. HOUBOWICZ ATTORNEY FOR PLAINTIFF CUMBERLAND County Court of Common Pleas CIVIL DIVISION NO. 08-342 CIVIL TEAM Defendant(s) TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. x4m ? I ??4'y's Francis S. Hallinan, Esquire Attorney for Plaintiff Dated: 03/24/08 PHS: 169274 f VERIFICATION W-""LMAO hereby states that he/she is A8MVWVICE Pt?' TRENT of COUNTRYWIDE 1-TOME LOANS, INC., servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. t N am c : KERI , ASSISTANT VICE PRESIDENT DA If : Title: ANTVICE PP q"?t1Q! ' Company: COUNTRYWIDE HOME LOANS, INC. I Ov ;: 16927.E «?., ?' r-.a ?= ? C.: .. ?-? ? ? b .. ?- ?;? ? ? ?_ ;?,;, , -- ?=; ??-; ' ?? ?.? -? : ? PHELAN HALLINAN & SCHMIEG, LLP By: Francis S. Hallinan, Esquire IDENTIFICATION NO. 62695 1617 JFK Boulevard, Suite 1400 PHILADELPHIA, PA 19103 1915) 563-7000 COUNTRYWIDE HOME LOANS, INC. VS. MARY M. HOLUBOWICZ A/K/A MARY M. SHOPE PAUL J. HOUBOWICZ Plaintiff Defendant(s) CUMBERLAND County Court of Common Pleas CIVIL DIVISION NO. 08-342 CIVIL TEAM I hereby certify that a true and correct copy of Plaintiff's Praecipe to Substitute Verification was sent via first class mail to the following on the date indicated below: MARY M. HOLUBOWICZ 708 SIXTEENTH STREET NEW CUMBERLAND, PA 17070 PAUL J. HOUBOWICZ 708 SIXTEENTH STREET NEW CUMBERLAND, PA 17070 ATTORNEY FOR PLAINTIFF GU'YyGItJ ?• Francis S. Hallinan, Esquire Attorney for Plaintiff Dated: 03/24/08 PHS: 169274 roa m -Tj r co