The URL can be used to link to this page

Home My WebLink About08-3822PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 MICHELE M. BRADFORD, ESQ., Id. No. 69849 JUDITH T. ROMANO, ESQ., Id. No. 58745 SHEETAL SHAH-JANI, ESQ., Id. No. 81760 JENINE R. DAVEY, ESQ., Id. No. 87077 LAUREN R. TABAS, ESQ., Id. No. 93337 VIVEK SRIVASTAVA, ESQ., Id. No. 202331 JAY B. JONES, ESQ., Id. No. 86657 PETER MULCAHY, ESQ., Id. No. 61791 ANDREW SPIVACK, ESQ., Id. No. 84439 v" JAIME MCGUINNESS, ESQ., Id. No. 90134 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 180706 GMAC MORTGAGE, LLC 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 Plaintiff V. MICHAEL J. ADAMS 42 BEARS SCHOOL LANE CARLISLE, PA 17013-8999 Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. D$-382a Civil Ier-m CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 180706 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 #: 180706 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 File #: 180706 THE LAW PROVIDES THAT YOUR ANSWER TO THIS 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 #: 180706 Plaintiff is GMAC MORTGAGE, LLC 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 2. The name(s) and last known address(es) of the Defendant(s) are: MICHAEL J. ADAMS 42 BEARS SCHOOL LANE CARLISLE, PA 17013-8999 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 06/20/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR NFM, INCORPORATED, DOING BUSINESS AS, NATIONAL FIDELITY FINANCE which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1958, Page 263. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 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 03/01/2008 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 #: 180706 6 The following amounts are due on the mortgage: Principal Balance $118,444.75 Interest $3,503.20 02/01/2008 through 06/25/2008 Attorney's Fees $1,250.00 Cumulative Late Charges $0.00 06/20/2006 to 06/25/2008 Cost of Suit and Title Search 550.00 Subtotal $123,747.95 Escrow Credit $0.00 Deficit $0.00 Subtotal 0.00 TOTAL $123,747.95 7. 8. 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 #: 180706 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 $123,747.95, together with interest from 06/25/2008 at the rate of $24.16 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. PHELAN HALLINAN & SCHMIEG, LLP By: L WRENCE T. PHELAN, ESQUIRE FRANCIS S. HALLINAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE MICHELE M. BRADFORD, ESQUIRE JUDITH T. ROMANO, ESQUIRE SHEETAL R. SHAH-JANI, ESQUIRE JENINE R. DAVEY, ESQUIRE LAUREN R. TABAS, ESQUIRE VIVEK SRIVASTAVA, ESQUIRE JAY B. JONES, ESQUIRE PETER MULCAHY, ESQUIRE ANDREW SPIVACK, ESQUIRE JAIME MCGUINNESS, ESQUIRE Attorneys for Plaintiff File #: 180706 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land situate in West Pennsboro Township, Cumberland County, Pennsylvania, bounded and described in accordance with Subdivision for Robert Boyer prepared by Larry Vern Neidlinger, Professional Engineer, a draft of same consisting of four pages dated July 18, 1975 being recorded in the hereinafter named Recorder's Office in Plat Book 27, Page 103, as follows: BEGINNING at a point in the original center line of Thirty-three (33) feet with Bear's School Lane at the Northeastern corner of land now or formerly of Neal Bressler and wife, described in deed recorded in the hereinafter named Recorder's Office in Deed Book'H', Volume 25, page 946; thence along the Northern line of said land now or formerly of Neal Bressler and wife, South 72 degrees 59 minutes 50 seconds West, a distance of Three Hundred Eighteen and Seventy-seven Hundredths (318.77) feet to a point at the dividing line between Lots Nos. 10 and 13 of Section 'C' as shown on said Subdivision Plan; thence along said dividing line between Lots Nos. 10 and 13 of Section 'C', North 24 degrees 16 minutes 34 seconds West, a distance of Ninety-five and Six Hundredths (95.06) feet to a point in the dividing line between Lots Nos. 10 and 11 Section 'C' as shown on said Subdivision Plan; thence along the dividing line between said Lots Nos. 10 and 11 of Section'C', North 59 degrees 05 minutes 36 seconds East, a distance of Two Hundred Ninety-nine and Fourteen Hundredths (299.14) feet to a point in the original center line of Thirty Three (33) feet wide Bear's School Lane; thence along the original center line of said Thirty-three (33) feet wide Bear's School Lane, South 30 degrees 54 minutes 24 seconds East, a distance of One Hundred Sixty-five (165) feet, more or less, to a point at the Place of BEGINNING. File #: 180706 CONTAINING Thirty-six Thousand Four Hundred Fifty-nine and Seventy-five Hundredths (36,459.75) square feet exclusive of the roadbed of Bear's School Lane and being all of Lot No. 10 of Section 'C' as shown on said Subdivision Plan for Robert Boyer recorded as aforesaid, plus a strip of land Twenty-five (25) feet in width lying between the Eastern line of said Lot No. 10 of Section'C' as shown on said Plan and the original center line of Thirty-three (33) feet wide Bear's School Lane, which Twenty-five (25) feet wide strip of land constitutes a portion of the roadbed of Bear's School Lane as shown on said Plan. For Informational Purposes Only: The improvements thereon being known as 42 Bears School Road, Carlisle, Pennsylvania 17013 BEING all and the same lot of ground which by Deed dated July 27, 2001, and recorded among the Land Records of Cumberland County, Pennsylvania in Liber No. 247, folio 3389, Instrument #2001-024758, was granted and conveyed by Robert P. Dunkle and Rose Ann Dunkle, unto Michael J. Adams and Bonnie S. Nesbit. Parcel No.: 46-07-0473-031 PREMISES: 42 BEARS SCHOOL LANE File #: 180706 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. M ? ltGU.?tQ,d?A- Attorney for Plaintiff */Se/ DATE: G - A5-- o,- oo c r oho W ?o 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-03822 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GMAC MORTGAGE LLC i VS ADAMS MICHAEL J WILLIAM CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsllvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon ADAMS MICHAEL J DEFENDANT the at 001 :05 HOURS, on the 30th day of June , 2008 at 42 BEARS SCHOOL LANE CARLISLE, PA 17013 by handing to MICHAEL J ADAMS DEFENDANT 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 7'07108 4- Sworn and Subscibed to before me this So Answers: 8.00 5.00 00 r 0.00 R. Thomas Kline .00 3.00 07/01/2008 PHELAN HALLINAN & SCHMIEG By: y Deputy Sheriff of I A. D. r PHELAN HALLINAN & SCHMIEG, LLP FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 GMAC MORTGAGE, LLC Plaintiff VS. MICHAEL J. ADAMS Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-3822 CIVIL TERM CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Date: -//?,2 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: Francis S. Hallinan, Esquire PHS #: 180706 VERIFICATION Jeffrey Stephan L Wted Sigftinjt Oft"im hereby states that he/she is r'''f Jeffrey Stephan Limited Signing QMW of GMAC MORTGAGE, LLC, servicing agent for Plaintiff in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregbing 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 unworn falsification to authorities. DATE: (d3o I Name: -ey Stephan Signing Officer Loan:0835019387 Company: GMAC MORTGAGE, LLC File #: 180706 PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 GMAC MORTGAGE, LLC Plaintiff VS. MICHAEL J. ADAMS Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-3822 CIVIL TERM CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certifx that a strue and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: MICHAEL J. ADAMS 42 BEARS SCHOOL LANE CARLISLE, PA 17015-8999 Date: 7/240 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: x?A?41 a Francis S. Hallinan, Esquire 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 GMAC MORTGAGE, LLC 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 Plaintiff, CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION V. MICHAEL J. ADAMS 42 BEARS SCHOOL LANE CARLISLE, PA 17013-8999 Defendant(s). NO. 08-3822 CIVIL TERM 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 MICHAEL J. ADAMS, 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 $123,747.95 Interest from 06/26/2008 to 08/13/08 $1,183.84 TOTAL $124,931.79 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, ESQUIRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: IS P PROT 180706 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 (215) S63-7000 GMAC MORTGAGE, LLC Plaintiff Vs. MICHAEL J. ADAMS Defendants TO: MICHAEL J. ADAMS 42 BEARS SCHOOL LANE CARLISLE, PA 17013-8999 DATE OF NOTICE: JITLY 25, 20OR : COURT OF COMMON PLEAS : CIVIL DIVISION : CUMBERLAND COUNTY :NO. 08-3822 CIVIL TERM FILE COPY 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 (800)990-9108 NAHILL, Legal Assistant I, . 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 GMAC MORTGAGE, LLC 1100 VIRGINIA DRIVE P.O. BOX 8300 Plaintiff, V. MICHAEL J. ADAMS Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-3822 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 MICHAEL J. ADAMS is over 18 years of age and resides at, 42 BEARS SCHOOL LANE, CARLISLE, PA 17013-8999. 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 r-? -P C-0 (?? 9s tf f, Ln 3s '-= 0 co I .,..s i (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GMAC MORTGAGE, LLC 1100 VIRGINIA DRIVE P.O. BOX 8300 Plaintiff, V. MICHAEL J. ADAMS CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-3822 CIVIL TERM Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on A /15 200$ . By: DEPU If you have any questions concerning this matter, please contact: DANIEL G. SCHMIEG, ESQUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURB ATION 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." + 1r tilk 7kjz?E PR 30 AN,; Phelan Hallinan & Sehmieg, LLP Attorney For Plaintiff 1617 HK Boulevard, Suite 1ft 13 c n L ,,rt N 1 D C 0 I i ., One Penn Center Plaza MNS`r'I.AVAH IA Philadelphia, PA 19103 215-563-7000 GMAC MORTGAGE, LLC Court of Common Pleas Plaintiff Civil Division vs CUMBERLAND County MICHAEL J. ADAMS Defendant No. 08-3822 CIVIL TERM TO THE PROTHONOTARY: PRAECIPE ? Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ? Please mark the above referenced case Settled, Discontinued and Ended. ? Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ? Please ))rk t in rem judgment Satisfied and the action Discontinued and Ended. Date: p(? P LAN LINAN nMIEG, LLP B Melissa J. Cantwell, sq.,1 . No.308912 Attorney for Plaintiff PHS # 180706 QVLA-+ 1154338 C? ?Z ?-7 4 3,F ? Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Attorney For Plaintiff Philadelphia, PA 19103 215-563-7000 GMAC MORTGAGE, LLC Plaintiff Court of Common Pleas vs MICHAEL J. ADAMS Defendant Civil Division CUMBERLAND County No. 08-3822 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: MICHAEL J. ADAMS 42 BEARS SCHOOL LANE CARLI ,E, P 17015-8999 Date: JC4 I Me ,ssa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff PHS 4 180706