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HomeMy WebLinkAbout08-3862PHELAN 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 JAIME MCGUINNESS, ESQ., Id. No. 90134 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 180622 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE 1100 VIRGINIA DRIVE P.O. BOX 8300 FORT WASHINGTON, PA 19034 Plaintiff V. MELISSA L. HACK-BECKER 11 I 1 TIVERTON ROAD MECHANICSBURG, PA 17050-7720 Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. D&- 3961 0- -Z- CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 180622 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 #: 180622 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 #: 180622 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 #: 180622 Plaintiff is U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE 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: MELISSA L. HACK-BECKER 1111 TIVERTON ROAD MECHANICSBURG, PA 17050-7720 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 09/23/2005 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS A NOMINEE FOR OAK STREET MORTGAGE, INC. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1925, Page 1566. 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 #: 180622 6 The following amounts are due on the mortgage: Principal Balance $291,464.79 Interest $7,042.77 02/01/2008 through 06/26/2008 (Per Diem $47.91) Attorney's Fees $1,250.00 Cumulative Late Charges $826.48 09/23/2005 to 06/26/2008 Cost of Suit and Title Search 550.00 Subtotal $301,134.04 Escrow Credit $0.00 Deficit $954.80 Subtotal 954.80 TOTAL $302,088.84 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 #: 180622 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 $302,088.84, together with interest from 06/26/2008 at the rate of $47.91 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: -Isl? 1? LAWRENCE T. PHELA SQUIRE FRANCIS S. HALLINAN, ESQUIRE DANIEL G. SCHMIEG, ESQUIRE MICHELE M. BRADFORD, ESQUIRE JUDITH T. ROMANO, ESQUIRE t.8flEETAL 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 #: 180622 LEGAL DESCRIPTION All that certain parcel of land situate in the Township of Hampden, County of Cumberland, Commonwealth of Pennsylvania being known and designated as follows: Beginning at a point on the western dedicated right-of-way line of Tiverton Road, at the dividing line of Lots Nos. 461 and 460; thence by line of Lot No. 461, North 52 degrees 40 minutes 29 seconds West, 152.47 feet to a point on lands now or formerly of Kingswood; thence by lands now or formerly of Kingswood, North 28 degrees 36 minutes 39 seconds East, 81.59 feet to a point; thence by line of Lots Nos. 457 and 458, South 75 degrees 32 minutes 05 seconds East, 130 feet to a point; thence by line of Lot No. 459, South 18 degrees 27 minutes 49 seconds East, 78.54 feet to a point on the western right-of-way line of Tiverton Road; thence by the western right-of-way line of Tiverton Road, by a curve to the left, having a radius of 200 feet, and an arc length of 90 feet, said curve also having a chord bearing and distance of South 50 degrees 13 minutes 00 second West, 89.24 feet to a point at the dividing line of Lots Nos. 461 and 460, the place of beginning. Being Lot No. 460 as shown on the Final Subdivision Plan of The Highlands of Hampden Square, Phase III, recorded in Plan Book 59, page 137. Tax/Parcel ID: 10-16-1056-249 PREMISES: 1111 TIVERTON ROAD File #: 180622 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. ? -LW ?" . I E? Attorney for Plai iff O I;Ib0 DATE: (0'-1- ? Rv ? ? , . a ? } ?> ?.- , ? E _._.y 7 ? ? 'j' ?_. --. ? ? ??J ? ? ?` [ `J 1? ?! j v t ? ` V ? .... !, ,? ? 1 _ 1 `. ?. SHERIFF'S RETURN - REGULAR CASE NO: 2008-03862 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND US BANK NATIONAL ASSOCIATION VS HACK-BECKER MELISSA L KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE HACK BECKER MELISSA L DEFENDANT the at 0010:00 HOURS, on the 12th day of July , 2008 at 1111 TIVERTON ROAD MECHANICSBURG, PA 17050 by handing to MELISSA BECKER DEFENDANT 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: So Answers: Docketing Service 18.00 14.00 Affidavit .00 Surcharge 10.00 R. Thomas Kline 00 0 07/14/2008 PHELAN HALLINAN & SCHMIEG Sworn and Subscibed to By: before me this day D pu y She of A.D. was served upon A PHELAN HALLINAN & SCHMIEG, LLP FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE Plaintiff VS. MELISSA L. HACK-BECKER Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-3862 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. Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff Date: Woo' By: 1 0 Francis S. Hallinan, Esquire PHS #: 180622 VERIFICATION U (?t ?k n hereby states that he/she is S.O. ad. of U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE, 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 s ct to the penalties of 18 Pa. C.S. Sec. 4904 relating to unworn falsification to authorities. DATE: JU4 i Na Je Title: muted st,nj Company: U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE Loan:7440101095 File #: 180622 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 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE Plaintiff VS. MELISSA L. HACK-BECKER Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-3862 CIVIL TERM CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify 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: MELISSA L. HACK-BECKER 1111 TIVERTON ROAD MECHANICSBURG, PA 17050-7720 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff Francis S. Hallinan, Esquire Date: ?v r PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identiftcation 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 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE V. Plaintiff, MELISSA L. HACK-BECKER 1111 TIVERTON ROAD MECHANICSBURG, PA 17050 Defendant(s). CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-3862-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 MELISSA L. HACK BECKER, 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 Plaintiff s damages as follows: As set forth in Complaint $302,088.84 Interest from 06/27/08 to 09/15/08 $3,880.71 TOTAL $305,969.55 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: q?OQ ?fo PROTHY 7 oeg 180622 PHELAN HALLINAN & SCHMIEG, LLP By: LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 DANIEL G. SCHMIEG, ESQ., Id. No. 62205 ONE PENN CENTER PLAZA, SUITE 1400 ATTORNEY FOR PLAINTIFF PHILADELPHIA, PA 19103 (215) 563-7000 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE Plaintiff V. MELISSA L. HACK-BECKER Defendant(s) TO: MELISSA L. HACK-BECKER 1111 TIVERTON ROAD MECHANICSBURG, PA 17050-7720 DATE OF NOTICE: August 22, 2008 COURT OF COMMON PLEAS CIVIL DIVISON NO. 08-3862 CIVIL TERM CUMBERLAND COUNTY 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. UAPORTANT 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 (10) 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 notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 JASON RICCO Legal Assistant PHS # 180622 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 U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE Plaintiff, V. MELISSA L. HACK-BECKER Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-3862-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 MELISSA L. HACK BECKER is over 18 years of age and resides at 1111 TIVERTON ROAD, MECHANICSBURG, PA 17050. 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 1 T 9 .Z' ?J ..C (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE Plaintiff, v. MELISSA L. HACK-BECKER CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 08-3862-CIVIL TERM Defendant(s). DANIEL G. SCHMIEG, ESQUIRE 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." Notice is given that a Judgment in the above-captioned matter has been entered against you on I 200 By: V DEPUTY v If you have any questions concerning this matter, please contact: Phelan Hallinan & Schmieg, LLP 1617 HK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 fUL TO I10NUktney For Plaintiff At F'MBE E?P?5rYl.ti?At? A1T'Y ' U.S. BANK NATIONAL Court of Common Pleas ASSOCIATION AS TRUSTEE Plaintiff Civil Division vs CUMBERLAND County MELISSA L. HACK-BECKER No. 08-3862 CIVIL TERM Defendant 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. X Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ? Please mark the in rem judgment Satisfied and the action Discontinued and Ended. Date: 3 ZZ L & SCHMIEG, LLP By: chael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff PHS # 180622 OLP Q ?dat it 11 F-4o?73q/ZS Phelan Hallinan & Schmieg, LLP 1617 HK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff U.S. BANK NATIONAL ASSOCIATION AS TRUSTEE Court of Common Pleas Plaintiff Civil Division vs MELISSA L. HACK-BECKER Defendant CUMBERLAND County No. 08-3862 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: MELISSA L. HACK-BECKER 1111 TIVERTON ROAD MECHANICSBURG, PA 17050-7720 Date: 3 2 Z/Z By:_ c/ John chael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff PHS # 180622