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.
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I E? Attorney for Plai iff O I;Ib0
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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
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(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
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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