HomeMy WebLinkAbout08-4475s?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
CIVIL ACTION - LAW
WACHOVIA BANK OF DELAWARE, NA
PLAINTIFF
VS
DOROTHEA L. BAILEY
DEFENDANT
CERTIFICATE OF LOCATION
306 SHED ROAD
NEWVILLE, PA 17241
MIFLIN TOWNSHIP
PARCEL No: 15-05-0413-025
Case Number: 0$ - gq,75 0. '
ivi t ,
Type of Pleading
CIVIL Division
Complaint in
Mortgage Foreclosure
Code and Classification:
Filed on Behalf Of:
Plaintiff
Counsel of Record:
Daniel J. Mancini, Esquire
Attorney at Law
201 A Fairview Drive
Monaca, PA 15061
(724) 728-4233
B ANIEL J. MANCINI, ESQ.
PA I.D. No. 39353
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724) 728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
Case Number:
VS
DOROTHEA L. BAILEY
DEFENDANTS
MORTGAGE FORECLOSURE
AVISO
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS
PERESENTADAS, ES ABSOLUTAMENTE NECESSAPJO QUE USTED RESPONDA DENTRO DE 20 DIAS
DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSAPJO QUE
USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE
USTED Y CUALQUIER OBJECCION ONTRA LAS QUEJAS EN ESTA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN
SU ARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL
DEMANDANTE Y EQUERIRA 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.
Lawyer Referral Services,
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724) 728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
Case Number:
VS
DOROTHEA L. BAILEY
DEFENDANTS
MORTGAGE FORECLOSURE
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
NOTICE
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.
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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Services,
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724)728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
Case Number:
VS
MORTGAGE FORECLOSURE
DOROTHEA L. BAILEY
DEFENDANTS
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 UNTI 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
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.
Dan 1 J ancini, Esq
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724)7284233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA
PLAINTIFF
CIVIL Division
Case Number: D F- `/y7.5? &a- ?
VS
DOROTHEA L. BAILEY
DEFENDANTS
MORTGAGE FORECLOSURE
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is: WACHOVIA BANK OF DELAWARE, NA, whose address is c/o Mancini
& Associates, 201 A Fairview Drive, Monaca, PA 15061.
2. Defendants are DOROTHEA L. BAILEY, whose last known address is 306 SHED
ROAD, NEWVILLE, PA 17241. DOROTHEA L. BAILEY are the mortgagors; with
DOROTHEA L. BAILEY as being the recorded owner of the mortgaged property
hereinafter described.
3. On or about, June 30, 1999, DOROTHEA L. BAILEY borrowed $103,200.00 and in
the enforcement of said debt executed and delivered a mortgage upon the premises
hereinafter described to the lender FIRSTAR BANK, NA., this mortgage is recorded in
the Office of the Recorder of Deeds of Cumberland County in Mortgage Record Book
1555, Page 427. Said mortgage was then assigned to FIRSTAR FINACE INC., and was
recorded at MBV 637, Page 411. The mortgage was further assigned to WACHOVIA
BANK OF DELAWARE F/K/A FIRST UNION HOME EQUITY BANK NA, and
recorded at MBV 637, Page 414. This mortgage and all instruments of assignment are
incorporated herein by reference in accordance with Pa. R.C.P. 1019 (g).Your plaintiff,
WACHOVIA BANK OF DELAWARE, NA is now the current owner of said mortgage,
and the assignment evidencing this ownership will be sent for recording at a later date.
4. The land subject to the Mortgage is 306 SHED ROAD, NEWVILLE, PA 17241, and is
more particularly described in Exhibit "A", which is attached hereof and part of this
Complaint.
5. The Mortgage is in default because monthly payments of principal and interest upon
said mortgage due July 23, 2007, and each month thereafter are due and unpaid, and by
the terms of said Mortgage, upon default in such payments for a period of one month, the
entire principal balance and all interest due thereon are collectible forthwith.
Unpaid Principal Balance $ 91,785.02
Delinquent Balance, including
Interest at $21.10 per diem $ 6,606.67
From 08/23/07 to 07/23/08
(based on contract rate of 8.39%)
Rec. Corp. Adv. $ 000.00
Escrow Advance $ 2,631.33
Accrued Late Charges $ 353.43
Bad CK Fees $ 00.00
Attorney's Fee
$ 4,589.25
Total
$ 105,965.70
** Together with interest at the per diem rate noted above after July 23, 2007 and other
charges and costs to date of Sheriffs 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 in accordance with the reduction
provisions of Act 6, if applicable, or that are actually incurred by Plaintiff.
6. No judgment has been entered upon said Mortgage in any jurisdiction.
7. The combined notice specified by the Pennsylvania Homeowner's Emergency
Mortgage Assistance Program, Act 91 or 1983 and Notice of Intention to Foreclose under
Act 6 of 1974 has been sent to each defendant on December 10, 2007, via certified and
regular mail, in accordance with the requirements of those acts.
8. Defendant is not a member of the Armed Forces of the United States of America, nor
engaged in any way which would bring them within the Soldiers and Sailors Relief Act
of 1940, as amended.
9. The Defendant has either failed to meet the time limitations as set forth under the
Combined Act 6/91 Notice or have been determined by the Pennsylvania Housing
Finance Agency not to qualify for Mortgage Assistance.
WHEREFORE, Plaintiff demands judgment in mortgage foreclosure `IN REM'
for the aforementioned total amount due together with interest at the rate of 8.39%
$21.10 per diem, together with other charges and costs including escrow advances
incidental thereto to the date of Sheriff's Sale and for foreclosure and sale of the property
within described.
Daniel J. Mancini, Esq.
Attorney Bar: PA 39353
Uurothea L Bailey Oreler Nuintxi: 40557 t - a
EXHIBIT A
ALL that certain tract of land with the improvements thereon erected, situate in Lower Mifflin Township,
Cumberland Coanty, Pennsylvania, bounded and described as follows:
BEGINNING at a point in the center of Township Road No. 412 theretofore erroneously designated as Township
Road No. 402}, which point is 378 feet, more or less, from the Northern boundary of the property now or
formerly of Paul Ickes; thence by land now or formerly of Clair W. Lrhman, South 45 degrees West 250 feet to a
stake. thence by the some, North 45 degrees West 145 feet to a stake; thence by the same, North 45 degms East
250 feet to a point in the center of Township Road No. 412 aforesaid; thence by the center of said Road, South
45 degrees East ) 45 feet to the place of BEGINNING.
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724)728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY,
PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
Case Number:
VS.
DOROTHEA L. BAILEY
Defendant(s).
VERIFICATION
Daniel J. Mancini, Esq., hereby states that he is the attorney for Plaintiff in this
matter, that He 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
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. Further, counsel submits that Plaintiff is outside the court's jurisdiction and
verification cannot be obtained with the time allowed for filing the pleading. It is
counsel's intention to substitute a verification from Plaintiff.
Dated this 23RD Day of July, 2008
Daniel 2JEJMancini, Esq.
Attorney Bar: Pa 39353
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04475 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WACHOVIA BANK OF DELAWARE NA
VS
BAILEY DOROTHEA L
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
BAILEY DOROTHEA L the
DEFENDANT , at 0017:55 HOURS, on the 29th day of July 2008
at 306 SHED ROAD
NEWVILLE, PA 17241 by handing to
ALEX BAILEY ADULT SON OF 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
V/V] Job 9,
So Answers:
18.00
13.00
.00
10.00 R. Thomas Kline
.00
41.00
07/30/2008
DANIEL MANCINI
Sworn and Subscibed to By:
before me this day
of A.D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
CIVIL ACTION - LAW
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF OS - N4 ?5
Case Number: 48-4474-
Type of Pleading
VS
DOROTHEA L. BAILEY
Mortgage Foreclosure
Praecipe for Default Judgment
DEFENDANT
CERTIFICATE OF LOCATION
306 SHED ROAD
NEWVILLE, PA 17241
MIFLIN TOWNSHIP
PARCEL No: 15-05-0413-025
Code and Classification:
Filed on Behalf Of:
Plaintiff
Counsel of Record:
Daniel J. Mancini, Esquire
Attorney at Law
201 A Fairview D
Monaca, PA 150 1
(724) 728-4233
A
By: DANIEL J. MANCINI, ESQ.
PA I.D. No. 39353
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724) 728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
VS
Case Number: 08-4474
MORTGAGE FORECLOSURE
DOROTHEA L. BAILEY
DEFENDANT
PRAECIPE FOR JUDGMENT FOR FAILURE TO
ANSWER AND ASSESSMENT OF DAMAGES
TO THE PROTHONOTARY: Kindly enter judgment, in rem, in favor of the Plaintiff, WACHOVIA
BANK OF DELAWARE, NA, c/o Daniel J. Mancini, Esquire, 201A Fairview Drive, Monaca, PA 15061,
and against Defendant DOROTHEA L. BAILEY, whose last known address is 306 SHED ROAD,
NEWVILLE, PA 17241 for failure to file an Answer to Plaintiff s Complaint within 20 days from service
thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows:
Unpaid Principal Balance $ 91,785.02
Delinquent Balance, including
Interest at $21.10 per diem $ 7,932.21
From 08/23/07 to 09/08/08
(based on contract rate of 8.39%)
Rec. Corp. Adv. $ 000.00
Escrow Advance $ 4,128.97
Accrued Late Charges $ 392.70
Bad CK Fees $ 00.00
Attorney's Fee $ 4,589.25
Total $ 108,825.15
I hereby certify the (1) the addresses of the Plaintiff and Defendants ' L?as shown above, and (2)
notice has been given in accordance with Rule 237. 1, copy attached.
Dan*l J. Mancini, Esq.
Attorney Bar No.: 39353
DAMAGES ARE HEREBY ASSESSED AS INDICATED.
DATE: azvog
P OTHO TA Y
"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."
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724) 728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
VS
Case Number: 08-4474
MORTGAGE FORECLOSURE
DOROTHEA L. BAILEY
DEFENDANT
AFFIDAVIT OF ACT 91 OF 1983
I, Daniel J. Mancini, Esquire, hereby affirm that I have complibd with Act 6 and
Act 91 of 1983, notice requirements in the above-captioned matte f
71-
J. Mancini, Esquire
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724) 728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
VS
Case Number: 08-4474
MORTGAGE FORECLOSURE
DOROTHEA L. BAILEY
DEFENDANT
AFFIDAVIT OF NAMES AND ADDRESSES
OF OWNERS AND DEFENDANTS
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DANIEL J. MANCINI, Esq., being duly authorized to make this affidavit on behalf of the Plaintiff
in the above action WACHOVIA BANK OF DELAWARE, NA„ being duly sworn according to law
deposes and says that to the best of his knowledge, information and belief the owner of 306 SHED ROAD,
NEWVILLE, PA 17241, the real property to be sold in the within execution and the defendants in the
judgment are DOROTHEA L. BAILEY, whose last known address 306 SHED RO D, NEWVILLE, PA
17241.
DATE: September 8, 2008
DANIEL J. MANCINI, ESQUIRE
Attorney for Plaintiff
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724) 728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
VS
Case Number: 08-4474
MORTGAGE FORECLOSURE
DOROTHEA L. BAILEY
DEFENDANT
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND ) SS:
Daniel J. Mancini, being duly sworn according to law, deposes and says that he is the attorney of
record, for the above-named Plaintiff, that he makes this Affidavit on Plaintiffs behalf, and that the
statements in this Affidavit are true to the best of his knowledge, information and belief.
Defendants DOROTHEA L. BAILEY are over 21 years of age.
Defendants are not in the military service of the United States as contemplated by the Soldier's
and Sailor's Civil Relief Act, as amended. 11
This affidavit is made in connection with the judgment upon a nod mortgage secured upon
the premises located at 306 SHED ROAD, NEWVILLE, PA 17241. ' f{
By: 4n V
Daniel . Mancini, Esq.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-04475 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WACHOVIA BANK OF DELAWARE NA
VS
BAILEY DOROTHEA L
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE was served upon
BAILEY DOROTHEA L the
DEFENDANT , at 0017:55 HOURS, on the 29th day of July , 2008
at 306 SHED ROAD
NEWVILLE, PA 17241 by handing to
ALEX BAILEY ADULT SON OF 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
Sworn and Subscibed to
before me this
of
So Answers:
18.00
13.00
.00
10.00 R. Thomas Kline
.00
41.00 07/30/2008
DANIEL MANCINI
By.
day
A. D.
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724) 728-4233
'PiTNEr stxwfS
001.100
IMPORTANT NOTICE
se you have failed to enter a written appearance personally or by attorney
your defenses or objections to the claims set forth against you. Unless you
date of this notice, a Judgment may be entered against you without a
•operty or other important rights. You should take this notice to a lawyer
yer or cannot afford one, go to or telephone the following office to find
Lawyer Referral Services,
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
a
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA
PLAINTIFF
VS
DOROTHEA L. BAILEY
DEFENDANT
TO: DOROTHEA L. BAILEY
306 SHED ROAD
NEWVILLE; PA 17241
DATE OF NOTICE: August 19, 2008
CIVIL Division
Case Number: 08-4475
MORTGAGE FORECLOSURE
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
nu- r I01Cr% VnD 'ruA 'r DrrDDOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE
'HIS CORRESPONDENCE IS NOT AND SHOULD NOT BE
tE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS
RCEMENT OF LIEN AGAINST PROPERTY.
t
Daniel J. Mancini, Esquire
Attorney for Plaintiff
t')
W o
ra
ca
a
c1y
c-n
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724) 728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
Case Number: 08-4474
VS
MORTGAGE FORECLOSURE
DOROTHEA L. BAILEY
DEFENDANT
RULE 236
NOTICE OF DEFAULT
To: Dorothea Bailey
306 Shed Road
Newville, PA 17241
You are hereby notified that the following Order, Decree or Judgment has been entered
against you on r?? J? aDO$
A Judgment of Default in the amount of $ 108.828.15 plus costs.
Ah k?=)
rothono
If you have any questions concerning the above, please contact:
DANIEL J. MANCINI, ESQUIRE
MANCINI & ASSOCIATES
201 A FAIRVIEW DRIVE
MONACA, PA 15061
724-728-4233
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
CIVIL ACTION - LAW
WACHOVIA BANK OF DELAWARE, NA
PLAINTIFF
CIVIL Division
08.44'15
Case Number: -68-44T4
VS
DOROTHEA L. BAILEY
DEFENDANT
CERTIFICATE OF LOCATION
306 SHED ROAD
NEWVILLE, PA 17241
MIFLIN TOWNSHIP
PARCEL No: 15-05-0413-025
Type of Pleading
Mortgage Foreclosure
Praecipe for Writ of Execution
Code and Classification:
Filed on Behalf Of:
Plaintiff
Counsel of Record:
Daniel J. Mancini, Esquire
Attorney at Law
201 A Fairview ve
Monaca, PA 15 1
(724) 728-4;6
By: DANIEL J. MANCINI, ESQ.
PA I.D. No. 39353
J
Daniel Mancini & Associates
Daniel J. Mancini, Esq.,
PA Bar ID: 39353
201 A Fairview Drive
Monaca, PA 15061
(724) 728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
VS
Case Number: 08-4474
MORTGAGE FORECLOSURE
DOROTHEA L. BAILEY
DEFENDANT
PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P.3180-3183
To the Director of the Office of Prothonotary
Issue writ of execution in the above matter:
Amount Due $ 108,825.15
From 7/24/08 to date of sale
(based on contract rate of 8.39%)
Dated this 8`h day of September, 2008.
Note: Property Description Attached
01-02
Attorney Bar No.: 39353
m
z s d
Daniel J. Mancini, Esq.,
Number 39353
201 A Fairview Drive
Monaca, PA 15061
(724)728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL ACTION - LAW
PLAINTIFF
CASE NO: 08-4474
MORTGAGE FORECLOSURE
VS
DOROTHEA L. BAILEY
DEFENDANT
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
WACHOVIA BANK OF DELAWARE, NA, Plaintiff in the above action, by its attorney, Daniel J. Mancini,
Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information
concerning the real property located at 306 SHED ROAD, NEWVILLE, PA 17241.
Name and address of Owner(s) or reputed Owner(s):
DOROTHEA L. BAILEY
306 SHED ROAD
NEWVILLE, PA 17241
Name and address of Defendant(s) in the judgment:
DOROTHEA L. BAILEY
306 SHED ROAD
NEWVILLE, PA 17241
Name and address of every judgment creditor whose judgment is a record lien on the real property
to be sold:
(PLAINTIFF IN THIS CASE)
WACHOVIA BANK OF DELAWARE, NA
701 CORPORATE CENTER DRIVE, RALEIGH, NC 27607
c/o Daniel J. Mancini, Esq. 201A Fairview Drive, Monaca, Pa 15061
08-4474 RECORDED 9/12/08 AMOUNT:$108,825.15
WACHOVIA BANK NA
1 OLD COUNTRY ROAD
CARLE PLACE, NY 11514
#2006-04430 RECORDED 8/2/2006 AMOUNT: $106,055.35
Name and address of the last recorded holder of every mortgage of record:
OTHER THAN PLAINTIFF IN THIS CASE
FIRSTAR BANK, NA
205 W. FOURTH STREET, CINCINNATI, OH 45202
MBV & PAGE 1555-435 RECORDED 7/6/1999 AMOUNT: $25,800.00
5. Name and address of every other person who has any record lien on the property:
DISCOVER CARD 2U29
3311 MILL MEADOW DRIVE, HILLIARD, OH 43026
#06-3200 RECORDED 6/5/2006 AMOUNT: $6,444.09
06-02
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the Sale:
Shelby Winter
529 Shed Road
Newville, PA 17241
Department of Revenue
Inheritance Tax Division
Strawberry Square
Harrisburg, PA 17105
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Program
PO Box 8486
Willow Oak Building
Harrisburg, PA 17105-8486
Department of Revenue
Bureau of Compliance
Sheriff Sale Section
PO Box 281230
Harrisburg, PA 17128-1230
Cumberland County Domestic Relations
P.O. Box 320
Carlisle, PA 17013
Name and address of every other person whom the Plaintiff has knowledge who has any interest
in the property which may be affected by the Sale:
UNKNOWN
I verify that the statements made in this Affidavit are true and correct to the best of my knowledge,
information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
`4904 relating to unsworn falsification to authorities.
Dated this 14th Day of January 2009
1,Mancini, Esq.
;v Bar No.: 39353
06-02
C? `=r1
?,
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Y ??.
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Daniel J. Mancini, Esq.,
Number 39353
201A Fairview Drive
Monaca, PA 15061
(724)728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL ACTION - LAW
PLAINTIFF
CASE NO: 08-4474
MORTGAGE FORECLOSURE
VS
DOROTHEA L. BAILEY
DEFENDANT
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the Sheriff's Sale of Real Property (real estate) will be held:
DATE: June 10, 2009
TIME: 10:00 a.m.
LOCATION: Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a
statement of the measured boundaries of the property, together with a brief mention of the buildings and any other
major improvements erected on the land.
DWELLING KNOWN AS 306 SHED ROAD, NEWVILLE, PA 17241.
ALL that certain tract of land with the improvements thereon erected, situate in
Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described as
follows:
Beginning at a point in the center of Township Road No. 412 (heretofore erroneosly
designated as Township Road No. 402), which point is 378 feet, more or less, from
the Northern boundry of the property now or formerly of Paul Ickes; thence by land
now or formerly of Clair W. Lehman, South 45 degrees west 145 feet to a stake;
thence by the same, North 45 degrees East 250 feet to a point in the center of
Township Road No. 412 aforesaid; thence by the center of said Road, South 45
degrees East 145 feet to the place of BEGINING.
THE LOCATION of your property to be sold is:
306 SHED ROAD
NEWVILLE, PA 17241
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within
Commonwealth and County to:
08-4474
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
DOROTHEA L. BAILEY
.146
A SCHEDULE OF DISTRIBUTION, being a list of the persons and/or governmental or corporate
entities or agencies being entitled to receive part of the proceeds of the sale received and to be disbursed by the
Sheriff (for example, to banks that hold mortgages and municipalities that are owed taxes) will be filed by the
Sheriff of this County thirty (30) days after the sale and distribution of the proceeds of sale in accordance with this
schedule will, in fact, be made unless someone objects by filing exceptions to it within ten (10) days of the date it is
filed.
Information about the Schedule of Distribution may be obtained from the Sheriff of the Court of Common
Pleas of Cumberland County, Pennsylvania, Cumberland County Courthouse.
THIS PAPER IS A NOTICE OF THE TIME AND PLACE OF THE SALE OF YOUR PROPERTY.
IT HAS BEEN ISSUED BECAUSE THERE IS A JUDGMENT AGAINST YOU
IT MAY CAUSE YOUR PROPERTY TO BE HELD, TO BE SOLD OR TAKEN TO PAY THE
JUDGMENT.
You may have legal rights to prevent your property from being taken away. A lawyer can advise you more
specifically of these rights. If you wish to exercise your rights, YOU MUST ACT PROMPTLY.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET FREE LEGAL ADVICE:
Lawyer Referral Services,
4th Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
THE LEGAL RIGHTS YOU MAY HAVE ARE:
1. You may file a petition with the Court of Common Pleas of the within County to open the judgment if
you have a meritorious defense against the person or company that has entered judgment against you. You may also
file a petition with the same Court if you are aware of a legal defect in the obligation or the procedure used against
you.
2. After the Sheriff s Sale you may file a petition with the Court of Common Pleas of the within County to
set aside the sale for a grossly inadequate price or for other proper cause. This petition MUST BE FILED
BEFORE THE SHERIFF'S DEED IS DELIVERED.
3. A petition or petitions raising the legal issues or rights mentioned in the preceding paragraphs must be
presented to the Court of Common Pleas of the within County. The petition must be served on the attorney for the
creditor or on the creditor before presentation to the court and a proposed order or rule must be attached to the
petition.
If a specific return date is desired, such date must be obtainne om the within County Court House before
presentation to the Court. I
Esq.
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Chiumet Title Iesrteeat Cat"by
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-4475 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WACHOVIA BANK OF DELAWARE, NA, Plaintiff (s)
From DOROTHEA L. BAILEY
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $108,825.15
L.L. $.50
Interest from 7/24/08 to date of sale (based on contract rate of 8.39%)
Atty's Comm %
Due Prothy $2.00
Atty Paid $160.00 Other Costs
Plaintiff Paid
Date: 1/22/09
Curtis R. Long, Protho tary
(Seal)
By:
Deputy
REQUESTING PARTY:
Name: DANIEL J. MANCINI, ESQUIRE
Address: DANIEL MANCINI & ASSOCIATES
201 A FAIRVIEW DRIVE
MONACA, PA 15061
Attorney for: PLAINTIFF
Telephone: 724.728.4233
Supreme Court ID No. 39353
Wachovia Bank of Delaware
VS
Dorothea L. Bailey
In The Court of Common Pleas of
Cumberland County, Pennsylvania
Writ No. 2008-4475 Civil Term
R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ
is returned STAYED per letter of request from Attorney Daniel Mancini.
Sheriff s Costs:
Docketing
Poundage
Law Library
Prothonotary
Mileage
Levy
Surcharge
So Answer
R. Thomas Kline, Sheriff
ark,
30.00
1.58
.50
2.00
11.70
15.00
20.00
$80.78 ?/o?.le4 ?,
0e 4k3sr-"
.2,7073
-
CIL ,>
Daniel J. Mancini, Esq.,
Number 39353
201A Fairview Drive
Monaca, PA 15061
(724)728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL ACTION - LAW
PLAINTIFF
CASE NO: 08-447'
VS
MORTGAGE FORECLOSURE
DOROTHEA L. BAILEY
DEFENDANT
AFFIDAVIT PURSUANT TO RULE 3129
(Affidavit No. 1)
WACHOVIA BANK OF DELAWARE, NA, Plaintiff in the above action, by its attorney, Daniel J. Mancini,
Esquire, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information
concerning the real property located at 306 SHED ROAD, NEWVILLE, PA 17241.
Name and address of Owner(s) or reputed Owner(s):
DOROTHEA L. BAILEY
306 SHED ROAD
NEWVILLE, PA 17241
2. Name and address of Defendant(s) in the judgment:
DOROTHEA L. BAILEY
306 SHED ROAD
NEWVILLE, PA 17241
3. Name and address of every judgment creditor whose judgment is a record lien on the real property
to be sold:
(PLAINTIFF IN THIS CASE)
WACHOVIA BANK OF DELAWARE, NA
701 CORPORATE CENTER DRIVE, RALEIGH, NC 27607
c/o Daniel J. Mancini, Esq. 201A Fairview Drive, Monaca, Pa 15061
084474 RECORDED 9/12/08 AMOUNT:$108,825.15
WACHOVIA BANK NA
1 OLD COUNTRY ROAD
CARLE PLACE, NY 11514
#2006-04430 RECORDED 8/2/2006 AMOUNT: $106,055.35
Name and address of the last recorded holder of every mortgage of record:
OTHER THAN PLAINTIFF IN THIS CASE
FIRSTAR BANK, NA
205 W. FOURTH STREET, CINCINNATI, OH 45202
MBV & PAGE 1555-435 RECORDED 7/6/1999 AMOUNT: $25,800.00
5. Name and address of every other person who has any record lien on the property:
DISCOVER CARD 2U29
3311 MILL MEADOW DRIVE, HILLIARD, OH 43026
#06-3200 RECORDED 6/5/2006 AMOUNT: $6,444.09
06-02
6. Name and address of every other person who has any record interest in the property and whose
interest may be affected by the Sale:
Shelby Winter
529 Shed Road
Newville, PA 17241
Department of Revenue
Inheritance Tax Division
Strawberry Square
Harrisburg, PA 17105
Department of Public Welfare
TPL Casualty Unit
Estate Recovery Program
PO Box 8486
Willow Oak Building
Harrisburg, PA 17105-8486
Department of Revenue
Bureau of Compliance
Sheriff Sale Section
PO Box 281230
Harrisburg, PA 17128-1230
Cumberland County Domestic Relations
P.O. Box 320
Carlisle, PA 17013
7. Name and address of every other person whom the Plaintiff has knowledge who has any interest
in the property which may be affected by the Sale:
UNKNOWN
I verify that the statements made in this Affidavit are true and correct to the best of my knowledge,
information or belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
`4904 relating to unworn falsification to authorities.
Dated this 140' Day of January 2009
06-02
Attorney Bar No.: 39353
Daniel J. Mancini, Esq.,
Number 39353
201 A Fairview Drive
Monaca, PA 15061
(724)728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL ACTION - LAW
PLAINTIFF
CASE NO: 08-4474
VS
MORTGAGE FORECLOSURE
DOROTHEA L. BAILEY
DEFENDANT
NOTICE OF SHERIFF'S SALE OF REAL ESTATE
PURSUANT TO
PENNSYLVANIA RULE OF CIVIL PROCEDURE 3129
TAKE NOTICE:
That the Sheriff s Sale of Real Property (real estate) will be held:
DATE: June 10, 2009
TIME: 10:00 a.m.
LOCATION: Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
THE PROPERTY TO BE SOLD is delineated in detail in a legal description mainly consisting of a
statement of the measured boundaries of the property, together with a brief mention of the buildings and any other
major improvements erected on the land.
DWELLING KNOWN AS 306 SHED ROAD NEWVILLE, PA 17241.
awya. u avc iVLiun
ALL that certain tract of land with the improvements thereon erected, situate in
Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described as
follows:
Beginning at a point in the center of Township Road No. 412 (heretofore erroneosly
designated as Township Road No. 402), which point is 378 feet, more or less, from
the Northern boundry of the property now or formerly of Paul Ickes; thence by land
now or formerly of Clair N. Lehman, South 45 degrees went 145 feet to a stake;
thence by the same, North 45 degrees East 250 feet to a point in the center of
Township Road No. 412 aforesaid; thence by the center of said Road, South 45
degrees East 145 feet to the place of BEGINING.
THE LOCATION of your property to be sold is:
306 SHED ROAD
NEWVELLE, PA 17241
THE JUDGMENT under or pursuant to which your property is being sold is docketed in the within
Commonwealth and County to:
084474
THE NAME(S) OF THE OWNER(S) OR REPUTED OWNERS of this property
DOROTHEA L. BAILEY
Daniel J. Mancini, Esq.,
Number 39353
201A Fairview Drive
Monaca, PA 15061
(724)728-4233
IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY
PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL ACTION - LAW
PLAINTIFF
CASE NO: 08-4474
MORTGAGE FORECLOSURE
VS
DOROTHEA L. BAILEY
DEFENDANT
LONG PROPERTY DESCRIPTION
ALL that certain tract of land with the improvements thereon erected, situate in
Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described as
follows:
Beginning at a point in the center of Township Road No. 412 (heretofore erroneosly
designated as Township Road No. 402), which point is 378 feet, more or less, from
the Northern boundry of the property now or formerly of Paul Ickes; thence by land
now or formerly of Clair W. Lehman, South 45 degrees West 145 feet to a stake;
thence by the same, North 45 degrees East 250 feet to a point in the center of
Township Road No. 412 aforesaid; thence by the center of said Road, South 45
degrees Bast 145 feet to the place of BEGINING.
BEING improved with a ranch type dwelling house with attached garage.
DWELLING KNOWN AS 306 SHED ROAD, NEWVILLE, PA 17241
IDENTIFIED as TAX/PARCEL ID#: 15-05-0413-025 In Deed Registry Office of
Cumberland County, Pennsylvania.
Mancini, Esquire
for Plaintiff
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 08-4475 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due WACHOVIA BANK OF DELAWARE, NA, Plaintiff (s)
From DOROTHEA L. BAILEY
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the gamishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $108,825.15 L.L. $.50
Interest from 7/24/08 to date of sale (based on contract rate of 8.39%)
Atty's Comm % Due Prothy $2.00
Atty Paid $160.00 Other Costs
Plaintiff Paid
Date: 1/22/09
(Seal)
urns R. Long, rothonotary
By:
Deputy
REQUESTING PARTY:
Name: DANIEL J. MANCINI, ESQUIRE
Address: DANIEL MANCINI & ASSOCIATES
201 A FAIRVIEW DRIVE
MONACA, PA 15061
Attorney for: PLAINTIFF
Telephone: 724.728.4233
Supreme Court ID No. 39353
Real Estate Sale # 25
On January 29, 2009 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Mifflin Township, Cumberland County, PA
Known and numbered as 306 Shed Road,
Newville, more fully described on Exhibit "A" filed
with this writ and by this reference incorporated herein.
Date: January 29, 2009
By:
v
R ?t 1 d b Z NV HOZ
M
r
i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
COMMONWEALTH OF PENNSYLVANIA
CIVIL ACTION - LAW
WACHOVIA BANK OF DELAWARE, NA CIVIL Division
PLAINTIFF
Case Number: 08-4475
Type of Pleading
VS Praecipe to Discontinue
And Settle Case in
Mortgage Foreclosure
DOROTHEA L. BAILEY
DEFENDANT
CERTIFICATE OF LOCATION
306 SHED ROAD
NEWVILLE, PA 17241
MIFLIN TOWNSHIP
PARCEL No: 15-05-0413-025
Code and Classification:
Filed on Behalf Of:
Plaintiff
Counsel of Record:
Daniel J. Mancini, Esquire
Attorney at Law
201 A Aii Dri
Monac61
(724) By: DANIEL'"`J,MANCIM, ESQ.
PA I.D. No. 39353
I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
WACHOVIA BANK OF DELAWARE, NA CIVIL DIVISION
VS.
DOROTHEA L. BAILEY FILE NO: 08-4475
PRAECIPE AND POWER OF ATTORNEY TO DISCONTINUE AND SETTkE
FORECLOSURE WITH RIGHT TO REFILE
TO THE PROTHONOTARY OF SAID COURT:
You are hereby authorized, empowered, and directed to enter, as indicated, the following
on the records thereof:
A 1. --X-- the within suit is Settled, Discontinued, Ended WI ROUT Prej dice and costs
paid and Plaintiff reserves right to file another foreclosure actiVr ul dDe endant fail with
its obligations to Plaintiff. Da te: August 27, 2009
WITNESS {if signer is other
than a registered attorney}:
Attorney
Attorney or Notary
Signature of
Daniel J. Mancini, Esg.
Type or print name of above signer
COST PAYMENT VERIFICATION
TO UNSWORN FALSIFICATION TO AUTHORITIES
Signature
FILE ?..; l ICE
?„?
OF THE PR," `H, ? . MARY
2009 SEP I I PH 1: 58
Y