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HomeMy WebLinkAbout08-4854GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 Market Street PHILADELPHIA, PA 19106 (215) 627-1322 LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 BE 11 2780 Lake Vista Drive Lewisville, TX 75067-3884 Plaintiff VS. JILL K. WHITMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 CIVIL ACTION: EJF-CTME14T IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Defendants NOTICE CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 68 - it aS4 (vi (Terwt 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 the 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 maybe entered against you by the Court without fiurther notice for any money claim in the Complaint of 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 AVISO LE RAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEIAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERBtA 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 IMIPORTANTES. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATEAMENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (SERVICIO DE REFERENCIA DE ABOGADOS), (215) 239-6300. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row, Carlisle, PA 17013 717-243-9400 COMPLAINT IN EJECTMENT I . Plaintiff is LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11, 2780 Lake Vista Drive, Lewisville, TX 75067-3884. 2. Defendants are JILL K. WHITMYER, and OCCUPANTS. 3. Plaintiff is the equitable owner of premises located at 707 Veronica Lane, Enola, PA 17025 C the Property"). A true and correct copy of the legal description of the Property is attached to this Complaint. 4. Plaintiff is the record owner of the Property by virtue of a Deed from the Sheriff of Cumberland County to LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11 recorded on at August 6, 2008 at instrument number#200826780. 5. Plaintiff is entitled to immediate possession of the Property. 6. The Defendants, JILL K. WHITMYER and OCCUPANTS, are occupying the Property without right, and so far as the Plaintiff is informed, without claim of title. 7. Plaintiff has demanded possession of the Property from the said Defendants, who have refused to deliver up possession of the same. WHEREFORE, Plaintiff requests judgment for possession of the Property. GOLDBECK McCAFFERTY & McKEEVER By: Michael McKeever, Esq. VERIFICATION 1 ?42f"014 SIMK?on behalf of the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. l understand that false statements therein are made subject to the penalties of 18 Pa.(C'.S. 4904 relating to unsworn falsification to authorities. Date: LS-14 - 6p xl IQ ti-t s .=.n Au v- WNW I ghtof &C A `4 ,tuw 1 noti-"M 5,dit: L loan tqW . -. wood Acx"AOwapwwxdt: dividjav Lac c.f't by 7'inv s't Iclt ?;.. , .•. '(='T ll tw tl?.< s?tit?ao?e; =,9 sccon15 last. X6 fir 3t » WE! ! _ 01. pw r[ I,=rr''ic ti 20 and 3% '0", 1 o = >' ol''>Ec. ", Skwdl :., V.>: .r 11 l,c e 105 `Q0 t; n ,10,Ea o4' thr r,-,? , et ,i zl? 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Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT WHITMYER JILL K but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , the within named DEFENDANT 707 VERONICA LANE WHITMYER JILL K NOT FOUND , as to ENOLA, PA 17025 NUMEROUS ATTEMPTS. APPEARED TO BE SOMEONE HOME, BUT NO ONE WOULD ANSWER THE DOOR. Sheriff's Costs: Docketing 18.00 Service 30.00 Not Found 5.00 Surcharge 10.00 qlz q?eQ .00 ? 63.00 So answers, R. Thomas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 09/15/2008 Sworn and Subscribed to before me this day of A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04854 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS WHITMYER JILL K ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT OCCUPANTS but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , OCCUPANTS 707 VERONICA LANE ENOLA, PA 17025 APPEARED TO BE SOME ONE HOME, BUT NO ONE WOULD ANSWER THE DOOR. Sheriff's Costs: Docketing 6.00 Service .00 Not Found 5.00 Surcharge 10.00 n 00 V21.00 So answers: R. Thomas Kline Sheriff of Cumberland County GOLDBECK MCCAFFERTY MCKEEVER 09/15/2008 Sworn and Subscribed to before me this day of A. D. GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11 2780 Lake Vista Drive Lewisville, TX 75067-3884 vs. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 08-4854 JILL K. WHITMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, Michael T. McKeever, Esq., in support of its Motion for Substituted Service, represents as follows: Plaintiff is the legal owner of the premises 707 Veronica Lane, Enola, PA, 17025 pursuant to a deed from the Sheriff of Cumberland County. 2. Plaintiff filed a Complaint in Ejectment on August 13, 2008 . Sheriff has been unable to effect service of the Complaint upon Defendants despite numerous attempts and despite the fact that Plaintiffs inspection of the premises indicates it is occupied. 4. As this is an action for possession, further investigation is unnecessary. Defendants have no right, title or interest in the premises, 707 Veronica Lane, Enola, PA, 17025. Plaintiff believes and therefore avers that Defendants are deliberately avoiding service. 6. Plaintiffs inability to affect personal service upon Defendants has deprived, and continues to deprive Plaintiff of the use and enjoyment of which it is the lawful owner. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint/Writ upon Defendants by posting the premises and certified and regular mail to the Defendants' last known address. Respectfully submitted, BY: Michael T. McKeeve •, sq. GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11 2780 Lake Vista Drive Lewisville, TX 75067-3884 vs. JILL K. WHITMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 VERIFICATION IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 08-4854 I, Michael T. McKeever, Esq., Attorney for Petitioner do hereby verify that the facts set forth in the foregoing Motion for Substituted Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities. BY: ichael T. McKeever, Esq. GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11 2780 Lake Vista Drive Lewisville, TX 75067-3884" JILL K. WHITMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 vs. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY Term No. 08-4854 MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR SUBSTITUTED SERVICE UNDER Pa.R.C.P. 430(a) Plaintiff has filed a Complaint in Ejectment, against Defendants which the Sheriff has been unable to personally serve upon Defendants. As noted in the attached Motion, Plaintiff has made a good faith attempt to ascertain Defendants whereabouts without success. Accordingly, the Court may approve alternative means of service. See Pa.R.C.P. 430(a). CONCLUSION For reasons stated above and in the attached Motion, the Court should enter an order allowing Plaintiff to serve the Complaint in Ejectment upon Defendants by posting the premises and certified mail and regular mail to the Defendants' last known address. Respectfully submitted, Michael T. McKeever, Esq. SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04854 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS WHITMYER JILL K ET AL R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT WHITMYER JILL K b t unable to locate Her in his bailiwick COMPLAINT - EJECTMENT , u was He therefore returns the the within named DEFENDANT , WHITMYER JILL K 707 VERONICA LANE NOT FOUND , as to ENOIjA, PA 1702511 NUMEROUS ATTEMPTS. APPEARED TO AE SOMEONI i-101,T ,?, i_:ji.T iv IiTJIi; v'YKi 1ji) r1Ij bpi h: < i.1 llc>??ke1 :i ),lra (?I C 11 {+? f l l l f 1! I I l.C. l : I L,.1 I. LA t :- .l! v, Ill Ull tNY i, i [I11 t;OI ?I )Ftl-?;!'I( Ihl `f 'A h'I?' W 11' I' V IV)f'kl{).!l/t 1.11/ i'i?JI111tS ?, VJlJi ll alltl ,_7U1):iU.L1Ut:U 1.V i)N l.U r"i-' A. j). I SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-04854 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS WHITMYER JILL K ET AL R. Thomas Kline ,Sheriff or Deputy Sheriff, who being du=1T swcrn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT OCCUPANTS but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , the within named DEFENnANT , OCCUPANTS NOT FOUND , as to 707 VERONICA LANE Q10iA, RA 17025 APPEARED TO BE SOME ONE HOME, BUT NO ONE WOULD ANSWER '.t`HN' DOOR . INJUL_ Lt)Jtlci 11. ThnmZ FCJ 'i.r?c C, 1w i 1. 1, A.. „ PrDVSK LLC Aflidavit of Good Faith Invesbpbon Coen* padded Mortnation: File Number: 69593EJ Attorney Firm: GOLDBECK, MCCAFFERTY & MCKEEVER Subject Name: Jill K. Whitmyer Property Address: Street: 707 Veronica Lane City: Enola State: PA Zip 17025 Sldp Results: Date of Birth: 08/1811970 Last Known Street: 707 Veronica Lane City: Enola State: PA ProVest File Number: 1213764 Dates: As of 9/26/2008 Phone: Zip: 17025 Death Records: As of 9/26/2008, the Social Security Administration has no death record on file for Jill K. Whitmyer. Sold Secw ty Numl er Search Completed. Employment Search: Unable to verify current employer. Creditor Irrforrrration: Creditors indicated the last reported address for Jill K. Whitmyer as 707 Veronica Lane, Enola, PA 17025. Departmert of Mohr The Pennsylvania Department of Motor Vehicles provided no change for Jill K. Whitmyer from Vahkie Records: 707 Veronica Lane, Enola, PA 17025. Pubic Licenses (Plot, Search performed provided no information. Real Estate. etc): V?RepisUatlon The County Voters Registration Office has no listing for Jill K. Whitmyer. Has no change for Jill K. Whitmyer from 707 Veronica Lane, Enola, PA 17025 There was no active military status found. 717-728-9259: Number listed to Cameron and Jill Whitmyer at 707 Veronica Lane, Enola, PA 17025, there was no answer. 7174834-5588: Called possible relative, Laurie Whitmyer, left message on answering madhine, no response. 717-728-3129: Called possible neighbor, S. Bogdon, there was no answer. On 9/26/2008, 1, Patti Garrett being duly sworn according to the law, deposes and says: I am employed by ProVest, LLC. I have conducted an investigation into the whereabouts of the above named subject. Above are the results of my investigation. rY ? ?f Affant a M: P i Garrett SU SCr*bed ?. ? Swv4r) tlgivre -no. - Nol(xy uL ic: Date: 9/28/2008 CYNTHIA LAWAN NOMber 2e. 201 GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11 2780 Lake Vista Drive Lewisville, TX 75067-3884 vs. JILL K. WHITMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 CERTIFICATE OF SERVICE of Cumberland County No. 08-4854 Michael T. McKeever, Esq., does hereby certify that true and correct copies of the foregoing Motion for Substituted Service have been served upon the Defendants this 3rd day of October , 2008, by first class mail, postage prepaid. JILL K. WHITMYER And OCCUPANTS 707 Veronica Lane Enola, PA 17025 IN THE COURT OF COMMON PLEAS BY: Michael T. McKeever, Esq. ? ? r ?::? c?a °"t"1 -? : ?? ?? _? -?,? , , ?? ?„,? ? -r 3 -.«a. ^7 3 ? :) ?..5 '?; '--f '%% GOLDBECK McCAFFERTY & McKEEVER MICHAEL T. MCKEEVER Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11 2780 Lake Vista Drive Lewisville, TX 75067-3884 VS. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY JILL K. WHITMYER and OCCUPANTS 707 Veronica. Lane Enola, PA 17025 No. 08-4854 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. MOTION FOR SUBSTITUTED SERVICE UNDER PA.R.C.P. 430(a) Plaintiff, by and through its attorney, Michael T. McKeever, Esq., in support of its Motion for Substituted Service, represents as follows: 1. Plaintiff is the legal owner of the premises 707 Veronica Lane, Enola, PA, 17025 pursuant to a deed from the Sheriff of Cumberland County. 2. Plaintiff filed a Complaint in Ejectment on August 13, 2008. Sheriff has been unable to effect service of the Complaint upon Defendants despite numerous attempts and despite the fact that Plaintiffs inspection of the premises indicates it is occupied. 4. Pursuant to Cumberland County Local Rule 208.3(ax2) and/or Rule 208.3(ax9), I, David Fein, Esquire, hereby certify that no judge has ruled on any other matters in this case. I further certify that I am not aware that the Defendant has obtained counsel. Moreover, .rn. due to the nature of this motion, it was not possible to locate or contact the Defendant to request his concurrence. As this is an action for possession, further investigation is unnecessary. Defendants have no right, title or interest in the premises, 707 Veronica Lane, Enola, PA, 17025. Plaintiff believes and therefore avers that Defendants are deliberately avoiding service. 7. Plaintiffs inability to affect personal service upon Defendants has deprived, and continues to deprive Plaintiff of the use and enjoyment of which it is the lawful owner. WHEREFORE, Plaintiff prays that the Court enter the attached order allowing Plaintiff to serve the Complaint/Writ upon Defendants by posting the premises and certified and regular mail to the Defendants' last known address. Respectfully submitted, , 199V BY: ichael T. McK ver, Esq. ?.,.? P ? ?-? w./ 5?w.r ¢?+ ?;; err ??"; y1 ?? ... t •,.t `_ j a'4 ! ?.! ^°.(. OCT 0 8 2008 6n LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11 2780 Lake Vista Drive Lewisville, TX 75067-3884 vs. JILL K. WHITMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 ORDER No. 08-4854 AND NOW, this 3of day of qLhytj' 2008, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it appearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Ejectment upon Defendants by posting a copy of the Complaint upon the premises 707 Veronica Lane, Enola, PA, 17025, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 707 Veronica Lane, Enola, PA, 17025, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Writ of Possession pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises. BY THE COURT: istribution list: J. Michael T. McKeever, Esquire, Suite 5000 -1\ Philadelphia, PA 19106-1532 ALL K W Independence Center, 701 Market Street, HITMYER, & OCCUPANTS 707 Veronica Lane Enola, PA 17025 e (ez ?aA4/go8 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY i UELJ crr 2g08OCT 30 p?j 2' 53 1'L ti??}{L?'.r;?` tilt PEN* CASE NO: 2008-04854 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS WHITMYER JILL K ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon OCCUPANTS the DEFENDANT , at 0958:00 HOURS, on the 7th day of November-, 2008 at 707 VERONICA LANE ENOLA. PA 17025 by handing to POSTED PER COURT ORDER AT 707 VERONICA LANE ENOLA a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Posting 6.00 Surcharge 10.00 00 22.00 Sworn and Subscibed to before me this day of , So Answers: Thomas Klin 11/12/2008 GOLDBECK MCCAFFERTY MCKEEVER By : )Deputy Sheri A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2008-04854 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS WHITMYER JILL K ET AL ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT WHITMYER JILL K was served upon the DEFENDANT , at 0958:00 HOURS, on the 7th day of November , 2008 at 707 VERONICA LANE ENOLA, PA 17025 by handing to 707 VERONICA LANE ENOLA a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Posting Surcharge i?) IY)u8 ?,` 18.00 15.00 6.00 10.00 .00 ? 49.00 Sworn and Subscibed to before me this day of , So Answers: vg?az,, ?Z- T mas in 11/12/2008 GOLDBECK MCCAFFERTY MCKEEVER By - Deputy Sheriff A.D. GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever Attorney ID #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE1 l 2780 Lake Vista Drive Lewisville, TX 75067-3884 Plaintiff VS. JILL K. WHTTMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 08-4854 PRAECIPE FOR JUDGMENT IN EJECTMENT Kindly enter Judgment in Ejectment in favor of the Plaintiff, LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11 and against the Defendants JILL K. WHHTMYER and OCCUPANTS for failure to file an Answer in the above action within (20) days of service. I HEREBY CERTIFY THAT ACCORDING TO rule 237. 1, written 10 day notice of Plaintiff's intention to file a Praecipe for Entry of Default Judgment was mailed to Defendants, a true and correct copy of which is attached hereto. I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11, 2780 Lake Vista Drive, Lewisville, TX 75067-3884 and that the names and last known address of the Defendants are JILL K. WHITMYER and OCCUPANTS 707 Veronica Lane, Enola, PA 17025. GOLDBECK McCAFFERTY & McKEEVER Michael T. McKeever, Esq. Attorney for Plaintiff ocr 0 8 W 4 LaSalle Bank National Association, as Trustee for Cerdficateholders for Bear Stearns Asset Backed Securities I LLC, And Backed Certificates, Series 2005 HEI 1 2780 Lake Vista Drive Lewisville, TX 75067-3894 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY No. 08-4854 vs. M,L K. WIEWYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 ORDER ???? jj AND NOW, this j044- day of 2008, upon consideration of the Plaintiffs Motion for Substituted Service under Pa.R.C.P. 430(a) and it wearing to the Court that Plaintiffs good faith efforts to ascertain the present whereabouts of Defendants has been unsuccessful, it is, ORDERED and DECREED: that Plaintiffs Motion is granted and the Sheriff and/or Plaintiff is directed to Serve the Complaint in Ejectment upon Defendants by posting a copy of the Complaint upon the premises 707 Veronica Lane, Enola, PA, 17025, and Plaintiff is directed to serve the Complaint by certified and regular mail to the Defendants' last known address at 707 Veronica Lane, Enola, PA, 17025, and that all further service of legal papers, including but not limited to motions, petitions and rules be made by certified and regular mail to Defendants' last known address and that Writ of Possession pursuant to Pennsylvania Rule of Civil Procedure 3129 may be made upon Defendants by sending copies of same to Defendants' last known address by certified and regular mail and by posting the premises. RY THE COURT: d Cqutt ?; . Distn"buhon list: `" 1?: Michael T. McKeever, Esquire, Suite 5000 - Mellon Independence Center, 701 Market Street, Philadelphia, PA 19106-1532 JILL K. WHITMYER, & OCCUPANTS 707 Veronica Lane Enola, PA 17025 GOLDBECK WCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215)627-1322 ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW EJECTMENT LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11 2780 Lake Vista Drive Lewisville, TX 75067-3884 VS. JILL K. WHITMYER & OCCUPANTS 707 Veronica Lane Enola, PA 17025 Defendant(s) CERTIFICATE OF SERVICE Term No. 08-4854 MICHAEL T. McKEEVER, ESQUIRE hereby certifies that on November 12, 2008 he did serve upon Defendant(s) JILL K. WHITMYER and OCCUPANTS a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated October 30, 2008. The undersigned understands that the statements herein and subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, ESQUIRE GOLDBECK McCAFFERTY & MCKEEVER BY: MICHAEL MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADtLPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF LaSalle Bank National Association, as Trustee for Certificateholders for Bear Steams Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HEl l 2780 Lake Vista Drive Lewisville, TX 75067-3884 Plaintiff VS. JILL K. WHTTMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 Defendants DATE OF THIS NOTICE: December 2, 2008 TO: OCCUPANTS 707 Veronica Lane Enola, PA 17025 IMPORTANT NOTICE IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 08-4854 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 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 BAR ASSOCIATION 2 LibaV Avenue Calisle, PA 17013 LEGAL SERVICES INC S Irvine Row Carlisle, PA 17013 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attomcy for Plaintiff GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL MCKEEVER, ESQ. ATTORNEY LD. #56129 SME 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHRAVELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11 2780 Lake Vista Drive Lewisville, TX 75067-3884 Plaintiff VS. JILL K. WHITMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 Defendants DATE OF THIS NOTICE: December 2, 2008 TO: JILL K. WIRTMYER 707 Veronica Lane Enola, PA 17025 IMPORTANT NOTICE Term No. 08-4854 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 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 BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF EJECTMENT GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. 1. That the above named Defendant, JILL K. WHITMYER, is about unknown years of age, that Defendant's last known residence is 707 Veronica Lane Enola, PA 17025, and is engaged in the unknown business located at unknown address. 2. That Defendant is 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 Action of Congress of 1940 and its Amendments. Date: DEC 17 2008 _ M&L 5719,n GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney ID #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6319 Attorney for Plaintiff LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HEl 1 2780 Lake Vista Drive Lewisville, TX 75067-3884 Plaintiff VS. JILL K. WHQTMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF EJECTMENT Term No. 08-4854 CERTIFICATION PURSUANT TO PA RC.P. N0.237 I, Michael T. McKeever, Esquire, attorney for Plaintiff, certify that a true and correct copy of the Praecipe for Judgment was sent to the following parties, via first class mail, postage prepaid: JILL K. W HTMYER OCCUPANTS 707 Veronica. Lane Enola, PA 17025 GOLDBECK McCAFFERTY & McKEEVER BY: MAvti??yh'?-`? C Michael T. McKeever, Esq. Attorney for Plaintiff DATED: December 15, 2008 n C c N CZ* c o -? cn r1l ..t3 ? {A r,j tT? "< C.P. 109 - P Praecipe for Writ of Possession (ACTION OF EJECTMENT) THE COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cumberland LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE11 2780 Lake Vista Drive Lewisville, TX 75067-3884 Plaintiff IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY 08-4854 VS. JILL K. WHITMYER and OCCUPANTS 707 Veronica Lane Enola, PA 17025 Defendants PRAECIPE FOR WRIT POSSESSION TO THE PROTHONOTARY: Issue the Writ of Possession in the above matter, for possession of 707 Veronica Lane EnohL PA 17025 (describe property) SEE ATTACHED LEGAL DESCRwnON Ejectment Quiet Title A. 5 -116 (Rev. 10/76) LMcCAFFERTY & McKEEVER BY: Michael T. McKeever, Esquire Attorney for Plaintiff x r 77 Q? 0, © ? cxs .Q ri 00 Al.l. 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L.". :w( sz. -tit CASE NO: 2008-04854 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA.: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS WHITMYER JILL K ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon OCCUPANTS the DEFENDANT at 0958:00 HOURS, on the 7th day of November., 2008 at 707 VERONICA LANE ENOLA, PA 17025 by handing to POSTED PER COURT ORDER AT 707 VERONICA LANE ENOLA a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 Posting 6.00 Surcharge 10.00 Thomas in .00 22.00 11/12/2008 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to before me this day of By:./~? (? . eputy Shdr-ifl- A.D. t SHERIFF'S RETURN - REGULAR - CASE NO: 2008-04854 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LASALLE BANK NATIONAL ASSOC VS WHITMYER JILL K ET AL ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon WHITMYER JILL K the DEFENDANT at 0958:00 HOURS, on the 7th day of November 2008 at 707 VERONICA LANE ENOLA, PA 17025 by handing to POSTED PER COURT ORDER AT 707 VERONICA LANE ENOLA a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 15.00 Posting 6.00 Surcharge 10.00 .00 49.00 Sworn and Subscibed to before me this day of , So Answers: s in ' 11/12/2008 GOLDBECK MCCAFFERTY MCKEEVER epuySei f A.D. 2 W2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS FOR BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES, SERIES 2005 HE11 VS. JILL K. WHITMYER Attorney's Plaintiff's Prothonotary Costs No. 08-4854 Civil Term- $$261.50 $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS FOR BEAR STEARNS ASSET BACKED SECURITITES I LLC, ASSET BACKED CERTIFICATES, SERIES 2005 HE11 being: (Premises as follows): 707 VERONICA LANE, ENOLA, PA 17025 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. &116? C is R. Long, otary, Common Pleas Court of Cu erland County, PA Date DECEMBER 18, 2008 (Seal) y 2of2 No 08-4854 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LASALLE BANK NATIONAL ASSOCIATION FOR TRUSTEE FOR CERTIFICATEHOLDERS FOR BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES, SERIES 2005 HE1l VS. JILL K. WHITMYER AND OCCUPANTS 707 VERONICA LANE ENOLA, PA 17025 WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 281.50 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MICHAEL T. MCKEEVER, ESQUIRE GOLDBECK, MCCAFFERTY & MCKEEVER 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 215-825-6319 ID # 56129 Attorney for Plaintiff (s) Where papers may be served By virtue of this writ, on the named appurtenances, and day of . I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this So Answers, Day of Prothonotary By Sheriff Deputy Phelan, Hallinan & Schmieg, LLP. Francis S. Hallinan, Esquire Attorney ID. 62695 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff LaSalle Bank National Association, as Trustee For Certificateholders of Bear Stearns Asset Backed Certificates, Series 2005 HE11 COURT OF COMMON PLEAS Plaintiff VS. Jill K. Whitmyer And Occupants CIVIL DIVISION Cumberland County No. 08-4854 Defendants TO THE PROTHONOTARY: Kindly enter my appearance as counsel for the Plaintiff in connection with the above captioned matter. F cis S. Hallinan, Esquire Attorney ID 62695 Phelan, Hallinan & Schmieg, LLP. 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 Date: February 4, 2009 ?? t t ni m c-n a C 3 GOLDBECK McCAFFERTY & McKEEVER By.- Michael T. McKeever, Esquire Attorney LD.#56129 Suite 5x00 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215.627-1322 Attorney for MUM LaSalle Bank National Asssocmt m as Trustee for Certificate holders far Bow Stearns Asset Backed Securities I LLC, Asst Backed Certif c#^ Series 2005 HE11 2730 Lake Vu is Drive Lewbvffle, TX 75067-3384 p1writiff vs. RLL K. WHITMYER AndOccupants 707 Veronica Larne Enola, PA 17025 DeftndwwKs) WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Term No. 0$-4>i54 Kindly withdraw my appearance on behalf of Plaintiff, LaSalle Bank National Association, as Trustee for Certificate holders for Bear Stearns Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005 HE 11, in the above captioned matter. GOLDBECK BY: iN THE COURT OF COMMON PLEAS ofC iend County CIVIL ACTION - LAW ACTION OF EJECTMENT & WKEEVER Date: January 26.2009 -row 7„ r r k7.3 ..? a"7 f y„ I • By virtue of this writ, on the 2 day of March 2009 I caused the within named LaSalle Bank et _ a l to have possession of the pre?g s described YM U X ap q Kwd 707 Veronica Lane, Enola, PA 1 `5 So Answers, Sworn and subscribed to before me this Day of Sheriff By d-4--- Sheriff's Return Advance Costs: 150.00 Sheriff's Costs: 101.48 Docketing 18.00 49.22 Surcharge 20.00 Possession 30.00 Poundage 1.98 Prothy 2.00 Refunded to Atty on 3/4/09 Milage 28.80 100.78 ??0?/04 ?-. Q on s 9-+ s''i4 C4& IL Y397 PL?I,,, Apg2"l 2of2 Attorney for Plaintiff (s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LASALLE BANK NATIONAL ASSOCIATION FOR TRUSTEE FOR CERTIFICATEHOLDERS FOR BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES, SERIES 2005 HE11 vs. JILL K. WHITMYER AND OCCUPANTS 707 VERONICA LANE ENOLA, PA 17025 WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 281.50 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MICHAEL T. MCKEEVER, ESQUIRE GOLDBECK, MCCAFFERTY & MCKEEVER 5000 MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 215-825-6319 ID # 56129 "C3 -a- jL •?r Vic- ELL ur Where papers may be served of this writ, on the and No 08-4854 Civil Term day of , . I caused the within _, to have possession of the premises described with the So Answers, Sworn and subscribed to before me this G? iof z WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS FOR BEAR STEARNS ASSET BACKED SECURITIES I LLC, ASSET BACKED CERTIFICATES, SERIES 2005 HEI 1 VS. JILL K. WHITMYER Attorney's Plaintiff's Prothonotary Costs No. 08-4854 Civil Term- $$281.50 $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) LASALLE BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CERTIFICATEHOLDERS FOR BEAR STEARNS ASSET BACKED SECURITITES I LLC, ASSET BACKED CERTIFICATES, SERIES 2005 HE11 being: (Premises as follows): 707 VERONICA LANE, ENOLA, PA 17025 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. C s . Long notary, Common Pleas Court of Cu erland County, PA Date DECEMBER 18, 2008 (Seal) Phelan, 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 R. 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 J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 One Penn Center @ Suburban Station Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Attorney for Plaintiff LaSalle Bank National Association, as Trustee for Certificateholders for Bear Stears Asset Backed Securities I LLC, Asset Backed Certificates, Series 2005-HEll vs. Plaintiff Court of Common Pleas Cumberland County No. 08-4854 Civil Term Jill K. Whitmyer or occupants Defendant(s) PRAECIPE TO WITHDRAW COMPLAINT SATISFY JUDGMENT AND DISCONTINUE AND END ACTION, WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, without prejudice, satisfy the judgment entered on this case discontinued and ended, upon payment of your costs only. Date Phelan, 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. 698,49 Judith T. Romano, Esq. Id. No. 58745 Sheetal R. 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 J. Mulcahy, Esq. Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Attorney for Plaintiff PHS# 197600 cc: Ill K. Whi4Mger of ouq ants RED 2069 JUi'l !2 Cam' -},