HomeMy WebLinkAbout08-6836
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Deutsche Bank National Trust Company as
Trustee under Pooling and Servicing
Agreement dated as of June 1, 2007
EquiFirst Loan Securitization Trust 2007-1
Mortgage Pass-Through Certificates, Series
2007-1
4837 Watt Avenue, Suite 100
No. Highlands, CA 95660,
Plaintiff,
Vs.
Norman L. Shirk
25 Carlisle Road
Newville, PA 17241,
and
Brianne M. Shirk
25 Carlisle Road
Newville, PA 17241,
Defendants.
Attorney for Plaintiff
File: 55.09623
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: Qi'
CIVIL ACTION
MORTGAGE FORECLOSURE
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 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
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
800-990-9108
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NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
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1. This communication is from a debt collector. This is an attempt to collect a
debt and any information obtained will be used for that purpose.
2. Unless you dispute the validity of this debt, or any portion thereof, within
30 days after receipt of this notice, the debt will be assumed to be valid by our
offices.
3. If you notify our offices in writing within 30 days of receipt of this notice
that the debt, or any portion thereof, is disputed, our offices will provide you with
verification of the debt or copy of the Judgment against you, and a copy of such
verification or judgment will be mailed to you by our offices.
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Deutsche Bank National Trust Company as
Trustee under Pooling and Servicing
Agreement dated as of June 1, 2007
EquiFirst Loan Securitization Trust 2007-1
Mortgage Pass-Through Certificates, Series
2007-1
4837 Watt Avenue, Suite 100
No. Highlands, CA 95660,
Plaintiff,
Vs.
Norman L. Shirk
25 Carlisle Road
Newville, PA 17241,
and
Brianne M. Shirk
25 Carlisle Road
Newville, PA 17241,
Defendants.
Attorney for Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION
MORTGAGE FORECLOSURE
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff, Deutsche Bank National Trust Company as Trustee under Pooling and
Servicing Agreement dated as of June 1, 2007 EquiFirst Loan Securitization Trust 2007-1
Mortgage Pass-Through Certificates, Series 2007-1 (the "Plaintiff'), is a corporation registered
to conduct business in the Commonwealth of Pennsylvania and having an office and place of
business at 4837 Watt Avenue, Suite 100, No. Highlands, CA 95660.
2. Defendants, Norman L. Shirk and Brianne M. Shirk, (collectively, the "Defendants"),
are adult individuals and are the real owners of the premises hereinafter described.
3. Norman L. Shirk, Defendant, resides at 25 Carlisle Road, Newville, PA 17241.
Brianne M. Shirk, Defendant, resides at 25 Carlisle Road, Newville, PA 17241.
4. On December 27, 2006, in consideration of a loan in the principal amount of
$107,100.00, Norman L. Shirk, the Defendant, executed and delivered to EquiFirst Corporation
an adjustable rate note (the "Note") with interest thereon at 9.800 percent per annum, payable as
to the principal and interest in equal monthly installments of $924.09 commencing February 1,
2007.
5. To secure the obligations under the Note, the Defendants executed and delivered to
Mortgage Electronic Registration Systems, Incorporated as nominee for EquiFirst Corporation a
mortgage (the "Mortgage") dated December 27, 2006, recorded on January 2, 2007 in the
Department of Records in and for the County of Cumberland under Mortgage Book 1977, Page
4785. Pursuant to Pa.R.C.P. 1019 (g) the mortgage is incorporated herein by reference. Plaintiff
is proper party plaintiff by way of an assignment to be recorded.
6. The Mortgage secures the following real property (the "Mortgaged Premises"): 25
Carlisle Road, Newville, PA 17241. A legal description of the Mortgaged Premises is attached
hereto as Exhibit "A" and made a part hereof.
7. The Defendants are in default of their obligations pursuant to the Note and Mortgage
because payments of principal and interest due May 1, 2008, and monthly thereafter are due and
have not been paid, whereby the whole balance of principal and all interest due thereon have
become due and payable forthwith together with late charges, escrow deficit (if any) and costs of
collection including title search fees and reasonable attorney's fees.
8. The following amounts are due on the Mortgage and Note:
Balance of Principal ................................$106,265.63
Accrued but Unpaid Interest from
4/1/08 to 11/18/08
@ 9.800% per annum
($28.53 per diem) ........................................$6,618.96
Accrued Late Charges ....................................$245.50
Corporate Advance ...................... .............$295.55
Escrow Advance .............................................$387.00
Title Search Fees ............................................$350.00
Reasonable Attorney's Fees ........................$1,250.00
TOTAL as of 11/18/2008 ........................$115,412.64
Plus, the following amounts accrued after November 18, 2008:
Interest at the Rate of 9.800 per cent per annum ($28.53 per diem);
Late Charges of $46.20 per month.
9. Plaintiff has complied fully with Act No. 91 (35 P.SA 680.40 1 (c) of the 1983 Session
of the General Assembly ("Act 91 ") of the Commonwealth of Pennsylvania, by mailing to the
Defendants at 25 Carlisle Road, Newville, PA 17241 as well as to address of residences as listed
in paragraph 3 of this document on July 7, 2008, the notice pursuant to § 403-C of Act 91, and
the applicable time periods therein have expired.
WHEREFORE, Plaintiff demands an in rem judgment against the Defendants for
foreclosure and sale of the Mortgaged Premises in the amount due as set forth in paragraph 8,
namely, $115,412.64, plus the following amounts accruing after November 18, 2008, to the date
of judgment: (a) interest of $28.53 per day, (b) late charges of $46.20 per month, (c) plus
interest at the legal rate allowed on judgments after the date of judgment, (d) additional
attorney's fees (if any) hereafter incurred, (e) and costs of suit.
MILSTEAD & ASSOCIATES, LLC
Mary L. Harbert-Bell, Esquire
Attorney for Plaintiff
VERIFICATION
I, Mary L. Harbert-Bell, hereby certify that I am an Attorney for Plaintiff and am authorized to
make this verification on Plaintiff's behalf. I verify that the facts and statements set forth in the
forgoing Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge,
information and belief. This verification is made subject to the penalties of 18 Pa. C.S. '4904,
relating to unsworn falsification to authorities.
Name: Mary L. Harbert-Bell, Esquire
Title: Attorney
11-10-'08 14:36 FROM- T-073 P021/031 F-340
)EXhibn, EXHIgITq
ALL that certain tract of land situate in the Township of West Pennsboro,
Cumberland County, rennsxylvania, being Lot No. X A in Block Z in Big Spring
Heights Plan of Lots laid out by Andrew McElwain, said plan being recorded in the
Recorder's Office and described as follows:
ON the South by the concrete road leading from Newville to Carlisle; on the West
by Lot No. 10; on the North by lend now or formerly of Andrew McMwvaia; ou the
East by Lot No. 12; having a frontage on the concrete road of fifty-one (51) feet and
six (6)i inches and a depth of three handred eighty-four (384) feet.
'1
iS2?^ 70tF1'c`
ex 977PG480I
11107P2wo 17:06:25 AM CUMBERLAND COUNTY
Inst.;6E 200700031 -Page 17 of 20
c°-,
LO
Ln ` 17)
?c?
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 2008-06836 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
SHIRK NORMAN L ET AL
R. Thomas Kline
Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
SHIRK NORMAN L
but was unable to locate Him
to wit:
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
serve the within COMPLAINT - MORT FORE
On December 16th , 2008 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs: So answe
Docketing 6.00
Out of County 9.00 ?__....
Surcharge 10.00 R. Thomas Kline
Dep Dauphin County 49.25 Sheriff of Cumberland County
Postage 1.68
75.93 ? ?a?1'??° g
12/16/2008
MILSTEAD & ASSOCIATES
Sworn and subscribe to before me
this day of
County, Pennsylvania, to
A. D.
SHERIFF'S RETURN - NOT FOUND
CASE NO: 2008-06836 P
COMMONTWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
SHIRK NORMAN L 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
SHIRK BRIANNE M but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT - MORT FORE
the within named DEFENDANT
99P BEETEM HOLLOW ROAD
SHIRK BRIANNE M
NOT FOUND , as to
NEWVILLE, PA 17241
DEFENDANT DOES NOT LIVE AT GIVEN ADDRESS.
Sheriff's Costs:
Docketing 6.00
Service 9.90
Not Found 5.00
Surcharge //?? 10.00
P 8 `T"'? 0. 9 0
So answers•
R. Thom As Kline
Sheriff of Cumberland County
MILSTEAD & ASSOCIATES
12/16/2008
Sworn and Subscribed to before
me this day of
A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06836 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
SHIRK NORMAN L ET AL
WILLIAM CLINE
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
4T4TRK NORMAN L
was served upon
the
DEFENDANT , at 1915:00 HOURS, on the 26th day of November , 2008
at 25 CARLISLE ROAD
NEWVILLE, PA 17241
BRIANNE M SHIRK
by handing to
ADULT IN CHARGE
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:
Docketing 18.00
Service 6.30
Affidavit .00
Surcharge 10.00
1AIWO e .00
34.30
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
12/16/2008
MILSTEAD & ASSOCIATES
By
Deputy Sheriff
of A. D.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06836 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DEUTSCHE BANK NATIONAL TRUST
VS
SHIRK NORMAN L ET AL
WILLIAM CLINE
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT - MORT FORE
SHIRK BRIANNE M
was served upon
the
DEFENDANT , at 1915:00 HOURS, on the 26th day of November , 2008
at 25 CARLISLE ROAD
NEWVILLE, PA 17241
BRIANNE M SHIRK
by handing to
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 6.00
Service 00
Affidavit 00
Surcharge 10.00 R. Thomas Kline
e',1?IR/OC ?n? .00
16.00
12/16/2008
MILSTEAD & ASSOCIATES
Sworn and Subscibed to By: .? _
01
before me this day Deputy Sheriff
of A. D.
In The Coin of Common Pleas of Cumberland Co.unty, Peniisylvaiiga
DQutsche Bank National Trust Company
vs.
Norman L.'Shirk et al
SERVE: Norman L. Shirk. No. 08-6836 civil
Now, November 20, 2008 , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
20 , at o'clock M. served the
upon
at
by handing to
a
and made known to
So answers,
Sheriff of
Sworn and subscribed before
me this day of , 20
copy of the original
COSTS
SERVICE _
MILEAGE _
AFFIDAVIT
the contents thereof.
County, PA
Mtfitg of the- *11crife
der
Mary Jane Sn
l E
t
D
R
y
sta
e
epu
ea
William T. Tully
Solicitor
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 780-6590 fax: (717) 255-2889
Jack Lotwick
Sheriff
Charles E. Sheaffer
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Commonwealth of Pennsylvania DEUTSCHE BANK NATIONAL TRUST
COMPANY
VS
County of Dauphin NORMAN L SHIRK
Sheriffs Return
No. 2008-T-2430
OTHER COUNTY NO. 086836
I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and
return, that I made diligent search and inquiry for NORMAN L SHIRK the DEFENDANT named in the
within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the
County of Dauphin, and therefore return same NOT FOUND, NOVEMBER 28, 2008.
PER MARY SHIRK (DEFT'S MOTHER) DEFENDANT LIVES IN NEWVILLE, PA
Sworn and subscribed to
before me this 1 ST day of December, 2008
So Answers,
lez?7° 1c-
NOTARIAL SEAL
RY JANE SNYDER, Notary Publi
Highspire, Dauphin County
LM Commission Expires Set 1 2010
Sheriff of Da in Co ty
By
Deputy SheriffK
G MILLER
Sheriffs Costs: $49.25 11/24/2008
MILSTI?AD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Deutsche Bank National Trust Company as
Trustee under Pooling and Servicing
Agreement dated as of June 1, 2007
EquiFirst Loan Securitization Trust 2007-1
Mortgage Pass-Through Certificates, Series
2007-1
4837 Watt Avenue, Suite 100
No. Highlands, CA 95660,
Plaintiff,
Vs.
Norman L. Shirk
25 Carlisle Road
Newville, PA 17241,
and
Brianne M. Shirk
25 Carlisle Road
Newville, PA 17241,
Defendants.
Attorney for Plaintiff
File: 55.09623
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 0?f ' LP?3(Q ?? r' ?a rln
CIVIL ACTION
MORTGAGE FORECLOSURE
I*RUE COPY FHOM RECOHL.
Ye:oft" wh1w. I we sit MY bw
Ad Eg Of Sad at $ ft.
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 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
32 S. Bedford Street
Carlisle, PA 17013
717-249-3166
800-990-9108
NOTICE PURSUANT TO FAIR DEBT COLLECTION PRACTICES ACT
1. This communication is from a debt collector. This is an attempt to collect a
debt and any information obtained will be used for that purpose.
2. Unless you dispute the validity of this debt, or any portion thereof, within
30 days after receipt of this notice, the debt will be assumed to be valid by our
offices.
3. If you notify our offices in writing within 30 days of receipt of this notice
that the debt, or any portion thereof, is disputed, our offices will provide you with
verification of the debt or copy of the Judgment against you, and a copy of such
verification or judgment will be mailed to you by our offices.
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Attorney for Plaintiff
Deutsche Bank National Trust Company as
Trustee under Pooling and Servicing
Agreement dated as of June 1, 2007
EquiFirst Loan Securitization Trust 2007-1
Mortgage Pass-Through Certificates, Series
2007-1
4837 Watt Avenue, Suite 100
No. Highlands, CA 95660,
Plaintiff,
Vs.
Norman L. Shirk
25 Carlisle Road
Newville, PA 17241,
and
Brianne M. Shirk
25 Carlisle Road
Newville, PA 17241,
Defendants.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No..
CIVIL ACTION
MORTGAGE FORECLOSURE
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff, Deutsche Bank National Trust Company as Trustee under Pooling and
Servicing Agreement dated as of June 1, 2007 EquiFirst Loan Securitization Trust 2007-1
Mortgage Pass-Through Certificates, Series 2007-1 (the "Plaintiff'), is a corporation registered
to conduct business in the Commonwealth of Pennsylvania and having an office and place of
business at 4837 Watt Avenue, Suite 100, No. Highlands, CA 95660.
2. Defendants, Norman L. Shirk and Brianne M. Shirk, (collectively, the "Defendants"),
are adult individuals and are the real owners of the premises hereinafter described.
'3. Norman L. Shirk, Defendant, resides at 25 Carlisle Road, Newville, PA 17241.
Brianne M. Shirk, Defendant, resides at 25 Carlisle Road, Newville, PA 17241.
4. On December 27, 2006, in consideration of a loan in the principal amount of
$107,100.00, Norman L. Shirk, the Defendant, executed and delivered to EquiFirst Corporation
an adjustable rate note (the "Note") with interest thereon at 9.800 percent per annum, payable as
to the principal and interest in equal monthly installments of $924.09 commencing February 1,
2007.
5. To secure the obligations under the Note, the Defendants executed and delivered to
Mortgage Electronic Registration Systems, Incorporated as nominee for EquiFirst Corporation a
mortgage (the "Mortgage") dated December 27, 2006, recorded on January 2, 2007 in the
Department of Records in and for the County of Cumberland under Mortgage Book 1977, Page
4785. Pursuant to Pa.R.C.P. 1019 (g) the mortgage is incorporated herein by reference. Plaintiff
is proper party plaintiff by way of an assignment to be recorded.
6. The Mortgage secures the following real property (the "Mortgaged Premises"): 25
Carlisle Road, Newville, PA 17241. A legal description of the Mortgaged Premises is attached
hereto as Exhibit "A" and made a part hereof.
7. The Defendants are in default of their obligations pursuant to the Note and Mortgage
because payments of principal and interest due May 1, 2008, and monthly thereafter are due and
have not been paid, whereby the whole balance of principal and all interest due thereon have
become due and payable forthwith together with late charges, escrow deficit (if any) and costs of
collection including title search fees and reasonable attorney's fees.
8. The following amounts are due on the Mortgage and Note:
Balance of Principal ................................$106,265.63
Accrued but Unpaid Interest from
4/1/08 to 11/18/08
@ 9.800% per annum
($28.53 per diem) ......................
Accrued Late Charges .......................
Corporate Advance ............................
Escrow Advance ................................
Title Search Fees .........................._-
Reasonable Attorney's Fees ..............
TOTAL as of 11/18/2008 ..................
................$6,618.96
............. $245.50
.............$295.55
.............$387.00
.............$350.00
..........$1,250.00
......$115,412.64
Plus, the following amounts accrued after November 18, 2008:
Interest at the Rate of 9.800 per cent per annum ($28.53 per diem);
Late Charges of $46.20 per month.
9. Plaintiff has complied fully with Act No. 91 (35 P.S.'1680.401(c) of the 1983 Session
of the General Assembly ("Act 91 ") of the Commonwealth of Pennsylvania, by mailing to the
Defendants at 25 Carlisle Road, Newville, PA 17241 as well as to address of residences as listed
in paragraph 3 of this document on July 7, 2008, the notice pursuant to § 403-C of Act 91, and
the applicable time periods therein have expired.
WHEREFORE, Plaintiff demands an in rem judgment against the Defendants for
foreclosure and sale of the Mortgaged Premises in the amount due as set forth in paragraph 8,
namely, $115,412.64, plus the following amounts accruing after November 18, 2008, to the date
of judgment: (a) interest of $28.53 per day, (b) late charges of $46.20 per month, (c) plus
interest at the legal rate allowed on judgments after the date of judgment, (d) additional
attorney's fees (if any) hereafter incurred, (e) and costs of suit.
MILSTEAD & ASSOCIATES, LLC
Mary L. Harbert-Bell, Esquire
Attorney for Plaintiff
VERIFICATION
I, Mary L. Harbert-Bell, hereby certify that I am an Attorney for Plaintiff and am authorized to
make this verification on Plaintiff's behalf. I verify that the facts and statements set forth in the
forgoing Complaint in Mortgage Foreclosure are true and correct to the best of my knowledge,
information and belief. This verification is made subject to the penalties of 18 Pa. C.S. ' 4904,
relating to unsworn falsification to authorities.
Name: Mary L. Harbert-Bell, Esquire
Title: Attorney
? 11-10-'08 14:36 FROM-
T-073 P021/031 F-340
)R,W;t A SX'qII3I_rq
ALL that certain tract of land situate in the Township of West Pennsboro,
Cumberland County, Peantylvania, being Lot No. X 1 is Block 2 in Sig Spring
Heights Plan of Lots laid out by Andrew McElwain, said Plan being recorded in the
Recorder's puce and described as follows:
ON the South by the concrete road leading from NewAlle to Carlisle; on the West
by Lot No. 10; olk the North by land now or !formerly of Andrew 1MlieMwida; on the
East by Lot No. 12; having a frontage on the concrete road of fifty-one (51) feet and
six (6) inches and a depth of three hundred eighty-four (384) feet.
BK 1977PG480 I
11107r20D5 11:05:25 AM CUMBERLAND COUNTY
Inst.# 200700031 - Page V of 20
ZS :E d b i AON 90Ot
Y { k
*
MILSTEAD & ASSOCIATES, LLC
BY: Mary L. Harbert-Bell, Esquire
ID No. 80763
220 Lake Drive East, Suite 301
Cherry Hill, NJ 08002
(856) 482-1400
Deutsche Bank National Trust Company as
Trustee under Pooling and Servicing
Agreement dated as of June 1, 2007
EquiFirst Loan Securitization Trust 2007-1
Mortgage Pass-Through Certificates, Series
2007-1,
Plaintiff,
Vs.
Norman L. Shirk,
and
Brianne M. Shirk,
Attorney for Plaintiff
55.09623
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
No.: 08-6836 Civil Term
Praecive to Dismiss the Mortgage
Foreclosure Action without Preiudice
Defendant(s)
TO THE PROTHONOTARY:
Kindly dismiss the above captioned Mortgage Foreclosure Complaint without
Prejudice.
MILSTEAD & ASSOCIATES, LLC
Mary L. Harbert-Bell, Esquire
Attorney ID No. 80763
{00357390}
APY
OF THE
2009 JUL -2 AN 11: 4 2