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Home My WebLink About09-1584U 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 „"drew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 198249 AURORA LOAN SERVICES, LLC. 2617 COLLEGE PARK SCOTTSBLUFF, NE 69361-2294 Plaintiff V. DONALD E. MEFFERT JAMIE L. MEFFERT 17 WESTGATE DRIVE MOUNT HOLLY SPRINGS, PA 17065 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM 06KI NO. jj, la q CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 199249 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service: Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 File #: 198249 1 • Plaintiff is AURORA LOAN SERVICES, LLC. 2617 COLLEGE PARK SCOTTSBLUFF, NE 69361-2294 2. The name(s) and last known address(es) of the Defendant(s) are: DONALD E. MEFFERT JAMIE L. MEFFERT 17 WESTGATE DRIVE MOUNT HOLLY SPRINGS, PA 17065 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 12/12/2005 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC., AS A NOMINEE FOR FIRST MAGNUS FINANCIAL CORPORATION, AN ARIZONA CORPORATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1934, Page 3659. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 09/01/2008 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 198249 6. The following amounts are due on the mortgage: Principal Balance Interest $191,400.72 08/01/2008 through 03/12/2009 $8,039.36 (Per Diem $35.89) Attorney's Fees Cumulative Late Charges $1,300.00 12/12/2005 to 03/12/2009 $256.32 Cost of Suit and Title Search Subtotal 750.00 Escrow $201,746.40 Credit Deficit $0.00 Subtotal $33.54 TOTAL 33.54 $201,779.94 7. If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less than the amount demanded based on work actually performed. The attorney's fees requested are in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an in ersonam judgment against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 198249 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $201,779.94, together with interest from 03/12/2009 at the rate of $35.89 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: ce T. an, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Attorneys for Plaintiff File #: 198249 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land with buildings and improvements thereon erected, if any, situate in Westgate Development, South Middleton Township, Cumberland County, Commonwealth of Pennsylvania bounded and described in accordance with Final Subdivision Plan for Phase No. IV for 'Westgate'Development prepared by Hartman & Associates, a copy of which is recorded in the Recorder of Deeds Office of Cumberland County in Plan Book Volume 81, Page 15 on May 23, 2000, bounded and described as follows: BEGINNING at a point on the western right-of-way line of Westgate Drive at the line of Lot No. 6, said point being located the following five (5) courses from the northern right-of-way line of West Pine Street 1) by a curve to the left, having a radius of twenty-five feet (R=25.00 feet), an arc distance of thirty-nine and twenty-seven hundredth feet (A/L=39.27 feet); 2) by a curve to the left, having a radius of one hundred ninety-three and six hundredth feet (R=193.06 feet), an arc distance of fifty and four hundredth feet (A/L=50.04 feet); 3) North fourteen degrees, zero minutes, zero seconds East (N 14 degrees 00 minutes 00 seconds E), a distance of two hundred seventy-five and thirty-seven hundredth feet (275.37 feet); 4) by a curve to the left, having a radius of three hundred seventy-five and thirty- seven hundredth feet (R=375.00 feet), an arc distance of one hundred ninety-eight and fifty-three hundredths feet (A/L=198.53 feet); 5) North sixteen degrees, twenty minutes, zero seconds West (N 16 degrees 20 minutes 00 seconds W), a distance of one hundred fourteen and thirty-eight hundredth feet (114.38 feet); thence from said point of Beginning, by Lot No. 6 South seventy-three degrees, forty minutes, zero seconds West (S 73 degrees 40 minutes 00 seconds W), a distance of one hundred forty- six and ninety-one hundredth feet (146.91 feet) to a point on the line of land now or late of Edward Oliveria; File #: 198249 Thence by said land North fifteen degrees, forty-seven minutes, fifteen seconds West (N 15 degrees 47 minutes 15 seconds W), a distance of eighty feet (80.00 feet) to a point; thence by Lot No. Y 8 North seventy-three degrees, forty minutes, zero seconds East (N 73 degrees 40 minutes 00 seconds E a distance of one hundred forty-six and fifteen hundredth feet (146.15 feet) to a point on the western right-of-way line of Westgate Drive; thence by said right-of-way South sixteen degrees, twenty minute s, zero seconds East (S 16 degrees 20 minutes 00 seconds E), a distance of eighty feet (80.00 feet), to a point, the place of BEGINNING. SAID TRACT CONTAINS 11,722.23 square feet. BEING Lot #7 of the Final Subdivision Plan of Westgate Development, Mt. Holly Springs, Cumberland County, Pennsylvania. EACH LOT in the subdivision will be limited to no more than 2,015.00 square feet of impervious surface. If a lot owner desires to exceed the total permissible impervious surface the approval of the board of supervisors shall be necessary in addition to any other approvals which are required by law. The tern 'impervious surface' shall be defined as set forth in the subdivision ordinance of 1990. This restriction shall be binding for all owners, heirs, successors, and assigns of the applicants and each lot owner. Parcel No. 40-32-2334-132 PROPERTY BEING: 17 WESTGATE DRIVE File #: 198249 VERIFICATION I hereby state that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R. C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unworn falsifications to authorities. DATE: 3140--) ttorney aintiff File #: 198249 "' Sheriffs Office of Cumberland County R Thomas Kline of cumbf, Edward L Schorpp Sheriff 6 Solicitor ew~ Ronny R Anderson y" Jody S Smith Chief Deputy QfF= OF TK SKRIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/1612009 07:00 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 16, 2009 at 1900 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donald E. Meffert by making known unto Jamie L. Meffert, wife of defendant, at 17 Westgate Drive, Mt. Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 03/16/2009 07:00 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 16, 2009 at 1900 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jamie L. Meffert by making known unto Jamie L. Meffert personalty, at 17 Westgate Drive, Mt. Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $49.40 (PAID) SO ANSWER March 17, 2009 R THOMAS KLINE, SHERIFF s De t SSheriff Docket No. 2009-1584 Aurora Loan Services, LLC v Donald Meffert - ° d C C= -n 77 ?. yid., 7 ? -. ". co 7 G PHELAN HALLINAN & SCHMIEG, LLP FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 AURORA LOAN SERVICES, LLC. Plaintiff VS. DONALD E. MEFFERT JAMIE L. MEFFERT Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 09-1584-CIVIL CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP AttoTey.for Plainti By: Francis S. Hallinan, Esquire Date: 04-09-09 PHS #: 198249 4%. VERIFICATION Q'-?_AL hereby states that he/she is ?Ny of AURORA LOAN SERVICES, LLC., servicing agent for AURORA LOAN SERVICES, LLC., in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: I P? Loan: 0032153819 File #: 198249 Nam Title: Angela Martinez Asst. Vide President Company: AURORA LOAN SERVICES, LLC. PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 AURORA LOAN SERVICES, LLC. Plaintiff VS. DONALD E. MEFFERT JAMIE L. MEFFERT Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION NO. 09-1584-CIVIL CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a strue and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: DONALD E. MEFFERT 17 WESTGATE DRIVE MOUNT HOLLY SPRINGS, PA 17065-2009 JAMIE L. MEFFERT 17 WESTGATE DRIVE MOUNT HOLLY SPRINGS, PA 17065-2009 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: Francis S. Hallinan, Esquire Date: 04-09-09 OF THE PP,0 "?,w-') NARY 2009 APR 14 AN 10., 50 Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 t/p`rancis 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 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. vs. DONALD E. MEFFERT JAMIE L. MEFFERT Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.09-1584-CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DONALD E. MEFFERT, and JAMIE L. MEFFERT, Defendant(s) 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 Plaintiff s damages as follows: As set forth in Complaint $201,779.94 Interest - 03/13/2009 to 07/01/2009 $3,983.79 TOTAL $205,763.73 I hereby certify that (1) the Defendants' last known address is 17 WESTGATE DRIVE, MOUNT HOLLY SPRINGS. PA 17065-2009, and (2) that notice has been given in accordance with Rule 237.1, copy attached. Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ~~~_ PHS # 198249 PROTHONOTARY Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 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., Ids 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 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 AURORA LOAN SERVICES, LLC. vs. DONALD E. MEFFERT JAMIE L. MEFFERT Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.09-1584-CIVIL VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant DONALD E. MEFFERT is over 18 years of age and resides at 17 WESTGATE DRIVE, MOUNT HOLLY SPRINGS, PA 17065-2009. (c) that defendant JAMIE L. MEFFERT is over 18 years of age and resides at 17 WESTGATE DRIVE, MOUNT HOLLY SPRINGS, PA 17065-2009. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~~- Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff AURORA LOAN SERVICES, LLC. v. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 09-1584-CIVIL DONALD E. MEFFERT JAMIE L. MEFFERT Defendant(s) TO: DONALD E. MEFFERT I7 WESTGATE DRIVE MOUNT HOLLY SPRINGS, PA 17065-2009 DATE OF NOTICE: June 18, 2009 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIT'T'EN APPERANCE 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHF,R 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. E, PHS # 198249 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. Office of the Prothonotary Cumberland County Bar Association Cumberland County Courthouse 32 South Bedford Street 1 Courthouse Square Carlisle, PA 17013 Carlisle, PA 17013 (717) 249-3166 (717) 240-6195 ; /Lawrence T. Phelan, Esq., Id. IVo. 3222'1 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 J ne R. Davey, Esq., Id. No. 87077 wren 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 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 198249 AURORA LOAN SERVICES, LLC. v. Plaintiff COURT OF COMMON PLEAS CIVIL DTVISON NO. 09-1584-CIVIL DONALD E. MEFFERT JAMIE L. MEFFERT Defendant(s) TO: JAMIE L. MEFFERT 17 WESTGATE DRIVE MOUNT HOLLY SPRINGS, PA 17065-2009 DATE OF NOTICE: June 18, 2009 CUMBERLAND COUNTY THIS FIRM TS A T)EBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII,ED TO ENTER A WRITTEN APPERANCE 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 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. PHS # 198249 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 /Lawrence T. Phelan, Esq ~Id. Nom-227 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 J ine R. Davey, Esq., Id. No. 87077 wren 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 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 198249 2009 JUL -6 P~9 I ~ 29 ~l~.oa Pa A'n`I ~,,~ 8 a3lss P.~ aa? ~ 13 (Rule of Civil Procedure No. 236) -Revised AURORA LOAN SERVICES, LLC. vs. DONALD E. MEFFERT JAMIE L. MEFFERT 17 WESTGATE DRIVE MOUNT HOLLY SPRINGS, PA 17065- 2009 CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No.09-1584-CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on ~~- E If you have any questions concerning t Lawrence T. Phelan, Esquire Francis S. Hallinan, Esquire Daniel G. Schmieg, Esquire Michele M. Bradford, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire Chrisovalante P. Fliakos, Esquire Joshua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 * * THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOUHAVE PREVIOUSLYRECEIVED ADISCHARGE INBANKRUPTCY, THIS IS NOT AND SHOULD NDT BE CONSTRUED TO BE ANATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OFA LIENAGAINSTPROPERTY. **