HomeMy WebLinkAbout09-3557Phelan 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
Joshua I. Goldman, Esq., Id. No. 205047
Courtenay R. Dunn, Esq., Id. No. 206779
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000 197908
ATTORNEY FOR PLAINTIFF
US BANK NATIONAL ASSOCIATION, AS COURT OF COMMON PLEAS
INDENTURE TRUSTEE FOR CMLTI 2006-AR1
3476 STATEVIEW BOULEVARD CIVIL DIVISION
FORT MILL, SC 29715
TERM
Plaintiff
V NO. 09 - 35 7 &IyilTerm
CUMBERLAND COUNTY
DESIREE MODITCH MINTZ
119 SOUTH WILSON STREET
CLEONA, PA 17042-3263
Defendant
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
File #: 197908
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 #: 197908
1. Plaintiff is
US BANK NATIONAL ASSOCIATION, AS INDENTURE TRUSTEE FOR CMLTI 2006-AR1
3476 STATEVIEW BOULEVARD
FORT MILL, SC 29715
2. The name(s) and last known address(es) of the Defendant(s) are:
DESIREE MODTTCH MINTZ
119 SOUTH WILSON STREET
CLEONA, PA 17042-3263
who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
On 01/04/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to WELLS FARGO BANK, N.A. which mortgage is recorded in the Office
of the Recorder of CUMBERLAND County, in Mortgage Book No. 1936, Page 3859. 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 10/01/2008 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 #: 197908
6. The following amounts are due on the mortgage:
Principal Balance $203,707.16
Interest $8,632.21
09/01/2008 through 05/27/2009
(Per Diem $32.09)
Attorney's Fees $1,300.00
Cumulative Late Charges $195.24
01/04/2006 to 05/27/2009
Property Inspections $45.00
Appraisal/Brokers Price Opinion $325.00
Mortgage Insurance Premium / $132.76
Private Mortgage Insurance
Cost of Suit and Title Search 750.00
Subtotal $215,087.37
Escrow
Credit $0.00
Deficit $851.23
Subtotal 851.23
TOTAL $215,938.60
8.
9.
If the mortgage is reinstated prior to a Sheriffs Sale, the attorney's fee set forth above may be less
than the amount demanded based on work actually performed. The attorney's fees requested are
in conformity with the mortgage and Pennsylvania law. Plaintiff reserves its right to collect
attorney's fees up to 5% of the remaining principal balance in the event the property is sold to a
third party purchaser at Sheriffs Sale, or if the complexity of the action requires additional fees in
excess of the amount demanded in the Action.
Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the
Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to
establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal
liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt
to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage
and sell the mortgaged premises pursuant to Pennsylvania Law.
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
File #: 197908
date(s) set forth thereon, and the temporary stay as provided by said notice has terminated
because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit
counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance
Agency.
10. This action does not come under Act 91 of 1983 because the mortgage premises is not the
principal residence of Defendant(s).
WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of
$215,938.60, together with interest from 05/27/2009 at the rate of $32.09 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 &
By:
ence T. el squire
'Francis S. Ekfffinan, 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
Attorneys for Plaintiff
File #: 197908
LEGAL DESCRIPTION
ALL THAT CERTAIN lot or parcel of land situate in the Township of Hampden, County of
Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to
wit:
BEGINNING at a point on the northern line of Lamp Post Lane, which point is on the line
dividing Lots Nos. Ten (10) and Eleven (11), Section 'B' on the hereinafter mentioned Plan of
Lots;
THENCE along said dividing line North sixteen degrees eight minutes thirty seconds West (N
16degrees 08 minutes 30 seconds W) one hundred twenty (120 feet) feet to a point on the
southern line of Lot No. Four (4), Section'B;
THENCE along the southern line of Lots Nos. Four (4) and Five (5) Section'B' North seventy-
three degrees fifty-one minutes thirty seconds East (N 73 degrees 51 minutes 30 seconds E)
ninety-five (95 feet) feet to a point on the western line of Lot No. Nine (9) Section'B ;
THENCE along the same South sixteen degrees eight minutes thirty seconds West (S 16 degrees
08 minutes 30 seconds W) one hundred twenty (120 feet) feet to a point on the northern line of
Lamp Post Lane;
File M 197908
THENCE along the northern line of Lamp Post Lane South seventy-three degrees fifty-one
minutes thirty-seconds West (S 73 degrees 51 minutes 30 seconds W) ninety-five (95 feet) feet
to the point of BEGINNING
BEING Lot No. Ten (10) Section B on Plan No. One (1) of PineBrook, which Plan is recorded in
Cumberland County Recorder's Office in Plan Book 13, Page 18
HAVING THEREON ERECTED a brick and aluminum siding dwelling house known and
numbered as 3807 Lamp Post Lane, Camp Hill, Pennsylvania
PARCEL #: 10-21-0275-007
PROPERTY ADDRESS: 3807 LAMP POST LANE
File M 197908
VERIFICATION
The undersigned attorney hereby states 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:.: S 2 ? D
omey for Pla'
O
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' APY
#7?.so po Arn/
Cm-* s?1195`1
-Ak
Loren A. Schrum, ID #28039
Reilly, Wolfson, Sheffey, Schrum
and Lundberg LLP
1601 Cornwall Road
Lebanon, PA 17042
(717) 273-3733
lschrumAleblaw.com
Counsel for Defendant, Desiree Moditch Mintz
US BANK NATIONAL ASSOCIATION,
AS INDENTURE TRUSTEE FOR
CMLTI 2006-AR I
Plaintiff
Vs.
DESIREE MODITCH MINTZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. 09-3557 Civil Term
ANSWER TO COMPLAINT
AND NOW, comes Defendant, Desiree Moditch Mintz, by and through her counsel,
Reilly, Wolfson, Sheffey, Schrum and Lundberg LLP, and hereby files this Answer to the
Complaint filed by US Bank, as follows:
1. Admitted.
2. Admitted.
3. Admitted.
4. Admitted.
5. Admitted in part, and denied in part. It is admitted that Defendant did not make
monthly payments due October 1, 2008, and for some months thereafter. However, it is averred
that Defendant made a lump-sum payment of $3,500 towards the obligation, which Defendant
understands is being held by Plaintiff and has not been applied to this obligation.
6. Denied for the reason set forth in the answer to Paragraph 5.
7. Admitted.
8. Admitted.
9. No answer necessary, as Paragraph 9 is a conclusion of law and not an averment
of fact. However, by way of further averment, Defendant denies that she received the Notice of
Intention to Foreclose.
10. Denied and averred instead that the premises has been the principal residence of
Defendant, and she only recently relocated so that renovations could be made to the mortgaged
premises.
WHEREFORE, Defendant, Desiree Moditch Mintz, prays that your Honorable Court
will enter judgment for her and against Plaintiff, with costs to Plaintiff.
REILLY, WrQLFSON, SHEFFEY, SCHRUM
14ND LUNDBERG LLP
By:
Loren A. Schrum, ID #28039
Counsel for Defendant
Date: June J-07-, 2009
VERIFICATION
I verify that the statements made in the foregoing document are true and correct to the
best of my knowledge, information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unworn falsification to
authorities.
Date: June /7 , 2009
CERTIFICATE OF SERVICE
I, Renee M. Condran, a secretary in the law offices of Reilly, Wolfson, Sheffey, Schrum
and Lundberg LLP, hereby certify that I mailed a copy of the foregoing document to the
following by U.S. First-Class Mail, postage prepaid, on June , 2009:
Andrew L. Spivack, Esquire
Phelan Hallinan & Schmieg, LLP
1617 JFK Boulevard
One Penn Center, Suite 1400
Philadelphia, PA 19103-1814
Renee M. Condran
Date: June, 2009
FILE t C.E
Y
2 6 0 9 1 1 18 A1r II:1
Sheriffs Office of Cumberland County
R Thomas Kline 0-11"tr c +tr?rr??t? Edward L Schorpp
Sheri Solicitor
Ronny R Anderson Jody S Smith
Chief Deputy 0MCE c.? --E $?ERIFF Civil Process Sergeant
US Bank National Association
Case Number
VS.
Desiree Moditch Mintz 2009-3557
SHERIFF'S RETURN OF SERVICE
06/02/2009 R. Thomas Kline, Sheriff who being duly sworn according to law states that he made a diligent search and
inquiry for the within named defendant, to wit: Desiree Moditch Mintz, but was unable to locate her in his
bailiwick. He therefore deputized the Sheriff of Lebanon County, PA to serve the within Complaint In
Mortgage Foreclosure according to law.
06/04/2009 Lebanon County Return: And now June 4, 2009 at 1035 hours, I Michael J. DeLeo, Sheriff of Lebanon
County, Pennsylvania, do herby certify and return that I served a true copy of the within Complaint in
Mortgage Foreclosure, upon the within named defendant, to wit: Desiree Moditch Mintz by making known
unto Tim Asper, adult in charge at 119 South Wilson Street Cleona, PA 17042 its contents and at the
same time handing to him personally the said true and correct copy of the same.
06/19/2009 03:20 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 19,
2009, at 1520 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Desiree Moditch Mintz, by making known unto Timothy Asper, boyfriend of
defendant, at 3807 Lamp Post Lane, Camp Hill, Cumberland County, Pennsylvania, 17011 its contents
and at the same time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $50.50 SO ANSWERS,
,
June 23, 2009 R THOMAS KLINE, SHERIFF
De uty S eriff
I r7
rv
iii
COMPLAINT IN MORTGAGE FORECLOSURE
No. 09-3557 PHELAN HALLINAN & SCHMIEG, LLP
(Return to Cumberland County) Francis S. Hallinan, Esquire
US Bank National Association 1617 JFK BLVD, Suite 1400
VS.
Philadelphia, PA 19103
(215) 563-7000
Desiree Moditch Mintz
STATE OF PENNSYLVANIA }
COUNTY OF LEBANON } SS:
Docket Page 29851
William F. Mohl, Deputy Sherif& being duly sworn according to law, deposes and says that he served the
within COMPLAINT IN MORTGAGE FORECLOSURE upon DESIREE MODITCH MINTZ the within
named DEFENDANT, by handing a true and attested copy thereof, personally to TIM ASPER, he being
her Fiance and Person in Charge at the time of service on June 4, 2004 at 10:35 A.M_, at 119 South
Wilson Street, Cleona (Cleona Borough), Lebanon County, Pennsylvania, and by making known to him
the contents of the same.
Sworn to and subscribed before me SO ANSWERS,
s 12?' day of June, 2009
ry Public
wi rARMAL SM
Lymxue Smith, Notary Public
Lel?on City, Lebanon County
?yy GiftmOuft-tWires Apt 23, 2012
'?v f Is
DEPUTY SHERIFF
Is
SHERIFF
SHERIFF'S COSTS IN ABOVE PROCEEDINGS
Advanced Costs paid on 6/3/09 Check No. 811933 Amount $ 100.00
Costs Incurred: Amount $ 52.00
Refund: Check No. 61563 Amount $ 48.00
All Sheriffs Costs shall be due and payable when services are performed, and it shall be
lawful for him to demand and receive from the party instituting the proceedings, or any party
liable for the costs thereof, all unpaid sheriffs fees on the same before he shall be obligated by
law to make return thereof.
Sec. 2, Act of June 20, 1911, P.L. 1072
LEBANON COUNTY SHERIFF'S OFFICE
400 South Eighth Street
Lebanon, Pennsylvania 17042
Telephone (717) 228-4410 Fax Number (717) 279-8398
ORDER FOR SERVICEREQUEST - TO BE COMPLETED BY REQUESTING ATTORNEY.
1. All information from the attorney must be filled-in before service can be made.
2. When comMetin¢ location for service be certain to have a valid address or directions. DO NOT use P.O.
Boxes or R.D.'s ADDRESSES ONLY. Provide the Township, if avolicable. If available, please also provide a
phone number or place of employment.
3. When a Deputy Sheriff' levies or attaches property, he or she will leave the property without a watchman and in
custody of whomever is found in possession, after notifying the person the property is under a Sheriff's Levy. The
Sheriff or Deputy is not liable in any way for protecting property.
4. Service will be executed in accordance with Rule 402 and Title 231, Pennsylvania Rules of Civil Procedure.
5. The attorney must certify all copies of process.
6. Supply a self-addressed stamped envelope for return of service.
1. PLAINTIFF(s): 2. COURT NUMBER: DATE FILED:
US BANK NATIONAL ASSOCIATION, AS INDENTURE Dq -355el 05/27/2009
TRUSTEE FOR CMLTI 2006-ARI
3. DEFENDANT(s) 4. TYPE OF WRIT OR COMPLAINT:
DESIREE MODITCH MINTZ Mort a e Foreclosure
NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO BE SERVED:
SERVICE DESIREE MODITCH MINTZ
1 ADDRESS (Street, Apartment No., City, Borough, Township, State and Zip Code):
119 SOUTH WILSON STREET, CLEONA, PA 17042-3263
NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO BE SERVED:
SERVICE
2 ADDRESS (Street, Apartment No., City, Borough, Township, State and Zip Code):
NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO BE SERVED:
SERVICE
3 ADDRESS (Street, Apartment No., City, Borough, Township, State and Zip Code):
NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO BE SERVED:
SERVICE
4 ADDRESS (Street, Apartment No., City, Borough, Township, State and Zip Code):
NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO BE SERVED:
SERVICE
5 ADDRESS (Street, Apartment No., City, Borough, Township, State and Zip Code):
NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO BE SERVED:
SERVICE
6 ADDRESS (Street, Apartment No., City, Borough, Township, State and Zip Code):
7. Name of Attorney or other Originator: 8. Telephone Number 9. Date
1 C
rGw S . (215) 563-7000 May 22, 2009
Print Name -
'f •? ,
Si Name
10. Send of S y to name and ddress below: (This area must be completed if notice is to be mailed)
Phelan inan & Schmieg, LLP
1617 JFK Boulevard, Suite 1400, One Penn Center Plaza, Philadelphia, PA 19103
SPECIAL INSTRUCTIONS FOR SERVICE:
If additional services are required, please attach a sheet noting each individual and location to be served.
File #: 197908
In The Court of Common Pleas of Cumberland County, Pennsylvania
US Bank National Association
vs.
Desiree Moditch Mintz
119 South Wilson Street
Cleona, PA 17042
Civil No. 2009-3557
Now, June 2, 2009, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of
Lebanon 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, , 20 , at o'clock M, served the
within
upon
at
by handing to
a
and made known to
Swom and subscribed before
me this day of ,20_
copy of the original.
the contents thereof.
So answers,
Sheriff of County, PA
COSTS
SERVICE $
MILEAGE
AFFIDAVIT
PHELAN HALLINAN & SCHMIEG, LLP
BY: SHEETAL R. SHAH-JANI, ESQUIRE
Identification No. 81760
One Penn Center at Suburban Station
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
US BANK NATIONAL ASSOCIATION, AS
INDENTURE TRUSTEE FOR CMLTI 2006-ARI
3476 STATEVIEW BOULEVARD
FORT MILL, SC 29715
Attorney for Plaintiff
COURT OF
PLEAS
CIVIL DIVISION
NO. 09-3557-CIVIL
Plaintiff
V.
DESIREE MODITCH MINTZ
119 SOUTH WILSON STREET
CLEONA, PA 17042-3263
Defendant
CUMBERLAND
PRAECIPE TO SUBSTITUTE VERIFICATION
TO THE PROTHONOTARY:
Kindly substitute the attached Complaint Verification executed by Helen Belton, Vice
President of Loan Documentation of WELLS FARGO BANK, N.A., servicing agent for Plaintiff
in this matter, for the verification executed by Andrew L. Spivack, Esquire, in connection with the
above referenced Action.
DATE: 12- bl
By:
Sheetal R. Shah-Jani,
Attorney for Plaintiff
r
PHELAN HALLINAN & SCHMIEG, LLP
BY: SHEETAL R. SHAH-JANI, ESQUIRE
Identification No. 81760
One Penn Center at Suburban Station
1617 JFK Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
US BANK NATIONAL ASSOCIATION, AS
INDENTURE TRUSTEE FOR CMLTI 2006-AR1
3476 STATEVIEW BOULEVARD
FORT MILL, SC 29715
Plaintiff
Attorney for Plaintiff
COURT OF COMMON PLEAS
CIVIL DIVISION
NO. 09-3557-CIVIL
V. CUMBERLAND
DESIREE MODITCH MINTZ
119 SOUTH WILSON STREET
CLEONA, PA 17042-3263
Defendant
CERTIFICATION OF SERVICE
I hereby certify that a true and correct copy of the foregoing Plaintiff ? Praecipe to
Substitute Verification was served by regular mail on the following parties on the date Risted below:
LOREN A. SCHRUM, ESQUIRE
1601 CORNWALL ROAD
LEBANON,, ?P 17042-7406
DATE: l(/ Z By. 4
Sheetal R. Shah-Jan
Attorney for Plaintiff
VERIFICATION
Helen Belton hereby states that he/she
Vice President of Loan Documentation of WELLS FARGO BANK, N.A., servicing agent for Pl4inti
US BANK NATIONAL ASSOCIATION, AS INDENTURE TRUSTEE FOR CMLTI 200
ARI, in this matter, that he/she is authorized to take this Verification, and that the statemen s
made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best f
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 unswom falsification to
authorities.
Name: Helen Belton
DATE: June 1, 2 0 0 9 Title: Vice President of Loan
Company: WELLS FARGO BANK, N
File k: 197908 Mintz
.
Lisp ???... C'_:1 .... ... G.:
PHELAN HALLINAN & SCHMIEG, LLP
BY: ANDREW L. SPIVACK, ESQUIRE
Identification No. 84439
One Penn Center at Suburban Station
1617 John F. Kennedy Boulevard, Suite 1400
Philadelphia, PA 19103-1814
(215) 563-7000
US Bank National Association, As
Indenture Trustee for CMLTI 2006-AR1
3476 Stateview Boulevard
Fort Mill, SC 29715
Plaintiff
VS.
Desiree Moditch Mintz
119 South Wilson Street
Cleona, PA 17042-3263
Defendant
PRAECIPE
TO THE PROTHONOTARY:
ATTORNEY FOR PLAINTIFF
Court of Common Pleas
Civil Division
Cumberland County
No.: 09-3557 Civil Term
X Please mark the above referenced case Discontinued and Ended without
prejudice.
Please mark the above referenced case Settled, Discontinued and Ended.
Please mark Judgments satisfied and the Action settled, discontinued and
ended.
PHS: 197908
Please Vacate the judgment entered and mark the action discontinued and
ended without prejudice.
Please withdraw the complaint and mark the action discontinued and
ended without prejudice.
Date:
d-"L ck
Andrew L. Spivack, E uire
Attorney for Plaintiff
PHS: 197908
ALED ;. ,.
OF THE R."
2009 JUL - 7 AiN 11 : 16
a
INTY