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HomeMy WebLinkAbout09-5713UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 /ADAM L. KAYES, ESQUIRE - ID #86408 MARGUERITE L. THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Navy Federal Credit Union "'COURT OF COMMON PLEAS 820 Follin Lane :CIVIL DIVISION Vienna, VA 22180 Plaintiff '-,Cumberland County V. Nancy L. Stawitz 318 8th street a/k/a = NO. 09 - 5q 13 0,16 1-"(erm 318 Eighth Street New Cumberland, PA 17070 Defendant(s) COMPLAINT IN MORTGAGE FORECLOSURE 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 11 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: N/A Assignments of Record to: N/A Recording Date: N/A 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant(s), Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 318 8th Street a/k/a 318 Eighth Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of New Cumberland COUNTY: Cumberland DATE EXECUTED: 10/27/95 DATE RECORDED: 11/1/95 BOOK: 1289 PAGE: 226 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure-said breach after notice, all sums secured by said. Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately Ir due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms (a) by failing or refusing principal and interest indicated below; (b) by failing or refusing indicated below. 6. The following amounts < of to wh, to 3.re the pay an di pay due Mortgage as follows: the installments of ae in the amounts other charges, if any, on the said Mortgage as of 8/11/09: Principal of debt due $54,670.84 Unpaid Interest at 7.125% from 3/1/09 to 8/11/09 (the per diem interest accruing on this debt is $10.47 and that sum should be added each day after 8/11/09) 1,715.59 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $0 and that sum should be added on the first of each month after 8/11/09) 534.06 Late Charges (monthly late charge of $21.13 should be added in accordance with the terms of the note each month. after 8/11/09) 140.63 Recoverable Balance 150.00 Attorneys Fees (anticipated and actual to 5% of principal) 2,733.54 TOTAL $60,549.66 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $60,549.66 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. UDREN LAW OFFICES, P.C. Attorneys for LP aintiff MARK J. UDREN, ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE --ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE LEGAL DESCRIPTION ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, LYING AND BEING IN THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLAND AND COMMONWEALTH OF PENNSYLVANIA, MORE PARTICULARLY DESCRIBED AS FOLLOWS: DESIGNATED AND KNOWN AS LOTS NO. 14, 15 AND 16 IN A CERTAIN PLAN OF LOTS CALLED "ELKWOOD", SURVEYED FOR THE WOOD, HARMAN REAL ESTATE ASSOCIATION BY GEORGE ROBERTS, CIVIL ENGINEER, WHICH IS DULY FILED AMONG THE RECORDS IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR THE COUNTY OF CUMBERLAND AFORESAID, IN DEED BOOK "M", VOLUME 5, PAGE 498, THE ABOVE DESCRIBED LOTS HAVING A FRONTAGE OF ONE HUNDRED TWENTY (120) FEET A DEPTH OF ONE HUNDRED FIVE (105) FEET. HAVING THEREON ERECTED A ONE AND ONE-HALF-STORY BRICK DWELLING HOUSE, KNOWN AND NUMBERED AS 318 EIGHTH STREET, NEW CUMBERLAND, PENNSYLVANIA. March 13, 2009 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE The AOMF.OWNF.ROS MORTGAGE ASSISTANC'F PROGRAM .MAP may he able to heip to cave gour home. This Notice expiajnc how the program works. This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO 0HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAMO EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Page 1 of 1 EXHIBIT A C HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER: Ngnsy L.Stawitz 318 8th Street ._New Cumb@rland,PA 17070 .. __......... 8005174043 __N-a? Federal Credit Union _-_? _-_.- --Navy- Federal Credit Union HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAV RF ELIGIBLE FOR FINANC:IAI, ASSTSTANCE WHICH CAN SAVE YOUR HOME FROM FOREC LOSURR AND HETY VOTT MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNEROS EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE GACTO), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORFC`T,OSTTRF - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a Oface-to-faceO meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MITST OCCUR WITH-IN THE NEXT (30) DAYS. IF YnTJ DO NOT APPT.Y FOR EMERGENCY MORTGAGF ARSTSTANC-F, YnTT MT iST BRMC; YOTTR MORTCTACrF T TP TO T)ATF THE PART OF THTS NOTICF. (`ATi,FT) OROW TO C1 IRF YOTTR MORTGACrF TIRE IT TO, $,xPT AINS T40W TO BRING YOUR MORTGAGE TTP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses, and telmhone number. are set forth at the end of this Notice, It is only necessary to schedule one face-to-face meeting. Advise your lender immediate]T of your intentions. APPLICATION FOR MORTG AC.E ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice:. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting. Page 2 of 2 YOU MAST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IM!gEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days 4p make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) NATURE, OF THE. DEFAULT - The MORTGAGE debt held by the above lender on your property located. at: 318 8th Street New Cumberland, PA 17070 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: MonthlWPay-ments of $_69©x„53 for January thro__ gh March 1.20092071.59__- _ M.onthllyLate Charges of $21.13 for Janusr?1?2004 throp-.gh Febrmry 1,.2(109_=$4 Other charges (explain/itemize): Other=$15.00 _Unpsid Late Charges = $21.13 __--------._--._._-.. _TOTAL AMOUNT PAST DUEL._ ---.25.... B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not anInahle): NA HOW TO CIIRF THE DFFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS SZ142.98_PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments mutt he mane either h-y each cashier's cherlc.ertifi .d .heck or menu order made payable and cent to, You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Do not use if not applicable-): NZA Page 3 of 3 -ql IF YOU DO NOT C'ITRF THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelmt . the inrtgggeebt_ This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose np on your mortgaged nr=rty- IF THE MORTGAGE IS FORECLOSED ITPONT - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If iron cure the. default within the TRiRTV (30) DAY period, you will not he required to pay attorneys fees- OTHER LF,NDER RF.MFDTFS - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. If your debt has been discharged in bankruptcy without your having reaffirmed it, then lender cannot pursue this remedy. RIGHT To CITRF THE i1FFAITT,T PRIOR TO SHF,RiFF'S SAi.F -- If you have not cured the default within the T14IRTY (30) DAY period and foreclosure proceedings have begun, you still have the tight to cure the default and prevent the sale at any time up to one hour before the Sh .riffs Sal ._ Yo a ma o so by nayingthe total amount then a. due, hn is any late -other chargQs then due, aconahl . attarney's fees and costs connected with the foreclosure sale and any other costs .onne&ed with the Sheriff'-, Sale as Specified in writinu by the lender and h rxxbi ing any ether requirement-, under the mn?gP. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSTBLE SHERIFF'S SALE RATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender/Servicer: _Navy. Federal Credit Union Address: 820 Follin Lane Phone Number: 1-703-255-7989 Fax Number: 1-703-255-7947 Contact Person: Mr. Sarder EFFECT OF SIFRIFF'S SALF. - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff s Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTIONT OF MORTGAGE, -- You may not transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied- Page 4 of 4 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document-is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 Page 5 of $ TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER., YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS, TO ASSERT AN'Y OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. . TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Page 6 of 6 HEMAP Consumer Credit Counseling Agencies CUMBERLAND County Report last updated: 101152007 10:03:08 AM Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 717.334.1518 CCCS of Western PA 2000 Lingiestown Road Harrisburg, PA 17102 888.511.2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 717.232.9757 Loveship, inc. 2320 North 5th Street Harrisburg, PA 17110 717.232.2207 Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 717.762.3285 PHFA 211 North Front Street Harrisburg, PA 17110 717.780.3940 800.342.2397 n' artified flail Provides: A mailing receipt A unique identifier for your mailpiece A record of delivery kept by the Postal Service for two years 'portent Reminders. Certified Mall may ONLY be combined with First-Class Mal$v or Priority Maly. Certified Malt is not available for aW,olp* of international mail. NO INSURANCE COVERAGE IS'\PROVIDED with Certified Mall. For valuables, please consider insured pr pogiftred Mail. For an additional fee, a Return R.64tAy'be requested to provide proof of delivery. To obtain Return Receipt service, pplI?se compiets and attach a Return Receipt (PS Form 3811) to the artiq* antlpdaappkable postage to cover the fee. Endorse mallpiece 'Return Recb" Mqu9ifted". To receive a fee waiver for a duplicate return receipt, a USPSO postmark on your Certified Mall receipt is required. For an additional fee, delive toa? .be. restricted to the addressee or addressee's authorized agenL ?istflerk or mark the mailplece with the endorsement "Restricted Defivery If a postmark on the Certified Mail receipt is desired, please present the arti- cle at -the post office for postmarking. If a postmark on the Certified Mail receipt is not needed, detach and affix label with postage and mail. IPORTANT: Save this receipt and present It when snaking an inquiry. Form 3800, August 200^0 (Reverse) PSN 7530.02.ODO.9047 m a o z ?? o U C c3• a o 1 ?. ? ci CD a 0 Ln Tl m r v m m ' rR r (D - to C:I N A? C3 Lu ¢ ??(a ? w a o d X rri o ri o. C3 © ? m w C3 M m a > a E a)0E U '- L T O co ? 0 "M ?p0?rO" `L Q y U 41- M t=` m 0 FL Ai - CZ 'V 0 r0?5,2 m:F;t6v?o N Z E E a Cc0 2 0=(L v c c o ie 'M 0 Z r i)<0 ¢ ` -` s I N 0 9 CCU 2 CD ILL CD M9 0 in a. d7 ? v LXi CN y u F DP, _ fq .: ff S t.p prf ?!? k t -i a w M ru a a a 0 tm w a 3 , 1:4 v V .Z V E R I F I C A T I O N The undersigned, hereby states that he/she is the attorney for the Plaintiff, a corporation unless designated otherwise; that he/she is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he/she has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his/her knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. UDREN LAW'' OFFICES, P.C. BY : ; /'4G?ee- Ao,,.dill' Attorneys for PlAintiff MARK J. UDREN,'ESQUIRE STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM L. KAYES, ESQUIRE MARGUERITE L. THOMAS, ESQUIRE Q FILED--i , APY OF THE F-'- 2 0 0 9 AU'-0 9 1.`': I.?' E 4-i8. so P4 Arr-l P14 aa93g9 Sheriffs Office of Cumberland County R Thomas Kline Sheriff a?ntu nt u?t?re6rr?? Ronny R Anderson ? ?D Chief Deputy ' - '-/ L Jody S Smith Civil Process Sergeant OFFICE OF 7-` S"ERIFF Edward L Schorpp Solicitor F1 LED - r E OF THE '".'',;oiARY 2009 AUS Z8 11-112: 15 1 G,1 J Navy Federal Credit Union vs. Nancy L. Stawitz SHERIFF'S RETURN OF SERVICE Case Number 2009-5713 08/24/2009 07:19 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 24, 2009 at 1919 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Nancy L. Stawitz, by making known unto Brad Bommerger, adult in charge at 318 8th Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.30 SO AN R August 25, 2009 R THOMAS KLINE, SHERIFF By V Deputy Sheriff UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF MARK J. UDREN, ESQUIRE - ID #04302 STUART WINNEG, ESQUIRE - ID #45362 LORRAINE DOYLE, ESQUIRE - ID #34576 ALAN M. MINATO, ESQUIRE - ID #75860 CHANDRA M. ARKEMA, ESQUIRE - ID #203437 LOUIS A. SIMONI, ESQUIRE - ID #200869 ADAM KAYES, ESQUIRE - ID #86408 MARGUERITE THOMAS, ESQUIRE - ID #204460 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Navy Federal Credit Union -COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION .Cumberland County V. Nancy L. Stawitz Defendant NO. 09-5713 Civil Term PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE. DATED:October 12, 2009 UDREN /LAAW OFFICES,PP.C. BY: /4 ???/?? Attorneys for Plai i f MARK J. UDREN, ESQ E STUART WINNEG, ESQUIRE LORRAINE DOYLE, ESQUIRE ALAN M. MINATO, ESQUIRE CHANDRA M. ARKEMA, ESQUIRE LOUIS A. SIMONI, ESQUIRE ADAM KAYES, ESQUIRE MARGUERITE THOMAS, ESQUIRE r i BLED v F THE P:; , ),.,;1,AF?Y 2009 OCT 16 Ali C: 3 0