The URL can be used to link to this page

Home My WebLink About09-8686Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 L,.,Ivlichele 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 1. 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 224310 CHASE HOME FINANCE LLC 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff V. BRADFORD G. HENSHAW SHERRY E. HENSHAW 264 BLACKSMITH ROAD CAMP HILL, PA 17011-8420 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. Q9 -8(08 0 Giv i I Term CUMBERLAND COUNTY File #: 224310 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. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 Fite #: 224310 Plaintiff is CHASE HOME FINANCE LLC 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name(s) and last known address(es) of the Defendant(s) are: BRADFORD G. HENSHAW SHERRY E. HENSHAW 264 BLACKSMITH ROAD CAMP HILL, PA 17011-8420 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. On 10/13/2006 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR COMMERCE BANK/HARRISBURG, N.A. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book No. 1969, Page 2958. 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. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 07/01/2009 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 #: 224310 6 The following amounts are due on the mortgage: Principal Balance $227,792.07 Interest $8,032.86 06/01/2009 through 12/15/2009 (Per Diem $40.57) Attorney's Fees $1,300.00 Cumulative Late Charges $431.93 10/13/2006 to 12/15/2009 Mortgage Insurance Premium / $178.21 Private Mortgage Insurance Cost of Suit and Title Search $-5-50-00 Subtotal $238,285.07 Escrow Credit $0.00 Deficit $1,784.82 Subtotal $1,794.92 TOTAL $240,069.89 7 8. 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 nut seeking a judgment of personal liability (or an in near onam 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 #: 224310 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. 10. The action does not come under Act 6 of 1974 because the original mortgage amount exceeds the dollar amount provided in the statute. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $240,069.89, together with interest from 12/15/2009 at the rate of $40.57 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 WFrancis Byan, Esq., Id. No.32227 n, Esq., Id. No. 62695 U aniel G. Schnlieg, 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 Attorneys for Plaintiff File #: 224310 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point on the western line of Blacksmith Road at the line dividing Lots No. 97 and 98 on the hereinafter mentioned Plan of Lots; thence southwardly along the western line of Blacksmith Road by an arc curving to the left having a radius of 685.31 feet an arc distance of 92.39 feet to the northern line of Lot No. 96 on the hereinafter mentioned Plan of Lots; thence along the same South 75 degrees 47 minutes West, 145.79 feet to the eastern line of Lot No. 200 on the said plan; thence along the same North 21 degrees 21 minutes East, 143.19 feet to the southern line of Lot No. 98 on said plan; thence along the same South 86 degrees 21 minutes east, 84.65 feet to the point of BEGINNING. BEING Lot No. 97 Plan of Section 6 of Allendale as recorded in the Cumberland County Recorder's Office in Plan Book 13, Page 35. HAVING THEREON ERECTED a brick and aluminum split level dwelling house, known and numbered as 264 Blacksmith Road. BEING the same premises which James G. Binkley and Patricia L. Binkley, husband and wife, by deed dated October 13, 2006, and intended to be recorded herewith, granted and conveyed unto Bradford G. Henshaw and Sherry F. Henshaw, Mortgagees herein. PREMISES BEING: 264 BLACKSMITH ROAD PARCEL#: 13-25-0010-027 File #: 224310 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 unsworn falsifications to authorities. C? /) Atto ey for Plainti ffJ DATE: J V File #: 224310 ffii '<< v L{? :J IC, aa.Oo Pty A? $ gggi 1.5 ?. a3!5 1?o SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor 4 O'xoj4 at CU111bt','11 fd 2010 JAN -5 PM 2: 29 CUM3& "i-J COUNIY Kwwyki4 Chase Home Finance LLC vs. Bradford G. Henshaw Case Number 2009-8686 SHERIFF'S RETURN OF SERVICE 12/18/2009 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: Bradford G. Henshaw, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 12/18/2009 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: Sherry E. Henshaw, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Dauphin County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 12/23/2009 Dauphin County Return: And now, December 23, 2009 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Sherry E. Henshaw the defendant named in the within Complaint in Mortgage Foreclosure and that I am unable to find her in the County of Dauphin and therefore return same NOT FOUND. Request for service at 6113 Knisley Street, Harrisburg, PA 17112 is Bradford G. Henshaw's x-wife's residence. The defendant has never resided at this address. 12/23/2009 Dauphin County Return: And now, December 23, 2009 I, Jack Lotwick, Sheriff of Dauphin County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Bradford G. Henshaw the defendant named in the within Complaint in Mortgage Foreclosure and that I am unable to find him in the County of Dauphin and therefore return same NOT FOUND. Request for service at 6113 Knisley Street, Harrisburg, PA 17112 is Bradford G. Henshaw's x-wife's residence. The defendant has never resided at this address. 12/24/2009 04:51 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on December 18, 2009 at 1651 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Bradford G. Henshaw, by making known unto himself personally, at 264 Blacksmith Road, 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. 12/24/2009 04:51 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on Decembei 18, 2009 at 1651 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Sherry E. Henshaw, by making known unto Bradford G. Henshaw, adult in charge at 264 Blacksmith Road, 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: $98.50 December 29, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF ay Deputy Sheriff CI)f iro- of the hvrf Mary Jane Mder Real Estate Depu Charles E. Sheaffer Chief Deputy William T. Tully Solicitor Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin CHASE HOME FINANCE LLC VS BRADFORD G HENSHAW Sheriff s Return No. 2009-T-3216 OTHER COUNTY NO. 20098686 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 SHERRY E HENSHAW 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, DECEMBER 23, 2009. THIS IS BREADFORD'S X-WIFE'S HOUSE. DEF NEVER LIVED AT THIS ADDRESS. DEF LIVES AT: 264 BLACKSMITH ROAD CAMP HILL, PA 17011 WITH HUSBAND BRADFORD Sworn and subscribed to So Answers, before me this 28TH day of December, 2009 k' ee ? NO i ARIAL SEAL ARY JANE SNYDER, Notary Public Highspire, Dauphin Counry M Commission Expires Set 1, 2010 f of D hin County, Pa. By Deputy Sheriff Deputy: TINA FRANCIS Sheriffs Costs: $68.5 12/22/2009 (Atf ict Of thl. her-if Mary Jane Snyder Real Estate Depu William T. Tully Solicitor • Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 780-6590 fax: (717) 255-2889 Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy Jack Lotwick Sheriff Commonwealth of Pennsylvania County of Dauphin CHASE HOME FINANCE LLC VS BRADFORD G HENSHAW Sheriff s Return No. 2009-T-3216 OTHER COUNTY NO. 20098686 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 BRADFORD G HENSHAW 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, DECEMBER 23, 2009. DEF'S X-WIFE CALLED. THIS IS HER ADDRESS. DEF LIVES AT: 264 BLACKSMITH ROAD CAMP HILL, PA 17011 DEF LIVES THERE WITH CURRENT WIFE SHERRY; AND HAS NEVER LIVED AT KNISLEY ST ADDRESS. Sworn and subscribed to before me this 28TH day of December, 2009 NOTARIAL SEAL ARY JANE SNYDER, Notary Public Highspire, Dauphin County [My Commission Expires Set 1, 2010 So Answers, he ' f of D in County, Pa. By • Deputy Sheriff" Deputy: TINA FRANCIS Sheriffs Costs: $68.5 12/22/2009 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Ll-?ancis 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 CHASE HOME FINANCE LLC Plaintiff vs. !,'lip l' wi f iVL 1010 JAN -? pt, y : 10 r? ze 'w C.±4• ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS : CIVIL DIVISION NO. 09-8686 CIVIL TERM BRADFORD G. HENSHAW CUMBERLAND COUNTY SHERRY E. HENSHAW Defendant(s) PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: PHS #: 224310 Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff BY:',4 S t/? ? Lawrence T. Phelan, Esq., Id. No. 32227 ?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 Date: 1-6-10 PHS #: 224310 VERIFICATION Beth Cottrell Assistant Secretary hereby states that he/she is of CHASE HOME FINANCE LLC, servicing agent for Plaintiff, CHASE HOME FINANCE 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. Name: % et 46e DATE: 2 ?-( Title: Assistant Secretary Company: CHASE HOME FINANCE LLC File #: 224310 Henshaw Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. 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 CHASE HOME FINANCE LLC Plaintiff VS. BRADFORD G. HENSHAW SHERRY E. HENSHAW Defendant(s) ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CIVIL DIVISION : NO. 09-8686 CIVIL TERM : CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true 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: BRADFORD G. HENSHAW 264 BLACKSMITH ROAD CAMP HILL, PA 17011-8420 PHS #: 224310 SHERRY E. HENSHAW 264 BLACKSMITH ROAD CAMP HILL, PA 17011-8420 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 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., 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 Date: 1-6-10 PHS #: 224310 Li 1 f 1r'R1 H QN �. 2813 OCT -4 : 1 r � g �+S PENNs � CUMBERLAND.vki T PHELAN HALLINAN, LLP BY: COURTENAY R. DUNN, ESQUIRE Identification No. 206779 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Courtenay.dunn@phelanhallinan.com (215) 563-7000 Chase Home Finance LLC : Court of Common Pleas 3415 Vision Drive : Civil Division Columbus, OH 43219 Plaintiff : Cumberland County • No.: 09-8686 v. • Bradford G. Henshaw • Sherry E. Henshaw • 264 Blacksmith Road • Camp Hill, PA 17011-8420 • Defendants • STATEMENT OF INTENTION TO PROCEED TO THE COURT: The above-referenced foreclosure action was protected by the automatic stay provisions of the Defendants Bradford G. Henshaw and Sherry E. Henshaw Chapter 13 Bankruptcy filed on January 23, 2010 at Docket No. 1:10-00488 in the Middle District of Pennsylvania. Plaintiff intends to proceed with its above foreclosure action should the Defendants' Bankruptcy be dismissed or Plaintiff receives relief from the automatic stay. DATE: p l ‘ BY: • Courtenay R. Dunn, Esquire Attorney for Plaintiff #718147 PHELAN HALLINAN, LLP BY: COURTENAY R. DUNN, ESQUIRE Identification No. 206779 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff Courtenay.dunn@phelanhallinan.com (215) 563-7000 Chase Home Finance LLC • Court of Common Pleas 3415 Vision Drive • Civil Division • Columbus, OH 43219 Plaintiff • Cumberland County • No.: 09-8686 • v. • Bradford G. Henshaw • Sherry E. Henshaw • 264 Blacksmith Road • Camp Hill, PA 17011-8420 • Defendants CERTIFICATION OF SERVICE, I hereby certify a true and correct copy of Statement of Intention to Proceed was served by regular mail to the following on the date listed below: Bradford G. Henshaw Sherry E. Henshaw 264 Blacksmith Road Camp Hill, PA 17011-8420 DATE: (Otgt ("47 BY: Courtenay R. Dunn, Esquire Attorney for Plaintiff #718147