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Home My WebLink About01-1118GOLDBECK MCCAFFERTY & MCKEEVER BY: Joseph A. Goldbeck, Jr. Attorney I.D.#16132 Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff DOVENMUEHLE MORTGAGE COMPANY LP 1501 Woodfield Road Schaumburg, IL 60173-4982 Plaintiff vs. BRETT R. OTTO AND KELLEY ANNE OTTO (Mortgagor(s) and Real Owner(s)) 20 Chestnut Street Mount Holly Springs, PA 17065 Defendant (s) : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY : CIVIL ACTION - LAW :ACTION OF MORTGAGE FORECLOSURE CIVIL ACTION: MORTGAGE FORECLOSURE THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORF~TION OBTAINED FROM YOU WILL BE USED FOR T~E PURPOSE OF COLLECTING T~E DEBT. NOTICE You have been sued in court. If you wisl~ to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with :he 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 withouK you a~d a judgment may be entered against you by the Cour~ without further notice for any money claimed in the Complaimt 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 Y(IL~R LAWYER AT ONCE. IF YOU DO NOT HAVE A L~WYSR OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OLrP WHERE YOU C~ GET LEGAL HELP. Cumberland County Bar Associatio~ 2 Liberty Avenue, Carlisle, PA (800) 990 9108 Legal Services I~c. 8 Irvine Row, Carlisle, PA 17013 (71?) 243 9400 AVI SO LE HAH DEMAArDADO A USTED EN LA CORTE. SI DESEA DEFENEERSE CONTRA LAS QUEJAS PERESENTADAE, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SEE SERVIDO CON ESTA DEMA~A Y AVISO. PAPua DEFENDERSE ES NECESSARIO QUE USTED, D SU ABOGD230, REGISTRE CON LA CORTE EN FOR~ ESCRITA, EL PUNTO DE VISTA DE I3STED Y CUALQUIER OBJECCION CON~ LAS QUEJAS EN ESTA DEM3~A. RECUERDE: SI USTED NO REPONDE A ESTA DE~a~NDA, SE PU~DH PROSEGUIR CON EL PROCHSO SIN SU FARTICIFACION. ENTONCES. LA COUTH PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMAN~ANTE Y REQUERIRA QUE USTED CUMP~A CON TODAS LAS PROVISIONES DE ESTA DEM~DA. POE RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA pEELER DINERO, PROPlRDAD U OTROS DERECHOS IMPORTANTES. LLEVE ESTA DE~NDA A Lqq ABOGADO IMHEDIATA~ENTE. SI NO CONOCE A UN ABOGADO, LLAME AL "LAWYER REFERENCE SERVICE" (EERVICIO DE REFERENCIA DE ~O~DJ3OS) , 215 238 6300. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA {800) 990 9108 Legal Services Inc. ~ Irvine Row, Carlisle, PA 17013 (717) 243 9400 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is DOVENMUEHLE MORTGAGE COMPA/qY LP, 1501 Woodfield Road, Schaumburg, IL 60173-4982. 2. The name(s) and address(es) of the Defendant(s) is/are BRETT R. OTTO, 20 Chestnut Street, Mount Holly Springs, PA 17065 and KELLEY ANNE OTTO, 20 Chestnut Street, Mount Holly Springs, PA 17065, who is/are the mortgagor(s) and real owner(s) of the mortgaged property hereinafter described. 3. On September 30, 1993, mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to GMAC MORTGAGE CORP. OF PA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County in Mortgage Book 1168, Page 252. By Assignment of Mortgage dated February 1, 1995, the mortgage was assigned to Plaintiff, which Assignment is recorded in Assignment of Mortgage Book No. 490, Page 849. These documents are matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g). 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 August 1, 2000, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon default in such payments for a period of one month, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage: Principal Balance Interest from 7/ 1/00 through 12/31/00 at 6.875% Per diem interest rate at $12.23 Attorney's Fee at 5% of Principal Balance Late Charges 8/ 1/00-12/31/00 Monthly late charge amount at $29.76 Costs of suit and Title Search $ 64,953.12 2,238.09 3,247.66 148.80 560.00 Escrow Balance Deficit Monthly Escrow amount $122.15 $ 71,147.67 86.01 $ 71,233.68 7. The Attorney's Fees 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 based on work actually performed. 8. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant(s/ by Certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "A". The Defendant(s) has/have not had the required face to face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant(s) through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands judgment in mortgage foreclosure the sum of $71,233.68, together with interest at the rate of $12.23, per day and other expenses incurred by the Plaintiff which are properly chargeable in accordance with the terms of the mortgage, and for the foreclosure and sale of the mortgaged premises. By: GOLDBECK McKEEVER BY: Joseph A. Goldbed~, Jr., Esq. Attorney for Plaintiff VERIFICATION I, Ed Bagd0n , as the representative of the Plainti~% corporation within named do hereby verify that I am authorized ~o and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subjec= ~o the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Da~e: 2/6/2001 Ed Baqdon Assistant V}ce-President #9127119 - OTT0,BRETT R, Legal Descriotion: ALL THAT CERTAIN LOT OF GROUND IMPROVED WITH A PARSONAGE SITUATE IN THE BOROUGH OF MOUNT HOLLY SPRINGS, CUMBERLAND COUNTY, PENNSYLVANIA, BOUNDED AS FOLLOWS: ON THE NORTH BY LOT NOW OR FORMERLY OF GEORGE W. KINSEE, ON THE EAST BY AN ALLEY, ON THE SOUTH BY LANDS NOW OR FORMERLY OF J.C. TRINE & WIFE, AND ON THE WEST BY CHESTNUT STREET BEING 40 FEET IN FRONT AND 180 FEET IN DEPTH. October 19, 2000 Brett R Otto 20 Chestnut St Mt Holly Spring PA 17065 SINCE 1844 EXHiBiT A Loan Number: 0009127119 Current Lender/Servicer: Dovenmuehle Mortgage Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), 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 FORECLOSURE - 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 "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 October 19, 2000 Kelley A Otto 20 Chestnut St Mt Holly Spring PA 17065 SINCE 1844 Loan Number: 0009127119 Current Lender/Servicer: Dovenmuehle Mortgage Inc. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), 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 FORECLOSURE - 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 "face-to-face" meeting with one of the designated consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT (30) DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT", EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 PAGE 2 OF 5 October 19, B R Otto 2000 SINCE 1844 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 telephone numbers of designated consumer credit counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of ~ur intentions. APPLICATION FOR MORTGAGE 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 assisance 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. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. IF 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 to 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.) DL137 Dovenmuehle Modgage, lnc. 1501WoodfieldRoad Schaumburg, lL60173~4982 (847) 619-5535 PAGE 3 OF 5 October 19, B R Otto 2000 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 20 Chestnut St Mt Holly Spring PA 17065 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the months and the following amounts are now past due: (a) Monthly payments from August 01, to present (at $ 595.14 (b) Previous late charges; (c) Property Inspections; (d) NSF Charges; (e) Other Provisions of the mortgage obligation, if any;. 2000 per month) (f) TOTAL AMOUNT OF (a) (b) (c) (d) and (e) REQUIRED AS OF THIS DATE: YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION applicable)~ following 1,791.38 70.95 8.75 .00 $ .00 $ $ 1,871.08 (Do not use if not HOW TO CURE THE DEFAULT - 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 $ 1,871.08, PLUS ANY MORTGAGE PAYMENTS ~ LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified check or money order made payable and sent to: ATTN: Collection Department LENDER NAME: Dovenmuehle Mortgage, Inc. ADDRESS: 1501 Woodfield Road, Suite 400E Schaumburg, IL 60173-4982 You can cure any other default by taking the thirty (30) DAYS of the date of this letter. applicable.) following action within (Do not use if not Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 PAGE 4 OF 5 October 19, B R Otto 2000 SINCE 1844 IF YOU DO NOT CURE 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 accelerate the mortgage debt. '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 upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON - 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 you cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE If you have not cured the default within THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale. You may do so by paying the total amount then past fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in writing by the lender and by performing any other requirements under the mortgage. 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 POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A Notice of the actual date of the Sheriff's 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. DL138 Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaurnburg, IL 60173-4982 (847) 619-5535 PAGE 5 OF 5 October 19, B R Otto 2000 SINCE 1844 HOW TO CONTACT THE LENDER: Dovenmuehle Mortgage, /inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 1-800-669-0340 Fax: 847-330-8032 Contact: Mr. Edward Bagdon EFFECT OF SHERIFF'S SALE - 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. ASSUMPTION OF MORTGAGE - You MAY or X 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. YOU MAY ALSO HAVE THE RIGHT * 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 INANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. * TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. * TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, iL 60173-4982 (847) 619-5535 SINCE 1844 ACT 91 NOTICE DATE OF NOTICE: October 19, 2000 TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name, address and phone number of Consumer Credit Counseling Agencies servinq your County are listed at the end of this Notice. If you have any questions, you may call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869, 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 any 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 vivendo en su casa. Si no comprende el contenido de esta notificacion obtenga una traduccion immediatamente llamanda esta agencia (Pennsylvania Housing Finance Agency) sin cargos al numero mencionada arriba. Puedes set elegible para un prestamo por el programa llamado "Homeowner's Emergency Mortgage Assistance Program" el cula puede salvar su casa de la perdida del derecho a redimir su hipoteca. DL139 Dovenmuehle Mortgage, Inc. 1501 Woodfield Road Schaumburg, IL 60173-4982 (847) 619-5535 SHERIFF'S RETURN CASE NO: 2001-01118 P COMHONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOVENMUEHLE MORTGAGE COMPANYLP VS OTTO BRETT R ET AL REGULAR SHAWN HARRISON , Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE OTTO BRETT R DEFENDANT , at 0018:05 HOURS, at 20 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 17065 KELLY ANNE OTTO {WIPE) a true and attested copy of COHPLAINT NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 27th day of February , 2001 by handing to - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing ]8.00 Service 3.72 Affidavit .00 Surcharge 10.00 .00 !11.72 Sworn and Subscribed to before me this 2~. day of ~ 2z~ ] A.D. notary ~ ' R. Thomas Kline 02/28/2001 GOLDBECK, By: Deputy S~ez4~f f SiHERIFF'S RETURN - CASE NO: 2001-01118 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DOVENMUEHLE MORTGAGE COMPANYLP VS OTTO BRETT R ET AL REGULAR SHAWN HARRISON Cumberland County, Pennsylvania, says, the within COMPLAINT - MORT FORE OTTO KELLEY ANNE DEFENDANT , at 0018:05 HOURS, at 20 CHESTNUT STREET MOUNT HOLLY SPRINGS, PA 17065 KELLY A/qNE OTTO a true and attested copy of COMPLAINT NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 27th day of February , by handing to together with - MORT FORE 2001 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 16.00 Sworn and Subscribed to before me this ~)~.~ day of ~ ~1~o1 A.D. # ~rothonot ary ' So Answers: R. Thomas Kline 02/28/2001 GOLDBECK,By: MCCA~~ Depuky~e~iff GOLDBECK, McCAFFERTY & McKEEVER Suite 500 - The Bourse Bldg. 111 S. Independence Mall East Philadelphia, PA 19106 215-627-1322 BY: MICHAEL T. MCKEEVER, ESQUIRE Attorney I.D. #56129 Attorney for Plaintiff DOVENMUEHLE MORTGAGE COMPANY LP 1501 Woodfield Road Schaumburg, IL 60173-4982 vs. BRETT R. OTTO AND KELLEY ~2~-NE OTTO (Mortgagor(s)) (Record Owner(s)) 20 Chestnut Street Mount Holly Springs, PA 17065 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Term No. 01-1118 Civil Term PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. JO JR. , ESQUIRE