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HomeMy WebLinkAbout11-0008OF THE PR07H0 QTAR Y 10I 1,.,1~~~ -3 AM 11: 3p CUM6ERLA~dD COUNTY PEFSi'~'S YLVA'~IA McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 3 ADA Irvine, California 92618 v. Brian M. Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 and Donna L. Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Attorneys for Plaintiff Cumberland County Court of Common Pleas Number f~ a (~ ' U ~ (1~L ( t'P'r/~ CIVIL ACTION/MORTGAGE FORECLOSURE - ~~~,~, ~~a Q~ la9~vs ~, ~~53D~ 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 ifyou 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas ex-puestas en las paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar 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 defiende, 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 provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pars usted. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMATION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARR EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800)990-9108 CIVIL ACTION/MORTGAGE FORECLOSURE - Plaintiff is Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3, a corporation duly organized and doing business at the above captioned address. 2. The Defendant is Brian M. Morrow, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 350 W Penn Street, Carlisle, Pennsylvania 17013. 3. The Defendant is Donna L. Morrow, who is the mortgagor and real owner of the mortgaged property hereinafter described, and his/her last-known address is 350 W Penn Street, Carlisle, Pennsylvania 17013. 4. On August 10, 2005, Brian M. Morrow and Donna L. Morrow made, executed and delivered a mortgage upon the premises hereinafter described to Argent Mortgage Company, LLC which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1918, Page 3921. 5. On February 27, 2008, the aforesaid mortgage was thereafter assigned by Argent Mortgage Company, LLC to Registered Holders of Argent Securities Inc., by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Instrument # 200805582. 6. The aforesaid mortgage was thereafter assigned by Registered Holders of Argent Securities Inc. to Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3, Plaintiffherein, by Assignment of Mortgage, which will be duly recorded in the Office of the Recorder of Cumberland County. 7. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 350 West Penn Street, Carlisle, Pennsylvania 17013. The mortgage is in default because monthly payments of principal and interest upon said mortgage due August 1, 2010 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. 9. The following amounts are due on the mortgage: Principal Balance Interest through November 24, 2010 (Plus $14.24 per diem thereafter) Attorney's Fee Late Charges Corporate Advance NSF Fees $ 67,961.03 $ 2,074.85 $ 1,250.00 $ 892.97 $ 197.20 $ 40.00 GRAND TOTAL $ 72,416.05 10. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et seq., commonly known as the Combined Notice of Delinquency has been sent to Defendant by regular mail with a certificate of mailing and by certified mail, return receipt requested. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $72,416.05, together with interest at the rate of $14.24 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WE~RG AND ~ONW.~~.C. BY: /_ _ /t X . //l/ Attorrfeys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIIZO, ESQUIRE VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, and are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. Y,P.C. BY: ~../!/ ~ ~ l/~~ Attorneys for Plaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIItE Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 v. Brian M. Morrow and Donna L. Morrow Date: 8!8/2005 ~ .~-.. p=dez 1~lyaber: 000027162 350 WEST PENN STREET Re: erica 1t. 1(orroK CARLISLE, PA 17013 Doane L. 1b=rox CUMBERLAND County =x8I8Z? '~' ALL THAT CERTAIN tract of land with the improvements thereon erected situate in the fourth (4th) Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: BEGINNING at a point, said point being a 1/4 inch drill hole 6 feet South of the Southern curb line of West Penn Street and 209.85 feet East of the Eastern line of Franklin Street; thence along lands now or formerly of William D. Shultz, South 15 degrees 58 minutes West 120.00 feet to a stake on the Northern side of a 12 foot wide public alley; thence along the Northern side of said public alley North 79 degrees 00 minutes West 94.83 feet to a stake; thence North 15 degrees 58 minutes East 120.00 feet through the partition wall of a concrete block garage and the partition wall of 350 West Penn Street and 352 West Penn Street to a 1/4 inch drill hole, said drill hole located 6 feet South of the Southern curb line of West Penn Street and 165.02 feet East of the Eastern side of Franklin Street; thence South 79 degrees 00 minutes East 44.83 feet to a 1/9 inch drill hole, the place of BEGINNING. HAVING thereon erected a two story frame dwelling house the Eastern portion of which is included herein and frame garage and Eastern half of a concrete block garage; being known and numbered as 350 West Penn Street, Carlisle, Pennsylvania. Time: 3:04:56 PM Exhibit "A" paps: 6 of 6 8K 19 l 8 P~ 3 Ordsr Number 000027162 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor `;4? Deutsche Bank National Trust Company vs. Donna L. Morrow (et al.) LED- H- t 4 -1" 0 E H- 4 . P,ru 2. 11 JAi 12 A 9' f.._t. U U Case Number 2011-8 SHERIFF'S RETURN OF SERVICE 01/06/2011 09:05 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 6, 2011 at 2105 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Donna L. Morrow, by making known unto herself personally, at 350 W. Penn Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handinc to her personally the said true and correct copy of the same. " lZi"40 -*e4- TIM 04K, DEPUTY 01/06/2011 09:05 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 6, 2011 at 2105 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Brian M. Morrow, by making known unto Donna Morrow, Wife of defendant at 350 W. Penn Street, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. TIM K, DEPUTY SHERIFF COST: $49.40 January 07, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 1.7616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 Plaintiff V. Brian M. Morrow and Donna L. Morrow Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 2011-8 Civil Term ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: C°) G ICU r, rM Z? -+Cy' r? Z_a C= -r1 l c? r- rT1 i 70 C) (D C:)- n r © 4 _M W Kindly enter judgment by default in favor of Plaintiff and against Defendants in the above-captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure and assess damages as follows: Principal interest from 11/25/10 to 02/08/11 $ 72,416.05 $ 1,082.24 Total MARC S. WEISBERG, ESQU`WI EDWARD D. CONWAY, ES U MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff ow'114 as f d al y pot- 102.6194, 2*,?5Y :9SY p0 +,,t AAa'14d AND NOW, this day of F#Mb• , 2011, Judgment is entered in favor of Plaintiff, Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3, and against Defendants, Brian M. Morrow and Donna L. Morrow, and damages are assessed in the amount of $73,498.29, plus interest and costs. Y THE PROTHONOTARY: McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 Plaintiff V. Brian M. Morrow and Donna L. Morrow Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS Attorneys for Plaintiff Number 2011-8 Civil Term AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendants, Brian M. Morrow and Donna L. Morrow, are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; and that the Defendants, Brian M. Morrow and Donna L. Morrow, are over eighteen (18) years of age, and reside as follows: Brian M. Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 SWORN AND SUBSCRIBED BEFORE ME THIS -7th _ DAY OF February- I ""i 61 Donna Street 13 TERRENCE J. M6CA%E MARC S. WEISBERG, E EDWARD D. CONWAY, MARGARET GAIRO, E; Attorneys for Plaintiff OTARY PUBLIC McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 Plaintiff Brian M. Morrow and Donna L. Morrow Defendants CUMBERLAND COUNTY Attorneys for Plaintiff COURT OF COMMON PLEAS Number 2011-8 Civil Term CERTIFICATION The undersigned hereby certifies that he is the attorney for Plaintiff, being duly sworn according to law, deposes and says that he deposited in the United States Mail a letter notifying the Defendants that judgment would be entered against them within ten (10) days from the date of said letter in aacc'iordance with Rule 237.5 of the rk?d as Exhibit "A". Pennsylvania Rules of Civil Procedure. Copies of said letters are,acftacd hereto an SWORN AND SUBSCRIBED BEFORE ME THIS _7th _ DAY OF February , 2011 ARY PUBLIC TERRENCE J. McCABE, E; MARC S. WEISBERG, ESQ EDWARD D. CONWAY, ES MARGARET GAIRO, ESQ] Attorneys for Plaintiff 4MMONWE,,A-,1 Z NOTARIAL Barbara J. Moyer- Notary E?A O?y of Philadelphia, Phiradelphia Eby tin' COMMISSION EXPIRES JAN.12, 2014 VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworr y fication to?thoris. THENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIR EDWARD D. CONWAY, ESQ E MARGARET GAIRO, ESQUI Attorneys for Plaintiff OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary January 28, 2011 To: Donna L. Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Ex?,,b?k ?? Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 vs. Brian M. Morrow Donna L. Morrow Cumberland County Court of Common Pleas Number 2011-8 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ,ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE . CLAIMS SET FORTH AGAINST VOU..IJk4s YOUACT WITHIN TEN (1'O)•,. DAYS FROM THE DATE OF THIS NOTICE, A RMOMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARINGAND YOU MAY LOSE YOUR PROPERTY OR OTHERIMPORTANT RIGHTS: YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THTS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATIONABOUI' AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO .UNA.,COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POX ABOGADO Y POR NO HABER.RADTCADO POR ESCXITO'CONTT T TkIBUNAL SUS.DEFENSAS U 013JECIONES it LOS 9ECLAM09 FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTTFICACION, EL TRIBUNAL PO.DRA, SIN NECESIPAD DE COMPARECER 1JS7'ED'EN CORTE 11 OIR-PREUBA ALOUNA, DICPAR SENTENCIA EN SU CONTRA Y LISTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU AI30GAD0 INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR,CON TNFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARL.O CON INFORMAC16N ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NI'NGCJN HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800)990.9108 McCABE,, Wj EISBERG, AND CONWAY, P.C. BY: / / e Attorneys for?laintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE lm OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary January 28, 2011 To: Brian M. Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 VS. Brian M. Morrow Donna L. Morrow Cumberland County Court of Common Pleas Number 2011-8 Civil Term NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRrrrEN APPEARANCE PERSONALLY OR BY. ATTORNEY ANq FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE Cl;A1NNSSETFbRTF1AGAINSTYOO. UNLESSYOUACTWfCI1TNTEIV.(I?'.;': DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU W ITHOUT A HEARINO AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RJGHTS, 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE O ]?OR ABOQADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS pEFENSAs U OBJECIONES A LOS RBCLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACC10N DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFIC?CIgN, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALOUNA, DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOSIMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A O TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DR EMPLEAR A UN ABOGADO. Sl LISTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEOIBLES EN UN HONORARIO REDUCIDO NI NINGON HONORARIO. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 McCABE,,?WEISBERG, AND CONWAY, P.C. BY: Attorneys forPaintiff TERRENCE J. McCABE, ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE lm OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Brian M. Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 Plaintiff V. Brian M. Morrow and Donna L. Morrow Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 2011-8 Civil Term NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. X Judgment by Default - Money Judgment - Judgment in Replevin Prothonotary - Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. g.'j 'I I OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Donna L. Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 Plaintiff V. Brian M. Morrow and Donna L. Morrow Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 2011-8 Civil Term NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. X Judgment by Default - Money Judgment - Judgment in Replevin - Judgment for Possession Prothonotary If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. g-? / + WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N011-8 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY Plaintiff (s) From BRIAN MORROW and DONNA MORROW (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $73,498.29 L.L.$.50 Interest FROM 02/09/2011 - - $1,365.04 AT $12.08 Arty's Comm % Due Prothy $2.00 Arty Paid $181.90 Other Costs Plaintiff Paid Date: 2/23/11 David D. B 11, Prothono (Seal) Deputy REQUESTING PARTY: Name: TERRENCE J. MCCABE, ESQUIRE Address: MCCABE, WEISBERG AND CONWAY 123 S. BROAD STREET, SUITE 2080 PHILADELPHIA, PA 19109 Attorney for: PLAINTIFF Telephone: 215-790-1010 Supreme Court ID No. 16496 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION FILE NO.: 2011-8 Civil Term Civil Term Deutsche Bank National Trust Company, as Trustee gyp` i for Argent Securities Inc., Asset-Backed AMOUNT DUE: $73,498.29 -o? . "- fgym- rgT - Pass-Through Certificates, Series 2005-W3 v. INTEREST: from 02/09/11 $1,365.04 at $12.08 3 --< = ~ Brian Morrow and Donna Morrow ATTY'S COMM.: '? „CCU "Ci « C? p. C- p Z t-:F r' COSTS: ? •"' TO THE PROTHONOTARY OF SAID COURT: The undersigned hereby certifies that the below does not arise out of a retail installment sale, contract, or account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended. PRAECIPE FOR EXECUTION Issue writ or execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs upon the following described property of the defendant(s) 350 West Penn Street. Carlisle. Pennsylvania 17013 (More fully described as attached) PRAECIPE FOR ATTACHMENT EXECUTION Issue writ of attachment to the Sheriff of CUMBERLAND County, for debt, interest and costs, as above, directing attachment against the above-named garnishee(s) for the following property (if real estate, supply six copies of the description, supply four copies of lengthy personalty list) and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s). (Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the defendant(s) described in the attached exhibit. DATE: February 17, 2011 (S) Ark ?0ALJ' ?a Ca? 49.(4o 9 A, W ti e, ?4•oo It /r c? . 5o U /, ? ? Sl . q o ?d a#h? Signature: Print Nam : MCCABE, WEISBERG AND CO Y Address: 123 S. Broad Street. Suite 2080 Philadelphia, PA 19109 Attorney for: Plaintiff Telephone: (215) 790 1010 Supreme Court ID No. 4Q,a is. 5c(.L t k_* 1133Co 51 ?s toil ? ? k JArif A?- Vi_ .l qg.quel McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 215 790-1010 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 Plaintiff V. Brian Morrow and Donna Morrow Defendants Attorneys for Plaintiff C3 -rt CUMBERLAND COUNTY COURT OAT_"M%N -ry PLEAS' ul pp w t? r' -ca C NO: 2011-8 Civil Term r r--, . y. a ul AFFIDAVIT PURSUANT TO RULE 3129 The undersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real property located at: 350 West Penn Street, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. Name and address of Owners or Reputed Owners Name Address Brian Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Donna Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Name and address of Defendants in the judgment: Name Address Brian Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Donna Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address Plaintiff herein 4 5 Name and address of the last recorded holder of every mortgage of record: Name Argent Mortgage Company, LLC Address One City Boulevard West Orange, California 92868 Name and address of every other person who has any record lien on the property: Name Address None 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 350 West Penn Street Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriff's Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o U.S. Dept of Justice, Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 United States of America c/o U.S. Dept of Justice, Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address None t verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. February 17, 2011 DATE TERRENCE J. McCABE, ESQUIft.- MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 CIVIL ACTION LAW Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 V. Brian Morrow and Donna Morrow Attorneys for Plaintiff Q.+ W w -C ? ItcIct-1-1 COURT OF COMMON PLEAS -L CUMBERLAND COUNTY Number 2011-8 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Brian Morrow Donna Morrow 350 W Penn Street 350 W Penn Street Carlisle, Pennsylvania 17013 Carlisle, Pennsylvania 17013 S CD Your house (real estate) at 350 West Penn Street, Carlisle, Pennsylvania 17013 is scheduled to be sold at Sheriffs Sale on June 1, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment of $73,498.29 obtained by Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: The sale will be canceled if you pay to Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are tiled with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 I %t McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 Plaintiff V. Brian Morrow and Donna Morrow Defendant Attorney for Plaintiff CUMBERLAND COUNTY r1l r. COURT OF COMMON PLEAS r {© I c' > c- Number 2011-8 Civil Term ::cp Q z-- vrt AFFIDAVIT OF SERVICE OF AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for the Plaintiff in the within matter, hereby certifies that on the 28th day of March, 2011, a true and correct copy of the Notice of Sheriffs Sale of Real Property was served on all pertinent lienholder(s) as set forth in Amended Affidavit Pursuant to 3129 which is attached hereto. A copy of the Notice of Sheriffs Sale and certificate of mailing is also attached hereto and made a part hereof. SWORN AND SUBSCRIBED BEFORE ME THIS o-)q+-h DAY OF Ha- r 2011 C NOTARY P LIC COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL Megan C. Paolucci -Notary Public City of Philadelphia, Philadelp'-;a County MY COMMISSION EXPIRES JAN. 06, 2014 McCABE, WERG & CQN}"Y, P.C. By: TERRENCE J. McCABE, ESQUIRE - ID 96 MARC S. WEISBERG, ESQUIRE - 1 616 EDWARD D. CONWAY, ESQUIRE $$34687 MARGARET GAIRO, ESQUIRE - I # 34419 McCABE, WEISBERG & CONWAY, P.C. TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 Plaintiff V. Brian Morrow and Donna Morrow Defendants Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 2011-8 Civil Term AMENDED AFFIDAVIT PURSUANT TO RULE 3129 The undersigned attorney for Plaintiff in the above action sets forth the following information concerning the real property located at 350 West Penn Street, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property is attached hereto. Name and address of Owners or Reputed Owners Name Address Brian Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Donna Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Name and address of Defendants in the judgment: Name Address Brian Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Donna Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address 4 5 Plaintiff herein Name and address of the last recorded holder of every mortgage of record: Name Argent Mortgage Company, LLC Address One City Boulevard West Orange, California 92868 Name and address of every other person who has any record lien on the property: Name Address 6. Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address Tenants/Occupants 350 West Penn Street Carlisle, Pennsylvania 17013 Commonwealth of Pennsylvania Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard Commonwealth of Pennsylvania 110 North 8' Street Inheritance Tax Office Suite #204 Philadelphia, PA 19107 Commonwealth of Pennsylvania 6th Floor, Strawberry Square Bureau of Individual Tax Department #280601 Inheritance Tax Division Harrisburg, PA 17128 Department of Public Welfare Willow Oak Building TPL Casualty Unit Estate P.O. Box 8486 Recovery Program Harrisburg, PA 17105-8486 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Clearance Support Department 281230 Department of Revenue Bureau of Harrisburg, PA 17128-1230 Compliance ATTN: Sheriff's Sales United States of America Domestic Relations Cumberland County United States of America United States of America c/o Atty General of the United States United States of America c/o Atty General of the United States U.S. Dept. of Justice Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 P.O. Box 320 Carlisle, PA 17013 c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 U.S. Dept of Justice, Room 5111 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Room 4400 950 Pennsylvania Avenue NW Washington, DC 20530-0001 Name and address of Attorney of record: Name Address I verify that the statements made in this Affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. McCABE, E?NWAY, P.C. March 28.2011 DATE Attorney or ti By:??/lam TECE J. McCABE, ESQUIREJ. McCABE ESQUIRE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY V. Brian Morrow and Donna Morrow Defendants DATE: March 28, 2011 TO: ALL PARTIES IN INTEREST AND CLAIMANTS Number 2011-8 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY OWNERS: Brian Morrow and Donna Morrow PROPERTY: 350 West Penn Street, Carlisle, Pennsylvania 17013 IMPROVEMENTS: Residential Dwelling The above-captioned property is scheduled to be sold at the Sheriffs Sale on June 1, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. Our records indicate that you may hold a mortgage or judgments and liens on, and/or other interests in the property which will be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of distribution will be filed by the Sheriff on a date specified by the Sheriff not later than thirty (30) days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within ten (10) days after the filing of the schedule. r, ? a.b-4Z r 00 J O? VI A W N F+ ° 8 y m U p ZA ?fS? O tb fD C ? O y n d S O ro d C U eo d ?p a O W 1 y? ? ? ?? m N O ? Ay7 -?bNd? ? nV ? ? m O Do o• I.y H KK d 0 ? z e ° , ?m= & y ?aQo ofD, axA7dn xbtdb xb??yv " xd??odn bcp axbwvn 0q:0 0= 0 0 nWy 0, (A goa ?????? -3-s?eo? z (A p1 = ee y W m v ao ?yyo e o/r? W y l l -ex sJAee3 Vi ? ,eo ?e CL O ?. R A4?S Vl W R " Sm y ` i7 '. eo A l r. Ol ?g `Z &. C= O O /1 C A = eb ? 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A `w R m as '?R R eo a C ?R?eD A a C aR?ee r ?, ? °??cr a o a ': w ? y C Aso '* a., CL ' e_?waA_ a < Off! ??-r ,°y < O "?? QQ R•?f,Q ??'? ro . WrOVj•0- >NR rb ??b???? doc.°„o CpR°o rA I%-% > o ,rim °+o = f?? ?OeAe RtiRo A g B . 00 0 a w oa f oar ? ?' w°' "?"d a A 8 ° , r O^ 'm C ? ? n a C A to tp CA p A Na ? ? W C ? O. ' O M ?+ K ? ee fQ ?' ? O R A Y 00 i p o N S? 0 co 9 ' o M c il 41, N 9 N? (D N 1 0 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson 1L_0f_?? ? Sheriff ?. ? ! 3 Jody S Smith Cir-_ Tr H r Pt?0 7?? ON Chief Deputy 1011 JUL -5 AM 8., 3b Richard W Stewart Solicitor CUMBERLAND COJNTY PENNSYLVANIA Deutsche Bank National Trust Company Case Number vs. 2011-8 Donna L. Morrow (et?an SHERIFF'S RETURN OF SERVICE 03/11/2011 01:36 P - Deputy Tim Black, being duly sworn according to law, states service was performed by postinc a true co y of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 350 W Penn Street, Carlisle, PA 17013, Cumberland County. 03/14/2011 07:30 P - Deputy Michael Barrick, being duly sworn according to law, served the requested Real Estate Writ, Not ce and Description, in the above titled action, by making known its contents and at the same time personal y handing a true copy to a person representing themselves to be DONNA MORROW- WIFE, who accepted as "Adult Person in Charge" for Brian M. Morrow at 350 W. Penn Street, Carlisle Borough, Carlisle, A 17013, Cumberland County. 03/14/2011 07:30 P - Deputy Michael Barrick, being duly sworn according to law, served the requested Real Estate Writ, Not ce and Description, in the above titled action, by making known its contents and at the same time personal y handing a true copy to a person representing themselves to be the Defendant, to wit: Donna L. Morrow at 350 W. Penn Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 05/20/2011 As directed by Terrance McCabe, Attorney for the Plaintiff, Sheriffs Sale Continued to 7/6/2011 06/29/2011 Ronny RlAnderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter{ of instruction from Attorney. SHERIFF COST: $1,0$7.49 June 29. 2011 SO ANSWERS, RONW R ANDERSON, SHERIFF i McCABE, EISBERG AND CONWAY, P.C. BY: TE RENCE J. McCABE, ESQUIRE - ID # 1649, MA C S. WEISBERG, ESQUIRE - ID # 17616 ED ARD D. CONWAY, ESQUIRE - ID # 3468' MA GARET GAIRO, ESQUIRE - ID # 34419 123 South Broad Street, Suite 2080 Philadelphia Pennsylvania 19109 215 790-1010 Deutsche Bank National Trust Company, as Trustee for Argent Secu ities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 Plaintiff V. Brian Morro and Donna Morrow Defendants Donna Morrow AFFIDAVIT PURSUANT TO RULE 3129 The dersigned, attorney for Plaintiff in the above action, sets forth the following information concerning the real properry located at: 350 West Penn Street, Carlisle, Pennsylvania 17013, as of the date the Praecipe for the Writ of Execution was filed. A copy of the description of said property being attached hereto. 1. Name and address of Owners or Reputed Owners Name Address Brian Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 2 Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS NO: 2011-8 Civil Term 350 W Penn Street Carlisle, Pennsylvania 17013 Name and address of Defendants in the judgment: Name Address Brian Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Donna Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address r Plaintiff herein 4 5 6 7 Name and address of the last recorded holder of every mortgage of record: Name Argent Mortgage Company, LLC Address One City Boulevard West Orange, California 92868 Name and address of every other person who has any record lien on the property: Name Address None Name and address of every other person who has any record interest in the property which may be affected by the sale: Name Address None Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Tenants/Occupants Commonwealth of Pennsylvania Commonwealth of Pennsylvania Inheritance Tax Office Commonwealth of Pennsylvania Bureau of Individual Tax Inheritance Tax Division Department of Public Welfare TPL Casualty Unit Estate Recovery Program PA Department of Revenue Commonwealth of Pennsylvania Department of Revenue Bureau of Compliance Address 350 West Penn Street Carlisle, Pennsylvania 17013 Department of Public Welfare Bureau of Child Support Enforcement P.O. Box 2675 Harrisburg, PA 17105 ATTN: Dan Richard 110 North 8`h Street Suite #204 Philadelphia, PA 19107 6th Floor, Strawberry Square Department #280601 Harrisburg, PA 17128 Willow Oak Building P.O. Box 8486 Harrisburg, PA 17105-8486 Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Clearance Support Department 281230 Harrisburg, PA 17128-1230 ATTN: Sheriffs Sales United States of America Internal Revenue Service Technical Support Group William Green Federal Building Room 3259 600 Arch Street Philadelphia, PA 19106 Domestic Relations P.O. Box 320 Cumberland County Carlisle, PA 17013 United States of America c/o United States Attorney for the Middle District of PA William J. Nealon Federal Bldg. 235 North Washington Avenue, Ste. 311 Scranton, PA 18503 and Harrisburg Federal Building & Courthouse 228 Walnut Street, Ste. 220 Harrisburg, PA 17108-1754 United States of America c/o U. S. Dept of Justice, Room 5111 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 United States of America c/o U.S. Dept of Justice, Room 4400 Atty General of the United States 950 Pennsylvania Avenue NW Washington, DC 20530-0001 8. Name and address of Attorney of record: Name Address None I veri that the statements made in this Affidavit a re true and correct to the best of my personal knowledge or information ? uid belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 r?lating to unsworn falsification to authorities. February 17, ^ 01 I TE RENCE J. McCABE, ESQUI DATE MARC S. WEISBERG, ESQUIRE EDWARD D. CONWAY, ESQUIRE MARGARET GAIRO, ESQUIRE Attorneys for Plaintiff McCABE, WYEISBERG AND CONWAY, P.C. BY: TE RENCE J. McCABE, ESQUIRE - ID # 16496 Attorneys for Plaintiff MA C S. WEISBERG, ESQUIRE - ID # 17616 ED ARD D. CONWAY, ESQUIRE - ID # 34687 MA GARET GAIRO, ESQUIRE - ID # 34419 123 South B oad Street, Suite 2080 Philadelphia Pennsylvania 19109 (215) 790-10 0 CIVIL ACTION LAW Deutsche Bank National Trust Company, as Trustee for COURT OF COMMON PLEAS Argent Securities Inc., Asset-Backed Pass-Through I Certificates, Series 2005-W3 CUMBERLAND COUNTY Brian and Donna Morrow V. Number 2011-8 Civil Term NOTICE OF SHERIFF'S SALE OF REAL PROPERTY To: Brian Morrow 350 Penn Street Carlis e, Pennsylvania 17013 Your Sheriffs Sale i Cumberland C of $73,498.29 Asset-Backed Donna Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 )use (real estate) at 350 West Penn Street, Carlisle, Pennsylvania 17013 is scheduled to be sold at June 1, 2011 at 10:00 a.m. in the Commissioner's Hearing Room located on the 2nd Floor of the my Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013 to enforce the court judgment stained by Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., ss-Through Certificates, Series 2005-W3 against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this 2. s Sale you must take immediate action: The sale will be canceled if you pay to Deutsche Bank National Trust Company, as Trustee for Argent Securities Inc., Asset-Backed Pass-Through Certificates, Series 2005-W3 the back payments, late charges, costs, and reasonable attorney's fees due. To find out how much you must pay, you may call McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need a attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sal q. (See the following notice on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling McCabe, Weisberg and Conway, P.C., Esquire at (215) 790-1010. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due on the sale. To find out if this has happened, you may call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. 4. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your real estate. A schedule of distribution of the money bid for your real estate will be filed by the Sheriff within thirty (30) days of the sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed schedule of distribution is wrong) are filed with the Sheriff within ten (10) days after the posting of the schedule of distribution. 7. You may also have other rights and defenses, or ways of getting your real estate back, if you act immediately after the sale. 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 Y U 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 ASSOCIATION DE LICENCIDADOS Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (800) 990-9108 LEGAL DESCRIPTION All that certain tract of Land with the improvements thereon erected situate in the fourth (4th) Ward of the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a point, said point being a 1/4 inch drill hole 6 feet South of the Southern curb line of West Penn 'treet and 209.85 feet East of the Eastern line of Franklin Street; thence along Lands now or for erly of William D. Shultz, South 15 degrees 58 minutes West 120.00 feet to a stake On the Northern side of a 12 foot wide public alley; thence along the Northern side of said public alley North 14 degrees 00 minutes West 44.83 feet to a stake; thence North 15 degrees 58 minutes Ea, t 120.00 feet through the partition wall of a concrete block garage and the partition wall of 350 West Penn Street and 352 West Penn Street to a 1/4 inch drill hole, said drill hole located 6 feet South of the Southern curb line of West Penn Street and 165.02 feet East of the Eastern side of Franklin Street thence South 74 degrees 00 minutes East 44.83 feet to a 1/4 inch drill hole, t1 e place of beginning. Tax Id No: 05-20-1798-212 350 West Peno Street, Carlisle, Pennsylvania 17013. BEING the sa e premises which RONALD L. MORROW AND LORETTA A. MORROW, HIS WIFE by deed dated May 31, 1996 and recorded June 10, 1996 in the office of the Recorder in and for Cumberland County in Deed Book 140, Page 731, granted and conveyed to Brian Morrow and Donna Morrow, husband and wife, in fee. FAX MAP P NRCEL NUMBER: 05-20-1798-212 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N011-8 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THEjSHERIFF OF CUMBERLAND COUNTY: To s itisfy the debt, interest and costs due DEUTSCHE BANK NATIONAL TRUST COMPANY Plaintiff ?(s) From RIAN MORROW and DONNA MORROW (1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or oth rwise disposing thereof, (3) If pr perty of the defendant(s) not levied upon an subject to attachment is found in the possession of anyon other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount I ue $73,498.29 Interest FROM 02/09/2011 - - $1,365.04 AT $12.08 Atty's Comm % Atty Paid $181.90 Plaintiff aid Date: 2/23/11 (Seal) REQUES Name: TI Address: 1 Attorney Supreme ( L.L.$.50 Due Prothy $2.00 Other Costs -i)? ?- .14a4?'L David D. ell, Prothonuta Deputy FING PARTY: RRENCE J. MCCABE, ESQUIRE ?ICCABE, WEISBERG AND CONWAY 23 S. BROAD STREET, SUITE 2080 'HILADELPHIA, PA 19109 Dr: PLAINTIFF 215-790-1010 'ourt ID No. 16496 TRUE COPY FROM RECORD In Testimony wtwea, I here unto set my hand and the seal of saki at Carlisle. Pa. This.&3-day of?? 20 -L Prothonotary On March 3, 2011 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA, Known and numbered as, 350 West Penn Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 3, 2011 By: Real Estate-Coordinator CUMBERLAND LAW JOURNAL Writ *o. 2011-8 Civil Deuts a Bank National Trust Company VS. Do na L. Morrow Brian M. Morrow Atty.: errance McCabe All that c rtain tract of Land with the improvements thereon erected situate in fourth (4th) Ward of the Borough f Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: Beginning at a point, said point being a 1/4 inch drill hole 6 feet South of the Southern curb line of West Penn Street and 209.85 feet East of the astern line of Franklin Street; thence along Lands now or formerly of William D. Shultz, South 15 degrees 5 minutes West 120.00 feet to a stak On the Northern side of a 12 foot 'de public alley; thence along the Nor ern side of said public alley North 4 degrees 00 minutes West 44.83 et to a stake; thence North 15 de rees 58 minutes East 120.00 feet hrough the partition wall of a concrete block garage and the partition all of 350 West Penn Street and 352 West Penn Street to a 1/4 inch d fill hole, said drill hole located 6 feet South of the Southern curb line of West Penn Street and 165.02 feet East of the Eastern side of Franklin Street thence South 74 degrees 00 minutes East 44.83 feet to a 1/4 inch drill hole, the place of Being kno as 350 West Penn Street, Carlisl , Pennsylvania 17013. BEING the same premises which RONALD L. MORROW AND LORETTA A. MORROW, HIS WIFE by deed dated May 3 , 1996 and recorded June 10, 19 6 in the office of the Recorder in and for Cumberland County in Deed Book 140, Page 731, granted and conveyed to Brian Mor- row and Donna Morrow, husband and wife, in f e. TAX MAP PARCEL NUMBER: 05- 20-1798-212. 57 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMO WEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND : Lis Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a 1 -.gal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical or the publication of all legal notices, and has, since January 2, 1952, been regularly issued wee ly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on he following dates, viz: April 22, April 29, and May 6, 2011 Af ant further deposes that he is authorized to verify this statement by the Cumberland Law Journ1, a legal periodical of general circulation, and that he is not interested in the subject matter oft the aforesaid notice or advertisement, and that all allegations in the foregoing statements is to time, place and character of publication are true. isa Marie Coyne, ditor SWORN TO AND SUBSCRIBED before me this 6 da of Ma 2011 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The.Patriot-News Co. the atn"ot?Xtws - 2020 Technology'Pkwy Suite 300 Now you know Mechanicsburg, PA 17050 Inquiries - 717455-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE II CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, bein? duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Penn ylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspaper of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patri t-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed otice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested i the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board f directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County o Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION C?PY This ad ran on the date(s) shown below: 04/22/11 04/29/11 05106/11 :. c .?........... Sworn tq-dnn subscribe ore rrle this'i ?ay',of May, 2011 A.D. Notary Pub i " COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Kisner, Notary Public Lower Paxton Twp., Dauphin County My Commission E)"es Nov. 26, 2011 Member, Penns*anla Association of Notaries Al tltar ° e of rand ffie 'MP**Oftf thereon erected "'n"te in ft futth (4th) Ward of the' of ciftle, Cumbertaad bounded and C?? as at Um" a POA PO, ? geJp.t 1/4 inch dry hole 6 feet Smjh bf he ? onthezn curb he of West Penn sheet. and 309,8r, feet East of the Ea9tearn line of Frapklin Street; thedtce nto?l;t?r-or formerly of Wilham D. , S 15+kpees 58 minutes West 126.00 feet to a 4falce On the Northern side o'0' U foot alley; tWgee 41wdd pub mlq i"th J4 4wm 00 minutes West 44,83 feet to a stgkc, tim= North 15 $8mb*tCsFA4 M00*t.*QU h the ire w411 tff a wamte Of A *Q-h n *Oct , liyoo sm w it a 1/4 Ss ket *kw of Nest Peen ?gRt..?pd ?.? met o'? to fie, , 0 '4 Sow East 44 • 74 *Fae? 06 minutes imct to a 1/4 inch hofC, ilic ? ?J?g ka? * ffi4 p West Penn a _ 17013. c:onnty io 17epd 140, 1 gd tbl?titt tnlf wo McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 SCOTT T. TAGGART, ESQUIRE - ID # 86862 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 BRIAN T. LAMANNA, ESQUIRE - ID# 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, As Trustee For Argent Securities Inc., Asset-backed Pass-throu, Plaintiff, V. Brian Morrow and Donna Morrow, Defendants. Attorney for Plaintiff cT C-1 ' i MrD C r- -0 n Ltd ?,. f:j-T7 C-) F =c.) J r CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 2011-8 Civil Term PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate, upon payment of your costs only, the default judgment entered in the above-captioned matter against defendant(s) BRIAN MORROW and DONNA MORROW on February 23, 201 1. This praecipe to vacate is filed without prejudice to plaintiffs rights in this matter and is without prejudice to plaintiffs right of recovery against defendant(s) on the underlying obligation. DATE: July 18, 2011 Christine L. Graham, Es uire Attorney for Plaintiff #&00 PD ATh/ C?1y?9?f(o McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID #74770 MARISA J. COHEN, ESQUIRE - ID # 87830 KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 BRIAN T. LAMANNA, ESQUIRE - ID# 310321 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, As Trustee For Argent Securities Inc., Asset-backed Pass-throu, Plaintiff, Brian Morrow and Donna Morrow, Defendants. CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 2011-8 Civil Term PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter as Discontinued and Ended, without prejudice, upon payment of your costs only. Cristine L. Graham, Esquire ATTORNEY FOR PLAINTI F Attorney for Plaintiff r? m --4 t n „ ? Z = N-- r _ -ti [/) -G N - ) r" _-4G:2 z -n ss :.:--rt c_- ?p 7:) McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 Attorney for Plaintiff r EDWARD D. CONWAY, ESQUIRE - ID # 34687 o MARGARET GAIRO, ESQUIRE - ID # 34419 -p3 - -q ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 ZM HEIDI R. SPIVAK, ESQUIRE - ID #74770 N MARISA J. COHEN, ESQUIRE - ID # 87830 -< r -- (:D SCOTT T. TAGGART, ESQUIRE - ID # 86862 r-:z -- c) KEVIN T. MCQUAIL, ESQUIRE - ID # 307169 vC-) C:3 _Tj CHRISTINE L. GRAHAM, ESQUIRE - ID# 309480 -- s BRIAN T. LAMANNA, ESQUIRE - ID# 310321 - s 123 South Broad Street, Suite 2080 Philadelphia, Pennsylvania 19109 (215) 790-1010 Deutsche Bank National Trust Company, As Trustee For Argent Securities Inc., Asset-backed Pass-throu, Plaintiff, V. Brian Morrow and Donna Morrow, Defendants. CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 2011-8 Civil Term CERTIFICATE OF SERVICE 1, Christine L. Graham, Esquire, Attorney for Plaintiff, hereby certifies that a true and correct copy of the within Praecipe to Discontinue and End, as well as Praecipe to Vacate Judgment, was served on the below person(s) by regular first class mail, postage prepaid, on 18th day of July, 2011. Brian Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 Donna Morrow 350 W Penn Street Carlisle, Pennsylvania 17013 DATE: July 18, 2011 C ristine L. Graham, squ e Attorney for Plaintiff