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Home My WebLink About11-4356F ILED-U Ili'-- Martha E. Von Rosenstiel, P.C. Cdr T=ar P F" 0 H0, E' Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit #7 40 €1 M Y 16 AM 10: 3 7 Secane, PA 19018'UMBERL?1i'Ii GO(1fi 9 (610) 328-2887 PENNSYLVANIA Attorney I.D. #52634 WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP1, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP1 4600 Regent Blvd. Ste 200 Irving, TX 75603 Plaintiff V. ROSA LUCIDON AND JOHN LUCIDON OR OCCUPANTS 1910 Spring Road, Rear Unit Carlisle, PA 17013 Defendant(s) 27747-CFC-EM Attorney for Plaintiff : COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY / ?? 04V71 NO. CIVIL ACTION - EJECTMENT NOTICE ADVISO 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 ELEGIBLE PERSONS AT A REDUCED FEE OR NO FEE Le ban demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar 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 a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO . ESTA OFICINA LE PUEDE PROVEER INF'ORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 P Alqy t6i q02 MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP I, MORTGAGE PASS- THROUGH CERTIFICATES, SERIES 2004-OP1 4600 Regent Blvd. Ste 200 Irving, TX 75603 27747-CFC-EM : COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff V. : NO. ROSA LUCIDON AND JOHN LUCIDON OR OCCUPANTS 1910 Spring Road, Rear Unit Carlisle, PA 17013 Defendant(s) : CIVIL ACTION - EJECTMENT 1. Plaintiff, Wells Fargo Bank, N.A. as Trustee for SABR Trust 2004-OP I, Mortgage Pass-Through Certificates, Series 2004-OP 1, is the owner of premises known as 1910 Spring Road, Rear Unit, Carlisle, PA 17013, more fully described in the legal description, a true and correct copy is attached hereto, made part hereof and marked as Exhibit I. 2. Plaintiff claims title to the aforesaid property by virtue of a Sheriffs sale held on January 05, 2011, in the execution of a judgment in mortgage foreclosure obtained in the Court of Common Pleas of Cumberland County, Docket No. 2006-2390 where Plaintiff was the successful bidder. 3. The Plaintiff became the owner of the said property by a sheriff's deed recorded on January 27, 2011 in the Office of the Recorder of Cumberland County at Instrument No. 201103314. A true and correct copy is attached hereto, made part hereof and marked as Exhibit II. 4. Plaintiff, by virtue of the aforesaid title, is the owner in fee of the said premises, and is entitled to possession thereof. The Defendants Rosa Lucidon and John Lucidon or Occupants are occupying the said premises without right, and so far as the Plaintiff is informed, without claim of title. WHEREFORE, plaintiff demands judgment for possession of 1910 Spring Road, Rear Unit, Carlisle, PA 17013. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. a E. Von Rosenstiel, squ e BYJacqueline _ F. McNally, Esquire Attorneys for Plaintiff VERIFICATION I verify that the statements made in the foregoing documents are true and correct and are matters of public record. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unworn falsification to authorities. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, P.C. BIAttorneeys a E. Von Rosenstiel, sq re acqueline F. McNally, Esquire for Plaintiff Dated: May 11, 2011 EXHIBIT I ALL THOSE TWO CERTAIN TRACTS OF LAND, TOGETHER WITH IMPROVEMENTS THEREON, ERECTED SITUATE IN NORTH MIDDLETON TOWNSHIP, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULAfRY BOUNDED AND DESCRIBED AS FOLLOWS; TRACT NO. I BEGINNING AT A POINT IN THE CENTER OF PENNSYLVANIA STATE HIGHWAY RATE. No. 34 LEADING FROM THE BOROUGH OF CARLISLE TOTHE BOROUGH OF NEW BLOOMFIELD, WHICH POINT 1s IN THE NORTHERN LINE OF CARLISLE AVENUE {lh"tACH STREET LOCATED HAS BEEN CHANGED AND M NOW CALLED WAGNER STREET, AS INDICATED ON THE PLAN OF LOTS ADOPTED BY GEORGE H. SCHfLLSSER AND DESIGNATED AS PLAN NO.1 OF SCHLUSSER VILLAGE, SAID PLAN BEING RECORDED IN THE OFFICE OF THE RECORDER OF DEEDS IN AND FOR CUMBERLAND COUNTY, PENNSYLVA144k IN PLAN BOOK 7; PAGE S. TINGE ALONG THE NORTHERN SIDE OF SAID CARLISLE. AVENUE, NORTH 84 DEGREES AS MINUTES WIEST, A DISTANCE OF 132.8 FEET TO A POINT IN LINE, OF LAND NOW OR FORMERLY OF GEORGE H: SCHLU4SSER; THENCE ALONG SAID LAN D$ NOW OR FORMERLY OF GEORGE H. SCHLUSSER, NORTH 5 DEGREES 15 MINUTES EAST, A DISTANCE OF 258.5 FEET TO A POINT IN LINE OF LOT NO.6 ON THE SAID PLAN OF LOTS. THENCE ALONG SAID LOT NO. B, SOUTH 94 DEGREES 45 MINUTES EAST, A DISTANCE OF 1'52.8 FEET' TO A POINT IN THE CENTER OF THE. AFORESAID PENNSYLVANIA STATE HIGHWAY ROUTE 34; THENCE ALONG THE CENTER OF SAID PENNSYLVANIA STATE HIGh1WAY ROUTE NO. 34, SOUTH 5 DEGREES 15 MINUTES WEST, A DISTANCE OF 255,5 FEET TO A POINT. THE PLACE OF BEGINNING. HAVING THEREON ERECTED A TW04TORY FRAM DWELLING HOUSE AND CONCRETE BLOCK GARAGE KNOWN AND NUMBERED AS 1010 SPITING ROAD, CARLISLE. PENNSYLVANIA. TRACT 40. 2 ON THE NORTH BY TRACT Na 1 ABOVE DESCRIBED; ON THE EAST BY THE CARLISLE-NEW BLOOMF IELD ROAD {KNOWN AS PENNSYLVANIA ROUTE; NO, 341; ON THE SOUTH BY WAGNER STREET AS SHOWN ON THE REVISED PUN OF FRY AVENUE LOTS ON PLAN NO..4 OF SCHLUSSER VILLAGE, WHICH PLAN IS RECORDED IN THE SAID RECORDERS OFFICE IN PLAN BOOK 7, PAGE 47; AND ON THE WEST BY LOT NOS.. 67 AND 68 AS SHOWN ON RAID REVISED PLAN OF FRY A'V'ENUE LOTS,. BEING A PORTION OF LOT NO.4 AND PART OF THE FORMER. CARLISLE AVENUE IERRO USLY SAID IN PRIOR DEED BE PART OF LOT NO. 5) AS SHOWN ON PLAN NO.1 OF SCHWSSER VI LLAGE. WHICH PLAN IS RECORDED IN THE SAO RECORDER'S OFRCE IN KAN BOOK 7, PAGE 5. CONTAINI IO * FEET MORE OR LESS, IN FRONT ON BAK) ROUTE NO. 34 AND EXTENDING IN DEPTH AT AN INCREASING WIDTH OF ISO FEET, MORE OR LESS. AND HAVING A WIDTH IN THE REAR OF 55 FEET. MORE OR LESS. THE ABOVE TWO LOTS OF GROUND ARE CONVEYED SUBJECT TO THE BUI LDING AND OTHER RESTRICTIONS AS SHOWN ON SAID PLAN OF LOTS RECOTRI ED AS AFORESAID, BEING KNOWN A3; 1910 SptkV Roo Carlisle, PA 17013 PROPERTY O NO-? 29.16.1094.241 TITLE TO SAID PREMISES IS VESTED IN .II**4 LUCIDON AND ROSE MARIA LUCISON. HUSBAN13 AND WIFE SY DEED FROM LEON C, MORRISON AND.IEANNETTE MORRISON, HUSBAND AND WIFE DATED 11113t2om RECD ROW I V1812003 IN DEED BDOX 200 PAGE 2040. AND BEING the same premises which were sold to WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP1, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP 1, as Trustee by the Sheriff of CUMBERLAND County on January 05, 2011 in execution of a judgment in mortgage foreclosure entered in the Court of Common Pleas of CUMBERLAND County Docket No. 2006-2390. w MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff WELLS FARGO BANK, N.A. AS TRUSTEE : FOR SABR TRUST 2004-OP I, MORTGAGE : PASS-THROUGH CERTIFICATES, SERIES : 2004-OP 1 : 4600 REGENT BLVD. STE 200 IRVING TX 75603 : PLAINTIFF vs. ROSA LUCIDON OR OCCUPANTS 1910 SPRING ROAD, REAR UNIT CARLISLE PA 17013 DEFENDANT(S) 27747CFJ-EM COURT OF COMMON PLEAS C-) c r CUMBERLAND COUNTY J= _ ? x rn c c r? ` w ° _<v --, --tca CASE NO: 11-4356 CIVIL ?? ?' - PRAECIPE TO ENTER JUDGMENT TO THE PROTHONOTARY: Enter judgment in the above captioned Ejectment action for failure of the above named defendants to file an answer within twenty days from date of service thereof. I hereby certify that Notice as provided in Rule 237.5 has been duly given, and that the time limits provided for in that notice have expired as evidenced by the attached Exhibit I. Property Address: 1910 SPRING ROAD, REAR UNIT CARLISLE PA 17013 Respectfully Submitted, MARTHA E. VONROSETIEL, P.C. N BY: Dated: June 2b, 2011 Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff shy. oo p .L lwy Gk d `lL sg A4"o9 N64`(_ ?.? 1 ied MARTHA E. VON ROSENSTIEL, P.C. Martha E. Von Rosenstiel, Esquire / No. 52634 Jacqueline F. McNally, Esquire / No. 201332 649 South Avenue, Suite 7 Secane, PA 19018 (610) 328-2887 Attorneys for Plaintiff WELLS FARGO BANK, N.A. AS TRUSTEE FOR COURT OF COMMON PLEAS SABR TRUST 2004-OP I, MORTGAGE PASS- CUMBERLAND COUNTY THROUGH CERTIFICATES, SERIES 2004-OP 1 PLAINTIFF VS. ROSA LUCIDON OR OCCUPANTS CASE NO: 11-4356 CIVIL 1910 SPRING ROAD, REAR UNIT CARLISLE, PA 17013 DEFENDANT TO: Rosa Lucidon or Occupants 1910 Spring Road, Rear Unit Carlisle, PA 17013 IMPORTANT NOTICE 27747CFJ-EM 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 YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A 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, PA 17013 717-249-3166 800-990-9108 Respectfully Submitted, MARTHA E. VON ROSENST 14L. P.C. BY: Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: June 07, 2011 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Court House, 1 Courthouse Square, Carlisle, PA 17013 , Prothonotary Rosa Lucidon or Occupants 1910 Spring Road, Rear Unit Carlisle, PA 17013 WELLS FARGO BANK, N.A. AS TRUSTEE : COURT OF COMMON PLEAS FOR SABR TRUST 2004-OP I, MORTGAGE : CUMBERLAND COUNTY PASS-THROUGH CERTIFICATES, SERIES : 2004-OP I PLAINTIFF VS. ROSA LUCIDON OR OCCUPANTS DEFENDANT(S) NO: 11-4356 CIVIL Notice Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment for possession has been entered against you in the above proceeding as indicated below: Prothonotary Q Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession Judgment on Award of Arbitration 0 Judgment on Court Findings If you have any questions concerning this notice, please call: Attorney Martha E. Von Rosenstiel, Esquire at this telephone number: 610-328-2887. 27747CFJ-EM Praecipe for Writ of Possession (Pa.R.C.P. 3160-3165) 27747CPG-EM COUNTY OF CUMBERLAND WELLS FARGO BANK, N.A: AS TRUSTEE FOR SABR TRUST COURT OF COMMON PLEAS 2004-OP1, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP1 DOCKET NO. 11-4356 CIVIL V. ROSA LUCIDON OR OCCUPANTS TO THE PROTHONOTARY: ATTORNEY I.D. #52634 _0 rn co ?r Cf7 ? G? ? r r, Kindly issue Writ of Possession in the above Ejectment matter. 1910 Spring Road, Rear Unit Carlisle, PA 17013 Respectfully Submitted, MARTHA E. VON ROS P.C. BY: MafEha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff 5yy.66 P y ttoor ybs" 1'7...00 cow B r t 4G.od it 11 00 a- Z7; f A Y ?a p? ?JuC,Co I lof 2 WRIT OF POSSESSION (Ejectment Proceedings PRCP3160-3165 etc.) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP I, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP 1 4600 REGENT BLVD. STE 200 IRVING, TX 75603 VS. No. 11-4356 Civil Term- ROSA LUCIDON OR OCCUPANTS 1910 SPRING ROAD, REAR UNIT CARLISLE, PA 17013 Costs Attorney's $ 196.00 Plaintiff's $ Prothonotary $ 2.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of Cumberland County, Pennsylvania (1) To satisfy the judgment for possession in the above matter you are directed to deliver possession of the following described property to: (Plaintiff (s)) WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP I, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP1 being: (Premises as follows): 1910 SPRING ROAD, REAR UNIT, CARLISLE, PA 17013 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defendant (s) and sell his/her (or their) interest therein. 15afid D. Buell, Prothonotary, Common Pleas Court of Cumberland Coun A Date JUNE 23, 2011 (Seal) 2 of 2 No 11-4356 Civil Term IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA WELLS FARGO BANK, N.A. AS TRUSTEE FOR SABR TRUST 2004-OP I, MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2004-OP1 Vs. ROSA LUCIDON OR OCCUPANTS WRIT OF POSSESSION P.R.C.P. 3160-3165 ETC. Costs Att'y $ 196.00 Plff (s) $ Prothy $ 2.00 Sheriff $ Plaintiff (s) attorney name and address: MARTHA E. VON ROSENSTIEL, ESQ. 649 SOUTH AVENUE, SUITE 7 SECANE, PA 19018 610-328-2887 ID #52634 Attorney for Plaintiff (s) By virtue of this writ, on the named appurtenances, and Where papers may be served day of I caused the within _, to have possession of the premises described with the Sworn and subscribed to before me this Day of , Prothonotary So Answers, Sheriff By Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Q ntp of cur!ngor/ 44 OFF CE OF THE SRERIFF FILED-OFFICE OF THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor Wells Fargo Bank NA vs. Rosa Lucidon (et al.) 1011 JUN 30 PM 3: 53 CUMBERLAND COUNTY PENNSYLVANIA Case Number 2011-4356 SHERIFF'S RETURN OF SERVICE 06/28/2011 05:06 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on MarcJune 28, 2011 at 1706 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Occupant(s), by making known unto Memina Catovic, occupant, at 1910 Spring Road, Rear Unit, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 06/29/2011 05:06 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Rosa Lucidon, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 1910 Spring Road, Rear Unit, North Middleton Township, Carlisle, PA 17013. SO ANSWERS, ))? June 29, 2011 RON R ANDERSON, SHERIFF .r Den s Fry, putt' Sheriff (c) CountySuite Shenfl, Telaosoft. Inc. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ,rr A C111ab"",4 17b FILED-OFF IC', Cat THE PROTWONOTA, `,' 2011 JUL 22 AM 8= 4 4 Richard W Stewart Solicitor OFFICE'' -- -?-.RIFF CUMBERLAND COUNT Y PENNSYLVANIA Wells Fargo Bank NA vs. Rosa Lucidon (et al.) Case Number 2011-4356 SHERIFF'S RETURN OF SERVICE 06128/2011 05:06 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on MarcJune 28, 2011 at 1706 hours, he served a true copy of the within writ of possession, in the above entitled action upon the within named defendant, to wit: Occupant(s), by making known unto Memina Catovic, occupant, at 1910 Spring Road, Rear Unit, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 06/29/2011 05:06 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Rosa Lucidon, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Writ of Possession as "Not Found" at 1910 Spring Road, Rear Unit, North Middleton Township, Carlisle, PA 17013. 07/21/2011 By virtue of this writ, Ronny R. Anderson, Sheriff caused the within named Plaintiff to have possession of the premises described as 1910 Spring Road, Rear Unit, Carlisle, PA 17013. Possession given to Ron Goldberg of Keller Williams Realty. SHERIFF COST: $82.44 SO ANSWERS, July 21, 2011 RON R ANDERSON, SHERIFF 50 LL few' j4'i L'ou^rySuitc Shenft. Tele?s?fi, li°rc:. 27747- CPG -EM (vacate) Martha E. Von Rosenstiel, P.C. Attorney for Plaintiff Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610 328-2887 Attorney I.D. # 52634 COURT OF COMMON PLEAS WELLS FARGO BANK, N.A. AS TRUSTEE : CUMBERLAND COUNTY FOR SABR TRUST 2004-OP1, MORTGAGE : PASS-THROUGH CERTIFICATES, SERIES : 2004-OP 1 NO: 11-4356 CIVIL PLAINTIFF c -5 - VS. ca XM M = cnr- ROSA LUCIDON OR OCCUPANTS DEFENDANTS ` X F; PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment in the above-referenced action. Respectfully Submitted, MARTHA E. VON ROSENSTIEL,V).C. BY, Martha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff Dated: August 29, 2011 48. oo PO A7 N at 4779a & 06641/5 27747- CPG -EM (disc & end) Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610 328-2887 Attorney I.D. # 52634 WELLS FARGO BANK, N.A. AS TRUSTEE : FOR SABR TRUST 2004-OP1, MORTGAGE : PASS-THROUGH CERTIFICATES, SERIES : 2004-OP I Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY NO: 11-4356 CIVIL PLAINTIFF VS. ROSA LUCIDON OR OCCUPANTS DEFENDANTS w 2 rn c.,2 ? -rJ rn '- ?? f ?rn r`? -moo D C-) D oM 7D PRAECIPE TO MARK CASE DISCONTINUED AND ENDED TO THE PROTHONOTARY: Kindly mark this action discontinued and ended without prejudice. Respectfully Submitted, MARTHA E. VON ROSENSTIEL, PI.C. rtha E. Von Rosenstiel, Esquire Jacqueline F. McNally, Esquire Attorneys for Plaintiff r. r Dated: August 29, 2011