HomeMy WebLinkAbout04-3972GOLDBECK M¢CAFFERTY & McKEEVER
BY: JOSEPH A. GOLDBECK, JR.
ATTORNEY I.D. #16132
S4~ITE 5000 - MELLON INDEPENDENCE CENTER.
701 MARKET STREET
PHILADELPHIA, PA 19106
(215) 627-1322
ATTORNEY FOR PLAINTIFF
COUNTRYWIDE HOME LOANS 1NC.
7105 Corporate Drive
PTX B-35
Plano, TX 75024-3632
Plaintiff
VS.
DEBORAH J. PREDMORE
DAVID E. SNYDER
Mortgagor(s) and Real Owner(s)
205 North 25th Street
Camp Hill, PA 17011 CIVIL ACTION: MORTGAGE
Defendant(s) FO~CLO~t,j{i~~
THIS FIRM IS A DEBT COLLECTOR AND V~rE ARE ATTEMPTINGTO COLLECT
A DEBT GYVED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU
V~I-LL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
1N THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
ACTION OF MORTGAGE FORECLOSURE
You have been sued in courl If you wish to defend against the claims set forth in the following pages, you must take action within iwenty (20) days after the Complatht and notice
are sen,ed, by entermg a written appearance personally or 0y attorney and filing in writing with the court your dethnses or objections lo the claims set tbrth against you. You are warned that if
you fail to do so the case may proceed without you mid a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim
or relic f requested by the plathti~ You may fase money or properly or other rlghts important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A1 ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO 10 OR TELEPHONE
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.
LEGAL SERVICES INC
8 Irvlne Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS. ES ABSOLUTAMENTE NECESSARIO QUE
USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU
ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PIJNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUF~IAS EN ESIA DEMANDA.
RECUERDE: SI USTED NO REPONDE A ESTA DEMAND& SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PGEDE.
SIN NOTIFICARIO. DEC1D1R A FAVOR DEL DEMANDANTE Y REQUERIR~ QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE
ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DI[NERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVA R I~STE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR IELEFONO LA OFICINA FIJADA
AQUI ABA JO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEER[~ INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER
SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013
717-243-9400
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff is COUNTRYWIDE HOME LOANS INC., 7105 Corporate Drive, PTX B-35 Piano, TX
75024-3632.
The name(s) and address(es) of the Defendant(s) is/are DEBORAH J. PREDMORE, 205 North 25th
Street, Camp Hill, PA 17011-3611 and DAVID E. SNYDER, 205 North 25th Street, Camp Hill, PA
17011-3611, who is/are the mortgagor(s) and real owner(s) of the mortgaged premises hereinafter
described.
On October 25, 1999 mortgagor(s) made, executed and delivered a mortgage upon the premises
hereinafter described to COUNTRYWIDE HOME LOANS INC., which mortgage is recorded in the
Office of the Recorder of Deeds of Cumberland County as Book: 1579 Page: 423. The mortgage has
not been assigned unless said assignment to the Plaintiffis hereafter mentioned. These documents are
matters of public record and are incorporated herein by reference in accordance with Pennsylvania Rule
of Civil Procedure 1019(g).
The premises subject to said mortgage is described as attached.
The mortgage is in default because monthly payment of principal and interest upon said mortgage due
April 01, 2004, and each month thereafter are due and unpaid, and by the terms of said mortgage, upon
default in such payments for a period ofnne 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 fi.om 03/01/2004
through 08/31/2004 at 7.7500%
Per Diem interest rate at $31.74
Attorney's Fee at 5.0% of Principal Balance
Late Charges from 04/01/2004 to 08/31/2004
Monthly late charge amount at $55.99
Costs of suit and Title Search
Monthly Escrow amount $358.25
$149,518.59
$5,840.15
$7,475.93
$279.95
$900.00
$164,014,62
$164,014.62
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.
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 Plaintiffhas 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 an in rem judgment in mortgage foreclosure in the sum of $164,014.62,
together with interest at the rate of $31.74, 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.
B~./. JOSEPH ~. GOLDBECK, JR., ESQUIRE
ATTORNEY FOR PLAINTIFF
VERIFICATION
I, Michael D. Vestal, as the representative of the Plaintiff corporation within named do
hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff
corporation and the facts set forth in the foregoing Complaint are tree and correct to the best of my
knowledge, information and belief. I understand that false statements therein are made subject to the
penalties of 18 Pa. C.S. 4904 relating to unswom falsification to authorities.
Date: ~ ~ [ 0 --0 7
Michael D. Vestal
COUNTRYWIDE HOME LOANS INC.
L¢o~,l Dcscrivlion: (As shown on Morto'a~,c)
ALL THAT CERTAIN TRACT OR PARCEL OF LAND AND PREMISES, SITUATE, LYING AND BEING IN THE
BOROUGH OF CAMP HILL, IN THE COUNTY OF CUMBERLAND, AND COMMONWEALTH OF PENNSYLVANIA,
MORE PARTICULARLY DESCRIBED AS FOLLOWS:
BEGINNING AT THE CORNER FORMED BY THE INTERSECTION OF THE NORTHERN LINE OF LOGAN STREET
WITH THE EASTERN LINE OF TWENTY-FIFTH STREET, FORMERLY LOCUST STREET; THENCE IN A
NORTHERLY DIRECTION ALONG THE EASTERN LINE OF TWENTY-FIFTH STREET NINETY (90) FEET TO A
POINT ON THE LINE OF LANDS NOW OR FORMERLY OF WALTER F. DEISSLER AND SYLVIA G. DEISSLEB. HIS
WIFE; THENCE iN AN EASTERLY DIRECTION ALONG SAID LINE ONE HUNDRED FORTY (140) FEET TO ST.
· IOHN;S ALLEY; THENCE IN A SOUTHERLY DIRECTION ALONG ST. JOHN'S ALLEY NINETY (90) FEET TO
LOGAN STREET; THENCE IN A WESTERLY DIRECTION ALONG THE NORTHERN LINE OF LOGAN STREET
ONE HUNDRED FORTY (140) FEET TO THE POINT OR PLACE OF BEGINNING.
BEING PORTIONS OF LOTS NOS. I, 2, 3, 4, 5, 6, AND 7, SECTION '~E", ON THE PLAN OF LOTS KNOWN AS PLAN
NO. 2, FIRST ADDITION TO THE BOROUGH OF CAMP HILL, LA[I) OUT AND ADOPTED BY ARTHUR B. RUPLEY
AND CALEB Bo BRINTON, SAID PLAN BEING RECORDED IN THE CUMBERLAND COUNTY RECORDER'S OFFICE
iN PLAN BOOI~ NO. I, PAGE $.
~Countrywide'
HOHE LOANS
June 2, 2004
David E Snyder
205 Nodh 25th Street
Camp Hill, PA 17011-0000
Certified Mall No.
Return Receipt Requested
Regular Mail
Account NO.: 645567
Property Address:
2D5 North 25th Street
Camp Hill, PA
Current Servleer:
Count~jwide Home Loans Servicing LP
ACT 91 NOTICE
_TAKE ACTION TO SAVE
EXHIBIT A
YOUR HOME FROM
FORECLOSURE
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
Q00~45567900000454622000454622
~Counbywide~
P,O, Box 10221
Van Nuy~, CA 91410-0£21
June 2, 2004
Deborah J Predmore
205 North 25th Street
Camp Hill, PA 17011-0000
Codified Mail No.
Return Receipt Requested
Regular Mail
Account No.: 645567
Property Address:
205 No~th 25th Street
Camp Hill. PA
Current Servicer:
Count~/wide Home Loans Servicing LP
ACT 91 NOTICE
TAKE ACTION TO SAVE
YOUR HOME FROM
FORECLOSURE
This la an official i~oflce that the mortoaqe on vour home is in default, and the lender intends tp foreGIoee.
Soeet fie information about the nature Df the default la provided in the attached Daoe~.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM gHEMAP) may be able to held to save
your home. This Notice exoletns how the~oreeram worlra.
To see if HEMAP can helD. you must MEET WITH A CONSUMER CREDIT COUNEELING AGENCY WITHIN 30
DAYS OF THE DATE OF THIS NOTICE. Take this Noitca with you when you meet with the Caucaeltoq Acancv.
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.
Countrywide
P,O. Box 6606~4
000~4~567~000D045462200045462~
TEMPORARy STAY OF FORECLOSURI[ - Under the Act, you are entttiod to a tempora~j stay of foreclosure on your
mortgage for thirty-five (35) days from the date of this Notice. During that time you must arrange and attend = "face-to-
face" meeting with one of the consumer credit counseliog agencies listed at the end of. this Notice. THIS MEETING
MUST OCCUR WITHIN THE NEXT (3~} DAY.~ iF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE
ASSISTANCE, YOU MUST BRING YOUR MORTGAGE UP TO EiATE. THE PART OF THIS NOTICE CALLED 'HOW
TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO!DATE.
CONSUMER CREDIT COUNSELING AGENCIES - ff you meet with one of the consumer credit counseling agencies
risted at the end of this notice, the lender may NOT take action against you for thirty.five (35) days after the date of this
meeting. The names, addresses and teleshona numbers of designated c~nsumer credit counselled a~enaise for the
co_untv in which the nroperb/is lOCated ere set forth at the end of this Notice. It is on~y necesean/to schedule one face-to-
face meeting. Advise your lender immedisteiv of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage Js in dofautt for the reasons set fodh later in this
Notice (see following pages for specific information about the nature of your default.) E you have tded and are unable to
resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's
Emergency Mortgage Aseistanse program. To do so, you must fili out, sign and file a completed Homeowner's
Emergensy 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 IMUST be filed or
postmarked within thirty-five (35) days of your face-to-face meeting.
YOU MUST PILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE
OTHER TIME PERIODS SET FORTH IN TI-IlS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME
IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL SE DENIED.
AGENCY ACTION - Available funds for emergency mortgage assistance are ve:y limited. They wi!~ be disbursed by the
Agency under the aiigioility criteria established by the Act. The Pennsylvania Housing Finance Agency las sixty (60) days
to make a decision after it receives your application. During that time, no foreclosdre proceedings will be pursued against
you it you have met the time requirements set forth above. You wilt be notified directly by the Pent~-yk, ania Housing
Finance Agency of its decision on your aapl~cstion.
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 A~ AN A'I'fEMP'r TO COLLECT THE DEBT,
(If you have filed ~ankruptcy you can still apply for Emergency Mortgage AssistanCe.)
NOTICE OF INTENT TO FORECLOSE
~OUR HOME LOAN IS IN DEFAULT FOR THE REASONS SET FORTH IN THIS NOTICE.
YOU MUST TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE
NATURE OF THE DEFAULT - Countrv~lde Home Leans Se~ylcln~l LP. (hereinafter "COUrer~wide") services your
home loan. Your home loan is in serious default because you have cot made your required payments. The total amcunt
cow required to reinstafe yot~ home I~n as of the date of this letter is as follows:
Monthiv Payments: 1,478.08 $4,434.24
Late Charees: 55.99 111.98
Other Charses: Uncollected Late Charges: .00
HOW TO CURE THE DEFAULT- Y~u may cure this default within THIRTY-FIVE (35) DAYS of the date et this letter, by
paying to us the above amount of $4,546.22, pies any eddifione] month;,/ payments, late charges, fees and other
epplisable charges which may fail due during this period. Such p~y/nent must be in the form of ueitified check, cashier's
check or money order, and made payable to Countrywide at P.O. Box 660654, Dallas, TX 75266-0694. If your check er
other payment is returned to us for insufficient funds or for any other reason, you will not have cured your defau~. No
extension of time to cure w~ll be granted due to a returned payment.
If you da not cure this default within THIRTY-FIVE (35) DAYS, we wilt aocelarete the payments doe-os your home loan.
This means whatever is owing on the original amount borrowed w~lt be considered due immediefely and you may ~sa the
chance to pay off your home loan in monthly installments, if the full payment of the amount in dotauit is not made within
THIRTY-FIVE (35) DAYS, we also intend to immediataiy start a lawsu'~'to foreciosa on your mortgaged proparty.
IF THE MORTGAGE IS FORECLOSED UPON - if the rcoitgage is foreclosed, the mortgaged propedy wi[; be sold by
the Sheriff to pay off the mortgage debt. If the default is cured before we begio legal proceedings, Countrywide will be
entitled to collect the rsasonab]e attorney's fees actually inCurred, up to $5~).00. However, if legal proceedings are
started, Countrywide will ba entitled to collect the reesor~ablo attorney's fees even if they are over $50.00. Any attorney's
fees will be added to the secured debt, which may also include our reasecable costs, ff you cure the default within the
THIRTY-FIVE (35) DAY period, you will not be required to pay attorney's fees. YOU HAVE THE RIGHT TO
REINSTATE AFTER ACCELERATION AND RIGHT TO ASSERT IN THE FORECLOSURE PROCEEDING THE
NON-EXISTENCE OF A DEFAULT OR ANY O;I'HER DEFENSE YOU MAY HAVE TO ACCELERATION AND
FORECLOSURE.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid pflncipel balance ansi all Other
sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO EORECLGS[.[RE_SALE - If you have ~ot cured the default within the
THIRTY-FIVE (35) DAY peded and fel~solosure proceedings have begun, you still have the dght to cure the default and
prevent the es~e at any time up to one Imur before the foreclosure sale. You may do so by paying the total amount then
past due, plus any late or other charges then due, reesonabis attorney's fees and costs conoected with the foreclosure
sale and any other costs connected with the foreclosure sale as specified in w~lng by the lender and by pertorming any
other requirements under the mortgage. Curing your default in the manner set forth irt this notice will restore your
mortgage to the same position as if you had never defaulted.
EARIJE,~T POSSIBLE FORECLOSURE SALE DATE - it is estimated that the eadlect date that a foreclosure sale
could be held would be appr~xirnately six (6} months from the date of this letter. A notice of the date of the foreclosure
sale will be sent to you before the sale, You may find out at any time exactly what the required peymect will be by cefling
us at the following number; 1-800-569-6654. This payment must be in tho form of a cashier's check, certified check or
money order and mede peyote to os at the address stated above. If the default is cured, the mortgage will be restored
to the same pusltlot~ as if no default had occurred, However, the defauif may net be cured more than three (3) times in
any calendar year.
HOW TO CONTACT THE LENDER:
Name of Le~ler: Coun~yv/Ide Home LOans Servicing LP
.~ddre~s: P. O. J~ox 10221 Dalla~ ~X 914100221
t~SSUMPTION OF MORTGAGE - Contact Countrywide ~lome Loans for information on the possible asoumab~lty of
If you are unable to cure your default on or before July 7, 2004, Countrywide wants you to be aware,of various options
that may be available to you through Countrywide to prevent a foreclosure sala of your propsrty. For example:
· Reoovment Plan: It is poosibla tpat you may be eligible for some form of payment assistance through Countrywide.
Our bes~c plan requires that Countrywide receive, up front, at laas~ ~ of the amount necessary to bring the account
current, and that the balance of the overdue amount he paid, along with the regular monthJy payment, over a defined
period of time. Other repayment plans aJso ere available.
Lean Medifisatioe: Alternatively, it is passible that the regular monthly payments can be lowered t~rough a
modificatiorl of the loon by reducing the interest rate and then adding the delinquent payments to the current loan
balance. Thisforeciosureal~ernative, however, tslinlifed to cer~aioidantybes.
Sale of Your Properly: Alternatively, if yo~ are wfllidg to sell your home in order to avoid foreclosure, it is possible that
the ~ala of your home can be approved through Countrywide even if your home is worth less t~an what is owed on if.
Deed-in-Lieu: Aitersaifvely, if your property is free from other liens er encumbrances, and if the default is due to a
serious financial hardship which is beyond your control, you may be eligible to deed your properly direst~y to the
Nateholder and avoid the fo~cidsure sale.
If you are interested in discussing foreclosure alternatives with Countrywide, you must cort~nt us immediataly, if you
request assistance, Countrywide will determine, in its sole discretion, whether such assistance will be extended to you. In
the meantime, Countrywide wilt pursue all of its fights and remedies under the home loan documents and as permitted by
law, unless it agrees 01herwisa in writing. Prsase be advised that failure to bitng the home lean current or to enter into a
written agreement as o~ioed above will result in the acoolerafion of the debt.
Time is of the essence. Should you hav~ any questions concerning this notice, please contact C(~untrywide's off[ce
Immsdiatal¥ at 1-800-669-6654, extension .
Sasha Roche
Loon Counse~)r
1-800-669-(~654, extension
Please be advised that this communication is from a debt soltecter.
SiHERIFF' S RETURN -
CASE NO: 2004-03972 P
COMMONWEA~LTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNRYWIDE HOME LOANS INC
VS
PREDMORE DEBORAH J ET AL,
REGULAR
SHA/qNON SHERTZER ,
Cumberland County, Pennsylvania,
says, the within COMPLAINT - MORT FORE
SNYDER DAVID E
DEFENDANT , at 1900:00 HOURS,
at 205 NORTH 25TH STREET
CAMP HILL, PA 17011
DAVID E. SNYDER
a true and attested copy of COMPLAINT
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 16th day of August , 2004
by handing to
- MORT FORE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 6.00
Service 11.10
Affidavit .00
Surcharge 10.00
.00
27.10
Sworn and Subscribed to before
me this 7~, ~ day of
~ A.D.
t hononary / -
So Answers:
R. Thomas Kline
o9/o3/2o04
GOLDBECKBy: MCC~Y~MC~
Deputy She~riff
SHERIFF'S RETURN - REGULAR
CASE NO: 2004-03972 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COUNRYWIDE HOME LOANS INC
VS
PREDMORE DEBORAH J ET AL.
DAVID MCKINNEY ,
Cumberland County, Pennsylvania,
says, the within COMPLAINT - MORT FORE
PREDMORE DEBOP~AH J
DEFENDANT , at 1920:00 HOURS,
at 2929 DICKINSON AVENGE
CAMP HILL, PA 17011
DEBORAH PREDMORE
a true and attested copy of COMPLAINT -
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 2nd day of September, 2004
by handing to
MORT FORE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 11.10
Affidavit .00
Surcharge 10.00
.00
39.10
Sworn and Subscribed to before
me this /~ ~ day of
Prothonotary '
So Answers:
R. Thomas Kline
09/03/2004
GOLDBECK MCCAFFERTY MCKEEVER
GOLDBECK McCAFFERTY & McKEEVER
BY: Joseph A. Goldbeck, Jr.
Attorney I.D. #16132
Suite 5000 Mellon Independence Center
701 Market Street
Philadelphia, PA 19106-1532
215-627-1322
^ttomey for Plaintiff
COUNTRYWIDE HOME LOANS INC.
7105 Corporate Drive
PTX B-35
Piano, TX 75024-3632
VS.
DEBORAH J. PREDMORE
DAVID E. SNYDER
(Mortgagor~s) and Record owner(s))
205 North 25th Street
Camp Hill, PA 17011
Plaintiff
IN THE COURT OF COMMON PLEAS
of Cumberland County
No. 04-3972
PRAECIPE TO SETTLE, DISCONTIN~ AND END
TO THE PROTHONOTARY:
Kindly mark the above case Settled, Discontinued
payment of your costs only.
JOSEPH A. GOLDBECK, JR.,
and Ended upon
ESQUIRE