HomeMy WebLinkAbout11-5329UDREN LAW OFFICES, P.C.
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
DANIEL S. SIEDMAN, ESQUIRE - ID #306534
HEATHER RILOFF, ESQUIRE - ID #309906
SHERNESE V. WOODBINE, ESQUIRE - ID#91209
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadings(a udren.com
OneWest Bank, FSB
C/O OneWest Bank, FSB
888 East Walnut Street
Pasadena, CA 91101
Plaintiff
V.
JOHN P. CASPER A/K/A JOHN F. CASPER
6343 NORTH POWDERHORN ROAD
MECHANICSBURG, PA 17055
MARY JANE S. CASPER
6343 NORTH POWDERHORN ROAD
MECHANICSBURG,, PA 17055
Defendant(s)
ATTORNEY FOR PLAINTIFF
COURT OF COMMON PLEAS -mac
CIVIL DIVISION xr'n rrnn__
CUMBERLAND County C^r -- 'ern
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COMPLAINT IN MORTGAGE FORECLOSURE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must take action within twenty (20) days after this Complaint and Notice
are served, by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the case may proceed without you and a judgment may be entered against you
by the Court without further notice for any money claimed in the Complaint or for any other
claim or relief requested by the Plaintiff. You may lose money or property or other rights
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY
BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT
MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FE "R
NO FEE. S
C_
ay
/a 71 y
LAWYERS REFERRAL SERVICE
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
AVISO
Le han 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 ascentar 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 dafiende, 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 provisiones de esta demanda. Usted
puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA
DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE
PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(800) 990-9108
NOTICE
The amount of your debt is as stated in the attached document. The name of the
creditor to whom the debt is owed is as named in the attached document. Unless you notify
us within 30 days after receipt of this Notice and the attached document that the validity of
the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If
you do notify us in writing of a dispute within the 30 day period, we will obtain verification
of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute
the debt, it is not an admission of liability on your part. Also, upon your written request
within the 30 day period, we will provide you with the name and address of the original
creditor if different from the current creditor.
If you notify us in writing within the 30 day period as stated above, we will cease
collection of your debt, or any disputed portion of it, until we obtain the information that
is required and mail it to you. Once we have mailed to you the required information, we
will then continue the collection of your debt.
This law firm is deemed to be a debt collector and this Notice and the attached document
is an attempt to collect a debt, and any information obtained will be used for that purpose.
UDREN LAW OFFICES, P.C.
/s/ Mark J. Udren, Esquire
Woodcrest Corporate Center
111 Woodcrest Road, Suite 200
Cherry Hill, NJ 08003-3620
(856) 669-5400
1. Plaintiff is the entity designated in the caption on a preceding page. Plaintiff is the
legal holder of the Mortgage that is the subject of this Action. Plaintiff is either the
current mortgagee of record, is the legal holder of the Mortgage by virtue of being
successor in interest to the current mortgagee of record, or is the legal holder of the
Mortgage by virtue of Assignment of Mortgage. If Plaintiff is the legal holder of the
Mortgage by virtue of Assignment of Mortgage, it is by the following Assignments of
Mortgage, all of which have either been recorded or Plaintiff is in the process of
formalizing the actual Assignment of Mortgage in Plaintiff s favor:
Assignor: First United Mortgage Services
Assignee: Howard Hanna Financial Services, Inc
Date of Assignment: 11/01/1993
Recorded Date: 11/15/1993
Book/Instrument #: 458
Page: 1149
Assignor: Howard Hanna Financial Services, Inc
Assignee: City Mortgage Corporation
Date of Assignment: 09/01/1994
Recorded Date: 09/22/1994
Book/Instrument #: 482
Page: 684
Assignor: City Mortgage Corporation
Assignee: Standard Mortgage Corporatio of Georgia
Date of Assignment: 05/27/1998
Recorded Date: 06/15/1998
Book/Instrument #: 579
Page: 399
Assignor: Standard Mortgage Corporatio of Georgia
Assignee: Indymac Bank, F.S.B., A Federally Chartered Savings Institution
Date of Assignment: 11/10/2003
Recorded Date: 12/08/2003
Book/Instrument #: 704
Page: 2643
Assignor: Indymac Bank, F.S.B., A Federally Chartered Savings Institution
Assignee: OneWest Bank, FSB
Date of Assignment: 11/18/2010
Recorded Date: 12/14/2010
Book/Instrument #: Instrument # 201036883
Page: n/a
2. Upon information and belief Defendant(s):
John P. Casper a/k/a John F. Casper and Mary Jane S. Casper
(hereinafter "Defendants"), are the owners of property located at 6343 North
Powderhorn Road, Mechanicsburg, PA 17055, by virtue of Deed dated 05/20/1991
and recorded 05/22/1991 in Official Records Book C-35 at Page 1096 of the Public
Records of Cumberland County, Pennsylvania (hereinafter the "Property").
3. On 11/01/1993, Defendant(s):
JOHN P. CASPER A/K/A JOHN F. CASPER AND
MARY JANE S. CASPER
promised to pay to the order of First United Mortgage Services, the principal
sum of $177,500.00 payable with interest thereon provided in the Note.
4. By Mortgage dated 11/01/1993, Defendant(s):
JOHN P. CASPER A/K/A JOHN F. CASPER AND
MARY JANE S. CASPER
to secure the Note, mortgaged to First United Mortgage Services, the Property
which is the subject of this action. The Mortgage was recorded on 11/15/1993 in
Official Records Book 1177 at Page 741. Said Mortgage is incorporated herein by
referenced in accordance with Pa.R.C.P 1019(g). A legal description of the
mortgage premises is attached hereto and made a part hereof.
5. Said mortgage is in default in that the payment due 03/01/2011, and all subsequent
payments have not been made, and by its terms, upon breach and failure to cure said
breach after notice, all sums secured by said Mortgage, together with the other charges
authorized by said Mortgage and itemized below, shall be immediately due.
6. After demand, the Defendant(s) continues to fail or refused to comply with the terms of
the Mortgage as follows:
(a) By failing or refusing to pay the installments of principal and interest when due in
the amounts indicated below;
(b) By failing or refusing to pay other charges, if any, indicated below.
The following amounts are due on the said Mortgage or modification agreement as of the
date stated below
Unpaid Principal Balance $113,904.72
Accumulated Interest $2,739.05
Accumulated Late Charges $174.90
Title Report $325.00
Attorney Fees- Estimated $1,300.00
NSF Charges $20.00
Grand Total $118,463.67
The above figures are calculated as of 06/07/2011:
The interest rate is subject to adjustment if more fully described as such in the note and
mortgage. The interest rate on the subject note is at 6.87500 %. The per diem interest accruing
on this debt is $21.45 and that sum should be added each day after the above date.
The late charge is subject to adjustment if more fully described as such in the note and
mortgage. The late charge rate on the subject note should be added in accordance to the terms of
the note and mortgage charged monthly at $58.30.
7. Breach letters have been sent to Defendant(s) in accordance with the requirements of the
subject mortgage, The Pennsylvania Act 6 of 1974 of the Commonwealth of
Pennsylvania and the Pennsylvania Homeowner's Emergency Mortgage Assistance
Program, Act 91 of 1983. Copies of the breach letters are attached hereto as Exhibit
"At'
WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the
sum of $118,463.67 plus ongoing interest, costs and attorneys fees and for sale of the Mortgaged
premises.
UDREN LAW OFFICES, P.C.
BY:-
Datiiel S'. ,a
PA IL) .10-6534
ALL THAT CERTAIN PARCEL KNOWN AS LOT NO. 60, PHASE 2, SECTION II,
HAMPDEN HEIGHTS, HAMPDEN TOWNSHIP, CUMBERLAND COUNTY,
PENNSYLVANIA, ACCORDING TO A PLAN OF HAMPDEN HEIGHTS FOR PARK
HILLS WEST, INC., BY WHITTOCK-HARTMAN, ROBERT HARTMEN, R.P.E.
DATED DECEMBER 18, 1987 AND RECORDED IN PLAN BOOK 58, PAGE 39,
BOUNDED AND DESCRIBED IN ACCORDANCE WITH SAID PLAN AS FOLLOWS:
BEGINNING AT A POINT ON THE NORTHERN RIGHT-OF-WAY LINE OF NORTH
POWDERHORN ROAD, SAID POINT BEING A COMMON PROPERTY CORNER OF
LOT #60 AND LOT #61; THENCE FROM SAID POINT OF BEGINNING IN A
WESTERLY DIRECTION ALONG SAID NORTHERN RIGHT-OF-WAY LINE OF
NORTH POWDERHORN ROAD NORTH 87 DEGREES 09 MINUTES 52 SECONDS
WEST A DISTANCE OF 110.00 FEET TO A COMMON PROPERTY CORNER OF LOT
#59 AND LOT #60; THENCE ALONG LOT #59 NORTH 02 DEGREES 50 MINUTES 08
SECONDS EAST A DISTANCE OF 125.00 FEET TO A POINT AT LANDS OF
BUNKER HILLS PLAN NO. 4; THENCE BY SAID LANDS OF BUNKER HILLS PLAN
NO.4 SOUTH 87 DEGREES 09 MINUTES 52 SECONDS EAST A DISTANCE OF 110.00
FEET TO A COMMON PROPERTY CORNER OF LOT #60 AND LOT #61; THENCE
ALONG LOT #61 SOUTH 02 DEGREES 50 MINUTES 08 SECONDS WEST A
DISTANCE OF 125.00 FEET TO A POINT ON THE NORTHERN RIGHT-OF-WAY
LINE OF NORTH POWDERHORN ROAD, THE POINT OF BEGINNING. SAID LOT
CONTAINS 13,750.00 SQUARE FEET. HAVING ERECTED THEREON A TWO
STORY DWELLING ALSO KNOWN AS 6343 NORTH POWERHORN ROAD.
AS DESCRIBED IN MORTGAGE BOOK 1177 PAGE 741
IndyMac Vlortgage Services
a Division of One West Bank @
PO Box 9042
Temecula, CA 92589-9042
Send Payments to:
IndyMac Mortgage Services
a Division of One West Bank O
PO Box 4045
Kalamazoo. MI 49003-4045
Send Correspondence to:
IndyMac Mortgage Services
a Division of One West Bank 0
PO Box 4045
Kalamazoo, MI 49003-4045
?196 9006 9295 1725 6880
JOHN CASPER
6343N POWDERHORN RD
MECHANICSBURG,, PA 17055
PRESORT
First-Class Mail
U.S. Postage and
Fees Pad
w So
20110503-72
EXHIBIT A
XC7' 8
Hone roan Servicing
6900 Beatrice Drive
Kalamazoo, MI 49009
05/03/2011
JOHN CASPER
6343N POWDERHORN RD
MECHANICSBURG„ PA 17055
RE: Loan Number:
Legal Description of Property:
3000763155
6343N POWDERHORN RD
MECHANICSBURG. PA 17055
Sent Via Certified Mail
7196 9006 9295 1725 6880
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgase on vour home is in default, and the lender intends to foreclose.
Specific information about the nature of the default is provided in the attached pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) MAY
BE ABLE TO HELP TO SAVE YOUR HOME. This Notice explains how the nrosram works. To see
if HEMAP can help you must MEET WITH CONSUMER CREDIT COUNSELING AGENCY
WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with
the Counseling Agency.
The name. address and phone number of Consumer Credit Counseling Agencies servicing your county are
listed at the end of this Notice. If you have any questions. you may call the Pennsylvania Housing Finance
Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call 1-717-780-1869)
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDIDO
DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAM.ANDO
ESTA AGENCI.A (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
L.LAMADO "HOMEOWNER'S EMERGENCY MORTGAGE, ASSISTANCE PROGRAM" EL.
CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTEC A.
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
W ep YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
OftF'Wfl'it Bank-
7196 90176 9295 1725 6880
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE, HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE -ACT-), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (Plus three (3) days for mailing).
During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSIS'T'ANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE.
THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT",
EXPL.AdNS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30)
days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit
counseling agencies for the county in which the property is located are set forth at the end of this Notice It is
only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default). You have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program,
To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program.
Application with one of the designated consumer credit counseling agencies listed at the end of this Notice.
Only consumer credit counseling agencies have applications for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily stop the
lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within
thirty (30) days of your face-to-face meeting with the counseling agency.
YOU SHOULD FILE A HEM.AP APPLICATION AS SOON AS POSSIBLE. IF YOL% HAVE A
MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF
THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING,
THEA THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A
FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION
CALLED "TEMPORARY STAY OF FORECLOSURE".
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME
PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY
TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You
will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN A
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by IndyMac Mortgage Services, a Division of
OneWest Bank on your property located at the above referenced address is in SERIOUS DEFAULT, because
you have not made the monthly payments that follow:
Next Payment Due Date:
Current Monthly Payment:
Total Monthly Payments Due:
Late Charges:
Other Charges:
Uncollected NSF Fees:
Other Fees:
Corporate Advance Balance:
Partial Payment Balance:
TOTAL. YOU MUST PAY TO CURE DEFAULT:
03/O1/2011
$1,593.17
$4,779.51
$116.60
$20.00
$0.00
$0.00
- 0.00
$4,916.11
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$4,916.11, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified
check or money order made Vayable and sent to:
IndyMac Mortgage Services, a Division of OneWest Bank
P.O. Box 78826
Phoenix, AZ 85062-88026
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This
means that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made
within 'T'HIRTY (30) Days, the lender also intends to instruct its attorneys to start legal action to foreclosure
upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the sheriff to
pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees
that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have
to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's
fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you
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7196 9006 9295 1725 6880
cure the default within the THIRTY (30) DAY period, you will not be required to pay attorney's fees.
OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default
within the THIRTY(30) DAY period and foreclosure proceedings have begun, you still have the right to cure
the default and prevent the sale at an time ime up to one hour before the Sheriff's Sale. You may do so by paying
the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs
connected with the foreclosure sale and any other costs connected with the Sheriff s Sale as specified in writing
by the lender and by performing any other requirements under the mortgage. Curing your default in the
manner set forth in this notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately h months from the date of
this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You may find out at any time exactly
what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
IndyMac Mortgage Services, a Division of OneWest Bank
2900 Esperanza Crossing
Austin, Texas 78758
Loan Resolution Department
1-877-908-4357
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you. continue to live in the property after the Sheriffs Sale,
a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may be eligible to sell or transfer your home to a buyer or
transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are
satisfied. You will need to obtain expressed approval of the lender prior to any sale or transfer or assumption
of the mortgage debt.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR
YEAR.)
• TO ASSERT THE NONEXISTENCE, OF A DEFAULT IN ANY FORECLOSURE.,
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
You may also contact a HUD-approved housing counseling agency toll-free at 1-800-569-4287 or TDD
1-800-877-8339 for the housing counseling agency nearest you. These services are usually free of charge.
CONSUMER CREDIT COUNSELING AGENCIES SERVICING YOUR COUNTY CAN BE
LOCATED ON THE ATTACHED LIST OF COUNSELING AGENCIES LOCATED IN THE
STATE OF PENNSYVANIA
This company is a debt collector and any information obtained will be used for that purpose.
However, if you have filed a bankruptcy petition and there is either an "automatic stay" in
effect in your bankruptcy case, or your debt has been discharged pursuant to the bankruptcy
laws of the United States, this communication is intended solely for informational purposes.
Sincerely.
IndyMac Mortgage Services, a Division of OneWest Bank, FSB
Loan Resolution
Please
1) Make your check payable to IndyMac Mortgage Services, a Division of OneWest Bank
2) Do not staple your payment to your billing statement
3) \ATrite your loan number on your check or money order
4) Do no include correspondence
5) Do not send Cash
6) Mail your payments to: IndyMac Mortgage Services, a Division of OneWest Bank
P.O. Box 78826
Phoenix. AZ 85062-88026
WAR
ti * Otieftst ltl<..
7196 9006 9295 1725 6880
i
CONSUMER CREDIT COUNSELING AGENCIES
SERVING CUMBERLAND COUNTY
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
Community Action Commission of Capt al
Region
1514 Derry Street
Harrisburg, PA 17104
717.232.9757
PA Interfaith Community Programs Inc
40 E High Street
Gettysburg, PA 17325
717.334.1518
IndyMac Mortgage Services
a Division of One West Bank 0
PO Box 9042
Temecula. CA 92589-9042
Send Payments to:
IndyMac Mortgage Services
a Division of One West Bank O
PO Box 4045
Kalamazoo. MI 49003-4045
Send Correspondence to:
IndyMac Mortgage Services
a Division of One West Bank CR
PO Box 4045
Kalamazoo, MI 49003-4045
;}
7196 9006 9295 1725 6903
MARY SCASPER
6343N POWDERHORN RD
MECHANICSBURG,, PA 17055
20110503-72
PRESORT
First-Class Mail
U.S. Postage and
Fees Paid
WSO
XC718
Home _oan Servicing
6900 Beatrice Drive
Kalamazoo, MI 49009
0-5/03/2011
MARY SCASPER
6343N POWDERHORN RD
MECHANICSBURG„ PA 17055
RE: Loan Number:
Legal Description of Property:
3000763155
6343N POWDERHORN RD
MECHANICSBURG,, PA 17055
Sent Via Certified Mail
7146 9DD6 9295 1725 6903
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on your home is in default, and the lender intends to foreclose.
Specific information about the nature of the default is provided in the attached Pages.
The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) MAY
BE ABLE TO HELP TO SAVE YOUR HOME. This Notice explains how the program works. To see
if HEMAP can heh. you must MEET WITH CONSUMER CREDIT COUNSELING AGENCY
WITHIN 33 DAYS OF TH.E., DATE OF THIS NOTICE. Take this Notice with you when you meet with
the Counseling Agency.
The name, address and phone number of Consumer Credit Counseling Agencies servicing your county are
listed at the end of this Notice. If you have any questions. you may call the Pennsylvania Housing Finance
Agency toll free at 1-800-342-2397. (Persons with impaired hearing can call 1-717-780-1869).
This Notice contains important legal information. If you have any questions, representatives at the
Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an
attorney in your area. The local bar association may be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENDIDO
DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATAMENTE LLAMANDO
ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENC?t) SIN CARGOS AL NUMERO
MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE, ASSISTANCE PROGRAM" El,
CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
HOMEOW'NER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME
Eli ` Fit:'Sx aCtk
7196 9006 9295 1729 6903
FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMF,OWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT' OF 1983 (THE -ACT-), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE:
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY
TEMPORARY STAY OF FORECLOSURE -- Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (Plus three (3) days for mailing).
During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit
counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN
THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE
THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT".
EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES -- If you meet with one of the consumer credit
counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30)
days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit
counseling agencies for the county in which the property is located are set forth at the end of this Notice. It is
only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE -- Your mortgage is in default for the reasons set forth
later in this Notice (see following pages for specific information about the nature of your default). You have
the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program.
To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program.
Application 'Mth one of the designated consumer credit counseling agencies fisted 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. To temporarily stop the
lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within
thirty (30) days of your face-to-face meeting with the counseling agency.
YOU SHOULD FILE A HEM.4P APPLICATION AS SOON AS POSSIBLE. IF YOL% HAVE A
AIEETIAIG WITH A COUNSELING AGE'VCY WITHIN 33 DAYS OF THE POSTMARIA DATE OF
THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING,
THE1V THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A
FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN TIIE SECTION
CALLED "TEMPORARY STAY OF FORECLOSURE".
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME
PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY
TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time. no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You
will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE.,: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN A
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date).
NATURE OF THE DEFAULT - The MORTGAGE debt held by hidyMac Mortgage Services, a Division of
OneWest Bank on your property located at the above referenced address is in SERIOUS DEFAULT, because
you have not made the monthly payments that follow:
Next Payment Due Date:
Current Monthly Payment:
Total Monthly Payments Due:
Late Charges:
Other Charges:
Uncollected NSF Fees:
Other Fees:
Corporate Advance Balance:
Partial Payment Balance:
TOTAL YOU MUST PAY TO CURE DEFAULT:
03/01/2011
$1,.593.17
$4,779.51
$116.60
$20.00
$0.00
$0.00
40.00
$4,916.11
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of
this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$4,916.11, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cashier's check, certified
check or money order made payable and sent to:
IndyMac Mortgage Services, a Division of OneWest Bank
P.O. Box 78826
Phoenix, AZ 85062-88026
IF YOU DO NOT CURE THE DEFAULT -- If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This
means that the entire outstanding balance of this debt will be considered due immediately and you may lose the
chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made
within THIRTY (30) Days, the lender also intends to instruct its attorneys to start legal action to foreclosure
upon your mortgaged property.
IF THE MORTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the sheriff to
pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees
that were actually incurred, up to $50.00. However. if legal proceedings are started against you, you will have
to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's
fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you
OneWesl Banc..
7196 9006 9295 1725 6903
cure the default within the THIRTY (30) DAY period, you will not be required to pav attorneys fees.
OTHER LENDER REMEDIES -- The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -- If you have not cured the default
within the THIRTY(30) DAY period and foreclosure proceedings have begun, you still have the right to cure
the default and prevent the sale at anon to one hour before the Sheriff's Sale. You may do so by pang
the total amount then past due, plus any late or other charges then due, reasonable attorney's fees and costs
connected with the foreclosure sale and anv other costs connected with the Sheriffs Sale as specified in writing
by the lender and by performing anv other requirements under the mortgage. Curing your default in the
manner set forth in this notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately 6 months from the date of
this Notice. A notice of the actual date of the Sheriffs Sale'rill be sent to you before the sale. Of course, the
amount needed to cure the default will increase the longer you wait. You may find out at any time exactly
what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
IndyMac Mortgage Services, a Division of OneWest Bank
2900 Esperanza Crossing
Austin, Texas 78758
Loan Resolution Department
1-877-908-4357
EFFECT OF SHERIFF'S SALE - You should realize that a Sheriff's Sale will end your ownership of the
mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale,
a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE - You may be eligible to sell or transfer your home to a buyer or
transferee who will assume the mortgage debt; provided that all the outstanding payments, charges and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are
satisfied. You will need to obtain expressed approval of the lender prior to any sale or transfer or assumption
of the mortgage debt.
YOU MAY ALSO HAVE THE RIGHT:
TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR
YEAR.)
• TO ASSERT THE, NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURF
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE
DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION
BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
You may also contact a HUD-approved housing counseling agency toll-free at 1-800-569-4287 or TDD
1-800-877-8339 for the housing counseling agency nearest you. These services are usually free of charge.
CONSUMER CREDIT COUNSELING AGENCIES SERVICING YOUR COUNTY CAN BE
LOCATED ON THE ATTACHED LIST OF COUNSELING AGENCIES LOCATED IN THE
STATE OF PENNSYVANIA
This company is a debt collector and any information obtained will be used for that purpose.
However, if you have filed a bankruptcy petition and there is either an "automatic stay" in
effect in your bankruptcy case, or your debt has been discharged pursuant to the bankruptcy
laws of the United States, this communication is intended solely for informational purposes.
Sincerely,
IndyMac Mortgage Services, a Division of OneWest Bank, FSB
Loan Resolution
Please
1) Make your check payable to IndyMac Mortgage Services, a Division of OneWest Bank
2) Do not staple your payment to your billing statement
3) Write your loan number on your check or money order
4) Do no include correspondence
S) Do not send Cash
6) Mail your payments to: IndyMac Mortgage Services, a Division of OneWest Bank
P.O. Box 78826
Phoenix, AZ 85062-88026
OneWest Ban
7196 9006 9295 1725 6903
CONSUMER CREDIT COUNSELING AGENCIES
SERVING CUMBERLAND COUNTY
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
Community Action Commission of Captiad PA Interfaith Community Programs Inc
Region 40 E High Street
1514 Deny Street Gettysburg, PA 17325
Harrisburg, PA 17104 717.334.1518
717.232.9757
V=C A SON
The nd ei is as arttl,nri??ri of OneWestBa ak,
's seavicer on behalf of IhF
P 1x17- r-ffand as such is L?1i_?r wTtwTth the bn corns records m ?m a;n r?i by One est Bak
r ;purpose of servicing sotg??e loms_ nh se r-cords (wEch irclnd,- data
eon lat1 m is, tl-rt•a1 ? caL1y i wed docrmenis, amd othm) m ma?z zt m nr the , e
by, of nom othe ;-fou-nali on provided by, persons with kaowlEti 6e of the acuYty and
t =n E -:lions refert-d m such records, and ae kept in The corase of busm ss activity
conai .r d. reg 1 Tly by OneWest Han?, FSB. I an anfho-,ized to nazl-e 'mss veEjfLcatjon on
bt a-L of Plaintia and hereby vc&7 that the fats set forth ia the L oregomg Comp Edn` in
Mort?.ige Foreclamr, are true and =--a to the best of ray owiedge, info, TjoD
belief
I ud.erstand du-d s?lse st tcm= herein ae made snbjec-t to the penal_des of Pa
C..S. §',904, rela_ng to uns-wom falsificxhon to azTthoj:jdes-
OneWestB?k, r' ?B on behAff of Plain -FT
JUN 21 2011
Name Kristen L. Rieger
'I-3 29- e_ Assistant Secretary
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
BY: MARK J. UDREN, ESQUIRE - ID #04302
STUART WINNEG, ESQUIRE - ID #45362
LORRAINE DOYLE, ESQUIRE - ID #34576
ALAN M. MINATO, ESQUIRE - ID #75860
SHERRI J. BRAUNSTEIN, ESQUIRE - ID #90675
MARGUERITE L. THOMAS, ESQUIRE - ID #204460
DANIEL S. SIEDMAN, ESQUIRE - ID #306534
HEATHER RILOFF, ESQUIRE - ID #309906
SHERNESE V. WOODBINE, ESQUIRE - ID#91209
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003-3620
856-669-5400 pleadinusAmdren.com
OneWest Bank, FSB COURT OF COMMON PLEAS
888 East Walnut Street CIVIL DIVISION
Pasadena, CA 91101 CUMBERLAND County
Plaintiff
V.
JOHN P. CASPER A/K/A JOHN F. CASPER NO. C
6343 NORTH POWDERHORN ROAD
MECHANICSBURG, PA 17055
MARY JANE S. CASPER
6343 NORTH POWDERHORN ROAD
MECHANICSBURG,, PA 17055
Defendant(s)
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
C 1
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1
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w
Kindly enter the appearance of the following counsel: Mark J. Udren, Esquire;
Stuart Winneg, Esquire; Lorraine Doyle, Esquire; Alan M. Minato, Esquire, Sherri J.
Braunstein, Esquire; Marguerite L. Thomas, Esquire; Daniel S. Siedman, Esquire;
Heather Riloff, Esquire, Shernese V. Woodbine, Esquire on behalf of the Plaintiff, in the
above-captioned matter.
UDREN LAW OFFI ,
BY:?---..
Daniel S. Siecirnan, c q;jire
PA ID 306534
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
FILED-GFFICE
1 THE PROTHONOTARY
2011 JUL -8 AM 8: 13
Richard W Stewart
Solicitor
One West Bank, FSB
vs.
Mary Jane S. Casper (et al.)
CUMBERLAND COUNTY
PENNSYLVANIA
Case Number
2011-5329
SHERIFF'S RETURN OF SERVICE
06/30/2011 03:27 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 30,
2011 at 1527 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Mary Jane S. Casper, by making known unto herself personally, at 6343
N. Powderhorn Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the
same time handing to her personally the said true and correct copy of the same.
DEN KS FRY, DEPeV
06/30/2011 03:27 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on June 30,
2011 at 1527 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: John P. Casper, by making known unto himself personally, at 6343 N.
Powderhorn Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the
same time handing to him personally the said true and correct copy of the same.
DENP S FRY, DEF6TY
SHERIFF COST: $54.00
July 01, 2011
SO ANSWERS,
RbNN"Y R ANDERSON, SHERIFF
( Cour ySuite Sheriff- Teaenseft. In-,
UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF
WOODCREST CORPORATE CENTER
111 WOODCREST ROAD, SUITE 200
CHERRY HILL, NJ 08003
856-669-5400
One West Bank, FSB =COURT OF COMMON PLEAS
888 East. Walnut Street € CIVIL DIVISION -
Pasadena, CA 91101 :Cumberland County W
Plaintiff ate `
V.
=NO. 11-5329-Civil --I CD
John P. Casper A/K/A John F.
Mob
C)
-
Casper =C:> -' "
CD C
Mary Jane S. Casper
6343 North Powderhorn Road .? N
Mechanicsburg, PA 17055
Defendant(s)
PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly mark the above DISCONTINUED WITHOUT PREJUDICE,
upon payment of your costs only.
DATED: August 2, 2011
Attorney for Pla
4-c?? 4at o
11060308-1