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PHELAN HALLINAN, LLP
Allison F. Wells, Esq., Id. No.309519
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia, PA 19103
215-563-7000
ATTORNEY FOR PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
WELLS FARGO BANK, N.A.
3476 STATEVIEW BOULEVARD CIVIL DIVISION
FORT MILL, SC 29715 Q O '~~ ~~
Plaintiff, NO.: ~ ~j -1 O D
vs.
AARON J. SKURZYNSKI
A/K/A AARON JOHN SKURZYNSKI
139 PLEASANT GROVE ROAD
MECHANICSBURG, PA 17050-1529
Defendant.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
And now comes WELLS FARGO BANK, N.A., by its attorneys, Phelan Hallinan, LLP
and files this Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is WELLS FARGO BANK, N.A., 3476 STATEVIEW
BOULEVARD, FORT MILL, SC 29715 (hereinafter "plaintiff').
062-PA-V3
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2. The Defendant, AARON J. SKURZYNSKI A/K/A AARON JOHN
SKURZYNSKI, is an individual whose last known address is 139 PLEASANT GROVE ROAD,
MECHANICSBURCJ, PA 17050-1529.
3. WELLS FARGO BANK, N.A., directly or through an agent, has possession of the
Promissory Note. WELLS FARGO BANK, N.A. is either the original payee of the Promissory
Note or the Promissory Note has been duly indorsed. A true and correct copy of said Promissory
Note is marked Exhibit "A", attached hereto and made a part hereof.
4. On or about August 13, 2008, AARON J. SKURZYNSKI made, executed and
delivered to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC AS NOMINEE
FOR PRIMARY RESIDENTIAL MORTGAGE INC. a Mortgage in the original principal
amount of $192,000.00 on the premises described in the legal description marked Exhibit "B",
attached hereto and made a part hereof. Said Mortgage being recorded in the Office of the
Recorder of CUMBERLAND County in Instrument No. 200828588. The Mortgage is a matter of
public record and is incorporated herein by reference in accordance with Pa.R.C.P. 1019(g),
which rule relieves the Plaintiff from its obligation to attach documents to pleadings if those
documents are of public record.
5. Plaintiff is the current Mortgagee. By Assignment of Mortgage recorded August
31, 2010, the mortgage was assigned to WELLS FARGO BANK, N.A. which Assignment is
recorded in the Office of the Recorder of CUMBERLAND County in Instrument No. 201024201.
The Assignment is a matter of public record and is incorporated herein by reference in
accordance with Pa.R.C.P. 1019(g), which rule relieves the Plaintiff from its obligation to attach
documents to pleadings if those documents are of public record.
6. AARON J. SKURZYNSKI A/K/A AARON JOHN SKURZYNSKI is record and
real owner of the aforesaid mortgaged premises.
7. Defendant is in default under the terms of the aforesaid Mortgage for, inter alia,
failure to pay the monthly installments of principal and interest due July 1, 2012.
062-PA-V3
8. As of 12/21/2012, the amount due and owing Plaintiff on the mortgage is as
follows:
Principal Balance $ 204,108.42
Interest 06/01/2012 through 12/21/2012 $ 7,926.66
Late Charges $ 206.52
Property Inspections $ 30.00
Escrow Deficit $ 2,044.59
Suspense Balance Credit $(500.00)
TOTAL $ 213,816.19
plus interest and all other additional amounts authorized under the Mortgage and Pennsylvania
Law, actually and reasonably incurred by Plaintiff, including but not limited to, costs (including
escrow advances) and Plaintiff's attorneys' fees and expenses. Plaintiff reserves the right to file
a motion in the above-captioned action to add such additional sums authorized under the
Mortgage and Pennsylvania Law to the above amount due and owing when incurred
9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of
Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended
in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have
been sent to the Defendant(s).
10. This is an in rem action only against the aforesaid mortgaged premises. Plaintiff
is not seeking a judgment of personal liability against the Defendant(s), but reserves its right to
do so in a separate legal action if such right exists. If Defendant(s) have received a discharge of
personal liability in a bankruptcy proceeding, this action is in no way an attempt to re-establish
such liability.
062-PA-V3
WHEREFORE, Plaintiff demands an in rem judgment in mortgage foreclosure for the
amount due of $ 213,816.19, with interest thereon plus additional costs (including additional
escrow advances), additional attorneys' fees and costs and for foreclosure and sale of the
mortgaged premises.
~ ~~~~ By:
Date.
. Wel ,Esq., Id. No.309519
for aintiff n /- i n /~ ~ ~' t
2~~~~
062-PA-V3
Exhibit "A"
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NOTE
Au;use I3, 2008
[Date)
MERS TELEPHONE: ('888) 679-6377
MECHANICSBURG PENNSYLVANIA
(CNy] [Brae)
139 PLEASANT GROVE ROAD, MECHANICSBURG, PENNSYLVANIA 17050
(Prope•nY,Addtesa]
1. BORROWER'S PROMISE TO PAY
in return for a loan that 1 have received, l promise to pay U.S. $192,000.00 (this amount is called "principal'j, plus interest,
to the order of the Lender. The Lender is PRIMARY RESIDENTIAL MORTGAGE WC.. I will make all payments under this
Note in the form of cash, check or money order.
[ understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and who is
entitled to receive payments under this Note is called the "'rote Holder."
2. INTEREST '
Interest will be charged on unpaid principal until the full amount of Principal has been paid. [will pay interest at a yearly
rate of 7.000°Io.
The interest rate required by this Section 2 is the rate 1 will pay both before and after any default described in Section 6(B) of
this Note.
3. PAYMENTS -
(A) Time atoll Place of Payment
1 will pay principal and interest by making a payment every month.
1 will make my monthly payment on the FIRST day of cash month beginning on October 1, 2006. I will make these
payments every month until I have paid all of the principal and interest and any other charges described below that 1 may owe under
this Note. Each monthly payment will be applied as of its scheduled due dato and will be applied to interest before Principal. If, on
September 1, 2038, I still owe amounts under this Note, I will pay those amounts in full on that date, which is called the °Maturity
Date. "
f wilt make my monthly payments at 4750 WEST WILEY POST WAY #1200, SALT LAKE CITY, UTAH 84116 or at a
different place if required by the Note Holder.
(B) Amount of Moutlliy Paymeuta
My monthly payment will be in the amount of U.S. $1,27738.
4. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of Principal at any time before they arc due. A payment of Principal only is known as a
"Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I may not designate a payment
as a Prepayment if [have not made all the monthly payments due under the Note.
I may make a full Prepayment or penis) Prepayments without paying a Prepayment charge. The Note Holds will use my
Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my Propayment to
the accrued and unpaid interest on the Prepayment amount, before applying my Prepayment to reduce the Principal amount of the
Note. If 1 melee a partial Prepayment, there will be no changes in the due date or in the amount of my monthly payment unless the
Note Holder agrees in writing to those changes.
5. LOAN CHARGES
MULTIS7'A7'E FIXED RAT$ N07'E-Singk FamilyF~ngle MttdFreddle Mac UNIFORM INSTRUMENT Form 32001J11t
Pogo t of 3
Initials: '
usc3200
1
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If a law, which applies to this loan and which sets maximum loan charges, es finally interpreted so that the interest or other
loan charges collected or to be collected in connection with this loan exceed the permithed limits, thee: (a) any sudt loan charge shall
be reduced by the amount necessluy to reduce the charge to the permitted limit; and (b) any sums already collected from me which
zxoeeded permitted limits will be refunded to me. The Note Holder may choose to make this refilttd by reducing the Principal I owe
under this Note or by making a direct payment to mc. If a refund reduces Principal, the reduction will be treated ss a partial
Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
!f the Note Holder has not received the full amatnt of any monthly payment by the end of fiftan (15) calendar days after the
date it is due, 1 will pay a tale charge to the Note Holder. The amount of the charge will be 5.000% of my overdue payment of
principal and interest. 1 will pay this late charge promptly but only once on each late payment.
(B) Default
If 1 do not pay the full amount of each monthly payment on the date it is due, I will be in default.
(C) Notice of Default
If I. am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a
certain date, the Note Holder may require me to pay immediately the full amount of Principal which bas not ban paid and all tfie,:
interest that 1 owe on that amount. That date must be at least 30 days after the date on which the notice is mailed to me or ddivered by ~
Other means. .
(D) No Waiver By Note Holder
Even if, at a time when 1 am in default, the Note Holder does not require me to pay immediately in foil as described above,
the Note Holder will still have the right to do so if I am in default at a later time.
(E) Payment of Note Ilolder'a Costa and E:peases
If the Note Holder has required me to pay immediately in full as described above, the Nate Holder will have the right to be
paid back by me for all of i is costs and expenses in enforcing this Note to the extent not prohibited by applicable law. These expenses
include, for example, reasonable attorneys' fees,
7. GIVING OF NOTICES
Unless applicable law nequirts a different method any notice that must be given to me under this Note will be given by
delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if 1 give the Note Holder a
notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it by first class
mail to the Note Holder at the address stated in Section 3(A) above or at a different address if [ am given a notice of that different
address.
8. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more then one person signs this Note, each person is fully and personally obligated to keep all of the promises made in this
Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or eadocser of this Note is also
obligated to do these things. Any person who takes over these obligations, including the obligations of a guarantor, suety or endorser
of this Notc, is also obligated to keep all of the promises made in this Note. The Note Holder may enforce its rights ands this Note
against each person individually or against all of us together. This means that any one of us maybe required to pey all of the amounts
awed under dlis Note.
4. WAIVERS
t and any other person who has obligations under this Noto waive the rights of Presentment and Notice of Dishonor.
"Presentment"means the right to require the Note Holder to demand payment of amounts due. °Notice of Dishonor "means the right
to require the Note Holder to give notice to other persons that amounts due have not been paid.
] 0. UNIFORM SECURED NOTE .
This Note is a uniform instrument with limited variations in some jurisdictions. in addition to the protections given to the
Note Holder under this Note, s Mortgage, Deed of Trust, or Security Deed (the "Security Instrvrnent'~, dated the same date as this
Note, protects the Note Holder from possible {oasts which might result if I do not keep the promises which [make in this Note. That
MULTISTATE FIXED RATE NOTE;-Single Family-Fnnnte Mae/Freddk Mae UNIFORM INSTRUMENT Form 32001J01
t'age 2 of 3
5N (0803).01 Initials
•
Security Instrument describes how and under what conditions I may be required to make immediate payment in full of al! amounts 1
awe under this Note. Some of those conditions are dexcribod as follows:
if ail or any part of the Ptnperty or any Interest in the Property is sold or transferrod {or if Borrower is not a
natural person and a bendcial interest in Borrower is sold or transferred) without Leader's prior written consent,
Under may roquire immediate payment in full of all sums enured by this Security Instrument. However, this
option shall not be exercised by Lender if such exeroise is prohibited by Applicable Law.
if Lender eaerciisrs this option, Lender shall give Borrower notice of accda'atioa. The notice shall provide
a period of not less tttam 30 days from the date the notice is given in accordance whit Saxiat t5 within which
Borrower must pay all sums secprod by this Security Instrument. if Borrower fails to pay these sums prior to the
expiration of this period, Lender may invoke any remedies permitted by this Security tnstnanertt without further
notice or demand on Borrower.
WITNESS THE HAND(S) AND SEAL(S) OF TH)r UNDERSIGNED.
~ ~ - (Seal) {Sea]) '! :•
R J. -Borrower .Bo~owa
Social Secatity No.: 22fl-7b 3694
(Seal) (Seat)
-Borrower -Borrower
W~~ Rr~eeotMux_, pa-y ta~tht order of
PRIMARY RESIDENTIAL MORTGAGE 1NC.
By: _
i
Name and Title: tJ
COI~J.El=NF7SITER
ASSISTANT SECRETARY
Closing Date: August 13, 2408
PAY TO Tt1E OI10Eq OF
We~bs~~F~~a~tgo 8t~llt, N.A.
By .f,L~.lS:~~~~~
yta trnaNlral toast ~
(Sigx t?rigixal OnJYJ
MUt.TISTATF: FIXED RATE NOTE-SMtsk F~milyFaa~le Mu/Freddk Mat UNIFORM INSTRUMENT Fsm 321101/01
PaQe3of3
iN (0807).01
Exhibit "B"
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground situate in the Township of Silver Spring, County of
Cumberland and State of Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point in the centerline of Township Route No. 595, said paint being
referenced eastwardly a distance of 983.16 feet from the centerline intersection of Township
Route Nos. 592 and 595; thence along the centerline of Township Route No. 595, South 58
degrees 16 minutes East, 50.43 feet to a point; thence continuing along the centerline of
Township Route No. 595, South 53 degrees 12 minutes East, 99.57 feet to a point; thence along
other land now or late of D. S. Poorman and Helen E. Poorman, his wife, South 31 degrees 36
minutes 20 seconds West, 177.69 feet to a stake; thence along land of same, North 58 degrees 16
minutes West, 150 feet to a stake; thence along land now or formerly of Edwin S. Metzger,
North 31 degrees 41 minutes East, 186.48 feet to a point in the center line of Township Route
No. 595, the place of BEGINNING.
HAVING thereon erected a dwelling commonly known as 139 Pleasant Grove Road.
PROPERTY ADDRESS: 139 PLEASANT GROVE ROAD, MECIiANICSBURG, PA
17050-1529
PARCEL # 38-14-0850-009
File #: 3 I I A 10
VERIFICATION
Darren Britt, hereby states that~ig~she is Vice President Loan Documentation of WELLS
FARGO BANK, N.A., plaintiff in this matter, that®'she is authorized to make this Verification,
and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are
true and correct to the best of~er information and belief. The undersigned understands that
this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
Name: Darren Britt
Title: Vice President Loan Documentation
Company: Wells Fargo Bank, N.A.
Date: O 1 /02/2013
M6-PA-V2 File # 311810
FORM 1
WELLS FARGO BANK, N.A.
Plaintiff(s)
IN THE COURT OF COMMON P~A~' n
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OF CUMBERLAND COUNTY, PE VA~1IA~ .~,
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AARON J. SKURZYNSKI A/IUA AARON JOHN
SKURZYNSKI
Defendant(s)
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
DIVERSION PROGRAM
You have been served with a foreclosure complaint that o~uld cause you to lose your home.
If you own and live in the residential property which is the subject of this foreclosure action, you may be able to
participate in acourt-supervised conciliation conference in an effort to resolve this matter with your larder.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference.
First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 2439400
extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you.
Once you have been appointed a legal representative, you must promptly meet with that legal representative within
twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all
requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal
representative complete a financial worksheet in the format ~tached hereto, the legal representative will prepare and a
Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the
service upon you of the foreclosure complaint. If you do so and a conciliationconference is scheduled, you will have an
opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your
lender before the mortgage foreclosure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a
conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal
representative. However, you must provide your lawyer with all reluested financial information so that a loan resolution
proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached
hereto, your lawyer will prepare and file a Request for Conciliation Conference wlh the Court, which must be filed
within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is
scheduled, you will have an opportunity to meet with a representative of your lender in an attemptto work out reasonable
arguments with your lender before the mortgage foreclosure suit proceeds forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS
REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully
Date
son F. ells., Es, q„ Id` ~l ~
No. 0 19 ~~'}
Attorney for Plaintiff ~
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas Docket #
BORROWER REQUEST FOR HARDSHIP ASSISTANCE
To complete your request for hardship assistance, your lender must consider your circumstances to determine
possible options while working with your counseling agency. Please provide the following information to
the best of your knowledge:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different):
City:
Phone Numbers:
Email:
# of people in household:
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household:
State: Zip:
Office:
Other:
How long?
State: Zip:
Yes ^ No ^ Listing date: Price: $
Realtor Phone:
Yes ^ No ^
Home:
Cell:
State: Zip:
Home:
Cell:
Office:
Other:
How long?
First Mortgage Lender:
Type of Loan:
Loan Number:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $
Date of Last Payment:
Date You Closed Your Loan:
Included Taxes & Insurance:
Primary Reason for Default:
Is the loan in Bankruptcy? Yes ^ No ^
If yes, provide names, location of court, case number & attorney:
Assets Amount Owed: Value:
Home: $ $
Other Real Estate: $ $
Retirement Funds: $ $
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Automobile #l: Model: Year:,
Amount owed: Value:
Automobile #2: Model: Year:
Amount owed: Value:
Other transportation (automobiles boats, motorcycles): Model:
Year: Amount owed: Value_
Monthly Income
Name of Employers:
l , Monthly Gross Monthly Net.
2, Monthly Gross Monthly Net.
3, Monthly Gross Monthly Net,
Additional Income Description (not wages):
1. monthly amount:
2. monthly amount:
Borrower Pay Days:
Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently paying)
EXPENSE AMOUNT EXPENSE AMOUNT
Mort a e Food
2" Mort a e Utilities
Car Pa ment(s) Condo/Nei h. Fees
Auto Insurance Med. (not covered)
Auto fuel/re airs Other ro a ment
Install. Loan Pa ment Cable TV
Child Su ort/Alim. S endin Mone
Da /Child Care/Tuft. Other Ex enses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes ^ No ^
If yes, please provide the following information:
Counseling Agency:_
Counselor:
Phone (Office): Fax:
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)
assistance?
Yes ^ No ^
If yes, please indicate the status of the application:
Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your
delinquency?
Yes ^ No ^
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender and lender's loan servicing
company:
Lender's Contact (Name):
Servicing Company (Name):
Contact:
Phone:
Phone:
I/We, ,authorize the above named
to use/refer this information to my lender/servicer for the sole purpose of evaluating my
financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to
use the counseling services provided by the above named
Borrower Signature
Co-Borrower Signature
Date
Date
Please forward this document along with the following information to lender and lender's
counsel:
1. Proof of income
2. Past 2 bank statements
3. Proof of any expected income for the last 45 days
4. Copy of a current utility bill
5. Letter explaining reason for delinquency and any supporting documentation (hardship
letter)
6. Listing agreement (if property is currently on the market)
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 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 FEE OR NO FEE.
CUMBERLAND COUNTY ATTORNEY
REFERRAL
CUMBERLAND COUNTY BAR ASSOCIATION
CUMBERLAND COUNTY COURTHOUSE
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717)249-3166
(800)990-9108
File #: 311810
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 191.03
215-563-7000
WELLS FARGO BANK,N.A. Court of Common Pleas
Plaintiff .
Civil Division
vs
CUMBERLAND County
AARON J.SKUR7YNSKI
A/K/A AARON JOHN SKURZYNSKI No. 13-188-CIVIL
Defendant
PRAECIPE
TO THE PROTHONOTARY:
® Please withdraw the complaint and mark the action Discontinued and Ended without prejudice.
❑ Please mark the above referenced case Settled, Discontinued and Ended.
❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice.
❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended.
❑ Please Vacate the 3udgment entered.
Date: PHELAN HALLINA ,LLP
By:
Jona n Lobb,Esq.,Id.No.31.2174
Attorney for Plaintiff
PHS#311810
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Phelan Hallinan, LLP Attorney for Plaintiff
1617 JFK Boulevard, Suite 1400
One Penn Center Plaza
Philadelphia,PA 1.9103
215-563-7000
WELLS FARGO BANK, N.A. Court of Common Pleas
Plaintiff Civil Division
V. CUMBERLAND County
AARON J. SKURZYNSKI No. 13-188-CIVIL,
A/K/A AARON JOHN SKURZYNSKI
Defendant PHS#311810
CERTIFICATION OF SERVICE
I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by
regular mail to the person(s) on the date listed below:
AARON J. SKURZYNSKI
A/K/A AARON JOHN SKURZYNSKI
139 PLEASANT GROVE ROAD
MECHANICSBURIG,PA 17050-1529
Date: PHELAN HALLINAN, LLP
By: /
Jonat an Lobb,Esq.,Id. No.312174
Attorney for Plaintiff
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