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HomeMy WebLinkAbout13-2261 Supreme Court:of Pennsylvania Cour Comm' <` Pleas For Prothonotary Use On O' ViliC eet C OV� y� �P� b $E t`A 1D, `_� C ounty Docket No: 13 -aa� i The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and service ofpleadings or other papers as required by law or rules of court. S Commencement of Action: 9 Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: SOVEREIGN BANK N.A. Lead Defendant's Name: EDWARD T. PARKER T I Are money damages requested? El Yes 0 No Dollar Amount Requested: El within arbitration limits 0 (Check one) 0 outside arbitration limits N Is this a Class Action Suit? ❑ Yes 0 No Is this an IVWJ Appeal? ❑ Yes . 0 No A Name of Plaintiff/Appellant's Attorney: Allison F. Wells, Esq., Id. No.309519, Phelan Hallinan, LLP ❑ Check here if you have no attorney (are a Self- Represented [Pro Sel Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment • Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections • Nuisance ❑ Dept. of Transportation • Premises Liability ❑ Statutory Appeal: Other • Product Liability (does not S include mass tort) ❑ Employment Dispute: • Slander/Libel/ Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: T I MASS TORT ❑ Other: 0 ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES • Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS • Toxic Waste ❑ Ejectment ❑ Common Law/Statutory Arbitration $ ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment • Ground Rent ❑ Mandamus • Landlord/Tenant Dispute ❑ Non - Domestic Relations 0 Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto • Dental ❑ Partition ❑ Replevin • Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Pa.R.C.P. 205.5 Updated 01/01/2011 C9 -'L; - M 1 ...., ch cn PHELAN HALLINAN, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 SOVEREIGN BANK N.A. 824 NORTH MARKET STREET COURT OF COMMON PLEAS SUITE 100 WILMINGTON, DE 19801 CIVIL DIVISION Plaintiff TERM V. NO. (3 - 0�0��0� �lVtl�cm EDWARD T. PARKER 66 WEST WILLOW STREET CUMBERLAND COUNTY CARLISLE, PA 17013 -3859 Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE 103.7 Ab A71Y & aa gr File #: 312063 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 #: 312063 1. Plaintiff is SOVEREIGN BANK N.A. 824 NORTH MARKET STREET SUITE 100 WILMINGTON, DE 19801 2. The name(s) and last known address(es) of the Defendant(s) are: EDWARD T. PARKER 66 WEST WILLOW STREET CARLISLE, PA 17013 -3859 who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 07/09/2004 EDWARD T. PARKER and LORI L. PARKER made, executed and delivered a mortgage upon the premises hereinafter described to PLAINTIFF which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Book 1873, Page 1267.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. Sovereign Bank is now known as Sovereign Bank, N.A. 5. The premises subject to said mortgage is described as attached. 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/2012 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 312063 7. The following amounts are due on the mortgage as of 03/11/2013: Principal Balance $63,912.39 Interest $1,834.61 05/01/2012 through 03/11/2013 Late Charges $153.27 Property Inspections $143.10 Property Preservations $2.50 Escrow Deficit $656.99 TOTAL $66,702.86 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 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) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 10. LORI L. PARKER was a co-record owner of the mortgaged premises as a tenant by the entirety. By virtue of LORI L. PARKER's death on or about 04/03/2007, her ownership interest was automatically vested in the surviving tenant by the entirety. File #: 312063 11. Plaintiff hereby releases LORI L. PARKER, from liability for the debt secured by the mortgage. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $66,702.86, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN XHALAN, LLP By: AT isoll4llls, Es ., d. No.309519 Attorney for P iff File #: 312063 Y � b LEGAL DESCRIPTION ALL THAT CERTAIN lot of ground with the improvements thereon erected, situated in the Borough of Carlisle, Cumberland County, Pennsylvania, more particularly bounded and described according to a survey made by Thomas A. Neff, Registered Surveyor, on December 4, 1966, as follows: BEGINNING at a point (a 1/4 inch drill hole in curb) on the South line of West Willow Street (60 feet wide), 110 feet East of the East line of South Pitt Street, and on the West line of an unnamed public alley (10 feet wide); thence by the West line of said alley South 13 degrees 45 minutes West 97.33 feet, crossing a 10 feet wide right of way to a stake up the southern line of said right of way and on line of land of Seibert A. Myers; thence by the southern line of said 10 feet wide right of way and land of Seibert A. Myers North 76 degrees 30 minutes West 17.50 feet to a stake; thence recrossing said right of way and along line of land of B.F. Dunkleberger and through the partition wall between the property and the property adjoining on the West North 13 degrees 45 minutes East 97.33 feet to a spike on the southern line of West Willow Street; thence by West Willow Street South 76 degrees 30 minutes East 17.50 feet to the place of BEGINNING. BEING improved with the eastern half of a double, two -story frame dwelling house, known as 66 West Willow Street, Carlisle, PA. PROPERTY ADDRESS: 66 WEST WILLOW STREET, CARLISLE, PA 17013 -3859 PARCEL # 04 -22- 0483 -103. File #: 312063 s � . c F VERIFICATION hereby states that he /she is I4��tl�c'�111ltt1'� oinf' SOV T?ITGN BAND, N.A., Plaintiff in this matter, that he /she is authorized to inake this Verification, and verify that the statements madc in the foregoing Civil Action in Mortgage Foreclosure are trice and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 1.8 Pa. C.S. See. 4904 relating to unsworn falsification to authorities. Na e: DATE: Title: Ft)re -c j ost.t e, Mmi n is 1 V.Q. � SOVEREIGN DANK, N.A bile #: 312063 Name: PARKER file N: 312061 FORM 1 IN THE COURT OF COMMON PLELI SOVEREIGN BANK N.A. OF CUMBERLAND COUNTY, PENNS-Y -- t Plaintiffs) rnsE .�� rn -r; z� Z -um vs. - tD Nl q EDWARD T. PARKER A� _ 6-n t + c� -t f Defendant(s) `� `o�o��D I Civil Z p ` NOTICE OF RESIDENTIAL MORTGAGE FORECLOS , DIVERSION PROGRAM You have been served with a foreclosure complaint that could 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 a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps t6 be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact Mi(Penn Legal Services at (717) 243 -9400 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 represcitative 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 attached 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 conciliation conference 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 requested 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 with 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 tomeet with a representative of your lender in an attempt to 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 submitted: LA t� Date Allison F. Wells, Esq., Id. ILU cn No.309519 Z(9� 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: CUSTOM Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes ❑ No ❑ Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes ❑ No ❑ Mailing Address (if different): City: State: Zip Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? CO-13011110WEII Mailing Address: City: State: Zip Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: 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 #1: 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: 1. 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 Mortgage Food 2 nd Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Mone Da /Child Care/Tuit. Other Expenses 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): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION 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 Date Co- Borrower Signature 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) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff , " � t Jody S Smith Chief Deputy 01 Vii • Richard W Stewart Solicitor OFFICE U Ti<SIMERtrN Sovereign Bank N.A. Case Number vs. Edward T Parker 2013-2261 SHERIFF'S RETURN OF SERVICE 06!2412013 04:30 PM-Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally"handing a true copy to a person representing themselves to be he Defendant, to wit:. Edward T Parker at 66 West Willow Street, Carlisle Borough, Carlisle, PA 013. *W fm CLINE, TY SHERIFF COST: $55.12 SO ANSWERS, May 29, 2013 RbNW R ANDERSON, SHERIFF m)County'uite Sheriff,Toieosoif,lnc. FORM 3 ok.I.icizi. F9, Iv.4.. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLWANIA cm Plaintiff(s) --1- r,, co rn rr r 1'i .. VS. .4 r- • �r 'p_._ VA,,,,,Q T- PA16-7 • \?`- Cp 2,- • Defendant(s) (3-- 226 I CIVIL = REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated 2 1�2 g 012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, a undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property,which is defendant's primary residence; 3. Defendant has been served with a"Notice of Residential Mortgage Foreclosure Diversion Program" and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. 0__ ? n i 7/2//20,3 Signature of Defendant's Counsel/Appointed Date Legal Representative gAl*/117-7 /1,— 3 Signature of Defendant Date Signature of Defendant Date -7/z-q1 )3 "fo vJ %ovv. ik" vvo. CoitCenA , .J- ✓te v,°r f 9G ei Mcl cavrT of vco nAe rj-64 J':d v.. P rp r±n-_. Ske -e-e's clerk k un,f; --emd oP Mai_. if vJOxS •VtaJ ctel;- rP ÷o me by ► repC-e5e0.4-0, '4e. 'Pro rv\ SI•tc>r, fir d-P ', _ P ,PA-e r cec e; v�n5 _ clot. )Wt 'a,-1--;b n t+0,(-4-td. ivio.k v. coM s +c, Wci 'Pew\ h.e ,l Lt-C - ?YtcsSa Q e s -Per re40 r VI Co Ls • e ,"':e✓, b ,c� - a ,d Qr-J x ‘ i-.16. mssA565 --For a -Cc w week 5 F h oct I ♦ eve 0-P 1u - was cit,W.e. "o is--a,11< -k---0 Pt i Ct V Y! VJ h t. A, O. 86 bev't ("LA' c7 JaC G4-, o( . Sive-_-% d,lf. 5evc yve ■ 4or0vt6a, or " or 1 a,t _(e re_s-e-rclo.+:c r . 4k sa s+oA ec T heeded � +0 c a r%t p 1 c "e- C__re c -1^ c©uws e \i-ill as po. + a M0419& _Forct05ure -b ve.(51 per ?ro9 cckvi1_. T w 0.g ch.104\e to_ q o4,41A,'e r recto rc 1 ft-V O r vIA Gt,- a ^ 0",a scteveclule- a p po+v:h- .N 4 o.-Ac rvb eC w,+L a. c'reci Gou45e10r rnos-c ki4 e w a5 pass∎ng 6? . A4 -I-14; s po ),\A- Croon.-1-1/ e__ ivaNG _ - 4c.k.aa l f ec&i(e couck_-_& CUMGn ov. aw. ,no us pct,51.edd (O eta/s, ar 0.5 ∎ -ca(- ter■0_," c / as +-o - • .c too_ 8.0..y e amok. 4'o b Ceo�v� rim K�. � realty .P► �tre a- \ea 4-o _ --- 5 4 V ),•./ owe_, bierterkal ' I A( td: V e(y vv1uC -cor 11C ur co0151 r ;o✓t • I. Ct-ke ------ wazrd Parke r SOVEREIGN BANK N.A. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION v. • EDWARD T. PARKER : NO. 2013 - 2261 Defendant : COMPLAINT IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the foregoing Request for Conciliation Conference on Allison F. Wells, Esquire, by depositing the same in the United States Mail, first class, on July 30, 2012, from Carlisle, Pennsylvania, addressed as follows: Ms. Allison F. Wells, Esquire 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 TURO ROBINSON Attorneys at Law Daniel L. Puskar, Esquire Supreme Ct. No. 311444 129 South Pitt Street Carlisle, PA 17013 Attorney for Defendant SOVEREIGN BANK, IN THE COURT OF COMMON PLEAS OF t. ; Plaintiff CUMBERLAND COUNTY, PENNSYLVANE VS. CIVIL ACTION NO. 13-2261 CIVIL cl- EDWARD T. PARKER, J = Defendant C4 CASE MANAGEMENT ORDER AND NOW, this 64 day of August, 2013, the parties having agreed to a conciliation conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court-supervised conciliation Conference on a 7 o2a/3 , at 3m. in Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff/lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and/or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendantiborrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing or ordered by the Court,the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff/lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff/lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, Kevin ess, P.J. z/Allison F. Wells, Esquire 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 For the Plaintiff Daniel L. Puskar, Esquire 129 South Pitt Street Carlisle, PA 17013 For the Defendant :rlm glbl 3 SOVEREIGN BANK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION NO. 13-2261 CIVIL EDWARD T. PARKER, Defendant IN RE: CONCILIATION CONFERENCE ORDER AND NOW,this 2V day of September, 2013, at the request of counsel,the conciliation conference set for September 27, 2013, is continued to Thursday,November 14, 2013, at 11:30 a.m. in Chambers of the undersigned. BY THE COURT, Kevin . Hess, P. J. Joseph Schalk, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff /aniel L. Puskar, Esquire 129 South Pitt Street Carlisle,PA 17013 For the Defendant n crr M :rlm --0 �> 'j CD CD On -C- CD SOVEREIGN BANK, IN THE COURT OF COMMON PLEAS OF Plaintiff • CUMBERLAND COUNTY, PENNSYLVANIA • vs. : CIVIL ACTION • •• NO. 13-2261 CIVIL EDWARD T. PARKER, Defendant IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 13 day of November, 2013, at the request of counsel, the conciliation conference set for November 14, 2013, is continued to Friday, February 14, 2014, at 2:30 p.m. in Chambers of the undersigned. BY THE COURT, ---� i 4 Kevin A . 'ess, P. J. ✓ Joseph Schalk, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff ✓ Daniel L. Puskar, Esquire 129 South Pitt Street Carlisle, PA 17013 For the Defendant :rlm et ir&I rn,:„ cnr- /03113 . SOVEREIGN BANK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION • : NO. 13-2261 CIVIL EDWARD T. PARKER, Defendant • IN RE: CONCILIATION CONFERENCE ORDER AND NOW,this /z- day of February, 2014, on agreement of the parties, the conciliation conference set for February 14, 2014, is continued generally. BY THE COURT, P Kevi V . Hess, P. J. Troy Sellars, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff ✓ Daniel L. Puskar, Esquire 129 South Pitt Street Carlisle,PA 17013 For the Defendant C") es 0/28 .1:rlm C:2741/1/1 �Cx' N .cp Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 THE Q T HONOTA 2014 MAR -7 Ali IC: 5+-4 CtJNBERLAND COUNTY PENNSYLVANIA Attorney For Plaintiff SOVEREIGN BANK, N.A. Plaintiff v. EDWARD T. PARKER Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 13-2261-CIVIL TERM PRAECIPE TO THE PROTHONOTARY: ® Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. n Please mark the above referenced case Settled, Discontinued and Ended. n Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. n Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑ Please Vacate the Judgment entered. Date: /V / PHELAN ° f" N , LLP ichael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff PH # 805825 By: Joh Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 Attorney For Plaintiff SOVEREIGN BANK, N.A. Plaintiff v. EDWARD T. PARKER Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 13-2261-CIVIL TERM I hereby certify true and regular mail to the person(s) on Daniel L. Puskar, Esquire 129 South Pitt Street Carlisle, PA 17013 Date: S /G%� CERTIFICATION OF SERVICE correct copies of the foregoing Plaintiffs Praecipe was served by the date listed below: ael Kolesnik, Esq., Id. No.308877 Attorney for Plaintiff