HomeMy WebLinkAbout13-3564 For Prothonotary Use Only:
Supreme Court of Pennsylvania .
-Co u rt. fi �C G ri1r' iarl P lea s
ivil. &-over Sheet
.Cumberland Cotanty Docket No.
T1re ir�fi�rrnulion coNeUc�d ore this form is used solt�h+ for corlrt adminisiratiott purposes. This fornl does not
str »lenient or replace thefiling and service or )teadin is or other Papers crs required hl+ law or rides o cowl.
Commencement of Action:
S 0 Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiffs Name: Quicken Loans Inc. Lead Defendant's Name: Stacey L. Danner
T
I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits
O (check one) ❑ outside arbitration limits
N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No
A Name of Plaintiff /Appellant's Attorney: McCabe, Weisberg and nd Conway, P.C.
❑ Check here if you have no attorney (a Self - Represented IPro 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 nol Inchrde Mass Tiert) CONTRACT (do not include Judginews) CIVIL, APPEALS
❑ intentional ❑ Buyer Plaintiff Administrative Agencies
Cl Malicious Prosecution ❑ Debt Collection: Credit Card o Board of Assessment
❑ Motor vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance 0 Department of Transportation
❑ Premises Liability (does nor Include o Statutory Appeal: Other
S mass tort)
E ❑ Slandcr /Libel/ Defamation o Employment Dispute:
❑ Other: Discrimination
C ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other
1
O ❑ Other
N MASS TORT
❑ Asbestos
❑ Tobacco
❑ '1'oxic Tort - DES
❑ Toxic Tort - Implant
B ❑Toxic Waste REAL PRUPER'PY MISCELLANEOUS
❑ Ejectment 13 Common Law /Statutory Arbitration
❑ Other:
❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Disput ❑ Non - Domestic Relations
H Mortgage Foreclosure: Residential Restraining Order
PROFESSIONAL LIABILITY D Mortgage Foreclosure: Commercial ❑ Quo Warranto
❑ Dental ❑ Partition ❑ Replevin
❑ Legal ❑ Quiet Title ❑ Other.
❑ Medical ❑ Other:
0 Other Professional:
Updated 1/1/2011
'U " .
J
PENS Yt A of / r y
A
McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff
BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496
MARC S. WEISBERG, ESQUIRE -ID # 17616
EDWARD D. CONWAY, ESQUIRE - ID # 34687
MARGARET GAIRO, ESQUIRE - ID # 34419
ANDREW L. MARKOWITZ, ESQUIRE - Ill # 28009
HEIDI R. SPIVAK, ESQUIRE - ID #74770
MARISA J. COHEN, ESQUIRE - ID # 87830
KEVIN T. MCQUAIL, ESQUIRE - ID # 307169
CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480
BRIAN T. LAMANNA, ESQUIRE - ID # 310321
ANN E. SWARTZ, ESQUIRE - ID # 201926
JOSEPH F. RIGA, ESQUIRE - ID # 57716
JOSEPH 1. FOL.EY, ESQUIRE - ID #314675
CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673
123 South Broad Street, Suite 1400
Philadelphia, Pennsylvania 19109
215) 790 -1010
Quicken Loans Inc. Cumberland County
1050 Woodward Avenue Court of Common Pleas
Detroit, MI 48226 /J
V. Number
Stacey L. Danner
12 Patton Road
Mechanicsburg, PA 17055
and
George E. Danner
12 Patton Road
Mechanicsburg, PA 17055
COMPLAINT IN MORTGAGE FORECLOSURE
ns
File 1171999
NOTICE AVISO
You have been sued in court. If you wish to defend Le han demandado a usted en la torte. Si usted quicre
against the claims set forth in the following pages, you defenderse de estas demandas ex- puestas en las paginas
must take action within twenty (20) days after this siguientes, usted tiene veinte (20) dias de plazo al partir
complaint and notice are served, by entering a written de la fecha de la demanda y la notification. Hace falta
appearance personally or by attorney and filing in asentar una comparencia escrita o en persona o con un
writing with the court your defenses or objections to the abogado y entregar a la torte en forma escrita sus
claims set forth against you. You are warned that if you defensas o sus objeciones a las demandas en contra de
fail to do so the case may proceed without you and a su persona. Sea avisado que si usted no se defiende, la
judgment may be entered against you by the court torte tomara medidas y puede continuar la demanda en
without further notice for any money claimed in the contra suya sin previo aviso o notification. Ademas, la
complaint or for any other claim or relief requested by torte puede decidir a favor del demandante y requiere
the plaintiff. You may lose money or property or other que usted cumpla con todas las provisiones de esta
rights important to you. demanda. Usted puede perder dinero o sus propiedades
u otros derechos importantes para usted.
YOU SHOULD TAKE T141S PAPER TO
YOUR LAWYER AT ONCE. IF YOU DO NOT USTED LE DEBE TOMAR ESTE PAPEL A
HAVE A LAWYER, GO TO OR TELEPHONE THE SU ABOGADO INMEDIATAMENTE. SI USTEDNO
OFFICE SET FORTH BELOW. THIS OFFICE CAN TIENE A UN ABOGADO, VA A O TELEFONEA LA
PROVIDE YOU WITH INFORMATION ABOUT OFICINA EXPUSO ABAJO. ESTA OFICINA LO
HIRING A LAWYER. PUEDE PROPORCIONAR CON INFORMATION
IF YOU CANNOT AFFORD TO HIRE A ACERCA DE EMPLEAR A UN ABOGADO.
LAWYER, THIS OFFICE MAY BE ABLE TO Sl USTED NO PUEDE PROPORCIONAR
PROVIDE YOU WITH INFORMATION ABOUT PARA EMPLEAR UN ABOGADO, ESTA OFICINA
AGENCIES TFIATMAY OFFER LEGAL SERVICES PUEDE SER CAPAZ DE PROPORCIONARLO CON
TO ELIGIBLE PERSONS AT A REDUCED FEE OR INFORMACION ACERCA DE LAS AGENCIAS
NO FEE. QUE PUEDEN OFRECER LOS SERVICIOS
LEGALES A PERSONAS ELEGIBLES EN UN
Cumberland County Bar Association HONORARIO REDUCIDO NI NINGUN
32 South Bedford Street HONORARIO.
Carlisle, PA 17013
(800) 990 -9108 Cumberland County Bar Association
32 South Bedford Street.
Carlisle, PA 17013
(800) 990 -9108
rile # 71999
Page 2
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is Quicken Loans Inc., duly organized and doing business at the above - captioned
address.
2. The Defendant is Stacey L. Danner, who is a mortgagor and real owner of the mortgaged
property hereinafter described, and his /her last -known address is 12 Patton Road, Mechanicsburg, PA 17055.
3. The Defendant is George E. Danner, who is a mortgagor and real owner of the mortgaged
property hereinafter described, and his /her last -known address is 12 Patton Road,. Mechanicsburg, PA 17055.
4. On December 1, 2010, Stacey L. Danner and George E. Danner, mortgagors, made, executed
and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration
Systems, Inc., as Nominee for Quicken Loans Inc., which mortgage is recorded in the Office of the Recorder
of Cumberland County in Mortgage Instrument Number 201037106 ( "the Mortgage "), such Mortgage being
incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P.
S. On March 8, 2013, the Mortgage was assigned by Mortgage Electronic Registration Systems,
Inc., as Nominee for Quicken Loans Inc., its Successors and Assigns, to Quicken Loans Inc., by Assignment
of Mortgage, recorded in the Office of the Recorder of Cumberland County in Assignment of Mortgage
Instrument Number 201307848, such Assignment of Mortgage being incorporated herein by reference
pursuant to Rule 1019(g) Pa. R. C. P.
6. The premises subject to said mortgage is described in the legal description attached as
Exhibit "A" and is known as 12 Patton Road, Mechanicsburg, Pennsylvania 17055.
7. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due October 1, 2012 and each month thereafter are due and unpaid, and by the terms of said
mortgage, upon default in such payments for a period of one month, the entire principal balance and all
interest due thereon are collectible forthwith.
File 9 71999
Page 3
t
8. The following amounts are due on the mortgage:
Principal Balance $ 166,405.04
Interest through March 7, 2013 $ 3,867.21
(.Plus $20.52 per diem thereafter)
Late Charges $ 173.36
Attorney's Fee $ 1,650.00
NSF Charges $ 150.00
GRAND TOTAL $ 172,245.61
The attorney's fees set forth above are in confonnity with the mortgage documents and Pennsylvania law,
and will be collected in the event of a third party purchaser at Sheriffs sale. If the mortgage is reinstated
prior to sale, reasonable and actually incurred attorney's fees will be charged in accordance with the
reduction provisions of Act 6, if applicable.,
9. Notice of Intention to Foreclose as required by Act 6 of 1974 (41 P.S. §403) and notice
required by the Emergency Mortgage Assistance Act of 1983 as amended under 12 PA Code Chapter 13, et
seq., commonly known as the Combined Notice of Delinquency has been sent to Defendants by regular mail
with a certificate of mailing and by certified mail, return receipt requested.
WHEREFORE, Plaintiff demands in rein Judgment against the Defendants in the sum of
$172,245.61, together with interest at the rate of $20.52 per diem and other costs and charges collectible
under the mortgage and for the foreclosure and sale of the mortgaged property.
McCABE, WEISBERG & CONWAY P.C. I'
BY:
[ ]Terrence J. McCabe, Esquire [ ] Marc S. Weisberg, Esquire
[ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire
[ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire
[ ] Marisa J. Cohen, Esquire [ ] Kevin T. McQuail, Esquire
[ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire
[ ] Ann E. Swartz, Esquire [ ],Joseph F. Riga, Esquire
[ ] Joseph 1. Foley, Esquire Ce ' ie P. DerKrikorian, Esquire
Attorneys for Plaintiff
rile 71999
Page 4
VERIFICATION
uldOR�A� / 14S , - , N , hereby states that he /she is A3157AA)7 S�xEr gV ofQuicken
Loans Inc., Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that-the
statements of fact made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best
of his/her knowledge, 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 AVA09PAE HASoe't1
DATE: (,,,Ll4 / ,a e r 3 Title: A5SISwi7 -5 c eTA
F i le #t: 71999
Name: Quicken Loans Inc. v. Stacey L. Danner and George E. Danner
File 11 71999
Page 5
EXHIBIT A - LEGAL DESCRIPTION
Tax Id Number(s): 18-22-0519-297
Land Situated in the Borough of Mechanicsburg in the County of Cumberland in the State of PA
BEGINNING AT A POINT ON THE SOUTHERN SIDE OF PATTON ROAD, WHICH POINT 15 ALSO THE DIVIDING LINE
OF LOT NOS. 15 AND 16, BLOCK D, ON THE HEREINAFTER MENTIONED PLAN OF LOTS; THENCE ALONG SAID
DIVIDING LINE, SOUTH 10 DEGREES 23 MINUTES EAST, 120 FEETTO A POINT; THENCE ALONG THE DIVIDING LINE
OF LOT NO. 15, BLOCK D AND LOT NOS, 19 AND 20, BLOCK D, SOUTH 79 DEGREES 37 MINUTES WEST, 70 FEET TO
A POINT, THENCE ALONG THE DIVIDING LINE OF LOT NOS. 15 AND 14, BLOCK D, NORTH 10 DEGREES 23
MINUTES WEST, 120 FEET TO A POINT ON THE SOUTHERN SIDE OF PATTON ROAD; THENCE ALONG THE
SOUTHERN SIDE OF PATTON ROAD, NORTH 79 DEGREES 37 MINUTES EAST, 70 FEET TO A POINT AND PLACE OF
BEGINNING.
Commonly known as; 12 Patton Road, Mechanicsburg, PA 17055
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Page 38 of 65
Qrdchcn Loans Inc, C64Wntfnl and Propridmra, All Rights M.WV44 2009 A ny u n nudrurizrd un•, hwimure. Rprbduction or distrihnrlon h srrimy prubibi(W
FORM l
Quicken Loans Inc. IN THE COURT OF COMMON PLEA�'_bF
Plaintiff CUMBERLAND COUNTY, PENNSY- 4Y.AI
'rn C-- j
VS.
Stacey L. Danner and George E. Danner V Civil �
P7 C -, _
Defendants Z 3 5
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE
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 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) 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 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 attached hereto, the legal representative will prepare and file 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 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 WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE
STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
4 Da [Signature of Counse for Plaintiff]
71999
Page 1
p 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
Please provide the following information to the best of your knowledge:
CUSTOM ER/PRIMARY APPLICANT
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 on household: How long?
Mailing Address (if different):
City: State: Zip:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people on 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 Payment 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: $ $
Saving's: $ $
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,
2.
3.
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 " 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 Support/Alim. Spending Money
Da /Child Care /Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes O No ❑
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax:
2
Email:
Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance?
Yes O 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 deliquency?
Yes O No ❑
If yes, please indicate the status of those negotiations:
Please provide the following information, if known, regarding your lender or lender's loan servicing company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: 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 obiligation
to use the 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:
Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting documentation (hardship letter)
Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson -
Sheriff �:af�ratargt`�g�
Jody S Smith €�+
� C-
C= _.-
Chief Deputy `� je
Richard W Stewart '"` -<
Solicitor OFrx-c r t4E PrFr r--= M-t a
<� S-4i
Quicken Loans, Inc. '
vs.
Case Number
Stacey L Danner{et al.} 2013-3564
SHERIFF'S RETURN OF SERVICE
06/24/2013 03:47 PM-Deputy Jason Kinsler, 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 the Defendant, to wit: Stacey
L Danner at 12 Patton Road, Mechanicsburg Borough, Mechanicsburg, PA 17055.
c,. l;v- �.-=�----.-- -/F
SON KINSLER, DEPUTY
06/24/2013 03:47 PM-Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing
a true copy to a person representing themselves to be Stacey Danner,Wife,who accepted as"Adult
Person in Charge"for George E Danner at 12 Patton Road, Mechanicsburg Borough, Mechanicsburg, PA
17055.
(SON NLER, DEPUTY
SHERIFF COST: $55.30 SO ANSWERS,
K;" 'K 60a:�—
June 25, 2013 RONW R ANDERSON, SHERIFF
(C)CountySuite Sheriff,Toieosott,Inc.
McCABE, WEISBERG AND CONWAY,P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID#16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID#17616
EDWARD D. CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 3441.9
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009 c -
HEIDI R.SPIVAK,ESQUIRE-ID#74770 '=
MARISA J.COHEN,ESQUIRE-ID#87830 rT t
KEVIN T.MCQUAIL,ESQUIRE-ID#307169 r-n
CHRISTINE L. GRAHAM ESQUIRE-ID#309480
BRIAN T. LAMANNA,ESQUIRE-ID#310321
ANN E.SWARTZ,ESQUIRE-ID#201.926
C --r:C:)-
JOSEPH F.RIGA,ESQUIRE-ID#57716 2:CD Z-
JOSEPH I.FOLEY,ESQUIRE-ID#314675 >>C:� ;- C ,
123 South Broad Street,Suite 1400 ---
Philadelphia,Pennsylvania 19109 <
(215)790-1016
Quicken Loans Inc. CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V. No. 13-3564
George E. Danner and Stacey L. Danner
Defendants
PRAECIPE
TO THE PROTHONOTARY:
® Please 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 Judgment entered.
DATE: McCABE,WEISBERG AND CONWAY,P.C.
BY:
[ ]Terrence J.McCabe, squire �,J Marc eisberg,Esquire
[ ]Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire
[ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire
[ ]Marisa J.Cohen,Esquire [ ]Kevin T.McQuail,Esquire
[ ] Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire
[ ]Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire
[ ]Joseph I.Foley,Esquire
Attorneys for Plaintiff
McCABE, WEISBERG AND CONWAY, P.C.
BY: TERRENCE J.McCABE,ESQUIRE-ID# 16496 Attorneys for Plaintiff
MARC S.WEISBERG,ESQUIRE-ID# 17616
EDWARD D.CONWAY,ESQUIRE -ID#34687
MARGARET GAIRO,ESQUIRE-ID# 34419
ANDREW L.MARKOWITZ,ESQUIRE-ID# 28009
HEIDI R.SPIVAK,ESQUIRE-ID#74770
MARISA J.COHEN,ESQUIRE-ID#87830
KEVIN T.MCQUAIL,ESQUIRE-ID#307169
CHRISTINE L.GRAHAM,ESQUIRE-ID#309480
BRIAN T.LAMANNA,ESQUIRE-ID#310321
ANN E.SWARTZ,ESQUIRE-ID#201926
JOSEPH F.RIGA,ESQUIRE-ID#57716
JOSEPH I.FOLEY,ESQUIRE-ID#314675
123 South Broad Street,Suite 1400
Philadelphia,Pennsylvania 19109
(215)790-1010
Quicken Loans Inc. CUMBERLAND COUNTY
Plaintiff COURT OF COMMON PLEAS
V. No. 13-3564
George E.Danner and Stacey L.Danner
Defendants
CERTIFICATE OF SERVICE
The undersigned Attorney for Plaintiff,hereby certifies that a true and correct copy of the within Praecipe was
served on the below persons by regular first class mail,postage prepaid,on the—f day of August,2013.
George E. Danner
12 Patton Road
Mechanicsburg,Pennsylvania 17055
Stacey L.Danner
12 Patton Road
Mechanicsburg,Pennsylvania 17055
DATE: �1 McCABE,WEISBERG AND CONWAY,P.C.
BY: &'t /- �w
[ ] Terrence J.McCabe,Esquire [ ��arc&Weisberg,Esquire
[ ] Edward D. Conway,Esquire [ ]Margaret Gairo,Esquire
[ ]Andrew L.Markowitz,Esquire [ ]Heidi R. Spivak,Esquire
[ ]Marisa J.Cohen,Esquire [ ]Kevin T. McQuail,Esquire
[ ] Christine L. Graham,Esquire [ ]Brian T.LaManna,Esquire
[ ]Ann E. Swartz,Esquire [ ] Joseph F.Riga,Esquire
[ ]Joseph I.Foley,Esquire
Attorneys for Plaintiff