HomeMy WebLinkAbout13-4561 Supreme Court.of.Pennsylvania
Cour Comb' Tleas
. �Z For Prothonotary Use Only:
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CU, RUANDM County Docket No:
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 a ers as required by law or rules of court.
S Commencement of Action:
O Complaint ❑ Writ of Summons ❑ Petition
E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking
C Lead Plaintiff's Name: JPMORGAN CHASE BANK, Lead Defendant's Name: RICHARD K. GAVER
T NATIONAL ASSOCIATION
I Are money damages requested? El Yes Z No Dollar Amount Requested: El within arbitration limits
0 (Check one) x❑ outside arbitration limits
N Is this a Class Action Suit? ❑ Yes x❑ No Is this an MDJ Appeal? ❑ Yes 0 No
A Name of Plaintiff /Appellant's Attorney: Melissa J. Cantwell, Esq., Id. No.308912, Phelan Hallinan, LLP
❑ Check here if you have no attorney (are a Self- Represented [Pro Se] 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 Ton) 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 ton) ❑ 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
B ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment
❑ Ground Rent ❑ Mandamus
❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
® 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.CP. 205.5 - Updated 0110112011
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2013 Ali G -S [',jj 9:
CUIMBERLAND CoUt4 i
PENNSYLVANIA
PHELAN HALLINAN, LLP
Melissa J. Cantwell, Esq., Id. No.308912
1617 JFK Boulevard, Suite 1400
ATTORNEY FOR PLAINTIFF
One Penn Center Plaza
Philadelphia, PA 19103
215 -563 -7000
JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION COURT OF COMMON PLEAS
1111 POLARIS PARKWAY
COLUMBUS, OH 43240 CIVIL DIVISION
Plaintiff TERM ,
v. NO. 7 - NSCQ I v l
RICHARD K. GAVER
34 LYNBROOK LANE CUMBERLAND COUNTY
DOYLESTOWN, PA 18901 -2816
Defendant
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
.1 D2. 75�,
File #: 324892 �/y /350 ,C��
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'2 C)
1. Plaintiff is
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
1111 POLARIS PARKWAY
COLUMBUS, OH 43240
2. The name(s) and last known address(es) of the Defendant(s) are:
RICHARD K. GAVER
34 LYNBROOK LANE
DOYLESTOWN, PA 18901 -2816
who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 10/12/2005 RICHARD K. GAVER made, executed and delivered a mortgage upon
the premises hereinafter described to CCO MORTGAGE CORP. , which mortgage is
recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage
Book 1927, Page 0111. By Assignment of Mortgage recorded 09/11/2006 the mortgage
was assigned to JPMORGAN CHASE BANK NATIONAL ASSOCIATION, which
Assignment is recorded in Assignment of Mortgage Book 730, Page 1368.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. The premises subject to said mortgage is described as attached.
5. The mortgage is in default because monthly payments of principal and interest upon said
mortgage due 03/01/2013 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 #: 324892
6. The following amounts are due on the mortgage as of 06/10/2013:
Principal Balance $68,074.30
Interest' $1,560.04
02/01/2013 through 05/31/2013
Late Charges $74.10
Property Inspections $42.00
Escrow Balance 674.82
TOTAL $69,075.62
7. 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.
8. The mortgage premises are vacant and abandoned
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $69,075.62,
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 HALLINAN, LLP
B
Melissa J. Cantwell, Esq., Id. No.308912
Attorney for Plaintiff
File #: 324892
LEGAL DESCRIPTION
ALL THAT CERTAIN lot of ground situate in the Borough of Shippensburg, Cumberland
County, Pennsylvania, more particularly bounded and described as follows:
BEGINNING at the Southeast corner of lot now or late of Mrs. R. C. Ogle, on the North side of
East Burd Street; thence Eastwardly along said Burd Street 57 feet, more or less, to corner of lot
now or formerly of Susan Boltz; thence by the same Northwardly 214 feet, more or less to an
alley formerly land of Samuel Warren; thence along said alley westwardly 57 feet, more or less,
to corner of said lot of Mrs. R. C. Ogle; thence by the same in a Southwardly direction 214 feet,
more or less to Burd Street, the place of BEGINNING.
PROPERTY ADDRESS: 121 EAST BURD STREET, SHIPPENSBURG, PA 17257 -1303
PARCEL #33 -33- 1867 -036.
File #: 324892
Pennsylvania Verification
Kristy L. Tarver , hereby states that h pis Vice President of
JPMorgan Chase Bank, N.A. the Plaintiff
in this matter, and is authorized to make this Verification. The statements of fact
contained in the foregoing Civil Action in Mortgage Foreclosure are true and
correct to the best of my information, and belief. I understand that this statement
is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn
falsification to authorities.
Kristy L. Tarver
Vice Presi ent
Date: -�
JPMorgan Chase Bank, N.A
Borrower: GAVER, RICHARD
Property Address: 121 E BURD ST SHIPPENSBURG Pennsylvania 17257
County: CUMBERLAND
Last Four of Loan Number: 0731
IN THE COURT OF COMMON
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION PLEAS
Plaintiff(s) OF CUMBERLAND COUNTY,
PENNSTLVANIA
vs.
RICHARD K. GAVER °
Defendants)
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NOTICE OF RESIDENTIAL MORTGAGE Q
FORECLOSURE DIVERSION PROGRAM � n C)-! >
You have been served with a foreclosure complaint that could cause you to lose your home 7
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 an attorney, 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 not charge to you. Once you have been appointed a legal
representative, you must promptly meet with the legal representative within twenty (20) days of the
appointment date. During that meeting, you must provide the legal representative with all the 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 attempt to work out a 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 the 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
our 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:
AUG 01 2013
Date Melissa J. Cantwell, sq., Id. No.308912
Signature of Counsel for Plaintiff
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Please 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 EIZ/1"111 MARY 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 in household: How long?
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.
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 Payments Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel/repairs Other prop. payment
Install. Loan Payment Cable TV
Child Su port/Alim. Spending Money
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 you know, regarding your lender or 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 services provided by the above
named
Borrower Signature Date
Co- Borrower Signature Date
Please forward this page along with the following information to lender:
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 #: 324892
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff -HE PRO THON'0 i.A
�}fad
4�ix�r �t L��r�r�Lr
Jody S Smith ��
Chief Deputy ' °; PM 2: 4 9
Richard W Stewart � �,a,` �
Solicitor car T ss;rl = PENNSYLVANIA
JPMorgan Chase Bank, National Association
Case Number
vs.
Richard K. Gaver 2013-4561
SHERIFF'S RETURN OF SERVICE
08/05/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Richard K. Gaver, but was unable to locate the Defendant in the
Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Bucks, Pennsylvania to serve the within
Complaint in Mortgage Foreclosure according to law.
08/22/2013 04:24 PM- Deputy Shawn Harrison, being duly sworn according to law, served the qu sted Complaint
in Mortgage Foreclosure by handing a true copy to a person representing thems ves t be Allen Carson,
Adult Occupant, who accepted as"Adult Person in Charge"for Richard at 12 East Burd Street,
Shippensburg Boro, Shippensburg, PA 17257-1303.
SH N HARRISON, DEPUTY
08/22/2013 04:24 PM- Deputy Shawn Harrison, being duly sworn according to law, served the r ested Complaint
in Mortgage Foreclosure by handing a true copy to a person representing t emsel s t be Taylor
Touzinski,Adult Occupant, who accepted as"Adult Person in Charge"for i r K. G ver at 121 East
Burd Street, Shippensburg Boro, Shippensburg, PA 17257-1303.
SH HARRISON, DEPUTY
09/04/2013 The requested Complaint in Mortgage Foreclosure returned by the Sheriff of Bucks County, the within
named Defendant Richard K. Gaver, not found. Edward J. Donnelly, Sheriff, Return of Service attached to
and made part of the within record.
SHERIFF COST: $79.60 SO ANSWERS,
September 10, 2013 RONKY R ANDERSON, SHERIFF
(c)CountySuito Sheriff,Teleosoft,Inc.
SH0201 SHERIFFS OFFICE - EDWARD J. DONNELLY, SHERIFF
DATE: 09/04/2013 ADMINISTRATION BUILDING
TIME: 19:31 DOYLESTOWN, PA 18901
BUCKS MISC DOCKET # 2013 31921 LOCATION: OUT OF COUNTY CLASS: ASSUMPSIT
***** SHERIFF'S RETURN OF SERVICE *****
SHERIFF'S OFFICE
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE PA 17013
ATTN:MELISSA CANTWELL
PLAINTIFF DEFENDANT
JPMORGAN CHASE BANK VS. GAVER RICHARD K
34 LYNBROOK LANE
DOYLESTOWN, PA 18901
08022013 COMPLAINT - CIVIL ACTION RECEIVED FROM CUMBERLAND COUNTY NJC
MELISSA CANTWELL
08122013 RECEIVED IN SHERIFF'S OFFICE FOR SERVICE. TRANSACTION # 13 1 15898 NJC
AMOUNT PAID $ 58 . 00
08272013 SHERIFF' RETURN, UNDER OATH, NOT FOUND BY DEPUTY MALATESTA AT 8 :45 A NJC
S TO DEFT, RICHARD K GAVER, AT 34 LYNBROOK LANE, DOYLESTOWN, PA. 3 A
TTEMPTS MADE. LEFT NOTICE, NO RESPONSE. 2 VEHICLES IN D/W. DEFT AVOI NJC
IDING SERVICE. REQUEST POSTING ORDER.
09042013 INVOICE MAILED TO CUMBERLAND COUNTY NJC
MELISSA CANTWELL, ESQ
END OF CASE
w
OF THE PROTHONOTARY
PHELAN HALLINAN,LLP
Allison F.Zuckerman,Esq.,Id.No.309519 20i3 OCT -7 AM 10: 23
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza CUMBERLAND COUNTY
Philadelphia,PA 19103 PENNSYLVANIA
allison.zuckerman@phelanhallinan.com
215-563-7000
JPMORGAN CHASE BANK, NATIONAL : COURT OF COMMON PLEAS
ASSOCIATION
Plaintiff : CIVIL DIVISION
vs. : CUMBERLAND COUNTY
•
RICHARD K. GAYER : No. 13-4561-CIVIL
•
Defendants
•
PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE
TO THE PROTHONOTARY:
Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above
captioned matter.
PHEL A A • , '
By: Al■....../
Allri F. /kerma sq., Id. No.309519
Attorney for Plai• • f
Date: q t
/alg, Svc Dept.
File#818650
411/
low..\ IP\\:7-5p&Ili
CJUIL /3L/9?W
acltoSol
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson i:!LED—OFFICE
Sheriff `' THE I OTHONU X31'F'i,
01 at Cititibto,
Jody S Smith n13 NOY _is PH 31* 54
Chief Deputy .
Richard W Stewart CUMBERLAND PENNSYLVANIA COUNTY
Solicitor r
-4 $HERf
JPMorgan Chase Bank, National Association
vs. Case Number
Richard K. Gayer 2013-4561
SHERIFF'S RETURN OF SERVICE
10/08/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Richard K. Gayer, but was unable to locate the Defendant in the
Sheriffs bailiwick.The Sheriff therefore deputizes the Sheriff of Bucks, Pennsylvania to serve the within
Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure
according to law.
11/01/2013 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in
Mortgage Foreclosure returned by the Sheriff of Bucks County, the within named Defendant Richard K.
Gayer, not found. Edward Donnelly, Sheriff, Return of Service attached to and made part of the within
record.
SHERIFF COST: $37.00 SO ANSWERS,
November 01, 2013 RONINK R ANDERSON, SHERIFF
e�,CountySth s:,hee Te,.oscfi in,,.
1
j S
' r' •
BUCKS COUNTY - OC
SHERIFF'S RETURN I of 1
Bucks County Case# 201332451 Filed 10/6/2013 in CUMBERLAND COUNTY
Bucks Case# 201332451 Rec'd 10/16/2013
Invoice to be mailed to Special Instructions
County Sheriffs Office
Attn:
Action Civil Action COMPLAINT
Plaintiff JPMORGAN CHASE BANK
-VS-
Defendant RICHARD K GAVER
34 LYNBROOK LANE
DOYLESTOWN, PA 18901
Address Served if Different
PHELAN HALLINAN
Special Instructions Served under Pa. R.C.P.#402
(A)(i)Defendant personally served
(A)(2)(i)Family Member
(A)(2)(i)Adult in Charge of Residence
(A)(2)(ii)Manager/Clerk at Deft's Lodging
(A)(2)(iii)Person in Charge of Business
By Handling to
By Posting
14ot"Served
' — -- 0 Days Ran Out Defendant Not Home
Defendant Moved Address Vacant
Defendant Unknown Deputy needs better address
Checked Post Office No Forwarding
Forwarding Address
Twp./Boro
Notes By Deputy
Witness ,
At o'clock(-AM PPM)on
The above document was served/not served on the defendant as per
information listed above in th oun , of Buc •r,ommonwealth of
Pennsylvania. ��
So answers: l•41°:
a,iff of Buck •dnty
Affirmed and Subscribed before me on this day / /
Prothontary
Affirmed and subscribed before me on this day / /
f Notary Public
My Com.Exp.
�. tir ç/ /tr c• ZONE 7
t
SH0201 SHERIFFS OFFICE - EDWARD J. DONNELLY, SHERIFF
DATE: 10/29/2013 ADMINISTRATION BUILDING
TIME: 19:39 DOYLESTOWN, PA 18901
BUCKS MISC DOCKET # 2013 32451 LOCATION: OUT OF COUNTY CLASS: ASSUMPSIT
***** SHERIFF'S RETURN OF SERVICE *****
SHERIFF'S OFFICE
CUMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE PA 17013
ATTN: . PHELAN HALLINAN
PLAINTIFF DEFENDANT
JPMORGAN CHASE BANK VS. GAVER RICHARD K
34 LYNBROOK LANE
DOYLESTOWN, PA 18901
10062013 COMPLAINT - CIVIL ACTION RECEIVED FROM CUMBERLAND COUNTY NJC
PHELAN HALLINAN
10162013 RECEIVED IN SHERIFF'S OFFICE FOR SERVICE. TRANSACTION # 13 1 19937 NJC
AMOUNT PAID $ 58 .00
10252013 SHERIFF' RETURN, UNDER OATH, NOT FOUND BY DEPUTY MALATESTA AT 9: 10 A NJC
S TO DEFT, RICHARD K GAYER, AT 34 LYNBROOK LANE, DOYLESTOWN, PA. 3 A
TTEMPTS MADE. GOOD ADDRESS. VEHICLES IN D/W. DEFT AVOIDING SERVICE. NJC
REQUEST POSTING ORDER.
10292013 INVOICE MAILED TO CUMBERLAND COUNTY NJC
PHELAN HALLINAN
END OF CASE
YL�S AUNy H/A
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas
ASSOCIATION
Plaintiff Civil Division
V. CUMBERLAND County
RICHARD K.GAVER No.13-4561-CIVIL
Defendant(s)
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 Judgment entered.
Date: 17-q PHELAN AL N LLP
By:
Chrisovalante P.Fliakos, Esq.,Id. No.94620
Attorney for Plaintiff
PH#818650
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas
ASSOCIATION
Plaintiff Civil Division
V. CUMBERLAND County
RICHARD K.GAVER No. 13-4561-CIVIL
Defendant(s)
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:
RICHARD K. GAVER
34 LYNBROOK LANE
DOYLESTOWN,PA 18901-2816
Date: v4 1`1 PHELAN HALLINAN, LLP
By: ("'+�=I
Chrisovalante P. Fliakos,Esq., Id. No.94620
Attorney for Plaintiff