HomeMy WebLinkAbout13-5117 Supreme Court"of Pennsylvania
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COnw C$1,><11 Pieas For Prothonotary Use Only:
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Conn 1.
tS' Docket No:
The information collected on this form is used solely for court administration purposes. This form does not
supplementor re lace the alin and .service *ofpleadings or other a ers as re wir=ed by law or rules o court.
Commencement of Action:
® Complaint O Writ of Summons ❑ Petition
Ei ❑ Transfer from Another Jurisdiction ❑ D eclaration of Taking
C, Lead Plaintiff s Name: OCWEN LOAN SERVICING, Lead Defendant's Name: JOHN K. MCKOWN
T LLC
Are money damages requested? El Yes R No Dollar Amount Requested: ❑ within arbitration limits
0 (Check one ) 0 outside arbitration limits
N Is this a Class Action Suit? ❑ Yes 0 No Is this an MDJ Appeal? ❑ Yes 19 No
Name of Plaintiff' /Appellant's Attorney: John Michael Kolesnik. Esq., Id. No.308877, Phelan Hallinan, LLP
A' ❑ Check here if you have no attorney (are a Self - Represented (Pro Sel Litigant)
Nature of the Place an "X" to the left of the ONE case category that most accurately describes your
Case 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
include mass tort) ❑ Employment Dispute:
S' ❑ Slander/Libel/ Defamation Discrimination
E+ ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board
C ❑ Other:
T -
t 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:
O Medical ❑ Other:
❑ Other Professional:
Pa.R. C.P. 205.5 Updated 0110112011
r ..
V l .ED OffFIC;
F THIE PROTHON01
2013 AUG 30 AH I0: 11
CUMBERLAND COUNTY
PENNSYLVANIA
PHELAN HALLINAN, LLP
John Michael Kolesnik, Esq., Id. No.308877
1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF
One Penn Center Plaza
Philadelphia, PA 19103
215 -563 -7000
OCWEN LOAN SERVICING, LLC
1100 VIRGINIA DRIVE COURT OF COMMON PLEAS
P.O. BOX 8300
FORT WASHINGTON, PA 19034 CIVIL DIVISION
Plaintiff TERM
v. NO.
JOHN K. MCKOWN
RHONDA D. MCKOWN CUMBERLAND COUNTY
1214 MITCHELL DRIVE
MECHANICSBURG, PA 17050 -3132
Defendants
CIVIL ACTION - LAW
COMPLAINT IN MORTGAGE FORECLOSURE
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,ti�� ►�3 �s P�
C1 71
F ile #: 318257 �� �� "l
1. Plaintiff is
OCWEN LOAN SERVICING, LLC
1100 VIRGINIA DRIVE
P.O. BOX 8300
FORT WASHINGTON, PA 19034
2. The name(s) and last known address(es) of the Defendant(s) are:
JOHN K. MCKOWN
RHONDA D. MCKOWN
1214 MITCHELL DRIVE
MECHANICSBURG, PA 17050 -3132
who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described.
3. On 11/19/2009 JOHN K. MCKOWN and RHONDA D. MCKOWN made, executed and
delivered a mortgage upon the premises hereinafter described to MORTGAGE
ELECTRONIC REGISTRATION SYSTEMS, INC AS NOMINEE FOR FAIRWAY
INDEPENDENT MORTGAGE CORPORATION, which mortgage is recorded in the
Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument
No. 200940377. By Assignment of Mortgage recorded 01/24/2013 the mortgage was
assigned to GMAC MORTGAGE LLC , which Assignment is recorded in Assignment of
Mortgage Instrument No. 201302640 The Assignment of Mortgage to PLAINTIFF is in
the process of being recorded. 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 10/01/2012 and each month thereafter are due and unpaid, and by the terms
File N: 318257
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.
& The following amounts are due on the mortgage as of 03/06/2013:
Principal Balance $183,737.26
Interest $3,539.47
09/01/2012 to 03/06/2013
Late Charges $240.03
Property Inspections $108.25
Escrow Deficit $917.09
Subtotal $188,542.10
Suspense Credit 145.50
TOTAL $188,396.60
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. 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.
File #: 318257
9. This action does not come under Act 91 of 1983 because the mortgage is FHA insured.
WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of
$188,396.60, 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
By:
Jo Lc ael Kolesnik, Esq., Id. No.308877
ey for Plaintiff
File #: 318257
LEGAL DESCRIPTION
ALL THAT CERTAIN piece or parcel of land situate in the Borough of Mechanicsburg, County
of Cumberland and State of Pennsylvania, bounded and described as follows, to wit
BEGINNING at a point on the North side of Mitchell Drive which point is at the division line of
Lots Nos. 22 and 23 on the hereinafter mentioned Plan of Lots; thence North 7 degrees 13
minutes 30 seconds West along said division line a distance of one hundred and ten (110) feet to
a point at the division line of Lot Nos. 6 and 22; thence North 82 degrees 46 minutes 30 seconds
East along said division line and beyond a distance of seventy (70) feet to a point at the division
line of Lots Nos. 21 and 22; thence South 7 degrees 13 minutes 30 seconds East along said
division line a distance of one hundred and ten (I 10) feet to a point on the Northern side of
Mitchell Drive; thence South 82 degrees 46 minutes 30 seconds West along aforementioned
Mitchell Drive a distance of seventy (70) feet to a point, the place of BEGINNING.
IT BEING Lot No. 22 on Section No.I Valley Stream Estates, which plan is recorded in and for
the County of Cumberland in Plan Book 13, page 6.
HAVING THEREON ERECTED a single family dwelling known and numbered as 1214
Mitchell Drive, Mechanicsburg, Pa. 17055.
UNDER AND SUBJECT to all conditions, restrictions and easements of record.
TAX MAP NO. 19 -23 -0569 -024
Pile N: 318257
BEING the same premises which Robert Lester Fry and Kathryn E. Fry, husband and wife, by
deed dated June 15, 2007 and recorded June 20, 2007 in the Office of the Recorder of Deeds in
and for Cumberland County, Pennsylvania, in Deed Book 280 page 2715 granted and conveyed
unto John K. McKown and Rhonda D. McKown, husband and wife.
PROPERTY ADDRESS: 1214 MITCHELL DRIVE, MECHANICSBURG, PA 17050 -3132
PARCEL # 19 -23 -0569 -024
Filc #: 318257
VERIFICATION
I,. Katelyn'*McCaaley
hereby state that I am Authorized Signer of
OCWEN LOAN SERVICING, LLC, mortgage servicing agent for Plaintiff in this matter. The
Plaintiff has delegated the mortgage servicing responsibility to OCWEN LOAN SERVICING,
LLC for the mortgage loan which is the subject of this action. Plaintiff lacks sufficient
information to make this verification because Plaintiff is not the entity which maintains the
business records for the mortgage. OCWEN LOAN SERVICING, LLC is in possession and
control of all documents and records supporting the statements in the foregoing complaint and
therefore the - servicer, rather than the Plaintiff, is the appropriate entity to make this verification.
I have reviewed the business records relating to this account, and am authorized to make
this verification. I hereby verify that the statements made 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. §4904 relating to unsworn
falsification to authorities.
DATE:
a e: Xatel cCaulay
Title: Authorized Signer,
OCWEN LOAN SERVICING, LLC
File #: 318257
Name: MCKOWN
File #: 277427
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
Fite #: 318257
FORM 1
IN THE COURT OF COMMON PLEA$
OCWEN LOAN SERVICING, LLC OF CUMBERLAND COUNTY, PENNSY NIi1r -�
Plaintiff(s) try C 'r''
vs. cW '
�.�
JOHN K. MCKOWN f y, cn
RHONDA D. MCKOWN Z+a c
Defendant(s) J 7 ivil ,y
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 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 to meet 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 submitte
S' Zy
Date ohm Michael Kolesnik, Esq., Id.
No.308877
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: State: Zip:
Is the property for sale? Yes ❑ No Listing date: Price: $
Realtor Name: Realtor Phone:
Borrower Occupied? Yes No EJ
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:
t Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
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:
I • Monthly Gross Monthly Net
2. Gross Montlily Net
3. Monthly Gross Monthly Net
Additional Income Description (not wages):
I 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 nd Mort a e Utilities
Car Pa ment s Condo/Neigh. Fees
Auto Insurance Med. not covered
Auto fuel/repairs Other prop-payment
Install. Loan Pa ment Cable TV
Child Su ort/Alim. Spending 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 lend'er's loan servicing
company:
Lender's Contact (Name): Phone:
Servicing Company (Name):
Contact: Phone:
UWe, 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. UWe understand that Uwe 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
at�iyxv of L:�t�rfbr�.��r'
Jody S Smith
Chief Deputy [
Richard W Stewart
Solicitor ��' �v
OFF 4E OF TH'i«:„!-:EFIFF
Ocwen Loan Servicing, LLC
vs. Case Number
John Kevin McKown (et al.) 2013-5117
SHERIFF'S RETURN OF SERVICE
09/17/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Rhonda McKown, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as"Not Found"at 1214 Mitchell Drive,
Mechanicsburg Borough, Mechanicsburg, PA 17050. Per ex-husband defendant does not reside at this
address but lives in West Virginia.
09/17/2013 06:20 PM- Deputy Ryan Burgett, 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:John
Kevin McKown at 1214 Mitchell Drive, Mechanicsburg Borough, Mechanicsburg, PA 17050.
RYAN BURGETT, D
09/19/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: Rhonda McKown, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure
Diversion Program and Complaint in Mortgage Foreclosure as"Not Served"at 590 E. Main Street,
Sutton, WV 26601. Per USPS.com"The address you provided is not recognized by the US Postal Service
as an address we serve. Mail sent to this address may be returned."
09/20/2013 Ronny R Anderson, Sheriff, who being duly sworn according to law, states that he served the within
Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure
upon the within named defendant, Rhonda McKown, in the following manner: On September 20, 2013 the
Sheriff mailed by certified mail, return receipt requested a true and correct copy of the within Notice of
Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure to the
defendant's last known address of 590 W. Main Street, Sutton, West Virginia 22601.The certified mail
return receipt card was received by the Cumberland County Sheriffs Office signed by Rhonda McKown
on 09-27-13. NOTE: Mail was forwarded to 71 Summit Center Circle, Sutton,WV 26601.
SHERIFF COST: $61.81 SO ANSWERS,
October 01, 2013 RbNW R ANDERSON, SHERIFF
tc)CountySuite Sheriff,Teleosoft,Inc.
WWI
■ 00mpte2e!Cams 1,2,and 8.Also c ornpkate
Item 4 H Res ftW DQvaty is clerked.
■ Print you rams and address on the reverse C . � Addressee
so that we can return the card to you. by( C.9de of Delivery
■ Attach this car to the back of the ma�lipkjce, :171C,c 3
or on the!Lo ,space permits.
D. Is delivery d rietent from Ham I?
1. Article Add to: If YES,enter delivery below.
'71 5u� f"tP,;>4�
Rhonda McKown
590 W. Main Street
Sutton,WVA 22601 a servton"
O Cermw Mail Cl Express Mail
O RgMmW D Return Receipt for Mer charrdise
O inured Mali ❑C.O.D.
4. Restricted Delivery?Pft Fee) ❑Yes
2. ArWe Number -
�nrrr 7007 0710 0003 22-10 3672--
Fit Fbhh 38 1; i iri Receipt fa¢ a¢tic rsao
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A
AFFIDAVIT OF SERVICE
PLAINTIFF CUMBERLAND COUNTY
OCWEN LOAN SERVICING,LLC
PH#812015 -
DEFENDANT SERVICE TEAM/bsp
JOHN K.MCKOWN COURT NO.: 13-5117-CIVIL
RHONDA D.MCKOWN
SERVE RHONDA D.MCKOWN AT: TYPE OF ACTION
71 SUMMIT CENTER CIR XX Mortgage Foreclosure
SUTTON,WV 26601-6380 XX Civil Action
SERVED 57 , (
Served and made own to RHONDA D.MCKOWN,DDfendant on the I day of N" ,20 3,at
(D 100,o'clock i M.,at 7 1 5.4 meh If C(fl4 , L,/ ,in the manner described below:
l�Defendant personally served.
7— -,,,v•
_Adult family member with whom Defendant(s)reside(s). In
Relationship is . = - r;
Adc;lt in charge of Defendant's residence who refused to give name or relationship. U> - ,...,
_Manager/Clerk of place of lodging in which Defendant(s)reside(s). _,�? r"
Agent or person in charge of Defendant's office or usual place of business. ........... �'"
an officer of said Defendant's company. 'C) m'
_Other: C .) ` ',
Description: Age Height Weight Race Sex Other ---k -
--.."
.
J W1,oS5
I, Jr Ain WI , a competent adult,being duly sworn according to law, depose and state that I personally
handed a true and correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned
case on the date and at the address indicated above.
Sworn to and subscribed
before me this day —& LO.i., ..l_
of ,20 .
Notary: B y:
NOT SERVED
On the day of ,20_,at o'clock .M.,I, ,a competent adult hereby state that
Defendant NOT FOUND because:
_Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant)
No Answer on at ,•
at
—
Service Refused
Other:
Sw. to and : bscribed (� y
be':,e m t 120 7day B 2j14/
�' ATTORNEY FOR PLAINTIFF Chrisovalante P.Fliakos,Esq.,Id.No.94620
Lawrence T.Phelan,Esq.,Id.No.32227 Courtenay R.Dunn,Esq.,Id.No.206779
Francis S.Hallinan,Esq.,Id.No.62695 Allison F.Zuckerman,Esq.,Id.No.309519
Daniel G.Schmieg,Esq.,Id.No.62205 Melissa J.Cantwell,Esq.,Id.No.308912
Michele M.Bradford,Esq.,Id.No.69849 Mario J.Hanyon,Esq.,Id.No.203993
Judith T.Romano,Esq.,Id.No.58745 John M.Kolesnik,Esq.,Id.No.308877
Jenine R.Davey,Esq.,Id.No.87077 Matthew G.Brushwood,Esq.,Id.No.310592
Lauren R.Tabas,Esq.,Id.No.93337 Zachary J.Jones,Esq.,Id.No.310721
Jay B.Jones,Esq.,Id.No.86657 Justin F.Kobeski,Esq.,Id.No.200392
Andrew L.Spivack,Esq.,Id.No.84439 Adam Davis,Esq.,Id.No.203034
JOSEPH E.DEBARBERIE,Esq.,Id.No.
315421
Official Seal
° b; Notary Public,State Of West Virginia
A James K Teranpo
�� }= 107 Brannon Street
..%. Stonewood WV 26301
My commission expires May 22.2022
r PRO TH1:0NU TA E .I
213 DEC 1 2910 34
CUMBERLAND COUNTY
PENNSYLVANIA
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
OCWEN LOAN SERVICING,LLC • Court of Common Pleas
Plaintiff
Civil Division
v.
•
CUMBERLAND County
JOHN K.MCKOWN •
RHONDA D.MCKOWN • No. 13-5117-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.
n 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.
I- Please Vacate the Judgment entered.
Date: 1 a, I'' I✓ PHELAN HALLIN ,LLP
By: AA 1A ! 'WilYdei4
Meredith W-
ooters,Esq.,Id.No.307207
Attorney for Plaintiff
PH#812015
Phelan Hallinan,LLP Attorney For Plaintiff
1617 JFK Boulevard,Suite 1400
One Penn Center Plaza
Philadelphia,PA 19103
215-563-7000
OCWEN LOAN SERVICING,LLC • Court of Common Pleas
Plaintiff •
•
Civil Division
v.
CUMBERLAND County
JOHN K.MCKOWN
RHONDA D.MCKOWN No. 13-5117-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:
JOHN K. MCKOWN
1214 MITCHELL DRIVE
MECHANICSBURG,PA 17050-3132
RHONDA D.MCKOWN
71 SUMMIT CENTER OR
SUTTON,WV 26601-6380
Date: 't� ( � I I `� PHELAN HALLINAN LLP
1 VIAJ6t"
By: ' /
Meredith Wooters, Esq., Id. No.307207
Attorney for Plaintiff