The URL can be used to link to this page

Home My WebLink About13-5762 For Prothonotary Use Only: S�upr�em�e �Ci�urt pf' P'��e�nnsyIvania, C0 to C,rmtl ��J ;P' lea .� Docket No. b .and �} f,. J The ii ?formation collected on this fw-m is used solelyfot• cotirt actiniiiistration putI.)oses. This form does not su »lenient or replace thefi and service o pleadin s or other papers as- req uired by law or rules o court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: EverBank Lead Defendant's Name: Brett R. Otto 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 I Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff /Appellant's Attorney: McCabe. Weisberg & Conway. P.C. ❑ Check here if you have no attorney (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 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 ❑ Department of Transportation ❑ Premises Liability (does not include ❑ Statutory Appeal: Other S mass tort) E ❑ Slander/Libel/ Defamation ❑ Employment Dispute: ❑ Other: Discrimination C ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other I O ❑ Other N MASS TORT ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant B ❑ Toxic Waste REAL PROPERTY MISCELLANEOUS ❑ Other: ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Disput ❑ 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: Updated 1/1/2011 C:) C-) c -� M CU C:) --4 7 0 CD (J) r— '<> CD T+y C= co < � -• 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 - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. COHEN, ESQUIRE - ID # 87830 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 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790 -1010 EverBank Cumberland County 301 West Bay Street Court of Common Pleas Jacksonville, FL 32202 ^ — Number ., el y I V. Brett R. Otto 20 Chestnut Street Mount Holly Spring, PA 17065 and Kelley Anne Otto 20 Chestnut Street Mount Holly Spring, PA 17065 COMPLAINT IN MORTGAGE FORECLOSURE e,vLL quLls? File # 66111 Page 1 NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within ex- puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se defiende, la corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notificacion. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisioner de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO TIENE BELOW. THIS OFFICE CAN PROVIDE A UN ABOGADO, VA A O TELEFONEA YOU WITH INFORMATION ABOUT LA OFICINA EXPUSO ABAJO. ESTA HIRING A LAWYER. OFICINA LO PUEDE PROPORCIONAR IF YOU CANNOT AFFORD TO CON INFORMATION ACERCA DE HIRE A LAWYER, THIS OFFICE MAY BE EMPLEAR A UN ABOGADO. ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE INFORMATION ABOUT AGENCIES THAT PROPORCIONAR PARA EMPLEAR UN MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, PA 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990 -9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990 -9108 File # 66111 Page 2 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is EverBank, duly organized and doing business at the above - captioned address. 2. The Defendant is Brett R. Otto, who is a mortgagor and real owner of the mortgaged property hereinafter described, whose last -known address is 20 Chestnut Street, Mount Holly Spring, PA 17065. 3. The Defendant is Kelley Aisne Otto, who is a mortgagor and real owner of the mortgaged property hereinafter described, whose last -known address is 20 Chestnut Street, Mount Holly Spring, PA 17065. 4. On September 30, 1993, Brett R. Otto and Kelley Anne Otto, mortgagors, made, executed and delivered a mortgage upon the premises hereinafter described to GMAC Mortgage Corporation of PA, which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1168, Page 252 (the "Mortgage "), such Mortgage being incorporated herein by reference pursuantto Rule 1019(g) Pa. R. C. P. 5. On February 1, 1995, the Mortgage was assigned by GMAC Mortgage Corporation of PA, a Pennsylvania Corporation, to Dovenmuehle Mortgage Company L.P., a Delaware Limited Partnership, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Mortgage Book 490, Page 849, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 6. On September 1, 2003, the Mortgage was assigned by Dovenmuehle Mortgage Company, L.P., a Delaware Limited Partnership, to Mortgage Electronic Registration Systems, Inc., a Delaware Corporation, its successors and assigns, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County in Mortgage Book 71.5, Page 3244, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 7. On June 5, 2012, the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc., a Delaware Corporation, its successors and assigns, to EverBank, Plaintiff herein, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201217052, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. File # 66111 Page 3 8. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 20 Chestnut Street, Mt Holly Spring, Pennsylvania 17065. 9. The mortgage is in default because monthly payments of principal and interest upon said mortgage due November 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. 10. The following amounts are due on the mortgage As of 09/09/13: Principal Balance $ 39,314.62 Interest through September 9, 2013 $ 2,536.88 (Plus $7.41 per diem thereafter) Late Charges $ 165.55 Attorney's Fee $ 1,650.00 Property Inspections $ 80.00 Escrow Advance $ 1,504.51 GRAND TOTAL $ 45,251.56 The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's 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. 11. 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 rem Judgment against the Defendants in the sum of $45,251.56, together with interest at the rate of $7.41 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. BY: [ ] Terrence J. Cabe, Esquire [-.4 -Marc S. Weisberg, "tsquire [ ] Edward D. Conway, Esquire [ ] Margaret Gairo, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Heidi R. Spivak, Esquire [ ] Marisa J. Cohen, Esquire [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ ] Joseph F. Riga, Esquire [ ] Joseph I. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire Attorneys for Plaintiff File # 66111 Page 4 VERIFICATION The undersigned, an officer of the Corporation which is the Plaintiff in the foregoing Complaint or an officer of the Corporation which is the servicing agent of Plaintiff, and being authorized to make this verification on behalf of Plaintiff, hereby verifies that the facts set forth in the foregoing Complaint are taken from records maintained by persons supervised by the undersigned who maintain the business records of the Property held by Plaintiff in the ordinary course of business and that those facts are true and correct to the best of the knowledge, information and belief of the undersigned. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA.C.S SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: NAME: P o I bin � urdock TITLE: VICe re ( pent COMPANY: EverBank v. Brett R. Otto and Kelley Anne Otto File # 66111 Page 5 EXHIBITA ALL TFfA1` CERTAIN fat of gmutld hgwwcd with a parsonage si[uate in the Borough of Mount Hotly Springs, Cumberland County, Pennsydvatie, bounded u follows: ON the North by lot now cc foupetly of Oemp W. Kinsce, on the East by an alley, on the Somb by lands tow or formerlyy d] C. '(Pine & wife, and on the West by Chestnut Sheet being 40 feet in front mid 184 feet in depth f:AI'i Jt POnnsylwnta Sr 1;,,••.r'otfumtmrland � ' .1 m tha Ory7Cr Mr the recording of Deeds in r•. r ,b,agrn) Caun a- r ',i��rlcv�� -_ yet r r, my h� �' swY' off, tT • • 'T eoax1168 Pact 2 05/02/2012 10:40:21 AM CUMBERLAND COUNTY Inst.# 199336142 - Page 7 of 7 FORM l EverBank IN .THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA C . vs. C 2m � rn�= .Brett R. Otto and Kelley.Anne Otto 11 SW Civil �7J --4 - r r,, :Defendants -<> � - r c C p NOTICE OF RESIDENTIAL MORTGAGE FORECL tM > 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. �R�s ectfully submitted: 10 41 am Date [ ignature of Counsel for Vlaintiff] 66111 Page 1 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 •• 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? CO-BORROWER Mailing Address (if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: # of people on household: How long? INFORMATION FINANCIAL 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: $ $ 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. 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 SupportlAlim. 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 ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 2 a 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 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 F 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) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ot Climb Jody S Smith I•i ,i.? _ .. Chief Deputy Richard W Stewart OC i ri i. + - Solicitor ERIFr- 11 IBE I-U C.J ;.;J ti C; ',,, PENNSYLVANIA EverBank Case Number vs. Brett R. Otto(et al.) 2013-5762 SHERIFF'S RETURN OF SERVICE 10/08/2013 09:17 PM - Deputy Dawn Kell, 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: Brett R. Otto at 20 Chestnut Street, Mount Holly Springs Borough, Mount Holly Springs, PA 17065.17 `) ,, DAWN KELL, DEPUTY 10/08/2013 09:17 PM- Deputy Dawn Kell, 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 Brett Otto, Husband. , who accepted as"Adult Person in Charge"for Kelley Anne Otto at 20 Chestnut Street, Mount Holly Springs Borough, Mount Holly Springs, PA 17065. . kid)0 DAWN KELL, DEPUTY SHERIFF COST: $51.91 SO ANSWERS, October 09, 2013 RONR ANDERSON, SHERIFF (rj Cou^tySui;e Sheriff Te eosot. nc. 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 �r4 MARGARET CAIRO,ESQUIRE-ID# 34419 ANDREW L.MARKOWITZ,ESQUIRE-ID#28009 �r; -. 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 ==CD `- JOSEPH F.RIGA,ESQUIRE-ID#57716 ] =' JOSEPH I.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1.010 EverBank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. No. 13-5762 Brett R. Otto and Kelley Anne Otto 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: lI 11 McCAB SBERG NWAY,P.C. BY: t [ ]Te nce J.McCabe,Es ire ]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 [ ]Amt E. Swartz,Esquire [ ]Joseph F.Riga,Esquire [/+Joseph I.Foley,Esquire [ ]Celine P.DerKrikorian,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 CAIRO,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 1.FOLEY,ESQUIRE-ID#314675 CELINE P.DERKRIKORIAN,ESQUIRE-ID#313673 123 South Broad Street,Suite 1400 Philadelphia,Pennsylvania 19109 (215)790-1010 EverBank CUMBERLAND COUNTY Plaintiff COURT OF COMMON PLEAS V. No. 13-5762 Brett R.Otto and Kelley Anne Otto 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 day of December,2013. Brett R.Otto 20 Chestnut Street Mount Holly Spring,Pennsylvania 17065 Kelley Anne Otto 20 Chestnut Street Mount Holly Spring,Pennsylvania 17065 DATE: McCABE,WEI G AND CQNWAY,P.C. BY: [ ]Terrence cCabe,Esquire arc . eisberg,Esquire [ ]Edward D.Conway,Esquire [ j 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 [ ]Celine P.DerKrikorian,Esquire Attorneys for Plaintiff