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HomeMy WebLinkAbout13-6469 For Prothonotary Use Only: Supreme. Court cf Pe nnsylvani a. P4 2 n2 rt bf �Co ; �i P' lea: S d.Cwa� Docket No.., '. and '. unty The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and ser of lead s or other papers as required b y law or rules of court. Commencement of Action: ® Complaint ❑ Writ of Summons ❑ Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking E v C ; Lead Plaintiffs Name: Federal National Mortgage Association Lead Defendant's Name: George Shughart Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits O (check one) ❑ outside arbitration limits Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppear ❑ Yes ® No �s A Name of Plaintiff /Appellant's Attorney: McCabe, Weisberg & Conwav, P.C. 13 Check here if you have no attorney (a Self- Represented [l'ro 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) ❑ Slander /Libel/ Defamation ❑Employment Dispute: E ❑ Other: Discrimination C ❑ Employment Dispute: Other 13 Zoning Board z�T ❑ Other s ,i ❑ Other MASS TORT N ❑ 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 11 Mortgage Foreclosure: Commercial ❑Quo Warranto ❑ Dental ❑ Partition P ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: 1 J' Updated 1/1/2 28 3 r Pt - k Ns yt 'BOUNTY' 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 - 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 Federal National Mortgage Association Cumberland County 14523 SW Millikan Way, Suite 200 Court of Common Pleas r Beaverton, OR 97005 � / _ � / / _ � Number 1 J (,,Cl `7 (I[ V. George Shughart 34 Prickly Pear Drive Carlisle, PA 17013 and Michael Rynard a/k/a Michael L. Rynard 34 Prickly Pear Drive Carlisle, PA 1.7013 and Alan G. Davis 34 Prickly Pear Drive Carlisle, PA 17013 COMPLAINT IN MORTGAGE FORECLOSURE p File # 74360 6 0 Page l 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, is 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 # 74360 Page 2 COMPLAINT IN MORTGAGE FORECLOSURE I. Plaintiff is Federal National Mortgage Association, a corporation organized and existing under the laws of the United States with its principal place of business at 3900 Wisconsin Avenue NW, Washington, DC 20016, with all pleadings and correspondence to be sent C/O Seterus, Inc. at 14523 SW Millikan Way, Suite 200, Beaverton, OR 97005, by and through service on the undersigned counsel. 2. The Defendant is George Shughart, who is a mortgagor and real owner of the mort gaged property hereinafter described, whose last -known address is 34 Prickly Pear Drive, Carlisle, PA 17013. 3. The Defendant is Michael Rynard a/k/a Michael L. Rynard, who is a mortgagor and real owner of the mortgaged property hereinafter described, whose last -known address is 34 Prickly Pear Drive, Carlisle, PA 17013. 4. The Defendant is Alan G. Davis, who is a mortgagor and real owner of the mortgaged property hereinafter described, whose last -known address is 34 Prickly Pear Drive, Carlisle, PA 17013. 5. On January 3, 2008, George Shughart, Michael Rynard a/k/a Michael L. Rynard, and Alan G. Davis, mortgagors, made, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc. as Nominee for SunTrust Mortgage, Inc., which mortgage is recorded in the Office of the Recorder of Cumberland County as Instrument Number 200800707 (the "Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 6. On June 13, 2011, the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc., to SunTrust Mortgage, Inc., by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 2011 l 8228, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. Mortgage Electronic Registration Systems, Inc. was acting in its capacity as Nominee.for Suntrust Mortgage, Inc. " 7. On May 28, 2013, the Mortgage was assigned by SunTrust Mortgage, Inc., to Federal National Mortgage Association, Plaintiff herein, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 20131.7525, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. File # 74360 Page 3 8. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 123 Elm Street, Carlisle, Pennsylvania 17013. 9. The mortgage is in default because monthly payments of principal and interest upon said mortgage due March 1, 2013 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: Principal Balance $ 90,845.59 Interest through November 1, 2013 $ 4,161.79 (Plus $15.24 per diem thereafter) Late Charges $ 59.78 Attorney's Fee $ 1,650.00 Escrow Advance $ 2,339.57 Property Inspections $ 75.00 GRAND TOTAL $ 99,131.73 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. Plaintiff complied with all notice requirements as prescribed by 41 P. S. § 101, et seq. (Act 6), and 35 P.S. 1680.401c, et seq. (Act 91), as applicable. WHEREFORE, Plaintiff demands in rein Judgment against the Defendants in the sure of $99,131.73, together with interest at the rate of $15.24 per diem and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISBERG & CO / WAY, P.C. BY: Gfi'L (N [ ] 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 [ ] Christine L. Graham, Esquire [ ] Brian T. LaManna, Esquire [ ] Ann E. Swartz, Esquire [ j Joseph F. Riga, Esquire [ ] Joseph 1. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire Attorneys for Plaintiff File # 74360 Page 4 VERIFICATION The undersigned, Lisa Lubbess , does hereby certify that he /she is Foreclosure Specialist of Seterus Inc. and that Seterus Inc. has been duly nominated and appointed by Federal National Mortgage Association , plaintiff herein, as its mortgage servicing agent in regard to the mortgage loan which is the subject of this action (the "Mortgage "). Federal National Mortgage Association lacks sufficient information to make this verification because Plaintiff is not the entity that maintains the business records for the Mortgage. Seterus Inc., in its capacity as mortgage servicing agent for Federal National Mortgage Association , maintains the business records for the Mortgage, and therefore does have sufficient information to make this verification in accordance with Pa.R.C.P. 1024(c)(1). I am authorized to make this Verification on Plaintiff s behalf and do hereby verify that the facts as set forth in the foregoing Complaint are true and correct to the best of my information and belief. I have access to and have reviewed the business records of Seterus Inc. for and relating to the Mortgage, and I make this Verification based on my review of those records, which are maintained by Seterus Inc. in the course of its regularly conducted business activities and are made at or near the time of the event, by or from information transmitted by a person with knowledge. . I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Dated: l O P-C - -Q—D 1 By: ! J Name: Lisa Lubbess Title: Foreclosure Specialist Name: Federal National Mortgage Association v. George Shughart, Michael Rynard a/k/a Michael L. Rynard and Alan G. Davis Loan Number ending with: 8473 File # 74360 Page 5 nb/22/2013 13:37 570- 374 -4761 ~ — HARVEY P MURRAY JR PAGE 17/18 EXHIBIT A ALL THAT CERTAIN messuage or tenement and half lot of ground situated in the First Ward of the Borough of Carlisle, in the County of Cumberland, and State of Pennsylvania, bounded and described as follows: ON the South by Elm Street; on the West by other half of lot now or formerly of Mrs. Walker, on the north by an alley along C.V.R.R tract, and on the east by lot now or formerly of Edgar B. Heckman; containing twenty feet In front of Elm Street and extending an even width one hundred and forty eight feet in depth to the aforesaid alloy, more or less. . , CUMBERLAND COUNTY inst.# 200800707 - Page 18 0! FORM 1 Federal National Mortgage Association IN THE COURT OF COMMON PLEA�O:F Plaintiff CUMBERLAND COUNTY, PENNSY.T s •t ; � �c k° LA cjn "jam: George Shughart, Michael Rynard a/k /a Michael L. Civil -s Rynard and Alan G. Davis C' CD Defendants -.-- 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: ( -� VA" 1 Date [Signature of Counsel for Plaintiff] 74360 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 ER/PRI 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 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: $ $ 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 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. I 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 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 ❑ 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: r Proof of income Past 2 bank statements Proof of any expected income for the last 45 days f Copy of a current utility bill r 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 RAnderson Sheriff Jody S Smith Chief Deputy Richard W Stewart xC Lri NJ Solicitor PE�i"-SYL`'Atill A Federal National Mortgage Association Case Number vs. George Shughart (et al.) 2013-6469 SHERIFF'S RETURN OF SERVICE 11/07/2013 03:51 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 Tracey Sposito, Tenant, who accepted as"Adult Person in Charge"for Occupant at 123 Elm Street, Carlisle Borough, Carlisle, PA 17013. J ER, DEPUTY 11/07/2013 03:51 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Alan G Davis, 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 123 Elm Street, Carlisle Borough, Carlisle, PA 17013. Tenant at this address never heard of defendant. 11/21/2013 11:38 AM- Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit:Alan G Davis, 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 34 Prickly Pear Drive, North Middleton Township, Carlisle, PA 17013. Deputies were unable to make contact wtih anyone at this address to effectuate service, but were given another possible address of 516 Longs Gap Road, Carlisle, PA. 11/25/2013 10:57 AM - Deputy Jeff Kolodzi, 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: Michael L.Rynard at 1 Codorus Creek Court, North Middleton Township, Carlisle, PA 17013. <��, a�A& JEPPt K LODZI, DEPUTY 11/25/2013 11:05 AM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Alan G Davis, 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 f ogund"at 516 Longs Gap Rd, North Middleton Township, Carlisle, PA 17013. Defendant does not reside at his address. 12/05/2013 08:12 PM - Deputy Shawn Gutshall, 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: eo�qe Shughart at 34 Prickly Pear Drive, North Middleton Township, Carlisle, PA 17013. HAWN GUTSHALL, SHERIFF COST: $115.68 SO ANSWERS, December 06, 2013 RON R ANDERSON, SHERIFF McCABE, WEISBERG AND CONWAY, P.C. 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 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Federal National Mortgage Association Plaintiff v. Michael Rynard a/k/a Michael L. Rynard, George Shughart and Alan G. Davis Defendants TO THE PROTHONOTARY: P� IQ PO I Y . PENNSYLVANIA �r CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 13 -6469 Civil PRAECIPE ® 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: ‘1/7// % McCAB .. SBER BY: [ ] Te ce J. McCabe, Es [ ] E s ward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff ONWAY, P.C. [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. Joseph I. Foley, Esq. [ ] Jennifer L. Wunder, Esq. McCABE, WEISBERG AND CONWAY, P.C. 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 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790 -1010 Federal National Mortgage Association Plaintiff v. Michael Rynard a/k/a Michael L. Rynard, George Shughart and Alan G. Davis Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 13 -6469 Civil 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 2 day of April, 2014. Michael Rynard a/k/a Michael L. Rynard 34 Prickly Pear Drive Carlisle, Pennsylvania 17013 George Shughart 34 Prickly Pear Drive Carlisle, Pennsylvania 17013 DATE: w/ / I %"/ McCABE, WEIS BY: [ ] Terrence J. Mc : e, Esq. [ ] Edward D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. Attorneys for Plaintiff Alan G. Davis 34 Prickly Pear Drive Carlisle, Pennsylvania 17013 CON [ ] M ieisberg, Esq. [ ] Margaret air , Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. LA]- Joseph 1. Foley, Esq. [ ] Jennifer L. Wunder, Esq.