Loading...
HomeMy WebLinkAbout14-0619 3 >� For Prothonotary Use Only: 'fitipr e:m e Co rtpf Pennsylvania cou 0 n P 1 ea S CUm?bC� -la[td Docket No. v 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 papers as required by law or rules of court. Commencement of Action: 0 Complaint ❑ Writ of Summons ❑ Petition Sf ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking Lead Plaintiffs Name: Wilmington Savings Fund Society, FSB, Not In Its Lead Defendant's Name: Sandra K. Mitchell µ C¢} Individual Capacity But Solely As Trustee Of The Primestar -H Fund 1 T Trust I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: ❑ within arbitration limits O N (check one) ❑ outside arbitration limits Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ Yes ® No 4 Name of Plaintiff/Appellant's Attorney: McCabe, Weisberg & Conway, P.C. ❑ Check here if you have no attorney a Self-Represented :Pro Se Litigant Y Y� p l 1 w° 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 .;E:;, •" 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 1 ❑ 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 ❑Zoning Board ❑ Other 40g' ❑ 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 ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Replevin ❑ Dental ❑ Partition p ...,u'. ❑Legal 11 Quiet Title ❑ Other: ❑ Medical ❑ Other: �...� ❑Other Professional: r "x Updated 1 /1/2011 Y co V4�di� 7r 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 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215 790 -1010 Wilmington Savings Fund Society, FSB, Not Cumberland County In Its Individual Capacity But Solely As Court of Common Pleas . . Trustee Of The Primestar -H Fund I Trust 5680 Greenwood Plaza Blvd Number #100 S Greenwood Village, CO 80111 V. Sandra K. Mitchell 23 Wheatfield Drive Carlisle, PA 17013 and Judy R. Mitchell 23 Wheatfield Drive Carlisle, PA 17013 COMPLAINT IN MORTGAGE FORECLOSURE C.L4 File 39099 V�o NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la carte. 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 at partir de la notice are served, by entering a written fecha de la demanda y la notification. 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 corre 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 torte judgment may be entered against you by the tomaramedidas ypuede continuarla demanda court without further notice for any money en contra suya sin previo aviso o notification. claimed in the complaint or for any other Adernas, la torte 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 provisions 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 P A P E L A S U 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 AB OGADO. ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE INFORMATION ABOUT AGENCIES THAT PROPORCIONAR PARR EMPLEAR UN MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT AREDUCED 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 # 39099 Page 2 This is a communication from a debt collector who is attempting to collect a debt, and any information obtained will be used for that purpose. Please Note: (1) unless, within thirty (30) days after your receipt of this notice, you dispute the validity of the debt, or any portion of the debt, we will assume that the debt is valid; (2) if you notify us in writing within thirty (30) days of your receipt of this notice that the debt, or a portion of the debt, is disputed, we will cease collection of the debt until we obtain verification of the debt or a copy of the judgment against you and mail to you a copy of the verification or judgment that we obtain; (3) upon your written request to us within thirty (30) days of your receipt of this notice for the name and address of the original creditor of your debt, we will cease collection of the debt until we mail to you the name and address of the original creditor, if different from the current creditor. Case Name: Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar -H Fund I Trust v. Sandra K. Mitchell and Judy R. Mitchell Cumberland County Pile # 39099 Page 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust. 2. The Defendant is Sandra K. Mitchell, who is a mortgagor and real owner of the mortgaged property hereinafter described, whose last -known address is 23 Wheatfield Drive, Carlisle, PA 17013. 3. The Defendant is Judy R. Mitchell, who is a mortgagor and real owner of the mortgaged Property hereinafter described, whose last -known address is 23 Wheatfield Drive, Carlisle, PA 17013. 4. On June 8, 2007, Sandra K. Mitchell and Judy R. Mitchell, mortgagors, made, executed and delivered amortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc. ( "MERS ") asnominee for Lighthouse Mortgage Service Company, Inc., its successors and assigns which mortgage is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1995, Page 3000 (the "Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 5. On March 27, 2012, the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc. ( "MERS ") as nominee for Lighthouse Mortgage Service Company, Inc., its successors and assigns to EMC Mortgage LLC, its successors and assigns, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201211528, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 6. On October 4, 2013, the Mortgage was assigned byEMC Mortgage LLC, its successors and assigns to Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar -H Fund I Trust, Plaintiff herein, by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201336702, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. File # 39099 page 4 7. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 23 Wheatfield Drive, Carlisle, Pennsylvania 17013. 8. The mortgage is in default because monthly payments of principal and interest upon said mortgage due January 1, 2011 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. 9. The following amounts are due on the mortgage: Principal Balance $ 239,721.01 Interest through January 9, 2014 $ 14,901.20 (Interest due and owing at a variable rate, currently $13.14 per diem) Late Charges $ 1,281.84 Attorney's Pee $ 1,650.00 Escrow Advance $ 6,885.67 Property Inspection Fees $ 80.15 Funds Owed to Borrowers $ (65.23) GRAND TOTAL $ 264,454.64 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. 1 10. 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. Pile # 39099 Page 5 i WHEREFORE, Plaintiff demands in rem Judgment against the Defendants in the sum of $264,454.64, together with interest due and owing at a variable rate, currently $13.14 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. McCabe, Esquire arc S. Weisberg, Es e [ ] 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 [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff Pile # 39099 Page 6 VERIFICATION The undersigned, ck MC0rxyw -A does hereby certify that he /she is 1�0.+rlo�c� i n 1 4'e C - 6( - of Statebridge Company, LLC and that Statebridge Company, LLC has been duly nominated and appointed by Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestax -H Fund I Trust, plaintiff herein, as its mortgage servicing agent in regard to the mortgage loan which is the subject of this action (the "Mortgage "). Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust lacks sufficient information to make this verification because Plaintiff is not the entity that maintains the business records for the Mortgage. Statebridge Company, LLC, in its capacity as mortgage servicing agent for Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar -H Fund I Trust, 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 Statebridge Company, LLC for and relating to the Mortgage, and I make this Verification based on my review of those records, which are maintained by Statebridge Company, LLC 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 unworn falsification to authorities. Dated: /U / I By: Name: O P010 Title: (Y \cu�a���.s��recA - o Nance: Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar -H Fund I Trust v. Sandra K. Mitchell and Judy R. Mitchell Loan Number ending with: 4432 File # 39099 Page 7 Exhibit "All Exhibit A ALL THOSE CERTAM piece or parcel of land situtete In Middlesex Township, Cumberland County, Pennsylvania, known as Lot 01, as described in accordance with subdivision plan of the Meadows, Plan #2, by Ronald S. Rafl'ensperger, Registered Surveyor, dated September 18, 1986, and recorded in Cumberland County Plan Book 52, Page 142, more particularly bounded and described as follows to wit: BEGMUNG at a point on the eastern right of way line of Wheatfield Drive, said point being referenced and located 155.50 feet South of the intersection of the Eastern right of way line of Wheatfield Drive and the Southera right of way line of Wild Rose Circle; thence along Lot No. 34 North 85 degrees 25 minutes East a distance of 157.27 feet to a point at Lot No. 32; thence along Lot No. 32 South 4 degrees 35 minutes East a distance of 150.00 feet to a point at the now Northern night of way line of Wheatfield Drive; thence along said night of way and a curve to the right having a radius of 150.00 feet an are length of 235.61 feet to a paint, the place of B'EGE414I YG. BEING KNOWN as 23 Wheatfield Drive, Carlisle, PA 17013. Btf 1995PG3017• 1 f , FORM 1, Wilmington Savings Fund Society, FSB, Not In Its IN THE COURT OF COMMON PLEAS OF Individual Capacity But Solely As Trustee Of The CUMBERLAND COUNTY, PENNSYLVANIA Primestar -H Fund I Trust Plaintiff _ , ." VS. Civil ra Sandra K. Mitchell and Judy R. Mitchell Defendants Co 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: Date [Signature of Counsel for Plaintif 39099 Page 1 _ a 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 Ell/1'111 N1 ARY 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 2n 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 /Tuit. 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: f Proof of income Past 2 bank statements Proof of any expected income for the last 45 days 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 R Anderson i y; } Sheriff - tk *" ; of `�arst� Jody S Smith " Chief Deputy ' 2E4 FEB 28 PM U ' Richard W Stewart + + Solicitor CUMBERLAND CC:„ir E PENNSYLVANIA Wilmington Savings Fund Society, FSB Case Number vs. Sandra K Mitchell (et al.) 2014-619 SHERIFF'S RETURN OF SERVICE 02/12/2014 09:30 AM - Deputy Amanda Ebersole, 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 Judy Mitchell, Daughter in Law, who accepted as "Adult Person in Charge"for Sandra K Mitchell at 23 Wheatfield Drive, Middlesex Townhip, Carlisle, PA 17013. A 'note s309--i0 AMA DA EBERSOLE, DEPUTY 02/12/2014 09:30 AM - Deputy Amanda Ebersole, 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: Judy R Mitchell at 23 Wheatfield Drive, Middlesex Township, Carlisle, PA 17013. tilt 1I 41.'1 AMANDA EBERSOLE, DEPUTY 02/19/2014 The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure returned by the Sheriff of Dauphin County, the within named Defendant Judy R Mitchell, not found. Hon. Jack Lotwick, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $74.78 SO ANSWERS, February 24, 2014 RONNY R ANDERSON, SHERIFF Shelley Ruhl y '' i Jack Duignan Real Esta e Deputy V ,� Chief Deputy ai∎Z .,4*�-4 Matthew L. Owens ��+�� •.,..� Michael W. Rinehart Solicitor Assistant Chief Deputy Dauphin County 101 Market Street Harrisburg,Pennsylvania 17101-2079 ph:(717)780-6590 fax:(717)255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania • WILMINGTON SAVINGS FUND SOCIETY, FSB, ET AL VS County of Dauphin • JUDY R. MITCHELL Sheriffs Return No. 2014-T-0375 OTHER COUNTY NO. 2014-619 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for JUDY R. MITCHELL the DEFENDANT named in the within COMPLAINT IN MORTGAGE FORECLOSURE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, FEBRUARY 19, 2014. PER DEFENDANT WHO CALLED INTO OFFICE, ADDRESS 4011 NANCY DRIVE, HARRISBURG, PA 17109 IS HER MOTHER-IN-LAWS RESIDENCE AND THE DEFENDANT DOES NOT RESIDE THERE. GOOD ADDRESS FOR THE DEFENDANT IS 23 WHEATFIELD DRIVE, CARLISLE, PA. Sworn and subscribed to So Answers,! before me this 19TH day of February, 2014 p i�"`L C_ Sheriff of Dauphin County, Pa. By ..JA .1L .I , /it COMMONWEALTH OF PENNSYLVANIA Deputy Sher n f f NOTARIAL SEAL Deputy: M• AN TRITT Karen M.Hoffman,Notary Public Sheriffs Costs: $47.25 2/11/2014 City of Harrisburg,Dauphin County My Commission Expires January 8,2018 FORM 3 Wilmington Savings Fund Society, : IN THE COURT OF COMMON PLEAS OF C71 FSB, Trustee of The Primestar -H 0 : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) r-i t'-3 Cr) 7- fli vs. -<' Sandra K. Mitchell and < .11i iv R Mitnhall o : 14 -619 ›`' Defendant(s) Civil cz: REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated G,bcvl.Q% , 2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property, which is defendant's primary residence; 3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion Program: and has taken all of the steps required in that Notice to be eligible to participate in a court- supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of De �. s Counsel /Appointed Legal Representati /40:00 31Arri\ aav-t) Da Si c ature of Defendant Date Signature of Defendant Date WILMINGTON SAVINGS FUND : IN THE COURT OF COMMON PLEAS OF SOCIETY, FSB, TRUSTEE OF : CUMBERLAND COUNTY, PENNSYLVANIA THE PRIMESTAR -H. VS. SANDRA K. MITCHELL and JUDY R. MITCHELL, Defendants CIVIL ACTION NO. 14 -0619 CIVIL CASE MANAGEMENT ORDER AND NOW, this ?no( day of April, 2014, the parties having agreed to a conciliation conference, it is hereby ORDERED AND DECREED that: 1. The parties and their counsel are directed to participate in a court- supervised Conciliation Conference on ,rt2 e a 0 tV , at gz: DCI p m. in Chambers No. 4 at the Cumberland County Courthouse, Carlisle, Pennsylvania. 2. At least twenty -one (21) days prior to the date of the Conciliation Conference, the defendant/borrower must serve upon the plaintiff /lender and its counsel a copy of the "Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon agreement of the parties in writing or at the discretion of the Court, the Conciliation Conference ordered may be rescheduled to a later date and /or the date upon which service of the completed Form 2 is to be made may be extended. Upon notice to the Court of the defendant/borrower's failure to serve the completed Form 2 within the time frame set forth herein or such other date as agreed upon by the parties in writing j1 ca or ordered by the Court, the case shall be removed from the Conciliation Conference schedule and the temporary stay of proceedings shall be terminated. 3. The defendant/borrower and counsel for the parties must attend the Conciliation Conference in person and an authorized representative of the plaintiff/lender must either attend the Conciliation Conference in person or be available by telephone during the course of the Conciliation Conference. The representative of the plaintiff/lender who participates in the Conciliation Conference must possess the actual authority to reach a mutually acceptable resolution, and counsel for the plaintiff/lender must discuss resolution proposals with the authorized representative in advance of the Conciliation Conference. If the duly authorized representative of the plaintiff /lender is not available by telephone during the Conciliation Conference, the Court will schedule another Conciliation Conference and require the personal attendance of the authorized representative of the plaintiff /lender at the rescheduled Conciliation Conference. 4. At the Conciliation Conference, the parties and their counsel shall be prepared to discuss and explore all available resolution options which shall include: bringing the mortgage current through a reinstatement; paying off the mortgage; proposing a forbearance agreement or repayment plan to bring the account current over time; agreeing to tender a monetary payment and to vacate in the near future in exchange for not contesting the matter; offering the lender a deed in lieu of foreclosure; entering into a loan modification or a reverse mortgage; paying the mortgage default over sixty months; and the institution of bankruptcy proceedings. 5. All proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. Marc S. Weisberg, Esquire McCabe, Weisberg & Conway, PC 123 S. Broad Street Philadelphia, PA 19109 For the Plaintiff Susan Hartman, Esquire One Irvine Row Carlisle, PA 17013 For the Defendants :rim BY THE COURT, Kevi A. Hess, P. J. WILMINGTON SAVINGS FUND : IN THE COURT OF COMMON PLEAS OF SOCIETY, FSB, TRUSTEE OF : CUMBERLAND COUNTY, PENNSYLVANIA THE PRIMESTAR-H vs. : CIVIL ACTION : NO. 14-0619 CIVIL SANDRA K. MITCHELL and JUDY R. MITCHELL, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this 6 M day of June, 2014, at the request of counsel for the parties,. the conciliation conference set for June 6, 2014, is continued to Friday, August 15, 2014, at 3:30 p.m. in Chambers of the undersigned. Nathan C. Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff /Susan Hartman, Esquire One Irvine Row Carlisle, PA 17013 For the Defendants :rlm Clop /rZ1../Lpy a.� BY THE COURT, ./ Kevin r . Hess, P. rnrn ter- r' F4, WILMINGTON SAVINGS FUND : IN THE COURT OF COMMON PLEAS OF SOCIETY, FSB, TRUSTEE OF : CUMBERLAND COUNTY, PENNSYLVANIA THE PRIMESTAR-H vs. : CIVIL ACTION : NO. 14-0619 CIVIL SANDRA K. MITCHELL and JUDY R. MITCHELL, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this day of August, 2014, at the request of counsel for the parties, the conciliation conference set for August 15, 2014, is continued to Wednesday, October 1, 2014, at 10:45 a.m. in Chambers of the undersigned. BY THE COURT, Nathan C. Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff -/<san Hartman, Esquire One Irvine Row Carlisle, PA 17013 For the Defendants :rlm co i.ex peLts.ta_ s apy G") WILMINGTON SAVINGS FUND : IN THE COURT OF COMMON PLEAS OF SOCIETY, FSB, TRUSTEE OF : CUMBERLAND COUNTY, PENNSYLVANIA THE PRIMESTAR-H vs. : CIVIL ACTION : NO. 14-0619 CIVIL SANDRA K. MITCHELL and JUDY R. MITCHELL, Defendants IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this / w day of October, 2014, following conciliation conference, this matter is removed from the Cumberland County Mortgage Foreclosure Diversion Program and the stay entered in this case is lifted. ✓Nathan C. Wolf, Esquire 10 West High Street Carlisle, PA 17013 For the Plaintiff‹. _- Fri ct9 rn ✓ Susan Hartman, Esquire zco ;-_ i One Irvine Row -{?' "-- Carlisle, PA 17013 < c For the Defendants x c w ^ ' :rim CO p l'e_S rr? t I lEct_I 1oN,y BY THE COURT, Kevin : Hess, P.J. McCABE, WEISBERG AND CONWAY, P.C. BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 a 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 1. FOLEY, ESQUIRE'- ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wilmington Savings Fund Society, FSB, Not I.n Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust Plaintiff v. Sandra K. Mitchell and Judy R. Mitchell Defendants Attorneys for Plaintiff O ICE F THE" t�' � IH I O N O T1 R Y 7014 DEC 1 I PH 2: 13 C„, 1 L I\L AND COUNTY PENN'S YLVA 11 CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-619 ASSESSMENT OF DAMAGES AND ENTRY OF JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment by default in favor of Plaintiff and against Defendants, Sandra K. Mitchell and Judy R. Mitchell, in the above -captioned matter for failure to answer Complaint as required by Pennsylvania Rules of Civil Procedure, and assess damages as follows: Amount Due Interest from 01/10/14 to 11/28/14 Total Date: /)/21//c7( AND NOW, this ` ` day of Mc BY: [ ] Terren J. McCabe, Esq. [ ] Ed . rd D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] •Marisa J. Cohen, Esq. [•. ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff BERG & $ 264,454.64 $ 4,244.22 $ 268,698.86 , P.C. [ ] [ ] [ arc S. Weisberg, Esq. argaret Gairo, Esq. idi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ 4] Joseph I. Foley, Esq. a y [ ] Lena Kravets, Esq. a 9110 S 1 a361h1 2014, Judgment is entered in favor of Plaintiff, ilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust, and rr against Defendants, Sandra K. Mitchell and Judy R. Mitchell, in rem only and not in personam, and damages are assessed in the amount of $268,698.86, plus interest and costs. .> BY THE PRO/ IIONO T 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 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust Plaintiff v. Sandra K. Mitchell and Judy R. Mitchell Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-619 AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: SS. The undersigned, being duly sworn according to law, deposes and says that the Defendants, Sandra K. Mitchell and Judy R. Mitchell, are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act, 50 U.S.C. App. §501, et seq.; and that the Defendants, Sandra K. Mitchell and Judy R. Mitchell, are over eighteen (18) years of age, and reside as follows: Sandra K. Mitchell, 23 Wheatfield Drive Carlisle, PA 17013 SWORN AND SUBSCRIBED BEFORE ME THIS -7Z DAY OF J4— X44r 4l4 s -JP' .. .� Judy R. Mitchell, 23 Wheatfield Drive Carlisle, PA 17013 Date: /7/77g. /!e7 OTARY PUBLIC/ COMi4!O!n€Y' .:ALT r OF t77.7:-frCILV i . NOTARIAL SEAL BARBARA J. MOYER, Notary Public City of Philadelphia, Phila. County My Commission Expires January 12, 2018 BY: ] Te ce J. McCabe, Esq. [ ] Marc S. Weisberg, Esq. ] Edward D. Conway, Esq. argaret Gairo, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Heidi R. Spivak, Esq. [ ] Marisa J. Cohen, Esq. [ ] Christine L. Graham, Esq. [ ] Brian T. LaManna, Esq. [ ] Ann E. Swartz, Esq. [ ] Joseph F. Riga, Esq. [ Joseph I. Foley, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Lena Kravets, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff AY, P.C. Department of Defense Manpower Data Center Status Repc t Pursuant to Sery cemembers Civil Relief Act Last Name: MITCHELL First Name: SANDRA K. Middle Name: Active Duty Status As Of: Nov -28-2014 Results as of : Nov -28-2014 06:56:28 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA r . , -- — — ►. Nom'-. NA This response This response reflects the individuals' active duty status based on the Active Duly Status Date Leff Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA 4 • NA ti - __.. ' - No - . 4 NA This response reflects where the individual left active duty'status Withln'367 Cat's preceding the Acttve Duty Status Date 1I The Member or HIs/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA `4 4 N" • NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PCO9SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: JF7B782F30D0U70 Department of Defense Manpower Data Center Status Report Pursuant t to Sery cernenbers Civil Relief Act. Last Name: MITCHELL First Name: JUDY R. Middle Name: Active Duty Status As Of: Nov -28-2014 Results as of : Nov -28-2014 06:56:29 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA `^.. • s .. '-` = , Nom`. NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date This response reflects the individuals' active duty status based on'the Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA 1t NA _ .- .' - No :r" 1 NA This response reflects where the Individual left active duty status within 367 days preceding the Active Duty Status Date 11 I The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA , ., NA �, - i. +r .•No'' - ':ri` NA This response reflects whether the Individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data. Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Yki t Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility 'Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(0 for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARs), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 6FUBK84FOODOT70 • 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 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust Plaintiff v. Sandra K. Mitchell and Judy R. Mitchell Defendants Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Number 14-619 AFFIDAVIT OF LAST -KNOWN MAILING ADDRESS OF DEFENDANTS COMMONWEALTH OF PENNSYLVANIA: COUNTY OF PHILADELPHIA: The undersigned attorney for the Plaintiff in the within matter, being duly sworn according to law, hereby deposes SS. and says that the last -known mailing addresses of the Defendants are: Sandra K. Mitchell 23 Wheatfield Drive Carlisle, Pennsylvania 17013 and Sandra K. Mitchell c/o Susan J. Harman, Esquire 1 Irvine Row Carlisle, Pennsylvania 17013 SWORN AND SUBSCRIBED BEFO • ME THIST--9 COMMONWEALT or PENNI:A(1.V Date: Mc BY: Judy R. Mitchell 23 Wheatfield Drive Carlisle, Pennsylvania 17013 And Judy R. Mitchell c/o Susan J. Harman, Esquire 1 Irvine Row Carlisle, Pennsylvania 17013 SBE AY, P.C. [ ] Te Ce J. McCabe sq. [ ] Edward D. Conway, sq. [ Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff [ ] Marc S. Weisberg, Esq. [ ] Margaret Gairo, Esq. [ 1 Heidi R. Spivak, Esq. ] Christine L. Graham, Esq. [ 1 Ann E. Swartz, Esq. [ 61 Joseph 1. Foley, Esq. [ 1 Lena Kravets, 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 LENA KRAVETS, ESQUIRE - ID # 316421 CAROL A. DiPRINZIO, ESQUIRE - ID # 316094 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 (215) 790-1010 Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust Plaintiff v. Sandra K. Mitchell and Judy R. Mitchell Defendants Attorneys for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS Number 14-619 CERTIFICATION The undersigned hereby certifies that he/she is the attorney for Plaintiff, being duly sworn according to law, deposes and says that a letter was deposited in the United States Mail notifying the Defendants that judgment would be entered against him/her/them within ten (10) days from the date of said letter in accordance with Rule 237.5 of the Pennsylvania Rules of Civil Procedure. Copies of said letters are attached hereto and marked as Exhibit "A". SWORN AND SUBSCRIBED BEFORE ME THIS DAY OF Y 2014. .a, .1 CAmMoNvvs NOTIL`5 BARBARA J. MOYER; Notary un City of Philadelphia,County 2010. M Commission E; - _—_ ..'crs.�t��i Date: /7 lag /i' M BY: BERG [ ] Terre - J. McCabe, Esq. [ ] Ed4rd D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff AY, P.C. [ ] Marc S. Weisberg, Esq. jMargaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [/}.Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. VERIFICATION The undersigned attorney hereby certifies that he/she is the Attorney for the Plaintiff in the within action, and that he/she is authorized to make this verification and that the foregoing facts based on the information from the Plaintiffs representative, who is out of jurisdiction and not available to sign this verification at this time, are true and correct to the best of his/her knowledge, information and belief and further states that false statements herein are made subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsification to authorities. G& 1V. •� P.C. [ ] Terrenc . McCabe, Esq. [ ] Edw D. Conway, Esq. [ ] Andrew L. Markowitz, Esq. [ ] Marisa J. Cohen, Esq. [ ] Brian T. LaManna, Esq. [ ] Joseph F. Riga, Esq. [ ] Celine P. DerKrikorian, Esq. [ ] Carol A. DiPrinzio, Esq. Attorneys for Plaintiff [ ] Marc ' Weisberg, Esq. [ ] Margaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [d] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust v. Sandra K. Mitchell and Judy R. Mitchell Cumberland County; Number: 14-619 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary October 29, 2014 To: Sandra K. Mitchell 23 Wheatfield Drive Carlisle, Pennsylvania 17013 Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust vs. Sandra K. Mitchell Judy R. Mitchell Cumberland County Court of Common Pleas Number 14-619 Civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 TOME A LAWYER, THIS OFFICE MAYBE 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 rws MCC BERG BY: .",/' NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y PORNO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUMO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALOUNA, DICTAR SENTENCIA EN SU CONTRA YUSTED PODRIA PERDERBIENES U OTROS DERECHOS IMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 WAY, P.C. '[ ] Terre e J. McCabe, Esquire [ ] Ed ard D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ . ] Celine P. DerKrikorian, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff ( • o S. Weisberg, Esquire [ ] Mar,:atet Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire r!] Joseph I. Foley, Esquire [ ] Lena Kravets, Esquire 39099 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary October 29, 2014 To: Judy R. Mitchell 23 Wheatfield Drive Carlisle, Pennsylvania 17013 Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust vs. Sandra K. Mitchell Judy R. Mitchell Cumberland County Court of Common Pleas Number 14-619 Civil NOTICE PURSUANT TO RULE 2373 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 rws NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOOADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OJR PREUBA ALGUNA, DICTAR S ENTENCI A EN SU CONTRA Y USTED PODRIA PERDER B IENES U OTROS DERECHOS IMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOOADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOOADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACIGN ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACI3N ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO Ni NINGIJN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 BY: [ ] Terrence J)IdCabe, Esquire [ ] Edward'6, Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff ] Marc S. Weisberg, Esquire [ ] Marg?ret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [, ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire 7] Joseph I. Foley, Esquire [ ] Lena Kravets, Esquire 39099 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary October 29, 2014 To: Judy R. Mitchell c/o Susan J. Harman, Esquire 1 Irvine Row Carlisle, Pennsylvania 17013 ington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust vs. Sandra K. Mitchell Judy R. Mitchell Cumberland County Court of Common Pleas Number 14-619 Civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR. DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 rws NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALGUNA,DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDER BIENES U OTROS DERECHOS IMPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACI6N ACERCA DE EMPLEAR A UN ABOOADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON 1NFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINGUN HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 ]VIcCA 3 ', WI 1S1 " G.A ► l ON , P.C. BY: ,i7 [ ] Terrenc: , ; McCabe, Esquire [ ] Edward D. Conway, Esquire [ ] Andrew L. Markowitz, Esquire [ ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff re S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire { ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [/J Joseph I. Foley, Esquire ["` _] Lena Kravets, Esquire 39099 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse, Carlisle, Pennsylvania 17013 Curt Long Prothonotary October 29, 2014 To: Sandra K. Mitchell c/o Susan J. Harman, Esquire 1 Irvine Row Carlisle, Pennsylvania 17013 ington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust vs. Sandra K. Mitchell Judy R. Mitchell Cumberland County Court of Common Pleas Number 14-619 Civil NOTICE PURSUANT TO RULE 237.5 NOTICE OF INTENTION TO FILE PRAECIPE TO ENTER JUDGMENT BY DEFAULT IMPORTANT NOTICE You ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. 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 Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (800) 990-9108 M NOTIFICACION IMPORTANTE USTED SE ENCUENTRA EN ESTADO DE REBELDIA POR NO HABER PRESENTADO UNA COMPARECENCIA ESCRITA, YA SEA PERSONALMENTE 0 POR ABOGADO Y POR NO HABER RADICADO POR ESCRITO CON ESTE TRIBUNAL SUS DEFENSAS U OBJECIONES A LOS RECLAMOS FORMULADOS EN CONTRA SUYO. AL NO TOMAR LA ACCION DEBIDA DENTRO DE DIEZ (10) DIAS DE LA FECHA DE ESTA NOTIFICACION, EL TRIBUNAL PODRA, SIN NECESIDAD DE COMPARECER USTED EN CORTE U OIR PREUBA ALOUNA,DICTAR SENTENCIA EN SU CONTRA Y USTED PODRIA PERDERBIENES U OTROS DERECHOS I MPORTANTES. USTED LE DEBE TOMAR ESTE PAPEL A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE A UN ABOGADO, VA A 0 TELEFONEA LA OFICINA EXPUSO ABAJO. ESTA OFICINA LO PUEDE PROPORCIONAR CON INFORMACION ACERCA DE EMPLEAR A UN ABOGADO. SI USTED NO PUEDE PROPORCIONAR PARA EMPLEAR UN ABOGADO, ESTA OFICINA PUEDE SER CAPAZ DE PROPORCIONARLO CON INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS SERVICIOS LEGALES A PERSONAS ELEGIBLES EN UN HONORARIO REDUCIDO NI NINON HONORARIO. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 0) 9909108 BY: n� SAY, P.C. [ ] Tel'rfllf J. McCabe, Esquire [ ] Edward D. Conway, Esquire ] Andrew L. Markowitz, Esquire ] Marisa J. Cohen, Esquire [ ] Brian T. LaManna, Esquire [ ] Joseph F. Riga, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Carol A. DiPrinzio, Esquire Attorneys for Plaintiff rws [ ] Marc S. Weisberg, Esquire [ ] Margaret Gairo, Esquire [ ] Heidi R. Spivak, Esquire [ ] Christine L. Graham, Esquire [ ] Ann E. Swartz, Esquire [� ] Joseph 1. Foley, Esquire [ ] Lena Kravets, Esquire 39099 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Sandra K. Mitchell 23 Wheatfield Drive Carlisle, Pennsylvania 17013 Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust Plaintiff v. Sandra K. Mitchell and Judy R. Mitchell Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-619 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT ha as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Sandra K. Mitchell c/o Susan J. Harman, Esquire 1 Irvine Row Carlisle, Pennsylvania 17013 Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust Plaintiff v. Sandra K. Mitchell and Judy R. Mitchell Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-619 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been enteredi i the aboo e proceedi as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Judy R. Mitchell 23 Wheatfield Drive Carlisle, Pennsylvania 17013 Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust Plaintiff v. Sandra K. Mitchell and Judy R. Mitchell Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-619 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in thea l ve proceedi as indicated below. Prothonotary X Judgment by Default Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010. • OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS Cumberland County Courthouse Carlisle, Pennsylvania 17013 Prothonotary To: Judy R. Mitchell c/o Susan J. Harman, Esquire 1 Irvine Row Carlisle, Pennsylvania 17013 Wilmington Savings Fund Society, FSB, Not In Its Individual Capacity But Solely As Trustee Of The Primestar-H Fund I Trust Plaintiff v. Sandra K. Mitchell and Judy R. Mitchell Defendants COURT OF COMMON PLEAS CUMBERLAND COUNTY No. 14-619 NOTICE Pursuant to Rule 236, you are hereby notified that a JUDGMENT has been entered in the above proceeding as indicated below. Prothonotary X Judgment by Default I �p Money Judgment Judgment in Replevin Judgment for Possession If you have any questions concerning this Judgment, please call McCabe, Weisberg and Conway, P.C. at (215) 790-1010.