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Home My WebLink About14-0633 Supreme Court --of Pennsylvania Cour Commolr! Pleas For Prothonotary Use Only: G v , Covek beet CUMR�L °1N '' Coun � � � _ ty Docket No: The information collected on this form is used solely for court administration purposes. This forin does not supplement or rep lace the filing and service ofpleadings or other papers as required by law or rules of court. S Commencement of Action: Complaint ❑ Writ of Summons ❑ Petition E+ ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff's Name: SANTANDER BANK, N.A.. Lead Defendant's Name: JAMES C. HARTZELL T I Are money damages requested? ❑Yes 9 No Dollar Amount Requested: 11 within arbitration limits 0 1 (Check one) 0 outside arbitration limits N Is this a Class Action Suit? ❑ Yes Z No Is this an MDJ Appeal? ❑ Yes 0 No A Name of Plaintiff/Appellant's Attorney: John D. Krohn, Esg , Id. No.312244, Phelan Hallinan, LLP ❑ Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant) Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies • Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment • Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections • Nuisance ❑ Dept. of Transportation • Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability (does not S include mass tort) ❑ Employment Dispute: ❑ Slander /Libel/ Defamation Discrimination E ❑ Other: ❑ Employment Dispute: Other ❑ Zoning Board C ❑ Other: T I MASS TORT ❑ Other: 0 ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort - DES • Toxic Tort - Implant REAL PROPERTY MISCELLANEOUS • Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration $ ❑ Other: ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto • Dental ❑ Partition ❑ Replevin • Legal ❑ Quiet Title ❑ Other: • Medical ❑ Other: • Other Professional: Pa.R.C.P. 205.5 Updated 01!01 /2011 i ir: 7 o� PHELAN HALLINAN, LLP John D. Krohn, Esq., Id. No.312244 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia, PA 19103 john.krohn@phelanhallinan.com 215 -563 -7000 SANTANDER BANK, N.A. . 824 NORTH MARKET STREET, SUITE 100 COURT OF COMMON PLEAS WILMINGTON, DE 19801 CIVIL DIVISION Plaintiff V. TERM 2 1V JAMES C. HARTZELL NO. 244 BRICK CHURCH ROAD NEWVILLE, PA 17241 -9428 CUMBERLAND COUNTY KATHY ANN HARTZELL 244 BRICK CHURCH ROAD NEWVILLE, PA 17241 -9428 JODY A. HARTZELL 244 BRICK CHURCH ROAD NEWVILLE, PA 17241 -9428 Defendants CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 931580 Vw x,90 1. Plaintiff is SANTANDER BANK, N.A. 824 NORTH MARKET STREET, SUITE 100 WILMINGTON, DE 19801 2. The name(s) and last known address(es) of the Defendant(s) are: JAMES C. HARTZELL 244 BRICK CHURCH ROAD NEW VILLE, PA 17241 -9428 KATHY ANN HARTZELL 244 BRICK CHURCH ROAD NEWVILLE, PA 17241 -9428 JODY A. HARTZELL 244 BRICK CHURCH ROAD NEWVILLE, PA 17241 -9428 who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 07/30/1985 JAMES C. HARTZELL and KATHY ANN HARTZELL made, executed and delivered a mortgage upon the premises hereinafter described to YORK FEDERAL SAVINGS AND LOAN ASSOCIATION, which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Book 785, Page 47.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. Sovereign Bank, N.A. s/b /m YORK FEDERAL SAVINGS AND LOAN ASSOCIATION is now known as Santander Bank, N.A. 5. The premises subject to said mortgage is described as attached. File k 931580 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/2013 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 7. The following amounts are due on the mortgage as of 12/30/2013: Principal Balance $6,869.13 Interest $260.02 05/01/2013 through 12/30/2013 Late Charges $236.85 Property Inspections $54.25 Escrow Deficit $1,086.0 0 TOTAL $8,506.25 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 9. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Mortgage Assistance Program pursuant to Act 91 of 1983, as amended in 2008, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s). File #: 931580 4 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $8,506.25, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN, LLP By: John D. Kro , Esq., Id. No.312244 Attorney for Plaintiff File #: 931.580 LEGAL DESCRIPTION ALL that land or parcel of land situate in Upper Frankford Township, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a stone in the center of the public road leading to the Brick Church and a corner of land formerly of Harry Hoover, now of James Shetron; thence by the same South 67 degrees West 19 perches to a stone; thence by lands of Aseph Wright Estate, North 37 -1/2 degrees West 28.8 perches to a stone; thence by the same North 67 degrees East 26.8 perches to a stone in the aforesaid public road leading from Gillespie's School House to the Brick Church; thence by said Road and lands formerly of Fred Sollenberger, now of George Wickard, South 21 -1/2 degrees East 28 perches to the place of Beginning. Containing four (4) Acres strict measure. BEING the same premises which James H. Shetron and Margaret M. Shetron by their deed dated July 30, 1985 and recorded in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania granted and conveyed unto James C. Hartzell and Kathy Ann Hartzell the mortgagors herein. PROPERTY ADDRESS: RD 4, A/K/A RR 4, AKA 244 BRICK CHURCH ROAD, NEWVILLE, PA 17241 PARCEL #43- 06- 0031 -002. File #: 931590 4. VERIFICATION TZY ;k.d6 3(J-.r.0 �Q 1) f� 1 1"0- M , , hereby states that he /she is 6d - s 'G ki of SANTANDER BANK, N.A., Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: ! oa$ Name:�D"i-Q-k Title:�'�( I m �nIS � SANTANDER BANK, N.A. File #: 931580 Name: HARTZELL Filet 931.580 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249 -3166 (800) 990 -9108 File #: 931580 • FORM 1 IN THE COURT OF COMMON PLEAS SANTANDER BANK, N.A.. OF CUMBERLAND COUNTY, PENNSYLVANIA., Plaintiff(s) VS. Z JAMES C. HARTZELL t ~ KATHY ANN HARTZELL Cn �.' JODI A. HARTZELL Defendant(s) 5civil �Z C) NOTICE OF RESIDENTIAL MORTGAGE FORECLOSUREw 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) 2439400 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 tit 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 representativewill prepare and a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have a opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so That a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: 1/-31 Date John D. Krohn, Esq., Id. No.312244 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: CUSTOMERAIRIMARY 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: _— Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? CO-BORROWER Mailing Address: City: State: -- Phone Numbers: Home: Office: Cell: Other: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No ❑ If yes, provide names, location of court, case number & attorney: Assets Amount Owed Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile 41: 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. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net 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 d 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 Su ort/Alim. Spending Mone Da /Child Care /Tuft. Other Ex enses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 4 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ❑ No ❑ If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ❑ No ❑ If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I /We, , authorize the above named to use /refer this information to my lender /servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I /we am /are under no obligation to use the counseling services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 1 Proof of income 2 Past 2 bank statements 3 Proof of any expected income for the last 45 days 4 Copy of a current utility bill 5 Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6 Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ; , Sheriff t E t r i Jody S Smithxxaxtx, u1trrai�r��rG 20111 MAR -Li AM 10; 38 Chief Deputy Richard W Stewart CUMBERLAND COUNTY Solicitor ., r A IF PENNSYLVANIA Santander Bank, N.A. vs. Case Number James C Hartzell (et al.) 2014-633 SHERIFF'S RETURN OF SERVICE 02/07/2014 04:22 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Jodi A. Hartzell, Spouse, who accepted as"Adult Person in Charge"for James C Hartzell at 244 Brick Church Road, Newville, PA 17241. RONALD HOOVER, DEPU SHERIFF COST: $92.12 SO ANSWERS, February 24, 2014 RONNII ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND C~UNTy Ronny RAnderson 8he�Y ._ �.�T�r�/n.',.'''- '''�/'�«/�VMU//\�, 2814 Me19 PM � � . °" [�� ` ' SCOUNTY - PENNSYLVANIA Jody S Smith Chief Deputy Richard W Stewart Solicitor OFFICE OF TRE SisERIFP *AMEND�0*+ Santander Bank, N.A. vs. James C Hartzell (et al.) Case Number 2014-633 SHERIFF'S RETURN OF SERVICE 02K07Y2014 Ronny R Anderson, Sheriff, being duly sworn according to |aw, states he made diligent search and inquiry for the wi'thin named Defendant to wit: Kathy Ann Hartzefl, but was unable to Iocate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint in Mortgage Foreclosure as "Not Found" at244Brick Church Road, Newville, PA 17241. It is believed, thatthe Defendant currently resides in Florida at an unknown Iocation, Per the NewviHe Postmaster mail is delivered to address given. 82/07/2014 04:22 PM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Complaint in Mortgage Foreclosure by "personaily" handing a true copy to a person representing themselves to be the Defendant, to wit: Jodi A Hartzell at 244 Brick Church Road, Newville, PA 17241. RONALD HOOVER, DEPUTY 0207/2014 04:22 PM - Deputy Ronald Hoover, be}ng duly sworn according to Iaw, served the requested Complaint in Mortgage Foreclosure by handing a true copy to a person representing UhemedvenhobeJodiA.Hartzo|. Spouse, who accepted as "Adult Person in Charge" for James C Hartzell at 244 Brick Church Road, Newville, PA 17241. RONALD HOOVER, DEPUTY SHERIFF COST: $9212 SO ANSWERS, February 24, 2014 RONNYR ANDERSON, SHERIFF PLAINTIFF SANTANDER BANK, N.A. DEFENDANT JAMES C. HARTZELI., KATHY ANN HARTZELL JODY A. HARTZELL SERVE KATHY ANN HARTZELL AT: 1113 VENETIAN HARBOR DR NE SAINT PETERSBURG, FL 33702 -1916 AFFIDAVIT 1' OF SERVICE _ CUMBERLAND COUNTY + + : ].,. r., MON U T A l; PH 4 931580 2014 pMfiR 25 All 10: 13 SERVICE TRAM/ als; COURT NO.: 14- 633 -CRS? rionERL N() COUNTY PENNSYLVANIA TYPE OF ACTION XX Mortgage Foreclosure XX Civil Action SERVE!) Served and made known to K.ATHY ANN HARTZELL, Defendant on the 'U day of �_ <G(f 20 ) at )ti..�_.___..., o'clock P. M., at J f J , \/e ,r__' +g,�_ y. Lbcr gg„. fr# ,, in the manner described below: __Defendant personally served. ST. isb ,..`y ,r) Adult fancily member with whom Defendant(s) reside(s). Relationship is > /7 Jew./ _ Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s) reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age Z$ f Height .5 i % !r Weight /ZO Race Sex /t1 Other 1, Mr eta .'G/ Z-A3L! f , a competent adult, being duly sworn according to law, depose and state that 1 personally handed a true and correct copy of the Foreclosure Complaint in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before meth's ! oZ-.. day of Z � '! , 20/V i Notar : By: 0L<55 p,roer 15'20,1 NOT SERVED On the da f of 20 , at _........_ o'clock M., 1 I).eftindTii OT�'O15 `T 6 anise: Vacant ,___ 1:)oes Not Exist Moved Does Not Reside (Not Vacant) No Answer on at __ Service Refused Other: Sworn to and subscribed before me this _.__.........___.. day of . 20 . WILLIAM HOFFMAN MY COMMISSION #FF001509 EXPIRES: MAR 20, 2017 Bonded through 1st State Insurance ,.a competent adult hereby state that Notary: Tay: ATTORNEY FOR PLAINTIFF Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id, No. 62695 Daniel G. Schmieg, Esq., id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., lei. No. 58745 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Jay B. Jones, bsq., Id. No. 86657 Andrew L, Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 9462.0 Courtenav R. Dunn, Esq., Id. No. 206779 Mario J. Hanyori, Esq., Id. No. 203993 John M. Kolesnik, Esq., Id. No. 308877 Matthew G. Brushwood, Esq., .Id. No, 310592 Justin F. Kobeaki, Esq., Id. No. 200392 Adam Davis, Esq., Id. No. 203034 Joseph E. DeBarberie, Esq., Id. No. 315421 EMILY M. PHELAN, Esq., Id. No. 315250 One Penn Center at Suburban Station 1617 John F. Kennedy Blvd., Suite 1400 Philadelphia, PA 19 103 -1814 Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Il ` GRGf17O!c, . I i` r�Ol�r, ; Z i HAY —8 10: 17 CLI 1B'Er,LAND PENNSYLVANIA 7Y Attorney For Plaintiff SANTANDER BANK, N.A. Plaintiff v. JAMES C. HARTZELL KATHY ANN HARTZELL JODY A. HARTZELL Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 14 -633 -CIVIL PRAECIPE TO THE PROTHONOTARY: ® Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. ❑ Please mark the above referenced case Settled, Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. n Please mark the in rem judgment Satisfied and the actio pisco inued and Ended. ❑ Please Vacate the Judgment entered. Date: S ( PH # 931580 PH By: Joseph A. De . fe, Esq., Id. No.200479 Attorney for Plaintiff LAN HALLIN Phelan Hallinan, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney For Plaintiff SANTANDER BANK, N.A. Plaintiff v. JAMES C. HARTZELL KATHY ANN HARTZELL JODY A. HARTZELL Defendant(s) Court of Common Pleas Civil Division CUMBERLAND County No. 14 -633 -CIVIL CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served by regular mail to the person(s) on the date listed below: JAMES C. HART/ILL RD4A/K/ARR4 A/K/A 244 BRICK CHURCH ROAD NEWVILLE, PA 17241 KATHY ANN HART/ILL 1113 VENETIAN HARBOR DR NE SAINT PETERSBURG, FL 33702-1916 JODY A. HARTZELL 244 BRICK CHURCH ROAD NEWVILLE, PA 17241 Date: rfry h A. Des. e, Esq., Id. No.200479 ttorney for Plaintiff