The URL can be used to link to this page

Home My WebLink About14-0674 For Prothonotary Use Only: SWprem Gou Nannsylvani.a. CO IH f r 01MII iI; !P lea s, Joet .•!J" •" llil slnd Docket No. •y L ,r1 County T'he information collected on this form is used solely for court administration purposes. T his fornt does not su) lenient or replace thefifing and service o pleadin s or other papers as required b , law or rules o court. Commencement of Action: S ® Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: Live Well Financial, Inc. Lead Defendant's Name: Gwendolyn Futch T I Are there money damages requested? ❑ Yes ® No Dollar Amount Requested: Cl within arbitration limits 0 (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? 0 Yes ® No A Name of Plaintiff /Appellant's Attorney: McCabe, Weisberg & Conway, P.C. ❑ Check here if you have no attorney (a Self - Represented [Pro Sel 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 i ❑ Premises Liability (does not include ❑ Statutory Appeal: Other S mass tort) E ❑ Slander/Libel/ Defamation ❑ Employment Dispute: ❑ Other: Discrimination C ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other r 0 ❑ Other MASS TORT N ❑ Asbestos ❑ Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort -Implant REAL PROPERTY MISCELLANEOUS B ❑Toxic Waste ❑ Ejectment ❑ Common Law /Statutory Arbitration ❑ Other: J ❑ Eminent Domain /Condemnation ❑Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlordfrenant 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: Updated 111/2011 e ��/ 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 -1D # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH 1. FOLE.Y, 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 Live Well Financial, Inc. Cumberland County 3900 Capital City Boulevard Court of Common Pleas Lansing, MI 48906 • ` ' � Un � lU 1 Number l V. Gwendolyn Futch, Administratrix of the Estate of Paul Futch, Deceased Mortgagor and Real Owner 99 Short Lane Newville, PA 17241 COMPLAINT IN MORTGAGE FORECLOSURE 2o�so�� ile # 76328 Page 1 NOTICE AVISO You have been sued in court. If you wish to Le han demandado a usted en la corte. Si defend against the claims set forth in the usted quiere defenderse de estas demandas following pages, you must take action within ex- puestas en las paginas siguientes, usted twenty (20) days after this complaint and tiene veinte (20) dias de plazo al partir de la notice are served, by entering a written fecha de la demanda y la notificacion. Hace appearance personally or by attorney and falta asentar una comparencia escrita o en filing in writing with the court your defenses persona o con un abogado y entregar a la corte or objections to the claims set forth against en forma escrita sus defensas o sus objeciones you. You are warned that if you fail to do so a las demandas en contra de su persona. Sea the case may proceed without you and a avisado que si usted no se defiende, la corte judgment may be entered against you by the tomara medidas y puede continuar la demanda court without further notice for any money en contra suya sin previo aviso o notificacion. claimed in the complaint or for any other Ademas, la corte puede decidir a favor del claim or relief requested by the plaintiff. You demandante y requiere que usted cumpla con may lose money or property or other rights todas las provisioner de esta demanda. Usted important to you. puede perder dinero o sus propiedades u otros derechos importantes para usted. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU USTED LE DEBE TOMAR ESTE DO NOT HAVE A LAWYER, GO TO OR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO BELOW. THIS OFFICE CAN PROVIDE TIENE A UN ABOGADO, VA A O YOU WITH INFORMATION ABOUT TELEFONEA LA OFICINA EXPUSO HIRING A LAWYER. ABAJO. ESTA OFICINA LO PUEDE IF YOU CANNOT AFFORD TO PROPORCIONAR CON INFORMATION HIRE A LAWYER, THIS OFFICE MAY BE ACERCA DE EMPLEARA UN ABOGADO. ABLE TO PROVIDE YOU WITH SI USTED NO PUEDE INFORMATION ABOUT AGENCIES PROPORCIONAR PARA EMPLEAR UN THAT 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 # 76328 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: Live Well Financial, Inc. v. Gwendolyn Futch, Administratrix of the Estate of Paul Futch, Deceased Mortgagor and Real Owner Cumberland County File # 76328 Page 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is Live Well Financial, Inc. 2. The Defendant is Gwendolyn Futch, Administratrix of the Estate of Paul Futch, Deceased Mortgagor and Real Owner, and his /her last -known address is 99 Short Lane, Newville, PA 17241. 3. On November 5, 2012, Paul T. Futch, mortgagor, trade, executed and delivered a mortgage upon the premises hereinafter described to Mortgage Electronic Registration Systems, Inc., as nominee for American Advisors Group which mortgage is recorded in the Office of the Recorder of Cumberland County as Instrument Number 201235890 (the "Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 4. On November 5, 2012, Paul T. Futch, also executed a promissory note secured by the aforementioned mortgage. Plaintiff, directly orthrough an agent, is in possession ofthe note and is the holder of the note with the right to enforce it; the note is either made payable to plaintiff or has been duly endorsed. 5. On September 24, 2013, the Mortgage was assigned by Mortgage Electronic Registration Systems, Inc., as nominee for American Advisors Group its successor and/or assigns to Live Well Financial, Inc., by Assignment of Mortgage, recorded in the Office of the Recorder of Cumberland County as Instrument Number 201335718, such Assignment of Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 6. On June 19, 2013, Paul T. Futch departed this life leaving title vested solely in Gwendolyn Futch by operation of law. 7. The premises subject to said mortgage is described in the legal description attached as Exhibit "A" and is known as 99 Short Lane, Newville, Pennsylvania 17241. 8. The mortgage is in default due to the death of Paul T. Futch, Deceased Mortgagor and Real Owner. File # 76328 Page 4 9. The following amounts are due on the mortgage: Principal Balance $ 209,780.00 Interest through January 31, 2014 $ 13,922.65 plus per month interest thereafter which may adjust in accordance with the terms of the note and mortgage Attorney's Fee $ 1,650.00 Mortgage Insurance Premiums (MIP) $ 10,239.41 Appraisals $ 425.00 Inspections $ 90.00 GRAND TOTAL $ 236,107.06 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. 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. WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $236,107.06, together with interest per month thereafter which may adjust in accordance with the terms of the note and mortgage, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. McCABE, WEISB G & CONWA , P.C. BY: � I [ ] Terrence J. McCabe, Esquire [- +Iq S. Weis erg, Esquire [ J 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 File # 76328 Page 5 VERIFICATION Jane Ward, hereby states that he /she is Assistant is Vice President of Celink, Attorney In Fact for Live Well Financial, Inc. Plaintiff in this matter, that he /she is authorized to make this Verification, and verify that the statements of fact made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, 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: Q Uh Name: Jane Ward Title: Assistant Vice President - 1 / l k— Name: Live Well Financial, Inc. v. Gwendolyn Futch, Administratrix of the Estate of Paul Futch, Deceased Mortgagor and Real Owner Loan Number ending with: 0005 File # 76328 Page 6 Exhibit A ALL THAT CERTAIN tract of land with the improvements thereon erected, situate in Lower Mifflin Township, Cumberland County, Pennsylvania, bounded and described in accordance with a Plan of Survey by Stephen H. Fisher, Professional Land Surveyor, dated June 8, 1981, and bearing Drawing No. 81107, as follows, to wit: BEGINNING at an iron pin set at a corner of property herein described and property now or formerly of John E. Karns; thence extending from said beginning point and along property now or formerly of John E. Karns, passing through an existing dirt lane, North 21 degrees 54 minutes 36 seconds East 149.56 feet to an existing iron pipe at property now or formerly of Paul Harvey; thence extending along same, and along dirt lane, South 16 degrees 52 minutes 52 seconds East 650.87 feet to an existing fence post; thence South 45 degrees 35 minutes 51 seconds West 261.74 feet to an existing fence post at property now or formerly of Elwood R. Gutshall; thence North 61 degrees 00 minutes West 550.83 feet to existing stone; thence continuing along property now or formerly of Elwood R. Gutshall, South 46 degrees 00 minutes West 107.10 feet to property now or formerly of Norman T. Kline; thence extending along same, North 58 degrees 21 minutes 54 seconds West 255.99 feet to an iron pin set at property now or formerly of Leroy H. Martin; thence extending along same, North 36 degrees 38 minutes 06 seconds East 786.21 feet to a point at property now or formerly of John E. Karns, aforementioned; thence extending along same, South 40 degrees 40 minutes 53 seconds East 383.22 feet to the first mentioned iron pin and Place of BEGINNING. BEING the same property conveyed to Paul T. Futch and Gwendolyn Futch by Deed from William M. Menaker and Grace M. Menaker, dated December 8, 1987 and recorded December 9, 1987 at Book C33, Page 26. Property Address: 99 Short Lane, Newville, Pennsylvania 17241 Tax ID/Parcel No.: 15 -05- 0413 -014 FORM 1 Live Well Financial, Inc. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. f n q Ti Gwendolyn Futch, Administratrix of the Estate of Paul Civil r=J r i� rr Futch, Deceased Mortgagor and Real Owner and Paul :;u M ' r � ; T. Futch � r cn i Def . :Z: � C-) ca,� r NOTICE OF RESIDENTIAL MORTGAGE FORECLOS F k 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. Respect lly submitted: i Date [Signature of Counsel for Plaint ffJ 76328 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: GUSTOM 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, motorc cY les): 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 Uwe am/are under no obiligation to use the services provided by the above named Borrower Signature Date Co- Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Vr Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement (if property is currently on the market) 3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY .., J Ronny R Anderson I ` ill t ql Sheriff a Est' of a�tiatrj1, Jody S Smith 14 114 11AR 12 PM 2: 143 Chief Deputy Richard W Stewart CUMBERLA CUNT Solicitor :, -E PENNSYLVANIA, Live Well Financial, Inc. vs. Case Number Gwendolyn Futch 2014-674 SHERIFF'S RETURN OF SERVICE 03/05/2014 12:02 PM - Deputy William Cline, 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 Defen•ant, to wit: Gwendolyn Futch at 99 Short Lane, Lower Mifflin, Newville, PA 17241. / ` I WIL"IAM CLINE, DEPUTY SHERIFF COST: $68.68 SO ANSWERS, March 07, 2014 RON R ANDERSON, SHERIFF Stanley H. Mitchell, Esquire 600 N. Second St., Ste., 402 P.O. Box 425 Pa., Atty., I.D. No. 32093 Harrisburg, PA., 17108 (717) 233 -3339 SHMitchell9(a�comcast. net Attorney For Defendant r ,l� 7 1 �;,li�Oil r� FILED-OFFICE THE TAR 2014 APR - (� PH 12: 01 CUMBERLAND COUNT'( PENNSYLVANIA LIVE WELL FINANCIAL, Plaintiff V GWENDOLYN FUTCH, ADMINISTRATRIX OF THE ESTATE OF PAUL FUTCH, DECEASED MORTGAGOR AND REAL OWNER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA No. 14 — 674 IN MORTGAGE FORECLOSURE ANSWER TO COMPLAINT IN MORTGAGE FORECLOSURE AND NOW, comes Defendant Gwendolyn Futch, by and through her attorney Stanley H. Mitchell, Esquire, who files the within Answer To Complaint In Mortgage Foreclosure, to wit: 1. Admitted. 2. Admitted, in part; Denied, in part. Admitted, Defendant Gwendolyn Futch is the Administratrix of the Estate of Paul Futch. Denied, that Paul Futch is the "real owner" inasmuch as Defendant Gwendolyn Futch is the wife of the Deceased and is record owner of premises situate at 99 Short Lane, Newville, Pennsylvania 17241. 3. After reasonable investigation, Defendant is without sufficient knowledge or information to form a belief as to the truth of the averment. 4. After reasonable investigation, Defendant is without sufficient knowledge or information to form a belief as to the truth of the averment. 5. After reasonable investigation, Defendant is without sufficient knowledge or information to form a belief as to the truth of the averment. 6. Admitted. 7. Admitted. 8. Specifically Denied. This paragraph to the extent it applies to Defendant constitutes a conclusion of law to which no answer is required. To the extent that an answer is required, Plaintiff's paragraph 8 is specifically denied and proof to the extent relevant and admissible is demanded. 9. Specifically Denied. This paragraph to the extent it applies to Defendant constitutes a conclusion of law to which no answer is required. To the extent that an answer is required, Plaintiffs paragraph 9 is specifically denied and proof to the extent relevant and admissible is demanded. 10. After reasonable investigation, Defendant is without sufficient knowledge or information to form a belief as to the truth of the averment. WHEREFORE, Defendant respectfully requests Your Honorable Court to dismiss Plaintiff's complaint. Respectfully submitted, Stanley H. Mitchell, Esquire 600 N. Second St., Ste., 402 P.O. Box 425 Pa., Atty., I.D. No. 32093 Harrisburg, PA., 17108 (717) 233 — 3339 SHMitche119@comcast.net Attorney For Defendant Date: April 3, 2014 VERIFICATION I, GWENDOLYN FUTCH, Administratrix, Estate of Paul Futch, hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 PA.,C.S. 4904 relating to unsworn falsification to authorities. Date: 9/ 3) 17 a1,2i #-/AIM *NDOLYN FUT,/ , Ad( inistratrix, ESTATE OF PAUL FUTCH CERTIFICATE OF SERVICE IN RE: LIVE WELL v GWENDOLYN FUTCH I hereby certify that I am this day serving the forgoing document by U.S. Mail, First Class, postage prepaid, upon the following: Date: April 3, 2014 Jennifer Wunder, Esquire 123 S. Broad St., Ste., 1400 Philadelphia, PA 19109 Stanley H. Mitchell, Esquire