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Home My WebLink About14-1178 SiIpreme Court of Pennsylvania Cour ^off Commo. Pleas v Wll For Prothonotary Use Only: iiv11 feet CUI�hBlZ .'11ND_'1" County r Docket No: The information collected on this form is used solely for court administration purposes. This form does not supplement or replace ihefiling and service o pleadin s or other a ers os req uired by law or rules of court. S Commencement of Action: ❑O Complaint ❑ Writ of Summons ❑ Petition E ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiff s Name: FLAGSTAR BANK, FSB Lead Defendant's Name: DIANNA L. SHUTT T I Are money damages requested? El Yes Z No Dollar Amount Requested: El within arbitration limits O (Check one) 9 outside arbitration limits N Is this a Class Action Suit? ❑ Yes 9 No Is this an MDJ Appeal? ❑ Yes 9 No A Name of Plaintiff /Appellant's Attorney: John D. Krohn, Esq., 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 B ❑ Other: ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment ❑ Ground Rent ❑ Mandamus ❑ Landlord /Tenant Dispute ❑ Non- Domestic Relations ® Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY El Mortgage Foreclosure: Commercial ❑ Quo Warranto ❑ Dental ❑ Partition ❑ Replevin ❑ Legal ❑ Quiet Title ❑ Other: ❑ Other: ❑ Medical ❑ Other Professional: Pa.R.C.P. 205.5 Updated 01/01/2011 �� ?�`I "��- �``� TA if cc,� 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 FLAGSTAR BANK, FSB 5151 CORPORATE DRIVE COURT OF COMMON PLEAS TROY, MI 48098 CIVIL DIVISION Plaintiff V. TERM ILA/ DIANNA L. SHUTT NO. I ALTOONA AVENUE ENOLA, PA 17025 -2504 CUMBERLAND COUNTY Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE �1b3.7spd ahi a� � IL6� (o1 File #: _938066 / ' p) o� r 11 ^ 1. Plaintiff is FLAGSTAR BANK, FSB 5151 CORPORATE DRIVE TROY, MI 48098 2. The name(s) and last known address(es) of the Defendant(s) are: DIANNA L. SHUTT 1 ALTOONA AVENUE ENOLA, PA 17025 -2504 who is /are the mortgagor(s) and /or real owner(s) of the property hereinafter described. 3. On 09/10/2008 DIANNA L. SHUTT and GARY E. SHUTT made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR NATIONS HOME FUNDING, INC., A CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 200832193. The PLAINTIFF is now the mortgagee and is in the process of formalizing an assignment of same. 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. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2013 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 File #: 938066 by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 02/21/2014: Principal Balance $107,909.86 Interest $4,855.92 07/01/2013 through 03/01/2014 Late Charges $790.06 Mortgage Insurance Premium / $43.90 Private Mortgage Insurance Property Inspection $144.00 Escrow Deficit $301.68 TOTAL $114,045.42 7. Plaintiff is not seeking a judgment of personal liability (or an in persona m 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. 8. 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) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. File #: 938066 9. This action does not come under Act 91 of 1983 because the mortgage is FHA - insured. 10. Plaintiff hereby releases GARY E. SHUTT from liability for the debt secured by the mortgage. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $114,045.42, 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: _ 9 John D. Kr km, Esq., Id. No.312244 Attorney for Plaintiff File #: 938066 LEGAL DESCRIPTION ALL THAT CERTAIN lot or piece of ground situate in the East Pennsboro township, county of Cumberland and commonwealth of Pennsylvania, being more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern line of Cumberland road, a distance of 125 feet west of the northwest corner of the intersection of Cumberland road and Altoona avenue, also being at line of lands now or formerly of William W. Shoop; thence north 10 degrees 28 minutes west along same, a distance of 40.31 feet to a point at line of lands now or formerly of Freeman Z. Frey; thence north 79 degrees 40 minutes east along same and through partition wall between the premises herein described and premises adjoining on the north hereof and beyond a distance of 125 feet to a point on the western line of Altoona avenue; thence southwardly along same 30.31 feet to a point; thence along an arc of curve to the right; having a radius of 10 feet, a distance of 15.71 feet to a point on the northern line of Cumberland road; thence westwardly along the same, a distance of 115 feet to a point, at the place of beginning, according to a survey dated May 14, 1958, by William E. Sees, Jr., a consulting engineer. BEING designated as tax parcel no. 09 -14- 0532 -338 in the deed registry office of Cumberland county, Pennsylvania. PROPERTY ADDRESS: 1 ALTOONA AVENUE, ENOLA, PA 17025 -2504 PARCEL #09 -14- 0832 -338 File #: 938066 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied - by Plaintiff and are true and correct to the best of my information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating'to unsworn falsifications to authorities. Jon D. Krohn Attorney for Plaintiff DATE: 21, �1y FORM 1 IN THE COURT OF COMMON PLEAS FLAGSTAR BANK, FSB OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. DIANNA L. SHUTT N .- In Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLO rJ1tE�- - ' DIVERSION PROGRAM �� You have been served with a foreclosure complaint that could cause you to lose your home. -7 If you own and live in the residential property which is the subject of this foreclosure action, you may be - Ae 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 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 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: 9 -1quo 11 0 _0enM9!!!__ Date John D. lohn, 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: CUSTOMER[PRIMARY 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 in household: How long? CO-BORROWER Mailing Address: City: State: Zip: 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 #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. 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 Money Day /Child Care /Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 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) + • v 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 #: 938066 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY :UN CA) C) LSD Flagstar Bank, FSB vs. Dianna L Shutt Case Number 2014 -1178 SHERIFF'S RETURN OF SERVICE 03/03/2014 04:22 PM - Deputy Jamie DiMartle, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Dianna L Shutt at 1 Altoona Avenue, East Pennsboro, Enola, PA 17025. SHERIFF COST: $44.95 I E DIMARTL , PUTY SO ANSWERS, March 05, 2014 RONfS' R ANDERSON, SHERIFF tc) CountySu to Sher releosor Michael J. Pykosh, Esquire ID # 58851 Dethlefs - Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone - (717) 975 -9446 Fax - (717) 975 -2309 mpykosh @dplglaw.com FLAGSTAR BANK, FSB Plaintiff v. DIANNA L. SHUTT Defendant HE Pii0T1-iON0 TA Y 20S} !I 1 [ � > R 28 6 PMT t1: 3 0 CUMBERLAND ND COUN 1 Y PEANNSYLA,AA- or Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No.14 -1178 : CIVIL ACTION : IN MORTGAGE FORECLOSURE REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated February 28, 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 unswor Isification to authorities. Michael . Pykosh, Esquire Defendant's Counsel / Legal Representative Dianna L. Shutt Defendant 3 -a. //L/ Date Date Michael J. Pykosh, Esquire ID # 58851 Dethlefs - Pykosh Law Group, LLC 2132 Market Street Camp Hill, Pennsylvania 17011 Telephone — (717) 975 -9446 Fax — (717) 975 -2309 mpvkoshCaZdplglaw.com Attorney for Defendant FLAGSTAR BANK, FSB Plaintiff v. DIANNA L. SHUTT Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No.14 -1178 : CIVIL ACTION : IN MORTGAGE FORECLOSURE CERTIFICATE OF SERVICES I hereby certify that a copy of the foregoing DEFENDANT'S REQUEST FOR CONCILIATION CONFERENCE, was hereby served by depositing the same within the custody of the United States Postal Service, First Class, postage prepaid, addressed as follows: Flagstar Bank, FSB c/o John D. Krohn, Esquire Phelan Hallinan, LLC 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Date: 3,L 7 p 7 By: Respectfully Submitted, Michael J. Pykosh, Esquire ID # 58851 Dethlefs - Pykosh Law Group, LLC 2132 Market Street Camp Hill, PA 17011 717- 975 -9446 Attorney for Defendant FLAGSTAR BANK, FSB, • • IN THE COURT OF COMMON PLEAS OF Plaintiff . • CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION rri r a ,./ : NO. 14 -1178 CIVIL -< DIANNA L. SHUTT, <c) Defendant r (7) �" CASE MANAGEMENT ORDER' �i1 AND NOW, this d 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 n /4, a 0 T y , at 07: 36 �, 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 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. ...7frirm D. Krohn, Esquire Phelan Hallinan, LLC 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 For the Plaintiff Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 For the Defendants :rim es• BY THE COURT, FLAGSTAR BANK, FSB, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 14-1178 CIVIL DIANNA L. SHUTT, Defendant ORDER AND NOW, this /41. day of May, 2014, at the request of counsel for the parties, the conciliation conference set for May 16, 2014, is continued to Friday, July'11, 2014, at 2:30 p.m. in Chambers of the undersigned. BY THE COURT, Kevi A. Hess, P.J. D. Troy Sellars, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff ichael Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 For the Defendants :rim ;D c---.} _L- . -- -2 r- 2„rrt rn x�-Ala ; ._.. Cn r- -c T rr, r .- cJ 7' r'itn - • -< x FLAGSTAR BANK, FSB, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 14-1178 CIVIL DIANNA L. SHUTT, Defendant ORDER AND NOW, this / '�' day of July, 2014, at the request of counsel for the parties, the conciliation conference set for July 11, 2014, is continued to Friday, August 22, 2014, at 2:30 p.m. in Chambers of the undersigned. BY THE COURT, 4AZ Kevin Hess, P.J. ✓ Joseph Schalk, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff •Michael Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 r For the Defendants --- (T7 G7 C.._ :z rr1 f, ,; -:` icole Chabatcr) :---.7.) Phelan Hallinan, LLP -<?.,- 1617 JFK Boulevard — Suite 1400 -< c :i- , ' Philadelphia, PA 19103 z - - -: T:, L. �..) :rlm' cn Co l'es f1*/c.i. i' ry/iy FLAGSTAR BANK, FSB, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. DIANNA L. SHUTT, Defendant : CIVIL ACTION : NO. 14-1178 CIVIL ORDER AND NOW, this 2 day of September, 2014, at the request of counsel for the parties, the conciliation conference set for September 26, 2014, is continued to Friday, October 24, 2014, at 3:30 p.m. in Chambers of the undersigned. BY THE COURT, / Joseph Schalk, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff Michael Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 For the Defendants Nicole Chabat Phelan Hallinan, LLP 1617 JFK Boulevard — Suite 1400 Philadelphia, PA 19103 :lee" op��s w .lee"q/ /4 fir :rim FLAGSTAR BANK, FSB, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION NO. 14-1178 CIVIL DIANNA L. SHUTT, Defendant ORDER AND NOW,this Z Y day of October, 2014, following conciliation conference, upon representation that the documents needed to bring the packet current will be submitted within fourteen(14) days, continued conciliation conference is set for Wednesday,November 26, 2014, at 11:45 a.m., in Chambers of the undersigned. BY THE COURT, Kevi . Hess, P.J. �oseph Schalk, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff ichael Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 For the Defendants ^°M h icole Chabat Phelan HallinanLLP 1617 JFK Boulevard- Suite 1400 Philadelphia, PA 19103 may--c Am 12 FLAGSTAR BANK, FSB, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 14-1178 CIVIL DIANNA L. SHUTT, Defendant ORDER AND NOW, this 2.L' day of November, 2014, following conciliation conference, it appearing that there have been several continuances of this matter without result, a continued conciliation conference is set for Friday, January 23, 2015, at 2:00 p.m., in Chambers of the undersigned. Unless the matter is resolved prior thereto, it is directed that the plaintiff, Flagstar Bank, FSB, send a representative to the continued conciliation conference on January 23, 2015. Said representative should have settlement authority in this case. BY THE COURT, Joseph Schalk, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff Michael Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 For the Defendants Nicole Chabat Phelan Hallinan, LLP 1617 JFK Boulevard — Suite 1400 Philadelphia, PA 19103 £bp e,5 l + led Itfaidht/ FLAGSTAR BANK, FSB, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION : NO. 14-1178 CIVIL DIANNA L. SHUTT, Defendant ORDER AND NOW, this 2 2;4 day of December, 2014, on request of counsel, the conciliation conference set for Friday, January 23, 2015, is continued generally, the matter to be relisted on the request of either party. The prior direction of the Court, requiring a representation of the plaintiff to appear at the conciliation conference, is VACATED. BY THE COURT, Joseph Schalk, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff Michael Pykosh, Esquire 2132 Market Street Camp Hill, PA 17011 For the Defendants icole Chabat Phelan Hallinan, LLP 1617 JFK Boulevard — Suite 1400 Philadelphia, PA 19103 1.Es LE'L a%aa,Ay CD