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HomeMy WebLinkAbout14-1653 S For Prothonotary Use Only: Supreme Court Of' Pe nnsyly ani.a�. Lou ci 4 l1 f ili411 on Pleas - ;,=C umberland Docket No. The in collected on this Erwin is used solely for c•our t administration purposes. This fnr•nr does not sgplVenient or re lace the rlin r and service o )leadin s or other a )ers as req uired by lmv 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: M &T Bank Lead Defendant's Name: Jennifer R. Hatton, Administratrix c.t.a., d.b.n. of the Estate T of Margaret B. Brown, Deceased Mortgagor and Real Owner I Are there money damages requested? ❑ Yes N No Dollar Amount Requested: ❑ within arbitration limits O (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes ® No Is this an MDJAppeal? ❑ 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 inchrde Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Department of Transportation ❑ Premises Liability (does not include 11 Statutory Appeal: Other S mass tort) E ❑ Slander/Libel/ Defamation ❑ Employment Dispute: ❑ Other: Discrimination C ❑ Employment Dispute: Other ❑ Zoning Board T ❑ Other I O ❑ Other N MASS TORT ❑ 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 ❑ Landlordfrenant Dispute ❑ Non - Domestic Relations N Mortgage Foreclosure: Residential Restraining Order PROFESSIONAL LIABILITY ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto • Dental ❑ Partition ❑ Replevin • Legal ❑ Quiet Title ❑ Other: ❑ Medical ❑ Other: ❑ Other Professional: Updated 1/1/2011 fvAjS Yf� Aft CC CI, � T 3" !A McCABE, WEISBERG & CONWAY, P.C. Attorneys for Plaintiff BY: TERRENCE J. McCABE, ESQUIRE - ID # 16496 MARC S. WEISBERG, ESQUIRE - ID # 17616 EDWARD D. CONWAY, ESQUIRE - ID # 34687 MARGARET GAIRO, ESQUIRE - ID # 34419 ANDREW L. MARKOWITZ, ESQUIRE - ID # 28009 HEIDI R. SPIVAK, ESQUIRE - ID # 74770 MARISA J. 'COHEN, ESQUIRE - ID # 87830 CHRISTINE L. GRAHAM, ESQUIRE - ID # 309480 BRIAN T. LAMANNA, ESQUIRE - ID # 310321 ANN E. SWARTZ, ESQUIRE - ID # 201926 JOSEPH F. RIGA, ESQUIRE - ID # 57716 JOSEPH I. FOLEY, ESQUIRE - ID # 314675 CELINE P. DERKRIKORIAN, ESQUIRE - ID # 313673 JENNIFER L. WUNDER, ESQUIRE - ID # 315954 LENA KRAVETS, ESQUIRE - ID # 316421 123 South Broad Street, Suite 1400 Philadelphia, Pennsylvania 19109 215)790 -1010 M &T Bank Cumberland County One Fountain Plaza Court of Common Pleas Buffalo, NY 14203 Number � L 'i — I V. Jennifer R. Hatton, Administratrix c.t.a., d.b.n. of the Estate of Margaret B. Brown, Deceased Mortgagor and Real Owner 414 West 3rd Avenue Parkesburg, PA 19356 COMPLAINT IN MORTGAGE FORECLOSURE CLIAk 163 -TSID C�jl �- 30 33a3 File # 70772 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 provisiones 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, GOTOOR PAPEL A SU ABOGADO TELEPHONE THE OFFICE SET FORTH INMEDIATAMENTE. SI USTED NO TIENE BELOW. THIS OFFICE CAN PROVIDE A UN ABOGADO, VA A O TELEFONEA YOU WITH INFORMATION ABOUT LA OFICINA EXPUSO ABAJO. ESTA HIRING A LAWYER. OFICINA LO PUEDE PROPORCIONAR IF YOU CANNOT AFFORD TO CON INFORMATION ACERCA DE HIRE A LAWYER, THIS OFFICE MAY BE EMPLEAR A UN ABOGADO. ABLE TO PROVIDE YOU WITH S I USTED NO PUEDE INFORMATION ABOUT AGENCIES THAT PROPORCIONAR PARA EMPLEAR UN MAY OFFER LEGAL SERVICES TO ABOGADO, ESTA OFICINA PUEDE SER ELIGIBLE PERSONS AT A REDUCED FEE CAPAZ DE PROPORCIONARLO CON OR NO FEE. INFORMACION ACERCA DE LAS AGENCIAS QUE PUEDEN OFRECER LOS Cumberland County Bar Association SERVICIOS LEGALES A PERSONAS 32 South Bedford Street ELEGIBLES EN UN HONORARIO Carlisle, PA 17013 REDUCIDO NI NINGUN HONORARIO. (800) 990 -9108 Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990 -9108 File # 70772 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: M &T Bank v. Jennifer R. Hatton, Administratrix c.t.a., d.b.n. of the Estate of Margaret B. Brown, Deceased Mortgagor and Real Owner Cumberland County File # 70772 Page 3 COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is M &T Bank, duly organized and doing business, at the above - captioned address. 2. The Defendant is Jennifer R. Hatton, Administratrix c.t.a., d.b.n. of the Estate of Margaret B. Brown, Deceased Mortgagor and Real Owner, and his/her last -known address is 414 West 3rd Avenue, Parkesburg, PA 19356. 3. On February 12, 2007, Margaret B. Brown, mortgagor, made, executed and delivered an Open -End Mortgage, Home Equity Line of Credit upon the premises hereinafter described to Manufacturers and Traders Trust Company which Open -End Mortgage, Home Equity Line of Credit is recorded in the Office of the Recorder of Cumberland County in Mortgage Book 1984, Page 393 (the "Mortgage "), such Mortgage being incorporated herein by reference pursuant to Rule 1019(g) Pa. R. C. P. 4. On February 12, 2007, Margaret B. Brown, also executed a Home Equity Account Agreement and Disclosure Statement secured by the aforementioned Mortgage (the "Note "). Plaintiff, directly or through an agent, is in possession of the 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. Pursuant to Restated Organization Certificate of Manufacturers and Traders Trust Company executed on July 6, 2004, Manufacturers and Traders Trust Company is also known as M &T Bank, Plaintiff herein. 6. On February 27, 2011, Margaret B. Brown departed this life. Letters of Administration D.B.N.C.T.A. were granted unto Jennifer R. Hatton, Administratrix of the Estate of Margaret B. Brown, Deceased Mortgagor and Real Owner. 7. The premises subject to said Mortgage is described in the legal description attached as Exhibit "A" and is known as .615 Harding Street, New Cumberland, Pennsylvania 17070. 8. The Mortgage is in default because monthly payments of principal and interest upon said Mortgage due June 9, 2012 and each month thereafter are due and unpaid, and by the terms of said Mortgage, File # 70772 Page 4 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 $ 67,159.23 Interest through January 31, 2014 $ 3,083.34 (Interest due and owing at a variable rate, currently $5.52 per diem) Late Charges $ 218.27 Attorney's Fee $ 1,650.00 Escrow Advance $ 4,686.22 Property Inspection Fees $ 42.00 Property Evaluation Fees $ 1 00.00 GRAND TOTAL $ 76,939.06 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. 11. Plaintiff does not hold the named Defendant personally liable on this cause of action and releases them from any personal liability. This action is being brought to foreclose their interest in the aforesaid real estate only. File # 70772 Page 5 WHEREFORE, Plaintiff demands in rem Judgment against the Defendant in the sum of $76,939.06, together with interest due and owing at a variable rate, currently $5.52 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. . BY: [ ] Terrence J. McCabe; Esqui [ arc S. Weisberg, dquire [ ] 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 1. Foley, Esquire [ ] Celine P. DerKrikorian, Esquire [ ] Jennifer L. Wunder, Esquire [ ] Lena Kravets, Esquire Attorneys for Plaintiff File # 70772 Page 6 VERIFICATION Jeffrey Stahl , hereby states that he /she is Assistant Vice PresidenbfM & Bank, 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. J�W ii'J� Name: Jeffrey Stahl DATE: t / — `��' n Title: Assistant Vice President File #: 70772 Name: M &T Bank v. Jennifer R. Hatton, Administratrix c.t.a., d.b.n. of the Estate of Margaret B. Brown, Deceased Mortgagor and Real Owner File # 70772 Page 7 Exhibit "A" �RfSTay_ ALL TMAT C RT N piece or parcel of .lend aituete in t he Borough Of N ew Cumurlacttl. County of C"berland and State of Pennsylvania, more particularly bounded and 4es'' cribed as follows, to wit:: - BEGiNMKC at , a point on the northerly side of Rarditug Street, said [point being one hundred a�venty (170) feet from the northeast corner of Harding Street and Beckley Drive measured along the northerly line of Harding Street;, thence in a nort'hwasterly direction along the dividing line between Lott Nos. 169 and 170 Sectlou 3 of the hereinafter mentioned Plan of Tots, one hundred thirty (130) feet'to a twenty (zo) foot alley; thence in a northeasterly direction $tong the southern line of said alley seventy- fjve'(75) feet io a, point; thence in a southeasterly direction on a lfne parallel with the ,aforementioned dividing line. one hundred thirty (130) ,Feet to the northern'lLue of Harding Street; tbernce.in a or}uthwesterly direction along the northern line of Harding $tree t, sevezty- fivi .,(75) fret to the place of HEDIM . BEING Lot No. 1.69, sectLon of the Plan of Cvmberjand Manor an recorded ,fie the Recorder a Office of-Cumberland Couttty in Plata 'gook 3 Page 54, and the vestern txp-ftty -five (25) feet of Lot No. 119., Section 2 Plan of Cvmhetland Manor, ea recorded in plaza Book 2, Page 73. �I FORM l M &T:Bank IN THE COURT OF COMMON PLEAbF Plaintiff CUMBERLAND COUNTY, P:ENNS r' i K v° �• " vs. Jennifer R. Hatton, Administratrix c.t.a., d.b.n. of the C.vll G,f Estate of Margaret B. Brown, Deceased Mortgagor - - �- and. Real Owner and Margaret B. Brown - Defendants NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a. foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court- supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within. twenty (20) days of your receipt of this notice, you must contact MidPenn. I..,egal Services at (717) 243 -9400 extension 251.0 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. representative will prepare and file a Request for Conciliation a worksheet m the format attached hereto, the legal Conference with. the Court, which .must be filed with the Court within sixty (60) days i w 11 have tan upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, y 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 How ever, ou wu t for your lawyer all request d fie ancia appoint of a legal. representative. Howe , } provide information so that a loan resolution proposal can be e prepared ill prepare behalf and file a Request a fo Conciliation . a Fiancial worksheet in the format attached hereto, y Conference with the Court, which must be filed with the Court within sixty (60) days of t 11 service up011 you of the foreclosure complaint. if you do so and a conciliation conference is scheduled, you 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: n�2 i""- �J —'-— [Signature of Counsel for Plaintiff] Date 70772 Page 1 FORM 2 Cumberland County Residential Mortgage :Foreclosure Diversion :Program Financial Worksheet Date: Cumberland County Court of Common .Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: CUSTOM ER/PRIMARY 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. 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. Other Expenses Amount .Available for Monthly Mortgage Payments Based on Income & .Expenses: Have you been working with a Housing Counseling Agency? Yes O 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: Proof of income Past 2 bank statements Proof of any expected income for the last 45 days Vr 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 Sheriff � u t, at u5 �araratr �� Jody S Smith ' Chief Deputy nilf APR 30 pU 3; 3/ Richard W Stewart CUMBERLAND Solicitor -�.. .. . � PENNSV DOUNTY LVANIA M&T Bank Case Number vs. 2014-1653 Jennifer R Hatton,Administratrix c.t.a, d.b.n. of the Estate of SHERIFF'S RETURN OF SERVICE 03/25/2014 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jennifer R Hatton, Administratrix c.t.a, d.b.n. of the Estate of, but was unable to locate the Defendant in the Sheriffs bailiwick. The Sheriff therefore deputizes the Sheriff of Chester, Pennsylvania to serve the within Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure according to law. 03/28/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Jennifer R Hatton,Administratrix c.t.a, d.b.n. of the Estate of, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure as"Not Found" at 615 Harding Street, New Cumberland Borough, New Cumberland, PA 17070. Residence is vacant. 04/08/2014 09:40 AM -The requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure served by the Sheriff of Chester County upon Jennifer R Hatton,Administratrix c.t.a, d.b.n. of the Estate of, personally, at 414 West 3rd Avenue, Parkesburg, PA 19356. Carolyn B. Welsh, Sheriff, Return of Service attached to and made part of the within record. SHERIFF COST: $71.21 SO ANSWERS, April 23, 2014 RONR ANDERSON, SHERIFF ..,z/ > 1111,111 • SHERIFF'S OFFICE OF CUMBERLAND COUNTY ' Ronny R Anderson Sheriff Jody S Smith Richard W Stewart Chief Deputy Solicitor M&T Bank vs. um er Jennifer R Hatton, Administratrix c.t.a, d.b.n. of the Estate of 2014-1653 SERVICE COVER SHEET N Service Details: Or Category: Civil Action - Notice of Residential Mortgage Foreclosure Diversion Progr Zo ne: v x Manner: Deputize w p Expires: 04/23/2014 ; Warrant: Notes: w 0) a g Serve To: Final Service: NName: Jennifer R Hatton, Administratrix c.t.a, d.b.i Served:Cf:&Adult In Charge • Posted • Other Primary 414 West 3rd Avenue Adult In ■ � ` Q Address: Parkesburg, PA 19356 Charge: e f\�n 1 —� (" Hpl' vc-ri a in- Phone: DOB: Relation: w Alternate Address: Date: Li( (j t l Time: 9 ;90 G o � M Phone: Deputy: t Mileage: Lu Attorney/Originator: Nr Name: McCabe Weisberg and Conway Phone: 215-790-1010 v _ Service Attempts; Date: N Time: j i 4 Mileage: [ , y De ut ,-_ p Notes/Special Instructions: _ f- I- U) z Now, March 25, 2014 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Chester County to < execute service of the documents herewith and make return thereof according to law. z O Return To: Cumberland County Sheriff's Office = One Courthouse Square Carlisle, PA 17013 Ronny R Anderson, Sheriff OFFICE OF THE SHERIFF CHESTER COUNTY JUSTICE CENTER '201 W. MARKET STREET, SUITE 1201 PO BOX 2746 WEST CHESTER, PA 19380-0989 Receipt Type Case Outstanding Amount 0.00 Receipt Number 520321 Receipt Date 04/03/2014 Case Number 2014-90513-SOC Description M&T BANK VS. HATTON, JENNIFER R/ADM CTA DBN OF EST MARGARET B BROWN Received From MCCABE, TERRENCE J. On Behalf Of M&T BANK Itemized Listing: Description Amount ESCROW 150.00 Receipt Payments Amount Reference Description Check 150.00 210955 Total Received 150.00 Net Received 150.00 Change 0.00 Comments 1B 1C MF Deputy Clerk DKELLY Transaction Date 04/03/2014 13:32:25.00 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 M&T Bank Plaintiff v. Jennifer R. Hatton, Administratrix c.t.a., d.b.n. of the Estate of Margaret B. Brown, Deceased Mortgagor and Real Owner Defendants TO THE PROTHONOTARY: CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 14-1653 Civil PRAECIPE ❑ Please mark the action Discontinued and Ended without prejudice. ❑ Please mark the above referenced case Settled, Discontinued and Ended. ❑ Please Vacate the judgment entered and mark the action Discontinued and Ended without prejudice. ❑ Please mark the in rem judgment Satisfied and the action Discontinued and Ended. ❑ Please Vacate the Judgment entered. DATE: ,o) 93)1 of M ABE, W`ISBE AND CON BY: [ ] Te nce J. McCabe, Esq. [ ] E. and 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. rgaret Gairo, Esq. [ ] Heidi R. Spivak, Esq. [ ] Christine L. Graham, Esq. [ ] Ann E. Swartz, Esq. [ I] Joseph I. Foley, Esq. [ ] 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 M&T Bank Plaintiff v. Jennifer R. Hatton, Administratrix c.t.a., d.b.n. of the Estate of Margaret B. Brown, Deceased Mortgagor and Real Owner Defendants CUMBERLAND COUNTY COURT OF COMMON PLEAS No. 14-1653 Civil CERTIFICATE OF SERVICE The undersigned Attorney for Plaintiff, hereby certifies that a true and correct copy of the within Praecipe was served on the below person by regular first class mail, postage prepaid, on the Jennifer R. Hatton, Administratrix c.t.a., d.b.n. of the Estate of Margaret B. Brown, Deceased Mortgagor and Real Owner 414 West 3rd Avenue Parkesburg, Pennsylvania 19356 DATE: 1 i/ / "ag. J % 1/ McC BY: ERG AND AY, ay of October, 2014. .C. [ ] Terre • - J. McCabe, Esq. [ ] Ed ,ard 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 [ ]M [] [ [ ] _ ine L. Graham, Esq. [ ] Ann E. Swartz, Esq. ] Joseph I. Foley, Esq. [ ] Lena Kravets, Esq. c S. Weisberg, Esq. argaret Gairo, Esq. Heidi R. Spivak, Esq.