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HomeMy WebLinkAbout14-2616 4 Supreme Court;of.Pennsylvania COUP C o n ; Pleas For Prothonotary Use Only: Cove eet CU]E;ND County Docket No: /n l V 4t`''zs== t n I . /�/ The information collected on this form is used solely for court administration purposes. This form does not supp lement or replace the filing and service o leadin s 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: PHH MORTGAGE Lead Defendant's Name: CASSIDY M. EDWARDS T CORPORATION I Are money damages requested? El Yes 0 No Dollar Amount Requested: El within arbitration limits O (Check one) 0 outside arbitration limits N Is this a Class Action Suit? ❑ Yes ❑x No Is this an MDJ Appeal? ❑ Yes 0 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 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 ❑ 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: U ❑ 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 ❑ 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 q 1. 1` S " yo � 3 L VA��,�� PHELAN HALLINAN, LLP John D. Krohn, Esq., Id. No. 312244 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215 -563 -7000 PHH MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD COURT OF COMMON PLEAS MOUNT LAUREL, NJ 08054 CIVIL DIVISION Plaintiff V. TERM CASSIDY M. EDWARDS NO. 1 aUGI U - 327 EAST BURD STREET SHIPPENSBURG, PA 17257 -1403 CUMBERLAND COUNTY Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE v ��103.� alp File #: 306875 1 20 /24 1. Plaintiff is PHH MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD MOUNT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: CASSIDY M. EDWARDS 327 EAST BURD STREET SHIPPENSBURG, PA 17257 -1403 who is /are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 07/06/2006 CASSIDY M. EDWARDS made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS A NOMINEE FOR ERA HOME LOANS which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1958, Page 2176. By Assignment of Mortgage recorded 09/21/2012 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201228971.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 05/01/2012 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. File #: 306875 6• The following amounts are due on the mortgage as of 04/21/2014: Principal Balance $143,185.78 Interest $18,388.60 04/01/2012 through 04/21/14 Late Charges $251.36 Property Inspections $123.75 Non Sufficient Funds Charge $163.24 Escrow Deficit $12,889.28 TOTAL $175,002.01 7. 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. 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 #: 306875 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $175,002.01, 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. Krolf, Esq., Id. No. 312244 Attorney for /Plaintiff File #: 306875 LEGAL DESCRIPTION ALL the following described tract of real estate being situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING on the South by East Burd Street; on the West by property now or formerly of Alice Gise; on the North by a public alley; and on the East by property formerly of W. E. McCune. The said lot having a frontage on East Burd Street aforesaid of 42 feet and extending uniformly in depth to the said alley on the North. SUBJECT, HOWEVER, to the conditions, restrictions and reservations of record. BEING THE SAME PREMISES which Erin L. Kramer and Kelly L. Sweeney, erroneously referred to as Kelley L. Sweeney, by Deed recorded simultaneously herewith in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 262, Page 3834, granted and conveyed unto Cassidy M. Edwards, single. PROPERTY ADDRESS: 327 EAST BURD STREET, SHIPPENSBURG, PA 17257 -1403 PARCEL # 32 -33- 1867 -040 File #: 306875 , VERIFICATION Willia Bellows hereby states that he /she is Assistant Vice Preside PHH MORTGAGE CORPORATION, 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. By PHH Mortgage Corporation, Its authorized agent, Date: ` z 0 By William Bellows Assistant Vice President PHS #: 306875 Name: EDWARDS File #: 306875 FORM 1 IN THE COURT OF COMMON PLEAS PHH MORTGAGE CORPORATION OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) vs. CASSIDY M. EDWARDS Q � Defendants I ' �"" I � QQ vil 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 Mid'enn 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 tomeet 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: Date r n r , John D. K Esq., Id. No., 312244 Attorney for Plaintiff CD 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: CUSTOM 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 in household: How long? 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 #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 nd 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 /Tuit. I Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ❑ No ❑ If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: 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) 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 #: 306875 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY TILED OFFICE O THE PROTHONOTARY of c mroi,prr_ orF.ICG w„F ThiE HF,RIFF 20111 MAY 13 Pit 05 CUMBERLAND COUNTY PENNSYLVANIA PHH Mortgage Corporation vs. Cassidy M Edwards Case Number 2014-2616 SHERIFF'S RETURN OF SERVICE 05/01/2014 05:31 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a person representing themselves to be Cindy Edwards, Mother, who accepted as "Adult Person in Charge” for Cassidy M Edwards at 327 Burd Street, Shippensburg Borough, Shippensburg, PA 17257. c94)12t,.2$17 -41.Z. JASON KINStER, DEPUTY SHERIFF COST: $50.60 SO ANSWERS, May 02, 2014 RONNR ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosofi, Lac. FORM 3 PHH MORTGAGE CORPORATION : IN THE COURT OF COMMON PLEAS OF 2001 BISHOS GATE BLVD : CUMBERLAND COUNTY, PENNSLV INIA' MOUNT LAUREL, NJ 08054 -17 - Plaintiff(s) rr? eorri , vs. o CASSIDY M. EDWARDS c-, n 327 EAST BURD STREET Defendant(s) : 14-2616 CIVIL - p z- SHIPPENSBURG, PA 17257 '' REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated v County Residential Mortgage Foreclosure Diversion Pro as follows: , 2012 governing the Cumberland , the undersigned hereby certifies 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 false statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Signature of Defendant's Counsel/Appointed Legal Representative Si re De ant Dat /3 Date Signature of Defendant Date i CERTIFICATE OF SERVICE I hereby certify that on June 30, 2014, I, Bret P. Shaffer, Esquire, of Baric Scherer, did serve a copy of the Request for Conciliation Conference, by first class U.S. mail, postage prepaid, to the party listed below, as follows: PHELAN HALLINAN, LLP John D. Khron, Esquire, Id. No. 312244 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Br t P. Shaffer, Esquire PHH MORTGAGE CORP., IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANI vs. : CIVIL ACTION CASSIDY M. EDWARDS, Defendant : NO. 14-2616 CIVIL CASE MANAGEMENT ORDER rn rn r r— AND NOW, this day of July, 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 fta r32d` a0'/f , at /' 30 . 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. Conciliation Conference on 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. John D. Khron, Esquire Phelan Hallinan, LLP 1617 JFK Bulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 For the Plaintiff Bret Shaffer, Esquire 19 W. South Street Carlisle, PA 17013 For the Defendants :rim 7 iy/IY `-r-r►� BY THE COURT, CJM , L 22 !j:• 45 PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 Attorney for Plaintiff PHH MORTGAGE CORPORATION Court of Common Pleas 2001 BISHOPS GATE BLVD MOUNT LAUREL, NJ 08054 Civil Division Plaintiff No. 14 -2616 -CIVIL v. Cumberland County CASSIDY M. EDWARDS 327 EAST BURD STREET SHIPPENSBURG, PA 17257-1403 Defendant MOTION TO LIFT CONCILIATION STAY Plaintiff, PHH Mortgage Corporation (hereinafter "Plaintiff'), by its attorney, Joseph P. Schalk, Esquire, hereby files the within Motion to Lift Conciliation Stay and in support thereof avers as follows: 1. On April 29, 2014, Plaintiff filed a Complaint in Mortgage Foreclosure against Defendants for their failure to make monthly payments of principal and interest upon their mortgage due May 1, 2012, and each month thereafter. A true and correct copy of the Complaint is attached hereto, made part hereof and marked as Exhibit "A". 2. On May 1, 2014, Plaintiff completed service of the Complaint in Mortgage 800637 Foreclosure along with the Cumberland County Residential Mortgage Foreclosure Diversion Program Notice upon the Defendant. A true and correct copy of the Sheriff's Return of Service is attached hereto, made part hereof and marked as Exhibit "B". 3. Pursuant to the Cumberland County Administrative Order February 28, 2012, which created the Cumberland County Residential Mortgage Foreclosure Diversion Program, the Foreclosure action is stayed for sixty (60) days from the date of service. 4. Within 60 days after service of the complaint, the Defendant may opt into the program by filing a Request for Conciliation Conference with the Court. Upon the filing of the request, the Court will schedule a Conciliation Conference. The program provides that Defendant must contact MidPenn Legal Services within the first twenty (20) days of receipt of notice if not represented by counsel. 5. If more than sixty (60) days has elapsed since the service of Notice of Residential Mortgage Foreclosure Diversion Program and the Defendant has not opted to participate in the Diversion Program Plaintiff may petition the Court to lift the stay and remove the case from the Diversion Program. 6. Defendant has failed to opt into the Cumberland County Residential Mortgage Foreclosure Diversion Program within sixty (60) days of service. 7. Since Defendant has opted not to participate in the Diversion Program, it is appropriate for the stay to be lifted. 800637 WHEREFORE, Plaintiff respectfully requests that this matter be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program and the automatic stay be lifted. Date: 2l (�J BY: 800637 Respectfully submitted, PHELAN HALLINAN, LLP Jose Atto Schalk, Esquire ey for Plaintiff • s •-•r• PHELAN HALLINAN, LLP John D. Krohn, Esq., Id. No. 312244 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 iN FFtGt PRO THONG TA 2014 APR 29 AH1.iO 33 CUMBERLAND P' SYLV'A j IA tt ATI ORNEY FOR PLAINTIFF PHH MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD COURT OF COMMON PLEAS MOUNT LAUREL, NJ 08054 CIVIL DIVISION Plaintiff v; TERM CASSIDY M. EDWARDS NO. - Q1� t u l.• 327 EAST BURD STREET SHIPPENSBURG, PA 17257-1403 CUMBERLAND COUNTY Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE ATTORNEY FILE COPY PI rm. - nrTI!p^1 File 8: 306875 lithin to .be true ane .orrect copy of the wiainor 41 ..+l x "geom.. S E C T I 0 N A S E C T I 0 N B Supreme Cour Cou Pennsylvania Pleas County For Prothonotary Use Only; Docket No: The information collected on this form is used solely for court administration purposes. This form does not .szr/Jpk»fent or iepirace'thej7linJ; and service .ra>rpl adinf;s or other lfaper,s as. reyuirerl bit law or rules i /'court. Commencement of Action: El Complaint 0 Writ of Summons 0 Petition 0 Transfer from Another Jurisdiction 0 Declaration of Taking Lead Plaintiff's Name: PHH MORTGAGE CORPORATION Lead Defendant's Name: CASSIDY M. EDWARDS Dollar Amount Requested: 0 within arbitration limits (Check one © outside arbitration limits Is this an MDJ Appeal? 0 Yes © No Are money damages requested? ■ Yes 0 No Is this a Class Action Suit? 0 Yes ll No Name of Plaintiff/Appellant's Attorney: John D. Krohn, Esq., Id. No, 312244 , Phelan Hallinan, LLP 0 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) O Intentional 0 Malicious Prosecution ❑ Motor Vehicle 0 Nuisance ❑ Premises Liability ❑ Product Liability (does not include mass tort) ❑ Slender/Libel/ Defamation ❑ Other: MASS TORT 0 Asbestos 0 Tobacco ❑ Toxic Tort - DES ❑ Toxic Tort - Implant ❑ Toxic Waste ❑ Other: .40 PROFESSIONA' ❑ Dental 0 Legal ❑ Medical ❑ Other Professional: AB T Pa. R. C P. 205.5 CONTRACT (do not include Judgments) 0 Buyer Plaintiff 0 Debt Collection: Credit Card ❑ Debt Collection: Other 0 Employment Dispute: Discrimination 0 Employment Dispute: Other 0 Other: CIVIL APPEALS Administrative Agencies ❑ Board of Assessment ❑ Board of Elections 0 Dept. of Transportation ❑ Statutory Appeal: Other ❑ Zoning Board ❑ Other: REAL PROPERTY 0 Ejectment O Eminent Domain/Condemnation 0 Ground Rent 0 Landlord/Tenant Dispute El Mortgage Foreclosure: Residential O Mortgage Foreclosure: Commercial 0 Partition O Quiet Title ❑ Other: IISCELLANEOUS ❑ Common Law/Statutory Arbitration O Declaratory Judgment 0 Mandamus 0 Non -Domestic Relations Restraining Order 0 Quo Warranto 0 Replevin ❑ Other: Updated 01/01/2011 PHH MORTGAGE CORPORATION Plaintiff(s) vs. CASSIDY M. EDWARDS Defendant(s) FORM I fN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Civil 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 Mid'enn 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 tomeet 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. 11. 6 -PI Date Respectfully submitted: John D. i til )%, 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: Borrower name(s): Property Address: City: 'State: Zip: Is the property for sale? Yes Q No'[j Listing date: Price: ,$. Realtor Name: :Realtor Phone:... Borrower Occupied? Yes 0 No [] Mailing Address (if different):: City: Phone Numbers: Home: Office; Cell: Other: State: zip: Email: # of people in household: How long? Mailing Address: City: Phone Numbers: Email: Home: Cell: Office: Other: State: Zip: # of people in household: How long? 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 E:1 No Li 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 fra: Model: Year: Amount owed: Value: Automobile #2: Moder: 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 MoirthlyNet, Additional Income Description (not wages): monthly amount: monthly amount: Borrower Pay Days: Co-BorrowerPay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food Tul.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 Other Expenses Day/Child Care/Tuit. , Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? YesLJ No If yes, please provide the following information: Counseling Agency: Phone (Office): Fax: Counselor: Email: . Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes D 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 D No D If yes, please indicate the status of those negotiations: Please provide the following information, if known, regarding your lender and lender's loan se company: Lender's Contact (Name): -. Phone: Servicing Company (Name):, Contact: I/We, Phone: g 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.. r. Borrower Signature Date Co -Borrower Signature Da 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) 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 N: 306875 PHELAN HALLfNAN, LLP John D. Krohn, Esq., Id. No. 312244 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215=563-7000 ATTORNEY FOR PLAINTIFF PHH MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD COURT OF COMMON PLEAS MOUNT LAUREL, NJ 08054 CIVIL DIVISION Plaintiff TERM CASSIDY M. EDWARDS NO., 327 EAST BURR STREET SHIPPENSBURG, PA 17257-1403 CUMBERLAND COUNTY Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 306875. Plaintiff is PHH MORTGAGE CORPORATION 2001 BISHOPS GATE BLVD MOUNT LAUREL, NJ 08054 2. The name(s) and last known address(es) of the Defendant(s) are: CASSIDY M. EDWARDS 327 EAST BURD STREET SHIPPENSBURG, PA 17257-1403 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3.. On 07/06/2006 CASSIDY M. EDWARDS made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS A NOMINEE FOR ERA HOME LOANS which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Book 1958, Page 2176. By Assignment of Mortgage recorded 09/21/2012 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Instrument No. 201228971.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 05/01/2012 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. File N: 306875 6. The following amounts are due on the mortgage as of 04/21/2014: Principal Balance $143,185.78 Interest $18,388.60 04/01/2012 through 04/21/14 Late Charges $251.36 Property Inspections $123.75 Non Sufficient Funds Charge $163.24 Escrow Deficit $12,889.28 TOTAL $175,002.01 7 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, 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 $: 306815 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $175,002.01, 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 Dro1 , Esq., Id. No. 312244 Attorney: `orPltinti Pilch: 306875 LEGAL DESCRIPTION ALL the following described tract of real estate being situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, bounded and limited as follows: BEGINNING on the South by East Burd Street; on the West by property now or formerly of Alice Gise; on the North by a public alley; and on the East by property formerly of W. E. McCune. The said lot having a frontage on East Burd Street aforesaid of 42 feet and extending uniformly in depth to the said alley on the North. SUBJECT, HOWEVER, to the conditions, restrictions and reservations of record. BEING THE SAME PREMISES which Erin L. Kramer and Kelly L. Sweeney, erroneously referred to as Kelley L. Sweeney, by Deed recorded simultaneously herewith in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book 262, Page 3834, granted and conveyed unto Cassidy M. Edwards, single. PROPERTY ADDRESS: 327 EAST BURP. STREET, SHIPPENSBURG, PA 17257-1403 PARCEL # 32-33-1867-040 File N: 306875 VERIFICATION William geltow7i , hereby states th t he/she is Assistant Vice Presldentf, P1 -IH MORTGAGE CORPORATION, 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: By jPHS #: 306875 Name: EDWARDS File #; 306875 By PHH Mortgage Corporation, Its authorized agent, William Bellows Assistant Vice President Ronny R Anderson Sheriff' Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 00 pt C11446 .4,00 OFF= OF THE $NERtFP PHH Mortgage Corporation vs. Cassidy M Edwards i Cue Number 2014-2616 SHERIFF'S RETURN OF SERVICE 05/01/2014 05:31 PM - Deputy Jason 1<lnsler, being duly sworn according to:law, servedthe'requested:Notice Of Residential Mortgage Foreclosure DIverlon Program and Complaint in Mortgage: Foreclosure by handing; a true copy to a person representing themselves:to be Cindy Edwards, Mother, who accepted as "Adult Person In Charge" for Cassidy :I Edwards at 327•Surd:'Street, Shippensburg Borough,: Shippensburg, PA. 17257. JAIfrOt KIN R, DEPUTY SHERIFF COST: $50.80 SO ANSWERS, May 02, 2014 (c) CountySulte Sheriff, Teleaso8 ins RONNY R ANDERSON, SHERIFF PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 Attorney for Plaintiff PHH MORTGAGE CORPORATION Court of Common Pleas 2001 BISHOPS GATE BLVD MOUNT LAUREL, NJ 08054 Civil Division Plaintiff No. 14 -2616 -CIVIL v. Cumberland County CASSIDY M. EDWARDS 327 EAST BURD STREET SHIPPENSBURG, PA 17257-1403 Defendant CERTIFICATION OF SERVICE I, Joseph P. Schalk, Esquire, certify that I caused true and correct copies of Plaintiff's Motion to Lift Conciliation Stay and proposed Order to be sent sent via first class mail to the person listed below on the date indicated: CASSIDY M. EDWARDS 327 EAST BURD STREET SHIPPENSBURG, PA 17257-1403 Date: 71 Zc/ 17 By: 800637 seph Attorn chalk, Esquire y for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PHH MORTGAGE CORPORATION Court of Common Pleas 2001 BISHOPS GATE BLVD MOUNT LAUREL, NJ 08054 Civil Division Plaintiff No. 14 -2616 -CIVIL v. Cumberland County CASSIDY M. EDWARDS 327 EAST BURD STREET SHIPPENSBURG, PA 17257-1403 Defendant ORDER AND NOW, this Z s` day of q , 2014, upon consideration of Plaintiff's Motion to Lift Conciliation Stay in the above captioned matter, it is hereby ORDERED and DECREED that this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program; it is further ORDERED and DECREED that the automatic Stay is lifted and Plaintiff may proceed with its Mortgage Foreclosure Action. CC: 800637 Cassidy M. Edwards Joseph P. Schalk, Esquire, Id. No. 91656 Attorney for Plaintiff ✓ PHELAN HALLINAN, LLP Joseph P. Schalk, Esquire, Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 x 7365 -ASSIDY M. EDWARDS 327 EAST BURD STREET SHIPPENSBURG, PA 17257-1403 ees cr' 7as/fy 800637 PHH MORTGAGE CORP., IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANI VS. CIVIL ACTION NO. 14-2616 CIVIL CASSIDY M. EDWARDS, Defendant IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this Z day of July, 2014, at the request of counsel, the conciliation conference in the above matter set for August 22, 2014, is continued to Friday, September 12, 2014, at 1:45 p.m. in Chambers of the undersigned. BY THE COURT, Kevi A. Hess, P.J. Joseph P. Schalk, Esquire 126 Locust Street , -' Harrisburg, PA 17101 FO he Plaintiff zrn 2;u r -nr71 <> v o Bret Shaffer, Esquire r—= :::1 19 W. South Street Carlisle, PA 17013 For the Defendants x'? ` Ce Xl PHELAN HALLINAN, LLP BY: JOSEPH P. SCHALK, ESQUIRE Identification No.: 91656 126 Locust Street Harrisburg, PA 17101 Telephone: (215) 563-7000, Ext. PHH MORTGAGE CORPORATION PLAINTIFF v. ZOR AUG 20 Pfl 1: 22 CUMBERLAND COUNTY PENNSYLV/ WA ATTORNEY FOR PLAINTIFF : COURT OF COMMON PLEAS : CUMBERLAND COUNTY : Civil Division CASSIDY M. EDWARDS : No. 14-2616 CIVIL DEFENDANT STIPULATED AGREEMENT AND NOW, this 12th day of August 2014, it is hereby agreed by and between, PHH Mortgage Corporation (hereinafter "Plaintiff'), by and through its counsel, Joseph P. Schalk, Esquire and Cassidy M. Edwards (hereinafter "Defendant") by and through his counsel, Bret Shaffer, Esquire, as follows: WHEREAS, the Plaintiff filed its Complaint in Mortgage Foreclosure on April 29, 2014 seeking an in rem judgment for default upon the terms of the Mortgage; WHEREAS, Plaintiff served the Complaint upon the Defendant on May 1, 2014; WHEREAS, Plaintiff filed a Motion to Lift the Stay imposed by the Cumberland County Foreclosure Diversion Program on July 22, 2014, which was granted on July 25, 2014; WHEREAS, unbeknownst to Plaintiff, the Court had entered a Court Order on July 14, 2014 placing this matter into the Diversion Program; WHEREAS, the parties to this Settlement Agreement are desirous of vacating the July 25, 2014 Order, therefore Plaintiff and Defendant agree as follows: 1. The Order dated July 25, 2014 is null and void by virtue of the July 14, 2014 Order placing this matter into the Cumberland County Foreclosure Diversion Program. 2. The stay imposed by the program will remain in effect until further Order of Court. 3. This settlement agreement may be executed in counterpart. Date: Date: Vir /17 ose f Schalk, Esquire Actor ey for Plaintiff X Bret P. Shaffer Esquire Attorney for Defendant PHELAN HALLINAN, LLP By: Joseph P. Schalk, Esquire Identification No. 91656 126 Locust Street Harrisburg, PA 17101 joseph.schalk@phelanhallinan.com 215-563-7000 Attorney for Plaintiff PHH MORTGAGE CORPORATION : COURT OF COMMON PLEAS PLAINTIFF : CUMBERLAND COUNTY v. : Civil Division CASSIDY M. EDWARDS : No. 14-2616 CIVIL DEFENDANT CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the executed Settlement Agreement was sent via first class mail to the persons on the date listed below: Bret P. Shaffer, Esquire 19. W. South Street Carlisle, PA 17013 Date: August 19, 2014 B es,phl . Schalk, Esquire ey for Plaintiff PHH MORTGAGE CORP., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION — LAW : NO. 14-2616 CIVIL CASSIDY M. EDWARDS, Defendant ORDER AND NOW, this 11th day of September, 2014, on agreement of the parties, the conciliation conference is continued until Friday, November 14th, 2014 at 2:30 PM. BY THE COURT, t./Keph P. Schalk, Esquire Phelan Hallinan, LLP 126 Locust Street Harrisburg, PA 17101 For the Plaintiff ...3ret Shaffer, Esquire 19 W. South St. Carlisle, PA 17013 For the Defendant :rlm -C- • PHH MORTGAGE CORP., : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANI vs. CASSIDY M. EDWARDS, Defendant : CIVIL ACTION : NO. 14-2616 CIVIL IN RE: CONCILIATION CONFERENCE ORDER AND NOW, this / 7' day of November, 2014, it appearing that the homeowner has been approved for a loan modification, conciliation conference herein is continued generally and a conciliation conference may be set at the request of either party. BY THE COURT, Kevin Hess, P. eph P. Schalk, Esquire 126 Locust Street Harrisburg, PA 17101 For the Plaintiff Bret Shaffer, Esquire 19 W. South Street Carlisle, PA 17013 For the Defendants op , r) ; Lc, L /0 ill 5. : CD DZIN N)