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14-4156
�f Supreme Cou' o. Pennsylvania Cour; ommo leas For Prothonotary Use Only: T OVehet Docket No: rt�f S/9 Curn erlancl ! County - /5-4 0-V 1' Term -, The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the filing and sendee of pleadings or other papers as required by law or rules of court. Commencement of Action: S El Complaint El Writ of Summons ❑❑ Petition. E Transfer from Another Jurisdiction 0 Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T Carrington Mortgage Services, LLC Heather N. Pryor Dollar Amount Requested: Owithin arbitration limits I Are money damages requested? Yes xi No O (check one) outside arbitration limits N Is this a Class Action Suit? Yes X No Is this an MDJAppeal? n Yes 0 No A Name of Plaintiff/Appellant's Attorney: Kevin P. Diskin, Esquire C-1 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 0 Intentional Buyer Plaintiff Administrative Agencies 0 Malicious Prosecution Debt Collection:Credit Card Board of Assessment El Motor Vehicle 171 Debt Collection:Other Board of Elections 0 Nuisance © Dept.of Transportation E] Premises Liability Statutory Appeal:Other S 0 Product Liability(does not include L`j mass tort) � Employment Dispute: Slander/Libel/Defamation Discrimination C 0 Other: Employment Dispute:Other Zoning Board T Other: I Other: O MASS TORT El Asbestos N El Tobacco Toxic Tort-DES Q Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS El Toxic Waste Q Ejectment Other: [I Common Law/Statutory Arbitration B ©Eminent Domain/Condemnation [I Declaratory Judgment © Ground Rent ® Mandamus 0 Landlord/Tenant Dispute ®Non-Domestic Relations 0 Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY El Mortgage Foreclosure:Commercial Quo Warranto (� Dental CI Partition ®Replevin Legal Quiet Title 0 Other: 0 Medical n Other: n Other Professional: Updated 1/1/2011 F Richard M. Squire& Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire e Kevin P. Diskin, Esquire - i E i'i F'J i ` ,;C Craig Oppenheimer, Esquire E r� ; ID. Nos. 04267/ 86727 /313264 `" 17 E k- One Jenkintown Station, Suite 104 tr i} R'L A i 0 :a TY 115 West Avenue F L N!,,;S Y LVA N I Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Carrington Mortgage Services, LLC, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, DOCKET NO: f q - eivil 1m V. CIVIL ACTION Heather N. Pryor 946 W Old York Rd MORTGAGE FORECLOSURE Carlisle, PA 17015, DEFENDANT COMPLAINT - CIVIL ACTION NOTICE TO DEFEND 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 of 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 LAWYE s 4 l 13.75 po ATT( 1 & CMS-147F/LC el 30810D& Y 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objecciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus edades u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION ACERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE.PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 717-249-3166 and 800-990-9108 2 CMS-147F/LC Y Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire ID. Nos. 04267/ 86727/313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Carrington Mortgage Services, LLC, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PLAINTIFF, PENNSYLVANIA V. DOCKET NO: Heather N. Pryor CIVIL ACTION 946 W Old York Rd Carlisle, PA 17015, MORTGAGE FORECLOSURE DEFENDANT COMPLAINT IN MORTGAGE FORECLOSURE PLAINTIFF, Carrington Mortgage Services, LLC, by and through its undersigned attorney brings this action in mortgage foreclosure upon the following cause of action: 1. PLAINTIFF, Carrington Mortgage Services, LLC, is a corporation, limited partnership, limited liability company, trust, federal savings bank, federal credit union, or national banking association under and pursuant to the National Banking Act(13 Stat. 99, 12 U.S.C. 1 et seq.) with its principal place of business at 1610 E. St. Andrew Place, Suite #B150, Santa Ana, CA 92705. 2. Defendant, Heather N. Pryor, is the real owner, mortgagor, and grantee in the last Deed of record to the real property located at 771 Longs Gap Rd Carlisle, PA 17013 including any/all 3 CMS-147F/LC r improvements and detached structures thereon as well as any/all riparian/water rights appertaining thereto (hereinafter collectively referred to as "Premises") . 3. On September 26, 2008, Defendant made, executed, and delivered a Mortgage to JP Morgan Chase Bank,NA (hereinafter referred to as "Originating Lender") as security for Defendant's payment and other obligations in consideration of a mortgage loan made to Defendant by the Originating Lender. Said Mortgage is recorded in the Office of the Recorder in and for Cumberland County, and was recorded on October 14, 2008 in Cumberland County as Instrument No./Doc ID 200833983. , and is incorporated herein by reference by virtue of Pa. R.C.P. 1019(g). 4. By Assignment of Mortgage dated December 31,2013 the Mortgage was assigned to PLAINTIFF, which Assignment is recorded as Instrument No. 201401930. Plaintiff is the holder of the mortgage. 5. A true and correct copy of the Legal Description is attached hereto,made part hereof, and marked as Exhibit"A". 6. The address of the Premises is 771 Longs Gap Rd, Carlisle, PA 17013. 7. The aforesaid Mortgage is in default because the required monthly payments due under the terms of the aforesaid Mortgage have not been made from November 1, 2013 through the present date. By the terms of the aforesaid Mortgage,upon breach and failure to cure said breach after written notice thereof, all sums secured by said Mortgage shall be immediately due and owing. 8. The terms of the aforesaid Mortgage further provide that, in the event of default, Defendant shall be liable for, inter alia, Plaintiffs costs, corporate advances, escrow advances, and attorneys' fees. 4 CMS-147F/LC 9. The following amounts are due as of June 13, 2014: Principal $ 127,245.96 Accrued Interest through June 13, 2014 $ 4,922.43 Late Fees $ 201.48 Attorneys' Fees to date $ 1,650.00 Total $ 134,019.87 plus additional pre judgment and post judgment interest at the per diem rate of$21.79 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, additional attorneys' fees and court costs, and any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage. 10. If the Mortgage is reinstated prior to a sheriff's sale,the attorneys' fees set forth in the preceding paragraph may be less than the amount demanded based on work actually performed. The attorneys' fees requested in the preceding paragraph are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect attorneys' fees of up to five percent (5%) of the remaining principal balance in the event the Premises is sold to a third party purchaser at sheriff's sale; or, if the complexity of the action requires additional fees, such fees may exceed the amount demanded in the preceding paragraph. 11. Notice of Intention to Foreclose pursuant to Act 6 and/or Act 91 was sent in accordance with Pennsylvania law more than 34 days ago. 5 CMS-147F/LC N WHEREFORE, Plaintiff respectfully requests that judgment in rem be entered in its favor and against Defendant, Heather N. Pryor, for foreclosure and sale of the Premises in the amounts due as set forth in Paragraph 9., namely $134,019.87, plus additional pre judgment and post judgment interest at the per diem rate of$21.79 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, additional attorneys' fees and court costs, any/all other sums recoverable by Plaintiff under the terms of the aforesaid Mortgage, and such other relief as this Court deems just and proper. RICHARD M. SQUIRE & ASSOCIATES,LLC Bye �RR' Bard M. Squire, Esq. (PA I.D.# 04267) Kevin P. Diskin, Esq. (PA I.D. # 86727) Craig Oppenheimer, Esq. (PA I.D.# 313264) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskinnsquirelaw.com coppenheimergsquirelaw.com Attorneys for Plaintiff Date: �- UNLESS YOU NOTIFY US WITHIN THIRTY (30)DAYS AFTER RECEIPT OF THIS LETTER/NOTICE/PLEADING THAT THE DEBT, OR ANY PART OF IT, IS DISPUTED,WE WILL ASSUME THAT THE DEBT IS VALID. IF YOU DO NOTIFY US OF A DISPUTE,WE WILL OBTAIN VERIFICATION OF THE DEBT AND MAIL IT TO YOU. ALSO UPON YOUR REQUEST WITHIN THIRTY (30) DAYS,WE WILL PROVIDE YOU WITH THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR IF DIFFERENT FROM THE CURRENT CREDITOR. THIS COMMUNICATION IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 6 CMS-147F/LC F Richard M. Squire&Associates,LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Craig Oppenheimer, Esquire ID.Nos. 04267 / 86727 /313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown,PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Carrington Mortgage Services, LLC, IN THE COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO: Heather N. Pryor 946 W Old York Rd CIVIL ACTION Carlisle, PA 17015, DEFENDANT MORTGAGE FORECLOSURE VERIFICATION Chris Lechtanski ,hereby states that he/she is employed as a AVP of Default of Carrington Mortgage Services, LLC, Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Complaint are true and correct to the best of my information and belief. I understand that this statement is made subject to the penalties of 18 P . C.S. Sec. 4904 relating to unsworn falsification to authorities. Chris Lechtmski,AVP d Defaufl for Cam 0 MW Sm�LLC.Aitomey O Fact Carrington Mortgage Services, LLC Name: Chris Lechtanski DATE: rr i Title: AVP of Default File#: CMS-147F 7 CMS-147F/LC Exhibit "A" ALL THOSE THREE(3) CERTAIN TRACTS OF LAND situate in North Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: TRACT NO. I,: BEGINNING at a point in the center of the Long's Gap Road at the dividing line between Lots IS and 16 on the hereinafter mentioned plan of lots; thence by said dividing line east 171 feet, more or less, to the west side of a proposed drive; thence by said proposed drive, South 60 feet to the dividing line between Lots 16 and 17 on said plan;thence by said dividing line, West 173 feet,more or less,to the center of Long's Gap Road; thence by center of said road,North 60 feet to the point of BEGINNING. BEING Lot No. 16 on Plan of Lots laid out by Amos L. Keck and recorded in the Office of the Recorder of Deeds in and for said Cumberland County,Pennsylvania in Plan Book 4, Page 52. The building line on said lot is 20 feet east of the fence line as shown on said plan oflots. HAVING THEREON ERECTED a single dwelling house. TOGETHER with the right to the said Grantee,her heirs, successors and assigns,to use the well located on the dividing line between Lot No. IS and the lot herein described, in common with the owner of said Lot No. IS, his heirs and assigns. The cost of maintaining said well shall be borne equally by the owners of the two lots of ground. TRACT NO. 2: BEING bound on the north by Lot No. 16 of that certain plan oflots in North Middleton Township, laid out for Amos D. Keck and duly recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 4, Page 52; on the east by a proposed. drive as laid out on the aforesaid plan of lots; on the south by Lot No. 18 and on the west by the Long's Gap Road and being sixty (60) feet in front along the Long's Gap Road and extending in depth one hundred seventy-four and twenty hundredths (174.20) feet from the center of the Long's Gap Road. It being Lot No. 1.7 as shown on the aforesaid plan of lots. TRACT NO. 3: BOUNDED on the North by Lot No. 17. On the East by public alley. On the South by property of Mr. Lehman. On the West by Long's Gap Road. Said lot of ground being known as Lot No. 18 in a Plan of Lots laid out by the said Amos L. Keck in February 1948, and recorded in the Office of the Recorder of Deeds in:Plan Book 4, Page 49. 8 CMS-147F/LC FORM I Carrington Mortgage Services, : IN THE COURT OF COMMON PLEAS OF LLC CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff(s) I -IT VS. 415� 0, Vf e(#4 Heather N. Pryor Defendant(s) 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 MidPenn Legal Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative at no charge to you.Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date. During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date [Signature of Counsel for Plaintiff] FORM 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: CLJSTOMEIZ/I'RIAIAIZN' AI)1'1,1('AN'I' Borrower name(s): Property Address: City: —State:—Zip: Is the property for sale? Yes ❑ No F-1 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: Bow long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: 9 of people in household: How long? —------------------------------.................. FINANCIAL INF0111NIATION 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: Horne: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile 41: Model: Year: Amount owed: Value: Automobile#2: Model: Year: Amount owed, Value: Other transportation(automobiles, boats,motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. 2. 3. Additional Income Description(not wages): 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 Mort gage 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 SupportJAfim. Spending Money Ila /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes M No Q If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: 2 Email: I-lave you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)assistance? Yes M No ❑ If yes,please indicate the status of the application: Have you had any prior negotiations with your lender orlender's loan servicing company to resolve your delinquency? Yes F] No❑ If yes,please indicate the status of those negotiations: Please provide the following information, if know,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 uselrefer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Uwe am/are under no obligation 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 Copy of a current utility bill Letter explaining reason for delinquency and any supporting documentation (hardship letter) Listing agreement(if property is currently on the market) 3 FORM 3 Carrington Mortgage Services, : IN THE COURT OF COMMON PLEAS OF LLC : CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff(s) VS. Heather N. Pryor• Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated Feb 2 8 ,2012 governing the Curnberland Count), 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 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 Date Legal Representative Signature of Defendant Date Signature of Defendant Date FORM 4 Carrington Mortgage Services, LLC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff(s) CIVIL ACTION VS. NO. Defendant(s) Heather N. Pryor CASE MANAGEMENT ORDER AND NOW,this day of 20 ,the defendant/borrower in the above-captioned residential mortgage foreclosure action having filed a Request for Conciliation Conference verifying that the defendant/borrower has complied with the Administrative Rule requirements for the scheduling of 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 at M.in 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. BY THE COURT,, J. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson . € Sheriff I HE PROTHON1) TA'. Jody S Smith Chief Deputy Richard W Stewart Solicitor 'r1b 2014 AUG 15 AM 9:33 CUMBERLAND COUNTY PENNSYLVANIA ©FF!CE OF Tk.w $H.,E,RIFF Carrington Mortgage Services, LLC vs. Heather Pryor Case Number 2014-4156 SHERIFF'S RETURN OF SERVICE 07/25/2014 07:51 PM - Deputy Jeff Kolodzi, 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 John Omacher, Tenant, who accepted as Occupant at 771 Longs Gap Raod, North Middleton, Carlisle, PA 17013. 07/29/2014 08:18 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Heather Pryor, 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 946 W. Old York Road, Dickinson Township, Carlisle, PA 17015. Per current resident the defendatn does not reside at this address. 08/12/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Heather Pryor, 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 213 N. Hanover Street, 2nd Floor, Rear, Carlisle, PA 17013. Deputies were unable to gain access to this apartment and were unable to locate the defendant at any address provided. SHERIFF COST: $49.78 SO ANSWERS, I�JCL"' August 12, 2014 RON -R ANDERSON, SHERIFF (c) CountvSuite Sheriff, Teleosoft, Inc. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff C) ,a – --: , -� as(1) 01 rn /) , (, ( S �i r" : c3 -1 -At .. -c) o IN THE COURT OF COMMON PLEF ?`' ` CUMBERLAND COUNTY, v rD PENNSYLVANIA -4. `' Carrington Mortgage Services, LLC PLAINTIFF, v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 DEFENDANT. TERM DOCKET NO: 14-4156 Civil Term CIVIL ACTION MORTGAGE FORECLOSURE MOTION FOR ALTERNATIVE SERVICE PURSUANT TO PA. R.C.P. 430 AND 3129.2(c)(1)(i)(C) AND NOW, comes Plaintiff, Carrington Mortgage Services, LLC, by its undersigned attorney Morris Scott, and moves this Honorable Court for an Order permitting alternative service of the Complaint and all other legal papers requiring service pursuant to Pa. R.C.P. 3129.2(c)(1)(i)(C) upon Defendant, Heather N. Pryor. In support thereof, Plaintiff avers the following: 1. Plaintiffs attempts to have Defendant personally served with the Complaint have been unsuccessful, as reflected on the Return of Service, attached hereto as Exhibit "A" and made a part hereof. 2. Pursuant to Pa. R.C.P. 430, Plaintiff has made good faith efforts to ascertain Defendant's current whereabouts. An Affidavit of Good Faith Investigation, F:\Clients\Carrington\Pryor-147F\MAS.fimKC2 which sets forth the specific inquiries made and the results thereof, is attached hereto as Exhibit "B" and made a part hereof. The Affidavit of Good Faith Investigation does not reflect any other possible current addresses for Defendant. See id. 3 In addition, Plaintiff has confirmed that Defendant received mail at the mortgaged premises through a Request for Change of Address or Boxholder, pursuant to 36 C.F.R. 265.6(d)(6)(ii) as of the date thereof. A true and correct copy thereof is attached hereto as Exhibit "C" and made a part hereof 4. Based on the foregoing, it is more likely than not that Defendant is avoiding and/or evading service of process. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa. R.C.P. 430 permitting service of the Complaint and all other legal papers requiring service pursuant to Pa. R.C.P. 3129(c)(1)(i)(C) upon Defendant by (1) sending a true and correct copy thereof to Defendant via simultaneous certified mail return receipt requested and regular mail postage prepaid to the mortgaged premises; and (2) posting a copy thereof on the mortgaged premises by any competent adult. Dated: FAClients\CarringtonTryor-147RMAS.fnni(C2 By: Respectfully submitted, Richard M. Squire & Assoi iates, LLC 1/ Richard M. Squire, Esq. (PA I.D.#04267) /Mevin P. Diskin, Esq. (PA I.D. #86727) orris A. Scott.,Esq. (PA I.D.#83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskin@squirelaw.com mscott@squirelaw.com Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Carrington Mortgage Services, LLC v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 PLAINTIFF, DEFENDANT(S). IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERM DOCKET NO: 14-4156 Civil Term CIVIL ACTION MORTGAGE FORECLOSURE VERIFICATION I, Kevin P. Diskin, hereby state that I am one of the attorneys for Plaintiff, a corporation unless designated otherwise; that I am authorized to make this Verification; that I have personal knowledge of the facts averred in the foregoing Motion; and that the statements made in the foregoing Motion are true and correct to the best of my knowledge, information, and belief. The undersigned understands that the statements herein are made subject to the Penalties of Pa. C.S. §4904, relating to unsworn falsification to authorities. Richard M. Squire & Associates, LLC Dated: F:\Clients\Carrington\Pryor-147F\MAS.frmKC2 By: Richard M. Squire, Esq. (PA I.D.# 04267) /Kevin P. Diskin, Esq. (PA I.D. # 86727) Morris A. Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskin@squirelaw.com mscott@squirelaw.com Attorneys for Plaintiff F:\Clients\Carrington\Pryor-147F\MAS.fimKC2 Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Carrington Mortgage Services, LLC v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 PLAINTIFF, DEFENDANT(S). IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERM DOCKET NO: 14-4156 Civil Term CIVIL ACTION MORTGAGE FORECLOSURE [Assigned Judge's name if in Berks Co.] CERTIFICATE OF SERVICE I, Kevin P. Diskin, hereby certify that, on this date, I served or caused to be served true and correct copies of the Plaintiff's Motion for Alternative Service, Verification, Brief/Memorandum of Law, and proposed form of Order upon the following person via regular mail - postage prepaid: Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 Dated: FAClients\CaningtonTryor-147RMAS.frinKC2 Richard By: Associates, LC ei 1IM char. Squire, sq. (PA I.D.# 04267) Kevin P. Diskin, Esq. (PA I.D. # 86727) 7Morris A. Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskin@squirelaw.com mscott@squirelaw.com Attorneys for Plaintiff Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Carrington Mortgage Services, LLC v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 PLAINTIFF, DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERM DOCKET NO: 14-4156 Civil Term CIVIL ACTION MORTGAGE FORECLOSURE BRIEF/MEMORANDUM OF LAW Pennsylvania Rule of Civil Procedure 430(a) provides, in pertinent part: (a) If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of defendant and the reasons why service cannot be made. Official Note A sheriffs return of "not found" or the fact that a defendant has moved without leaving a new forwarding address is insufficient evidence of concealment. Gonzales v. Polis, 238 Pa. Super. 362, 357 A.2d 580 (1976). Notice of intended adoption mailed to last known address requires a "good faith effort" to discover the correct address. Adoption of Walker, 468 Pa. 165, 360 A.2d 603 (1976). An illustration of good faith effort to locate the defendant includes (1) inquires of postal authorities including inquiries pursuant to the Freedom of Infoiniation Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends and employers of the Defendant and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. As reflected on the attached Return of Service, Plaintiffs multiple attempts to have the FAClients\Carrington\Pryor-147F1MAS.fraKC2 Defendant personally served with the Complaint have been unsuccessful. See Ex. "A." Good faith efforts to discover the current whereabouts of Defendant have been made, as evidenced by the numerous inquiries listed in the Affidavit of Good Faith Investigation. See Ex. "B." In particular, inquiries have been made to the following persons and entities: 1 Directory Assistance, White Pages, and On -Line Telephone Records; 2. County Tax Assessment; 3 Federal Aviation Administration; 4. United States Drug Enforcement Administration; 5. Pennsylvania Department of State -Uniform Commercial Code filings; and 6. Pennsylvania Department of Corrections. See id. Also searched were United States Bankruptcy Court records, sexual offenders database, nationwide professional licenses, federal firearms and explosives licenses, and civil proceedings filed in the Commonwealth of Pennsylvania. See id. Notably, the Affidavit of Good Faith Investigation does not reflect any other possible current addresses for Defendant. See id. Plaintiff has confirmed that Defendant received mail at the mortgage premises through the **Carlisle** Postmaster, by way of a Request for Change of Address or Boxholder, pursuant to 36 C.F.R. 265.6(d)(6)(ii) as of the date thereof. See Ex. "C." Based on the foregoing, it is more likely than not that Defendant is avoiding and/or evading service of process. For all of the foregoing reasons, Plaintiff respectfully requests that this Honorable Court enter an Order pursuant to Pa. R.C.P. 430 permitting service of the Complaint and all other legal papers requiring service pursuant to Pa. R.C.P. 3129(c)(1)(i)(C) upon Defendant by (1) sending a true and correct copy thereof to Defendant via simultaneous certified mail return receipt requested and regular mail postage prepaid to the mortgaged premises; and (2) posting a copy thereof on the mortgaged F:\Clients\Carrington\Pryor-147F\MAS.frmnKC2 premises by any competent adult. Dated: lit it FAClients\CarringtonTryor-147RMASSrinKC2 By: Respectfully submitted, Richard M. Squire & Associates, LLC ha . quire, Esq. (PA I.D.# 04267) evin P. Diskin, Esq. (PA I.D. # 86727) orris A. Scott, Esq. (PA I.D.# 83587) 1 f5 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com kdiskin@squirelaw.com mscott@squirelaw.com Attorneys for Plaintiff Exhibit "A" Ronny R Anderson Sheriff Jody S Smith Chief Depu Richard W Stewart Solicitor SHERIFFS OFFICE OF CUMBERLAND COUNTY Carrington Mortgage ServicesLLC vs. Heather Pryor Case Number 2014-4156 SHERIFF'S RETURN OF SERVICE 07/25/2014 07:5PM Deputy Jeff Kolodzi, being duly law. served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by handing a true copy to a porson representingthemselves to be John Omacher, Tenant, who accepted as Occupant at 771 Longs Gap Raod, North MddIeton, CrIis?e, PA 1701 a. 07C28/2014 08:16 PM - Ronny R Anderson, Sheriff, betng duly sworn according.holaw'statenhemadodi|igentoeorch d inquiry for the within named Defenant to wit: HeathPryor, but was unableto locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mprtgage Foreclosure as "Not Found" at 946 W. Old York Road, Dickinson Township, Carlisle, PA 17015. Per current resident the defendatn does not reside at this address. 0012/2014 Ronny R Anderson, Sherff, being duly sworn accordingto law, states he made diligent h andi | for the within named Defendant to wit: Heather Pryor, 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/NortQogmFonec|oaunapo^NctFound"at213N.HmnoverStpamt.2nd Floor, Rear, Carlisle, PA 17013. Deputies were unable to gain access to this apartment and were unable to locata the defendant at any address provided. SHERIFF COST: *4S78 SO ANSWERS, August 12, 2014 RONNYRANDERSON, SHERIFF 1." u '• •��. `�`��. .���1,14k'`' •� „� Exhibit "B": Affidavit of Good Faith Investigation AFFIDAVIT OF GOOD FAITH INVESTIGATION Commonwealth of Pennsylvania County of Montgomery I, Rosemary McGrory Sweet, an Owner of Rosemary McGrory Sweet Investigation, BEING OF FULL AGE AND UPON MY OATH STATE AND DEPOSE THE FOLLOWING: SS: 1) 1 HAVE PERFORMED A GOOD FAITH INVESTIGATION ON THE FOLLOWING SUBJECT AND PROPERTY LOCATED IN THE COMMONWEALTH OF PENNSYLVANIA. 1. THE SUBJECTS NAME(S) IS/ARE: HEATHER N PRYOR DOB:5/17/1984 AKA HEATHER N OTOOLE 2. THE PROPERTY ADDRESS IS 771 LONGS GAP RD, CARLISLE PA 17013-8556, CUMBERLAND COUNT( 2) THE FOLLOWING SEARCHES WERE PERFORMED IN AN EFFORT TO LOCATE THE SUBJECT(S): 1. SOCIAL SECURITY MASTER DEATH INDEX: NO RECORD FOUND 2. THE SUBJECTS CURRENT ADDRESS AS DETERMINED BY THIS REPO.RT IS BELIEVED TO: 946 W OLD YORK RD, CARLISLE PA 17015-9619, CUMBERLAND COUNTY (Dec 2013 - Apr 2014) Name Associated with Address: HEATHER N PRYOR Current Residents at Address: HEATHER N PRYOR 717-243-2298 • EDT THRUSH GLENN S 771 LONGS GAP RD, CARLISLE PA 17013-8556, CUMBERLAND COUNTY (Oct 2008 - Feb 2014) Name Associated with Address: HEATHER N PRYOR Current Residents at Address: HEATHER N PRYOR 717-387-2105 3. DIRECTORY ASSISTANCE, WHITE PAGES, AND OTHER ON-LINE TELEPHONE RECORDS Phones Plus(s): Name: PRYOR, HEATHER Address: 771 LONGS GAP, CARLISLE PA 17013-8556 Phone Number: 717-387-2105 - EDT Phone Type: Mobile Carrier: VERIZON WIRELESS -PA - ( WAYNESBORO , PA ) 4. ADDRESS HISTORY SEARCH Address Summary: 946 W OLD YORK RD, CARLISLE PA 17015-9619, CUMBERLAND COUNTY (Dec 2013 - Apr 2014) 771 LONGS GAP RD, CARLISLE PA 17013-8556, CUMBERLAND COUNTY (Oct 2008 - Feb 2014) 5. STATEWIDE COUNTY TAX ASSESSMENT AND PROPERTY OWNERSHIP Possible Properties Owned by Subject: Property: Parcel Number- 29-15-1247-011 Book - 20083 Page - 3982 Owner Name: HEATHER PRYOR Property Address: - 771 LONGS GAP RD, CARLISLE PA 17013-8556, CUMBERLAND COUNTY Owner Address: 946 W OLD YORK RD, CARLISLE PA 17015-9619, CUMBERLAND COUNTY Land Usage - SINGLE FAMILY RESIDENTIAL Assessed Value - $151,400 Land Size - 29621 SF Year Built - 1948 Legal Description - LOTS 16, 17 & 18 PB4 PG49 & 52 Data Source - B Property: Parcel Number - 23-0Q17-017-000000 Owner Name: HEATHER PRYOR Owner Name 2: KENNETHE L PRYOR Property Address - 7583 LYONS RD, WAYNESBORO PA 17268-9503, FRANKLIN COUNTY Data Source - A Property: Parcel Number- 15-1247-0011-0000000-29 Book - 2008 Page -33982' Owner Name: HEATHER PRYOR Property Address: - 771 LONGS GAP RD, CARLISLE PA 17013-8556, CUMBERLAND COUNTY Owner Address: 771 LONGS GAP RO7CARLISLE PA 17013-8556, CUMBERLAND COUNTY Sale Date - 09/26/2008 Sale Price -$133,700 Land Usage- RESIDENTIAL (NEC) Total Market Value - $151,400 Assessed Value - $151,400 Land Value - $53,700 Improvement Value - $97,700 Land Size - 29,620 Square Feet Year Built - 1948 Seller Name: LOUISE E BARR Legal Description - LOTS 16, 17 & 18 PB4 PG49 & 52 Data Source - A Property: Parcel Number- 29-15-1247-011 Owner Name: HEATHER PRYOR Property Address - 771 LONGS GAP RD, CARLISLE PA 17013-8556, CUMBERLAND COUNTY Sale Date - 09/26/2008 Sale Price - $133,700 Seller Name: E BARR LOUISE Loan Amount - $136,374 Loan Type - NEW CONVENTIONAL Data Source - B Property: Parcel Number - 15-1247-0011-0000000-29 Book -2008 Page • 33983 Owner Name: HEATHER PRYOR Property Address - 771 LONGS GAP RD, CARLISLE PA 17013-8556, CUMBERLAND COUNTY Sale Date - 09/26/2008 Loan Amount - $136,374 Loan Type - CONVENTIONAL Data Source - A 6. UNIFORM COMMERCIAL CODE FILINGS NO RECORD FOUND 7. FEDERAL BANKRUPTCY COURT NO RECORD FOUND 8. STATEWIDE CIVIL COURT RECORDS, LIENS, AND JUDGEMENTS NO RECORD FOUND 9. PENNSYLVANIA DEPARTMENT OF CORRECTIONS CURRENT INMATES NO RECORD FOUND 10. PEOPLE IN THE NEWS - PHILADELPHIA INQUIRER, DAILY NEWS, BUSINESS JOURNAL NO RECORD FOUND 11. SEXUAL OFFENDERS DATABASE NO RECORD FOUND 12. FEDERAL AVIATION ADMINISTRATION REGISTERED AIRCRAFT NO RECORD FOUND 13 PROFESSIONAL LICENSES (NATIONWIDE) Professional Ucense(s): W Professional License 1 Name: PRYOR, HEATHER N License Address: 771 LONGS GAP RD, CARLISLE PA 17013-8556, CUMBERLAND COUNTY License State: Pennsylvania License Number: CO252848 License Type: COSMETOLOGIST Profession/Board: COSMETOLOGY License Status: ACTIVE Issue Date: Feb 12, 2004 Expiration Date: Jan 31, 2012 Professional Ucense 2 Name: PRYOR, HEATHER N License Address: 315 E LIBERTY ST, CHAMBERSBURG PA 17201-2633, FRANKLIN COUNTY License State: Pennsylvania License Number: CO252848 License Type: COSMETOLOGIST Profession/Board: COSMETOLOGY License Status: ACTIVE Issue Date: Feb 12, 2004 Expiration Date: Jan 31, 2010 Professional Ucense 3 Name: PRYOR, HEATHER N License Address: 21 N CHURCH ST APT 4, WAYNESBORO PA 172684249, FRANKLIN COUNTY License State: Pennsylvania License Number: CO252848 License Type: COSMETOLOGIST Profession/Board: COSMETOLOGY License Status: ACTIVE Issue Date: Feb 2,m04 Expiration Date: Jan 31, 2006 14. FEDERAL FIREARMS AND EXPLOSIVES LICENSES (NATJONWDE) NO RECORD FOUND 15. DEA CONTROLLED SUBSTANCE LICENSES (NATIONWIDE) NO RECORD FOUND 16. CORPORATIONS AND BUSINESS 'AND POSSBLE EMPLOYERS NO RECORD FOUND 17 OTHER INFORMATION NO RECORD FOUND 3) 1 DECLARE THAT THE FOREGOING IS TRUE AND CORRECT May 15, 2014 SIGNATURE: SWORN TO AND SUBSCRIBED BEFORE ME THIS 1SthDay ofMay, 2O14 NOTARY PUBLIC COMMONWE.ALTH OF PENNSYLVANIA NOTARIAL SEAL PATRICIA TARDITI, Notary Public City of Philadelphia, Phila, County My Commission Expires June 13, 2016 Exhjojt ►►C►► RICHARD M. SQUIRE & ASSOCIATES, LLC ATTORNEYS AT LAW Richard M. Squire * Kevin P. Diskin Morris A. Scott • Also Admitted In MI) ^ Also Admitted in NJ Postmaster Carlisle, PA 17015 Dear Madam or Sir Montgomery County Office One Jenkintown Station 115 West Avenue, Suite 104 Jenkintown, PA 19046 Tel.: (215) 886-8790 Fax: (215) 886-8791 www.squirelaw.com August 19, 2014 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: Heather N. Pryor Address: 946 W Old York Rd Carlisle, PA 17015 Note: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 36 CFR 265.6(d)6(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester (e.g., process server, attomey, party representing himself): Attorney at Law 2. Statute or regulation that empowers me to serve process (not required when requester is an attorney or a party acting pro se - except a corporation acting pro se must cite statute): N/A 3. The names of all known parties to the litigation: Carrington Mortgage Services, LLC v. Heather N. Pryor 4. The court in which the case has been or will be heard: Cumberland County Court of Common Pleas, Pennsylvania 5. The docket or other identifying number if one has been issued: Not yet issued 6. The capacity in which this individual is to be served (e.g. defendant or witness): Defendant WARNING THE SUBMISSION OF FALSE INFORMATION EITHER (1) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OR (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Richard M. Squire & Associates, LLC By: , iCAID lir . Scj i ti'Lt ,I ( Ric and M. Squire, Esquire FOR POST OFFICE USE ONLY No change of address order on file. NEW ADDRESS or BOXHOLDER'S POSTMARK Not known at address given. NAME and STREET ADDRESS Moved, left no forwarding address. No such address. Carrington Mortgage Services, LLC PLAINTIFF, v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERM DOCKET NO: 14-4156 Civil Term CIVIL ACTION MORTGAGE FORECLOSURE ORDER GRANTING ALTERNATIVE SERVICE PURSUANT TO PA. R.C.P. 430 AND 3129.2(c)(1)(i)(C) AND NOW, this 7. day of , 20 / Y, upon consideration of Plaintiffs Motion for Alternative Service pursuant to Pa. R.C.P. 430 and 3129.2(c)(1)(i)(C), and upon consideration of any response thereto, and good cause showing; it is hereby ORDERED that Plaintiff may serve the Complaint and all other legal papers requiring service pursuant to Pa. R.C.P. 3129(c)(1)(i)(C) upon Defendant, Heather N. Pryor, by (1) sending a true and correct copy thereof to Defendant via simultaneous certified mail - return receipt requested and regular mail - postage prepaid to the mortgaged premises located at 771 Longs Gap Rd, Carlisle, PA 17013; and (2) posting a true and correct copy thereof on the mortgaged premises by any competent adult. Service of the aforementioned mailings is effective upon the date of mailing and is to be effectuated by Plaintiffs attorney, who will file with the Prothonotary's Office a Certificate of Service as to such mailing. "Richard M. Squire, Esquire Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Tel: (215) 886-8790 Fax: (215) 886-8791 Email: rsquire@squirelaw.com Ca> iccgit tifry BY THE COURT: Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 or opposing counsel Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-879 Attorneys for Plaintiff FILED -OFFICE OF THE PROTHONOTAIV,' 20140CT 10 PM I:514 CUMBERLAND COUNTY PENNSYLVANIA Carrington Mortgage Services, LLC, PLAINTIFF, v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TERM DOCKET NO: 14-4156 Civil Term CIVIL ACTION DEFENDANT. PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly mark the Plaintiff's Complaint in the above matter as reinstated. RICHARD M. SQUIRE & ASSOCIATES, LLC By: Date: 06 -1 --Ober CMS-147F/KC2 Richard M. Squire, Esq. Kevin P. Diskin, Esq. Morris A. Scott, Esq. Attorneys for Plaintiff cvlsaus. 3haieo SHERIFF'S OFFICE OF CUMBERLAND COUNTY RonnyRAnderson r LE1)-Ot F1CL Sheriff THE PRO NQ irt,'� t x, o��-�rai�Gr���is 2tJROCT 2r PM 59 CUMBERLAND COUNTY PENNSYLVANIA Jody S Smith Chief Deputy Richard W Stewart Solicitor QFS SCE OF THE Sk„F,IFF Carrington Mortgage Services, LLC vs. Heather Pryor Case Number 2014-4156 SHERIFF'S RETURN OF SERVICE 10/15/2014 08:21 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Heather Pryor, pursuant to Order of Court by "Posting" the premises located at 771 Longs Gap Raod, North Middleton, Carlisle, PA 17013 with a true and correct copy according to law. L I • CLINE, DEPUTY SHERIFF COST: $41.27 SO ANSWERS, October 16, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuile Sherif(, Teieosof;, Ino. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 80193 / 313264 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff L'r NiL , 71-ri Ti! -S' [Lt.: Carrington Mortgage Services, LLC, PLAINTIFF, V. Heather N. Pryor, DEFENDANTS. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW TERM DOCKET NO: 14-4156 Civil Term CERTIFICATE OF SERVICE pltrri 5 4, (1)H--, ttiereby certify that, pursuant to the Order of the Cumberland County Court of Common Pleas dated September 19, 2014 (relating to alternative service of the Plaintiff's Complaint), attached hereto as Exhibit "A" and made a part hereof, the Plaintiff's reinstated Complaint was served as follows: a. Via posting at 771 Longs Gap Rd, Carlisle, PA 17013, on October 15, 2014 A true and correct copy of the Cumberland County Sheriff's Affidavit of Return for posting of the Complaint is attached hereto as Exhibit "B" and made a part hereof. b. Via simultaneous regular mail -postage prepaid and certified mail -return receipt requested to 771 Longs Gap Rd, Carlisle, PA 17013 on October 30, 2014 True and correct copies of the certified mail receipt and PS Form 3877 are collectively attached hereto as Exhibit "C" and made a part hereof. Dated: November 6, 2014 RICHARD M. SQUIRE & ASSOCIATES, LLC BY: Richard M. Squire, Esquire , Robert W. Cusick, Esquire 47 Morris A. Scott, Esquire Attorney for Plaintiff Exhibit "A' Carrington Mortgage Services, LLC PLAINTIFF, v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IERM DOCKET NO: 14-4156 Civil Term CIVIL ACTION MORTGAGE FORECLOSURE ORDER GRANTING ALTERNATIVE SERVICE PURSUANT TO PA. R.C.P. 430 AND 3129.2(c)(1)(i)(C) AND NOW, this i day of S , 20 / Y, upon consideration of Plaintiffs Motion for Alternative SeMce pursuant to Pa. R.C.P. 430 and 3129.2(c)(1)(i)(C), and upon consideration of any response thereto, and good cause showing; it is hereby ORDERED that Plaintiff may serve the Complaint and all other legal papers requiring service pursuant to Pa. R.C.P. 3129(c)(1)(i)(C) upon Defendant, Heather N. Pryor, by (1) sending a true and correct copy thereof to Defendant via simultaneous certified mail - return receipt requested and regular mail - postage prepaid to the mortgaged premises located at 771 Longs Gap Rd, Carlisle, PA 17013; and (2) posting a true and correct copy thereof on the mortgaged premises by any competent adult. Service of the aforementioned mailings is effective upon the date of mailing and is to be effectuated by Plaintiffs attorney, who will file with the Prothonotary's Office a Certificate of - - - -- Service as to such mailing: - cc: Richard M. Squire, Esquire Richard M. Squire & Associates, LLC One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Tel: (215) 886-8790 Fax: (215) 886-8791 Email: rs quire@s quire] aw. co m KC2 BY THE COURT: Exhibit "B" Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY 6k�(ttt, �vt C:iaukr�fy�fh OFF rE( 7t+.Fs e:rE; Carrington Mortgage Services, LLC vs. Heather Pryor Case Number 2014-4156 SHERIFF'S RETURN OF SERVICE 10/15/2014 08:21 PM - Deputy William Cline, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure upon the within named Defendant, to wit: Heather Pryor, pursuant to Order of Court by "Posting." the premises located at 771 Longs Gap Raod, North Middleton, Carlisle, PA 17013 with a true and correct copy according to law. SHERIFF COST: $41.27 Octoher 16, 2014 (C) CountvSuile Sheriff, 'i o!eoson Ine. L I M CLINE, DEPUTY SO ANSWERS, RONNY R ANDERSON, SHERIFF Exhibit "C" NAME AND ADDRESS OF SENDER INDICATE TYPE OF MAIL CHECK APPROPIATE BLOCK FOR POSTMARK AND DATE OF RECEIPT $1.200 Richard M. Squire & Associates 115 West Avenue, Suite 104 Jenkintown, PA 19046 0 Registered Mail 0 Insured 0 COD 0 Certified Mail 0 Express Mail Registered Mail: 0 With Postal Insurance 0 Without Postal Insurance Affix stamp here if issued as certifcata ti PC FIRST or for additional copies of this bill. 0625oo0£ ei m Line Number of Article Name of Addressee, Street, and Post -Office Address Postage Fee Handling Charge Act Value (If Regis.) Insured Value Due Sender If C.Q.D. R.R. Fee S.D. Fee S.H. Fee ------->c;,""i1'�i�'.ja.` Remarks 1 CMS -147 Complaint MAS Reg Mail Heather N. Pryor , 771 Long Gap Road Carlisle, PA 17013 2 3 4 5 6 7 8 9 10 11 12 Total Number of Pieces Listed by Sender Total Number of P' izt,M.' Received at — • ice ' , 6 / ice 4;��� PS7xSMASTER, PER (Nawrie of receiving employee) „W, s , , /',� t •!C� - . The full declaration of value is required on all maximum indemnity payable for nonnegotiable reconstruction insurance is $50,000 per piece maximum indemnity payable on Express Mail indemnity payable is $25,000 for Registered handling charges apply only to Third- and Fourth special handling service. domestic and international registered mail. The documents under Express Mail document subject to a limit of $50,000 per occurrence. The merchandise insurance is $500. The maximum Mail, $500 for COD and $500 for Insured Mail. Special -Gass parcels. Special delivery service also includes/ PS FORM 3877 FOR REGISTERED, INSURED, C.O.D., CERTIFIED, AND EXPRESS MAIL STAGE CLASS 863006 19046 Tp: Heather N. Pryor 771 Longs Gap Calisle, PA 17013 SENDER: REFERENCE. CMS-147/KC2 9314 8699 0430 0007 7292 67 r Form 3600 i� anuary_2t105 RETURN Pastago 1 RECEIPT SERVICE Poslage & Fees UMW Receipt for Certified Mair No Insurance Coverage Provided 1 Do Not Use for International Mall 1 MARK OR DATE. Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert Cusick, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Attorneys for Plaintiff ri C) fV 77, rr cJ C.}_ Carrington Mortgage Services, LLC PLAINTIFF, v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015, DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 14-4156 Civil Term CIVIL ACTION PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of Plaintiff and against Heather N. Pryor, Defendant, for his/her/its/their failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises as described in Plaintiffs Complaint, and assess Plaintiff's damages as follows: As set forth in the Complaint $ 134,019.87 Interest from 06/14/2014 to 12/18/14 $ 3.421.03 Total $ 137,440.90 I hereby certify that (1) the addresses of the Plaintiff and Defendant are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. RS3 RICHARD M. SQUIRE & AS , S CIATES, LLC 6.50p1 Ri hard _ . Squire, Esq. (PA I.D.# 04267) 0133060 Robert Cusick, Esq. (PA I.D. # 80193) 0 5q8 V Morris A. Scott, Esq. (PA I.D.# 83587) i),,,heern,i feci By: 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire(a squirelaw.com rcusick(a,squirel aw.com mscott(asquirelaw. com Attorneys for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICA DATE: /a/aa//V RS3 Richard M. Squire & Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Robert Cusick, Esquire Morris A. Scott, Esquire ID. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, Pa 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Carrington Mortgage Services, LLC PLAINTIFF, v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015, DEFENDANT. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO: 14-4156 Civil Term CIVIL ACTION VERIFICATION OF NON-MILITARY SERVICE The undersigned hereby verifies that he is one of the attorneys for the Plaintiff in the above -captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) that Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemember's Civil Relief Act of 2003, as amended. (b) that Defendant(s) is/are over 18 years of age and reside(s) or maintain(s) an address at 771 Longs Gap Rd, Carlisle, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. RS3 RICHARD M. SQUIRE & ASSOi IATES, LLC / /,// Rich M. Squire, Esq. (PA I.D.# 04267) Obert Cusick, Esq. (PA I.D. # 80193) Morris A. Scott, Esq. (PA I.D.# 83587) RS3 115 West Avenue, Suite 104 Jenkintown, PA 19046 215-886-8790 215-886-8791 (fax) rsquire@squirelaw.com rcusick@squirelaw.com mscott@squirelaw.com Attorneys for Plaintiff 4 Department of Defense Manpower Data Center Status Report Pursuant to Servicemembers Civil Relief Act Last Name: PRYOR First Name: HEATHER Middle Name: N Active Duty Status As Of: Dec -18-2014 Results as of : Dec -18-2014 06:39:30 AM SCRA 3.0 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA ..-w _ - No11 NA This response reflects the Individuals' active duty' status based on -the Active Duty Status Date Left Active Duty Within 367 Das of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA f _ .. NA %.--- - - •r -"k ' .J - -No - ' \ I NA This response reflects where the individualleft active duff status within 367 days preceding therActive Duty Status Date The Member or His/Her Unit Was Notified of a Future Call -Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA ` • NA ' ♦ ' . -' -Nof f NA This response reflects whether the individual or his/her unit has received eerty notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. Mary M. Snavely -Dixon, Director Department of Defense - Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves (TARS), Marine Corps Active Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: Y161W510R162F70 Richard M. Squire & Associates, LLC By: Richard M. Squire, Esquire Robert W. Cusick, Esquire Morris A. Scott, Esquire I.D. Nos. 04267 / 80193 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown, PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 Attorneys for Plaintiff Carrington Mortgage Services, LLC, v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 PLAINTIFF, DEFENDANTS. TO: Heather N. Pryor 771 Longs Gap Road Carlisle PA 17013 DATE OF NOTICE: November 24, 2014 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO: 14-4156 Civil Term CIVIL ACTION THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 and 800-990-9108 Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 Date Carrington Mortgage Services, LLC PLAINTIFF, v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 DEFENDANTS. NOTICE TO: Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 Pursuant to requirements of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on /000//if , a judgment(decree)(order) was entered against you in this office the p Mz eedi •. •-- , indicated . ' e. Prothonotary Deputy Prothonotary Date Mailed: RS3 5 Office of the PROTHONOTARY Cumberland County 1 Courthouse Square Carlisle, PAA 17013-3387 717-240-6195 Date Carrington Mortgage Services, LLC PLAINTIFF, v. Heather N. Pryor 946 W Old York Rd Carlisle, PA 17015 DEFENDANTS. NOTICE TO: Heather N. Pryor 771 Longs Gap Rd Carlise, P A17013 Pursuant to requirement s of Pennsylvania Rules of Civil Procedure, Rule 236, notice is hereby given that on 4.2. c2a, RS3 , a judgment(decree)(order) was entered against you in this office ithe proceeding as indicated ab Deputy Prothonotary Date Mailed: 6