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HomeMy WebLinkAbout14-5928 Supreme Co nnsylvania COU f. Jmmo leas For Prothonotary Use Onlyt T}� vll t Docket No: f Std ?l �' / ct1 ,a�15 r� County The information collected on this form is used solely for court administration purposes. This form does not supplement or replace the f ling and sen4ce of pleadings or other papers as required by lain or rules of court. Commencement of Action: n Complaint ® Writ of Summons [3 Petition ® Transfer from Another Jurisdiction ® Declaration of Taking E C Lead Plaintiff's Name: Lead Defendant's Name: T LSF8 Master Participation Trust Georgialee G Sorrow,Randall E Sorrow I Are money damages requested? ®Yes El No Dollar Amount Requested: Owithin arbitration limits (check one) Inoutside arbitration limits N Is this a Class Action Suit? E3 Yes El No Is this an MDJAppeal? 0 Yes S No A Name of Plaintiff/Appellant's Attorney: Kevin P. Diskin, Esquire 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 ®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 S E3 Product Liability(does not include E mass tort} ®Employment Dispute: Slander/Libel/Defamation Discrimination C [3 Other: ® Employment Dispute:Other ® Zoning Board 1, ® Other: 1 ® Other: d MASS TORT ® Asbestos N nTobacco ® Toxic Tort-DES ® Toxic Tort-Implant REAL PROPERTY MISCELLANEOUS ® Toxic Waste ® Other: 0 Ejectment ® Common Law/Statutory Arbitration l3 Eminent Domain/Condemnation r3Declaratory Judgment ® Ground Rent ® Mandamus Landlord/Tenant Dispute ®Non-Domestic Relations Q Mortgage Foreclosure:Residential Restraining Order PROFESSIONAL LIABLITY 0 Mortgage Foreclosure:Commercial ®Quo Warranto ® Dental ®Partition ®Replevin 13 Legal ® Quiet Title [3 Other: Medical ® Other: Other Professional: Updated If112©Il Richard M. Squire &Associates, LLC Attorne)(;jfgftO F i FBy: Richard M. Squire, Esquire ` f` Kevin P. Diskin, Esquire 2014 OCT Morris A. Scott, Esquirei{ ' ' ID.Nos. 04267/ 86727/ 83587 CUMQERL `z One Jenkintown Station, Suite 104 E�`, LV/ t 115 West Avenue Jenkintown,PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 LSF8 Master Participation Trust, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA PLAINTIFF, DOCKET NO: V. CIVIL ACTION Georgialee G Sorrow MORTGAGE FORECLOSURE 4063 Cherokee Avenue Camp Hill, PA 17011 Randall E Sorrow 4063 Cherokee Avenue Camp Hill, PA 17011, DEFENDANTS 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 1 + � 10, 7I CAL-575E/RD1 �,�1. /� 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 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 AVISO LE RAN 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. 2 CAL-575F/RD1 Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle,PA 17013 717-249-3166 and 800-990-9108 3 CAL-575F/RDI Richard M. Squire &Associates, LLC Attorneys for Plaintiff By: Richard M. Squire, Esquire Kevin P. Diskin, Esquire Morris A. Scott, Esquire ID.Nos. 04267/ 86727/ 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown,PA 19046 Telephone: 215-886-8790 Fax: 215-886-8791 LSF8 Master Participation Trust, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PLAINTIFF, PENNSYLVANIA V. DOCKET NO: Georgialee G Sorrow CIVIL ACTION 4063 Cherokee Avenue Camp Hill, PA 17011 MORTGAGE FORECLOSURE Randall E Sorrow 4063 Cherokee Avenue Camp Hill, PA 17011, DEFENDANTS COMPLAINT IN MORTGAGE FORECLOSURE PLAINTIFF,LSF8 Master Participation Trust, by and through its undersigned attorney brings this action in mortgage foreclosure upon the following cause of action: 1. PLAINTIFF, LSF8 Master Participation Trust, 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 13801 Wireless Way, Oklahoma City, OK 73134 4 CAL-575F/RDI 2. Defendants, Georgialee G Sorrow and Randall E Sorrow, are the real owners, mortgagors, and grantees in the last Deed of record to the real property located at 4063 Cherokee Avenue Camp Hill, PA 17011 including any/all improvements and detached structures thereon as well as any/all riparian/water rights appertaining thereto (hereinafter collectively referred to as [Premises[) . 3. On October 19, 2007, Defendants made, executed, and delivered a Mortgage to Beneficial Consumer Discount Company d/b/a Beneficial Mortgage Co of Pennsylvania (hereinafter referred to as [Originating Lender[) as security for Defendants'payment and other obligations in consideration of a mortgage loan made to Defendants by the Originating Lender. Said Mortgage is recorded in the Office of the Recorder in and for Cumberland County, and was recorded on October 23, 2007 in Cumberland County as Instrument No./Doc ID 200740458. , and is incorporated herein by reference by virtue of Pa. R.C.P. 1019(g). 4. By Assignment of Mortgage dated September 15, 2014 the Mortgage was assigned to PLAINTIFF, which Assignment is in process of being recorded. 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 0A 0 6. The address of the Premises is 4063 Cherokee Avenue, Camp Hill, PA 17011. 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 October 24, 2012 through the present date. By the terms of the aforesaid Mortgage, upon breach and failure to cure said 5 CAL-575F/RDI 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, Defendants shall be liable for, inter alia, Plaintiffs costs, corporate advances, escrow advances, and attorneys' fees. 9. The following amounts are due as of August 20, 2014: Principal $ 132,495.83 Accrued Interest through August 20, 2014 $ 41,082.64 Late Fees $ 1,264.26 Property Inspection $ 37.50 Escrow Advances $ 5,038.50 Less Unapplied Funds $ (800.00) Attorneys'Fees to date $ 2,350.00 Total $ 181,468.73 plus additional pre judgment and post judgment interest at the per diem rate of$41.40 or at the adjusted amount if the interest rate is variable, additional late charges, additional corporate advances, additional escrow advances, additional attorneys F-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® sale, the attorneys Mees set forth in the preceding paragraph may be less than the amount demanded based on work actually performed. The attorneys Ofees requested in the preceding paragraph are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect attorneysOfees 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® sale; or, if the complexity of the action requires additional fees, such fees may exceed 6 CAL-575F/RDI 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. WHEREFORE,Plaintiff respectfully requests that judgment in rem be entered in its favor and against Defendants, Georgialee G Sorrow and Randall E Sorrow, for foreclosure and sale of the Premises in the amounts due as set forth in Paragraph 9., namely $181,468.73, plus additional pre judgment and post judgment interest at the per diem rate of$41.40 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 . SQUIRE & SSOCIAT , LLC By: 'chard M. Squire, Esq. (PA I. 4267) Kevin P. Diskin, Esq. (PA I.D. 6727) Morris A. Scott, Esq. (PA I.D.# 83587) 115 West Avenue, Suite 104 Jenkintown,PA 19046 215-886-8790 215-886-8791 (fax) rsciuire@squirelaw.com kdiskin@squirelaw.com mscott@sguirelaw.com Attorneys for Plaintiff Date: UNLESS YO NOTIFY US WITHIN THIRTY (30) DAYS AFTER RECEIPT OF THIS LETTER/NOTICE/PLEADING THAT THE DEBT, OR ANY PART OF IT, IS 7 CAL-575F/RDI 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. 8 CAL-575F/RD1 Richard M. Squire&Associates,LLC Attorneys for Plaintiff By: Richard M. Squire,Esquire Kevin P. Diskin, Esquire Morris A. Scott, Esquire ID.Nos. 04267 / 86727 / 83587 One Jenkintown Station, Suite 104 115 West Avenue Jenkintown,PA 19046 Telephone:215-886-8790 Fax:215-886-8791 LSF8 Master Participation Trust, IN THE COURT OF COMMON PLEAS PLAINTIFF, CUMBERLAND COUNTY, PENNSYLVANIA V. DOCKET NO: Georgialee G Sorrow 4063 Cherokee Avenue CIVIL ACTION Camp Hill, PA 17011 MORTGAGE FORECLOSURE Randall E Sorrow 4063 Cherokee Avenue Camp Hill, PA 17011, DEFENDANTS VERIIFIC'ATION Theodore Schroeder Jr.alkla Ted Schroeder ,hereby states that he/she is employed as a oefaun service officer .,:.of Caliber Home Loans, Inc., as Successor for LSF 8 Master Participation Trust, Plaintiff in this made' 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 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name- LSF icipation Trust, aliber Home Loans, Inc. solely in its capacity as servicer Theodore Schroeder Jr.alkla Ted Schroeder 9 CAL-575F/RD1 v DATE: �1 �4 ZU( �( Title: Default service Officer File#: CAL-575F Name:Georgialee G Sorrow and Randall E Sorrow 10 CAL-575F/RD1 Exhibit QA❑ Legal Description ALL jWj-CMAJf4 PXMMW'SITUATM Ili TtCM*14HiP OF LOCR PENNSYLVMIA. WAta MME FMLy'DMISM IN A OM DATM 10!1511989 ANS FECOM 10/1911999, ARM IME- LAW W (F M CUM AND,STATE SE' F" ABM, 1N MM YMOC 2 AND PAGE: 1149. 'LAX MAP In PARCEL tQ ND'.:-13-2-Y-0799-156 Property Address:4063 Cherokee Ave.,Camp Hill, PA 17011 11 CAL-575F/RDI FORM:I LSF8 Master Participation Trust IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY;PENNSYLt�Nl* - Plaintiff(s) VS. Q-, 1 Georgialee G Sorrow : ` Randall E Sorrow o Defendant(s) � avilcn ...-- NOTICE OF RESIDENTIAL MORTGAGE FORECLOSi��' 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 251.0 or(800)822-5288 extension 2510 and request appointment of a legal representative at no charge to you.Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty(20)days of the appointment date. During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. 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: 10/2/2014 1 i Date [Signature.of Counsel 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 Please provide the following information to the best of your knowledge: MERU NURNI&WIMU NEW, Borrower name(s): Property Address: City: State:- Zip: Is the property for sale? Yes❑ Non 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: zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? FINANCL,kt, INFORNIATION 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 F1 If yes,provide names,location of court,case number&attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1:Model: Year: Amount owed: Value: Automobile#2:Model: Year: Amount owed; Value: Other transportation(automobiles,boats,motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. 2. 3. Additional Income Description(not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay I?ays:. Monthly Expenses; (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT 1 Mortgage Food 2° Mortgage Utilities Car Pa ment s Condo/Neigh.Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop. payment Install.Loan Pa meat Cable TV Child SupporttAlim. Spending Mone Da /Child Care/Tuit. Other Expenses i Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes❑ No Q If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: 2 Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP)assistance? Yes ❑ No❑ If yes,please indicate the status of the application: Have you bad any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes F-1 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 use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. VWe understand that I/we 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 LSF8 Master Participation Trust : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff(s) vs. Georgialee G Sorrow Randall E Sorrow Defendant(s) CIVIL REQUEST FOR CONCILIATION CONFERENCE Pursuant to the Administrative Order dated _'2012 governing the Cumberland County Residential Mortgage Foreclosure Diversion Program,the undersigned hereby certifies as follows: 1. Defendant is the owner of the real property which is the subject of this mortgage foreclosure action; 2. Defendant lives in the subject real property,which is defendant's primary residence; 3. Defendant has been served with a"Notice of Residential Mortgage Foreclosure Diversion,Program"and has taken all of the steps required in that Notice to be eligible to participate in a court-supervised conciliation conference. The undersigned verifies that the statements made herein are true and correct. I understand that 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 LSF8 Master Participation Trust IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Plaintiff(s) CIVIL ACTION VS. Georgialee G Sorrow NO. Randall E i5erfienolant(s) 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 representati ve 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 theplaintifflender 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. S. All:proceedings in this matter are stayed pending the completion of the scheduled conciliation conference. BY THE COURT, J. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ©CT 2 l PM 2: 59 GUMBO NSYLVA ATS PEN OFFiCE OF THE St. RIFF LSF8 Master Participation Trust vs. Georgialee Gould Sorrow (et al.) Case Number 2014-5928 SHERIFF'S RETURN OF SERVICE 10/10/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Georgialee Gould Sorrow, 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 5 Rockaway Drive, Camp Hill, PA 17011. Deputies were advised by Randall Sorrow that the defendant now resides at 5 Rockaway Drive, Camp Hill, PA 17011. 10/10/2014 07:47 PM - Deputy Jamie DiMartile, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mortgage Foreclosure by "personally' handing a true copy to a person representing themselves to be the Defendant, to wit: Randall Edward Sorrow at 4063 Cherokee Ave, Lower Allen, Camp Hill, PA 17011. jA VIIE DIMA TI E, DEPUTY 10/14/2014 07:30 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Notice of Residential Mortgage Foreclosure Diversion Program and Complaint in Mo ?••e Fo cl•sure by handing a true copy to a person representing themselves to be Carol Kochenour, m bt wr o a cepted as "Adult Person in Charge" for Georgialee Gould Sorrow at 5 Rockaway Drive, Ca • iI , "A 1 011. SHA HARRI ON, DEPUTY SHERIFF COST: $77.90 SO ANSWERS, October 15, 2014 (c) CountySuito Sheriff, Teleosoft, Inc. RONNYR ANDERSON, SHERIFF