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HomeMy WebLinkAbout06-0553 .' Phelan, Hallinan & Schmieg By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center Plaza Suite 1400 Philadelphia, PA 19103 (215) 563'7000 U.S. Bank National Assciation, As trustee Under The Pooling And Servicing Agreement Dated As of June 1, 2003 Among Credit-Based Asset Servicing And Securitization LLC., Merrill Lynch Mortgage Investors, Inc., Litton Loan Servicing LP And U.S. Bank National Association, C-BASS Mortgage Loan Asset- Backed National Association, C-BASS Mortgage Loan Asset- Backed Certificates, Series 2003 CB3 4828 Loop Central Drive Houston, TX 77081-2226 v. William Vaitkunas Or Occupants 417 Fourth Street New Cumberland, PA 17070 Attorney for Plaintiff Court of Common Pleas Civil Division Cumberland County Term No. Of- - SS..3 C' l'--r- lUl 1€R-Yv") CML ACTION - EJECTMENT "'''This firm is a debt collector attempting to collect a debt and any information obtained will be used for that purpose, If you have previously received a discharge in bankruptcy and this debt was not reaffinned, this correspondence is not and should not be construed to be an attempt to collect a debt, but only enforcement of a lien against property."'* 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 (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 and other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. You should take this paper to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot afford to hire a lawyer, this office may be able to provide you with information about agencies that may offer legal services to eligible persons at a reduced fee or no fee. CUMBERLAND COUNTY CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 PHS: 130071 ". 1. Plaintiff is U.S. Bank National Assciation, As trustee Under The Pooling And Servicing Agreement Dated As of June 1, 2003 Among Credit-Based Asset Servicing And Securitization LLC., Merrill Lynch Mortgage Investors, Inc., Litton Loan Servicing LP And U.s. Bank National Association, C-BASS Mortgage Loan Asset-Backed Certificates, Series 2003 CB3. 2. Defendant is William Vaitkunas Or Occupants. 3. Plaintiff is equitable owner of premises located at 417 Fourth Street, New Cumberland, P A 17070. a legal description of which is attached. 4. Plaintiff became owner of said premises as a result of foreclosure and judicial sale by the Sheriff of Cumberland County. on December 7, 2005. 5. Plaintiff, by virtue of the above. is the equitable owner of said premises, and is entitled to possession thereof. The defendant is occupying the said premises without right and so far as the plaintiff is informed, without claim oftitle. 6. Plaintiff has demanded possession of the said premises from the said defendant who has refused to deliver up possession of same. WHEREFORE, plaintiff seeks to recover possession of said premises. ~ S-~~ " ranClS S. Hallman, EsqUIre Attorney for Plaintiff EXHIBIT A ALL THAT CERTAIN PROPERTY SITUATEO IN THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLAND ANO COMMONWEALTH OF PENNSYLVANIA. BEING MORE FULLY DESCRIBED IN A FEE SIMPLE DEED DATEO 11/13/1998 AND RECORDED 11/17/1998, AMONG THE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE. IN VOLUME 189 PAGE 275. TAX PARCEL IDS: 25-25-0006-012 ADDRESS: 417 FOURTH ST. NEW CUMBERLAND, PA 17070 . VERIFICATION Francis S. Hallinan hereby states that he is the attorney for the Plaintiff in this eviction action and is authorized to make this verification. The statements made in the foregoing Civil Action - Ejectment are correct to the best of my knowledge, information, and belief. I was the attorney for the Plaintiff or Plaintiffs predecessor in interest in the underlying foreclosure action. I am with the law firm on the writ of execution, and my law firm or an agent of my firm purchased the property on behalf of the Plaintiff by bidding on the property at the sheriff's sale. 1 am making this verification rather than a representative of the Plaintiff because I have personal knowledge of the purchase of this property at sheriff's sale. The undersigned understands that this statement is made subject to the penalties of 18 Pa,C.S. ~4904 relating to unsworn falsification to authorities. I h~ /d(; Dale ! , ! -.. r~ Fr ncis S. Hallinan, Esquire ttorney for Plaintiff (.::> ./Q P ~ V( t- ~ _ ..t. V1 ~ ~ \) ..c:.. -< .) ~ ~ ?-- ~t -L r.,.'-' ('I -,-1 ,,; c_ . .) (~' c) '.' '.-.,' Q --p . ~; - .') SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00553 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCIATION VS VAITKUNAS WILLIAM R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT VAITKUNAS WILLIAM but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT NOT FOUND , as to the within named DEFENDANT , VAITKUNAS WILLIAM 417 FOURTH STREET NEW CUMBERLAND, PA 17070 PER POST OFFICE, DEFT'S ADDRESS IS 26 WYMAN ST LAWRENCE, MA 01841-1016-26. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 14.96 5.00 10.00 .00 47.96 ---:--::;:::=7 soa~. ~ ~ wr. / R. Thomas K lne Sheriff of Cumberland County PHELAN HALLINAN SCHMIEG 02/03/2006 Sworn and subscribed to before me <5:.- this '1 day of 1~ ":~~. (lIP Pr honot. Phelan Hallinan & Schmeig, LLP BY Francis Hallinan, Esquire Identification No. 62695 One Penn Center at Suburban Station 1617 JFK Boulevard Philadelphia, PA 19103-1814 (215) 563-7000 Attorney for Plaintiff U.S. bank National Association, As trustee Under The Pooling And Servicing Agreement Dated As of June 1, 2003 Among Credit-Based Asset Servicing And Securitization LLC., Merrill Lynch Mortgage Investors, Inc., Litton Loan Servicing LP And U.S. Bank National Association, C-Bass Mortgage Loan Asset- Backed National Association, C- Bass Mortgage Loan Asset- BlJ.cked Certificates, Series 2003-CB3 Plaintiff Court of Common Pleas Civil Division vs. NO. 06-553-Civil Term William Vaitkunas Or Occupants Cumberland County Defendants PRAECIPE TO REINSTATE CIVIL ACTION/EJECTMENT TO THE PROTHONOTARY Kindly reinstate the Civil Action in Ejectment with reference to the above captioned matter. Date: February 21, 2006 \'.-' Phelan Hallinan & Schmieg, LLP BY: Francis S. Hallinan, Esqnire Identification No. 62695 One Penn Center@ Snburban Station Suite 1400 1617 John F. Kennedy Bonlevard Philadelphia, PA 19103-1814 C~l5) <;63-7000 Attorney for Plaintiff U.S. Bank National Association, As Trustee Under The Pooling And Servicing Agreement Dated As of June 1, 2003 Among Credit-Based Asset Servicing And Securitization LLC., Merrill Lyneh Mortgage Investors, Ine., Litton Loan Servicing LP And U.S. Bank National Association, C-Bass Mortgage Loan Asset-Baeked National Association, C-Bass Mortgage Loan Asset-Backed Certificates, Series 2003-CB3 Court of Common Pleas Plaintiff Civil Division vs. NO. 06-553 Civil Term William Vaitkunas Or oecupants Cumberland County Defendants Pr~u~cipe to [".-ley Thom9~ M9rs.is.e As nefpnrismt TO THE PROTHONOTARY: Pursuant to P.A RCP. 4]0 (a)(2), kindly index Thomas Marsise as Defendant in the above captioned matter. Thomas Marsise was found in possession of the premises located @ 417 Fourth Street, New Cumberland, PA 17070, and was served with a eopy of the Complaint on March 2, 2006. , ancis S. Hallinan, Esquire / Attorney for Plaintiff Date: Mareh?1 7006 C~ .....n 85 -." , j-,~, ...i, , Phelan Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esquire Identification No. 12248 One Penn Center Plaza, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, P A 19103 (215) 563-7000 Attorney for Plaintiff u.s. Bank National Association, as Trustee under the Pooling and Servicing Agreement dated as of June 1,2003 among Credit-Based Asset Servicing and Securitization LLC, Merrill Lynch Mortgage Investors, Inc., Litton Loan Servicing LP and U.S. Bank National Association, C-Bass Mortgage Loan Asset-Baeked Certificates, Series 20OJ-CBJ COURT OF COMMON PLEAS CIVIL DIVISION vs No. 06-553-Civil Term William Vaitkunas, Thomas Marsise or occupants 417 Fourth Street New Cumberland, P A 17070 Cumberland County PRAECIPE FOR JUDGMENT IN EJECTMENT TO THE PROTHONOTARY: Kindly enter Judgment in Ejeetment in favor of the Plaintiff, U.S. Bank National Association, as Trustee under the Pooling and Servicing Agreement dated as of June 1, 2003 among Credit-Based Asset Servicing and Securitization LLC, Merrill Lyneh Mortgage Investors, Inc., Litton Loan Serviicng LP and U.S. Bank National Association, C-Bass Mortgage Loan Asset-Baeked Certificates, Series 2003-CB and against the Defendant(s) Thomas Marsise and or occupants for possession of premises, 417 Fourth Street, New Cumberland, PA 17070 for failure to file an Answer within twenty (20) days of service. I hereby eertifY that aeeording to Rule 237.1, written 10-day notiee of Plaintiffs intention to file a praeeipe for Entry of default Judgment was mailed to Defendant(s), a true and eorreet eopy ofwhieh is attaehed hereto/, ~~ L,. ran is S. Hallinan, Esqui e Att ney for Plaintiff ~ Default Judgment entered as indieated above. DATE PHELAN HALLINAN & SCHMIEG, L.L.P By: Francis S. Hallinan, Esquire Identification No. 62695 One Penn Center@ Suburban Station, Suite 1400 ]617 John F. Kennedy Boulevard Philadelphia, PA ]9103-]8]4 Attorney for Plain1iff U.S. Bank National Association, As Trustee Under The Pooling And Servieing Agreement Dated As of June], 2003 Among Credit-Based Asset Servicing And Securitization LLC., Merrill Lynch Mortgage Investors, Ine., Litton Loan Servicing LP And U.S. Bank National Association, C-Bass Mortgage Loan Asset-Backed National Association, C-Bass Mortgage Loan Asset-Backed Certificates, Series 2003-CB3 COURT OF COMMON PLEAS CIVIL DIVISION v. CUMBERLAND COUNTY William Vaitkunas Or Occupants No. 06-553-CIVIL TERM TO: Thomas Marsise (occupant) 417 Fourth Street (Garage) New Cumberland, PA 17070 DATE OF NOTICE: Marrh 2], 200<; This Firm is a debt collector attempting to collect a debt. This Notice is sent to you in an attempt to collect the indebtedness referred to herein, and any information obtained from you will be used for that purpose. If you have previously received a discharge in bankruptcy, this correspondence is not valid and should not be construed to be an attempt to collect a debt, but only as enforcement of lein against property. IMPORTANT NOTTCR 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 (10) 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 paper to your Lawyer at onee. If you do not have a lawyer, got to or telephone the offiee set forth below. This offiee can provide you with the information about hiring a lawyer. If you eannot afford to hire a lawyer, this office may be able to provide you with infonnation about ageneies that may offer legal services to eligible persons at a reduced fee or no fee. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ~(:t'/ ~ rancis S. Hallinan, Esquire Attorney for Plaintiff , Phelan Hallinan & Schmieg, LLP By: Francis S. Hallinan, Esqnire Identification No. 62695 One Penn Center Plaza, Suite 1400 1617 John F. Kennedy Boulevard Philadelphia, P A 19103 (215) 563-7000 Attorney for Plaiutiff U.S. Bank National Association, as Trustee under the Pooling and Servicing Agreement dated as of June 1,2003 among Credit-Based Asset Servicing and Securitization LLC, Merrill Lynch Mortgage Investors, Inc., Litton Loan Servicing LP and U.S. Bank National Association, C-Bass Mortgage Loan Asset-Backed Certificates, Series 2003-CB3 COURT OF COMMON PLEAS CIVIL DIVISION vs No. 06-553-Civil Term William Vaitkunas, Thomas Marsise or oecupants 417 Fourth Street New Cumberland, P A 17070 Cumberland County VERIFICATION OF NON-MILITARY SERVICE FRANCIS S. HALLINAN, ESQUIRE, hereby verifies that he is Attorney for Plaintiff in the above captioned matter, and that on information and belief, he has knowledge of the following facts, to wit: (a) That the defendant(s) is/are not in the Military or Naval Service ofthe United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) That defendant Thomas Marsise Or occupants, is over 18 years of age, and resides at 417 Fourth Street, New Cumberland, PA 17070. This statement is made subject to the penalties of]8 PA. C.S.S 4904 relating to unsworn falsification to authori1ies. t ~ 0 --v~ r;h ~ C~. !'-.-:, c.....' :-, c {-.:l () C.'.__ . (I );~.". --;-J ["\- --- () ." r ....j -:c: --J , ( ,'~ ~ \'- ~ (\ -r:::- r~ Q.[ ......... ~ - D b ~.~ ~ -l_ " .' ~-..} '-- +---- --" \I ' '"'-- ( ,------, -~ , , PRAECIPE FOR WRIT OF POSSESSION COMMONWEALTH OF PENNSYL VANIA County of Cumberland U.S. Bank National Association, as Trustee under the Pooling and Servicing Agreement dated as of June 1,2003 among Credit-Based Asset Servicing and Securitization LLC, Merrill Lynch Mortgage Investors, Inc., Litton Loan Servicing LP and U.S. Bank National Assoeiation, C-Bass Mortgage Loan Asset-Baeked Certificates, Series 2003-CB3 COURT OF COMMON PLEAS CIVIL DIVISION vs No. 06-553-Civil Term William Vaitkunas, Thomas Marsise or occupan1s 4] 7 Fourth Street New Cumberland, PA 17070 Cumberland County PRAECIPE FOR WRIT OF POSSESSION TO THE PROTHONOTARY: Issue Writ of Possession in the above matter for possession of: 417 Fourth Street, New Cumberland, PA 17070 ..PLEASE SEE THE ATTACHED LEGAL DESCRIPTION".. Being Known as NO.4] 7 Fourth Street ~ +- -,) 0 (V 75-. #- l ~ -- () c: (J o \Y '-h --C:: :r::J --.J ....c:-. \> ~ ~ ~ ~ :--l'l ("\ "\? ~ - \)- c \~ ~ g f'-, ~ .......- ,.2:: ..\J 0 ~ --- ....p 0< \)' ..:j J::: C) Vf 0 "-C\ ~ c; I) \) r-- I \ I ~ ~ ~ ~ ~ ~ , - ~ ~ - .:: - - --- - "- ~ ~. ~ ~ V<. --{) \:> r C) I p~ tI' ~~ ~7 r:-- :::-1 cr'l . EXHIBIT A ALL THAT CERTAIN PROPERTY SITUATED IN THE BOROUGH OF NEW CUMBERLAND IN THE COUNTY OF CUMBERLANO AND CDMMONWEALTH OF PENNSYLVANIA, BEING MORE FULLY DESCRIBED IN A FEE SIMPLE DEED DATED 11/13/1998 AND RECORDED 11/17/1998, AHONG tHE LAND RECORDS OF THE COUNTY AND STATE SET FORTH ABOVE, IN VOLUME 189 PAGE 275. TAX PARCEL IDS: 25-25-0006-012 ADDRESS: 417 FOURTH ST. NEW CUMBERLAND, PA 17070 . . WRIT OF POSSESSION (Ejectment Proceedings PRep 3160 - 316:; etc.) IN THECOURT OF' COMMON PLEAS OF CUMBERL~ND COllN"1 Y, PENNSYLVANIA U.s. BANK, NATIONAL ASSOCIATION, AS TRUSTEE, ETAL. No. 06-553-CIVIL TERM Tenm vs. No. Tenm Costs Att'y. $ PJ'ff (s) $ Prothy. $ WILLIAM VAITKUNAS, THOMAS MARSISE 191.42 OR OCCUPANTS 1.00 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of CUMBERLAND County, Pennsylvania (I) To satisfy the judgmentJ?1i ??S~1MiO\\l~t8~ceoAgs'8ef~Hc\W, aIfsd~ab~-&'Jp ~WEYlIf\l:P~8\ID~tthe followmg descnbed property to: AND SERVICING AGREEMENT DATED AS OF JUNE 1, 2003, AMONG CREDIT- BACKED ASSET SERVICING AND SECURITIZATION LLC, MERRILL LYNCH MORTGAGE INVESTORS, INC., LITTON LOAN SERVICING LP AND U.S., BANK NATIONAL ASSOCIATION, C-BASS MORTGAGE LOAN ASSET BACKED CERTIFICATES, SERIES 2003-CB3 Plaintiff (s) being: (Premises as follows): 417 FOURTH STREET NEW CUMBERLAND, PA 17070 (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (s) and sell his/her (or their) interest therein. (SEAL) /J ~ rJ/ /' I (/IA::d....3) K c:<~ Pr6tho~otaIy, Common Pleas Cowt of Cwnbc County, Pennsylvania ~ L Dt r _0 .0fc /)/74 ,[./--- Deputy Date !\peil 5, 2006 ~ :r '" @ 'U '" 'U '" ... en ::; '" '< 0', '" en !'l ~ < " '" 0 0. " o {IJ '1:l :r ... '" 0 .... s- Si ":: ::01 ::;; ~ ':< ~ ~ n o en ~ en :-0:::; ?:;l:l n..... . >-l :-00 w'Tl ......" ""0 '?m Wm ....trl ""m <rom trl..... >-l0 0Z '" ..-. '""' '""' ..-. ~ <: :>- ..-. >-J ~ Z :>- en >-J :I: ~ en ~ en ..-. en M o :>' o o o c '" ~ rl en By virtue of this writ, on the I caused the within named have possession of the premises described with the appurtenances, and _ Z'" M~ ",...., O"l ~g "'''" Mrl :o<>:I: '""' :>-[}J Zrl 0:>' - '" '" '"drl :>- 3'\1\ .... ~ \ ::01 '" ~ ::;; ~ en ~ "" "" "" "" f-' . o o f-' "'. f-' ... W day of Sworn and subscribed to before me this day of So Answers, Prothonotary By_~_ OZH:>-:>-C ~::r> z CJ} z. :;:dt-3<:cnt:::ltr.l l-3Htr:lt:t::l . HOVlHt.r.:l... tTjZt-3 tr:l ~>O(fl:;dt;d or:o<>"'<::>- :.r> U)~H!2': rl:>-- <:0'" r::lc.o HH tr.ltr:lHnZ~ '" oZH0;J,> o(")z 1--3 tF.lHo GJ:J>H '" :>- - 00 ,,"rl :>-,,"Z t-IHrtZt:t::lc:. n \:'10 H t:> t:l' ..... enZrl ~ CZ - rl[}J"':>- 7'...0 N Otr1Zr.n ~~ ooZOrl[}J o:1:I: 01 c::: 0 ~ l-oool W '" r :>' t:> 0 ,~, ,~, 1:>- 0..-.:>-..-. :;l:l n O[}J:>->-Jrl:>- t""0 tdooZHMrl ......... w Nt:> H .... c 5 ~ i"i '-< ~ ~:;l:l ,,",,"HC- '-'>-l rl<lOZ ("") <: 0"-'Z"':>- 0 en:>-O- 0>0_ GJ H I-" ~""J '" z:3 ~- ;;J Z n Sr;o~~j~ :;I> I-d '" 0 rl...."-< ~ Z "''''_7' :>-:<: "'" "'" ~1'3~~cI:'rlO en :>'01'3 Z Z tl;::~z:3~~;:g ,en,"", ~-<, ~. '""' ';;J rl t"" ~ 0"'><"':I::<::r.; '" ~ Z t:> "'...~, gJ",Q::1",zo I o,looooi l-r1 :<:"'0;"- o:>-r ,,"enH rl"'Z 0t:>0 :>-. o '" z z o 0 1 o H <: H r rl '" ~ (;l (;l .... ... 3 3 , to Sheriff Deputy SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-00553 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCIATION VS VAITKUNAS WILLIAM R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT VAITKUNAS WILLIAM but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - EJECTMENT , NOT FOUND , as to the within named DEFENDANT , VAITKUNAS WILLIAM 417 FOURTH STREET NEW CUMBERLAND, PA 17070 DEFENDANT NO LONGER LIVES AT GIVEN ADDRESS. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 14.96 5.00 10.00 .00 47.96 So a.n....swe~s~~. ~./ R. Thomas Kline Sheriff of Cumberland County PHELAN HALLINAN SCHMIEG 03/03/2006 Sworn and subscribed to before me this .1.1.4- day of .~ , """ AD~ al' prot.lfono~ary 1 SHERIFF'S RETURN - REGULAR CASE NO: 2006-00553 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND U S BANK NATIONAL ASSOCIATION VS VAITKUNAS WILLIAM ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - EJECTMENT was served upon OCCUPANT the DEFENDANT , at 1830:00 HOURS, on the 2nd day of March 2006 at 417 FOURTH STREET NEW CUMBERLAND, PA 17070 by handing to THOMAS MARSISE, OCCUPANT a true and attested copy of COMPLAINT - EJECTMENT together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 6.00 .00 .00 10.00 .00 16.00 ~~~ , .. R. Thomas Kline day of 03/03/2006 PHELAN HALLINAN SCHMIEG B~,~ Deputy Sher f Sworn and Subscribed to before me this J. IA-r A.D. PHELAN HALLINAN & SCHMIEG, LLP By: Francis S. Hallinan Esquire Atty. J.D. No.: 62695 One Penn Center at Suburban Station Suite 1400 Philadelphia, PA 19103-1814 (215) 563-7000 ttorney for Plaintiff U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE UNDER THE POOLING AND SERVICING AGREEMENT DATED AS OF JUNE 1, 2003 AMONG CREDIT-BASED ASSET SERVICING AND SECURITIZATION LLC, MERR LL LYNCH MORTGAGE INVESTORS, INC., LITTON LOAN SERVICING LP AND U.S. BANK NATIONAL ASSOCIAT ON, C-BASS MORTGAGE LOAN ASSET-BACKED CERTIFIC TES, SERIES 2003-CB3 Plaintiff Court 0 Common Pleas CUMB RLAND County No. 06- 53-CIVIL TERM vs. WILLIAM V AITKUNAS THOMAS MARSISE OR OCCUPANTS Defendant(s) PRAECIPE TO WITHDRAW COMPLA SATISFY JUDGMENT AND DlSCONTINU END ACTION WITHOUT PREJUDIC TO THE PROTHONOTARY: Kindly withdraw the complaint filed in the instant matter, with ut prejudice, satisfy the judgment and mark this case discontinued and ended, upo payment of your costs only. s/ds/OG / t Date ~ F ancis S. Halli an Attorney for PIa ntiff PHS # 130071 D ,..., 0 ~ ~;: c;:') .... cr- ~. .-< :pu> I.... -< tnF w -CP' , -;'JO :~~j ~? , :0>- C.4~~ c :::;:: cst" (.~ . ~-~\ L~ ~ $5 .." -<.' W --< l!.IU . ~ = ~. 8.:!!.::. (! " OFFICE OF THE SHERIFF CUMBERLAND COUNTY. FA lOOb APR , 1 A 8: 45 >:: H .... .... H ~ <: > H >-'3 ~ en "C "C ;J> ~ u:T ::r a 8; ~ . <IT ~. ..., So ~ ';<: >-'3 Si ';<: '" "" '-" 0 ~ u:T :"0< ~ ;:c~ C")- u:T H . ..., u:T ."tl0 t>1 ''''l 0 () . .... 0 ...."'::1 :<l ~ 0\0 0 '" 7"00 n ....00 n ....t:rl C 0\ en '" "'en g; t:rl- >-'3 ...,0 u:T .... .... .... .... 0z ..... \.0;; ..... ..... . . 0 ~ 0 .... ~ z.o- ~~ ::r <IT n"", @ ~o '1:l "'~ 0> t>1 >-'3' '1:l ES"" <IT' ..., '" >u:T 3 ~~ 0> . t>1 '< t>1 ""'. "'>-'3 (') \. > '" <IT .... ..., " . .... <IT 0 0- .... 0 By virtue of this writ, on the day of I caused the within name(j have possession of the premises described with the appurtenances, and WRIT OF POSSESSION RETURNED STAYED THIS DATE PER ATTY nZH>~C t>1 > Z u:T . :;O~<tr.l tI) t-3Htz:lt'%J . H 0 en t-3 en'" ""'Z>-'3 t>1 H>Ou:T:<l'" n....:<lt>1<:~ ~>;n:;j~i"l tz:ltOHH tntllHnZZ . OZHC;>> (")(jZ t-3 tr.l H. Cj) > H t>1 >. c;> 0 ~;:j....~[':J~ t>10HS~.... ()_ u:TZ >-'3 ~ c:: Z ... t-3t1l _ ~ N 0 t>1 Z u:T ""''''' onZn>-'3u:T t:l:1- 01 c::: 0 "-I ~ """'....:<l t:J n ,-, t:rl ,!,~~~~~ ~n "'u:TZHt>1>-'3 to "" N t:J H ~ '"' ;':u:T> 0"'..... 0t>1 >-'3'-0 Z t:l~. ~:;jt:~. ()..., <: C;>H Zt>1 > 00 u:T > n. u:T _ c;> H ..... c::-' t>1 z..... >-'3 Z n r-' C;>hN~..., 0 0..... 0u:T '"" ~ > ",. 0 >-'3~""" .... Z "" 1:1 "tl s: >~~~ct:rlo ~ :<lozZZ t>1CHZt:JZ_ >-'3' .... c;> t>1 en ..:: ,u:T.... :<l>(, ~. ....~>-'3t"'~ ~ ~ ~fHl ~ en tl~g~",zo 10- "'l ;':"'0>- 0>.... :<lu:TH >-'3t>1Z c;>t:Jc;> >. Il' t>1 f.b!biI ~ ==>> 1hb Eh!k. ~ Z Z ~ ~ I n H is .... >-'3 ~ ;;J ;;J '3 ~ , to Sheriff's Docketing Sure-harge Pro thy Milage 'PolHH:lage Return: 18.00 30 Of) 1. 00 31.68 8~.~6 Advance Costs: 150.00 Sheriff's Costs: 82.30 6/. 10 Rpfllnc1pc1 to Atty on 5/3/06 SOA~~ ~"'~~-e By C~.nuku- ~ff.. ;:)\..)0 ~/ Deputy \ .O'l> C;t.,6 3q ~).. R...v. 171 'IS'i - Sworn and subscribed to before me this dayof~ ~ ~. Q~~ 7 .. ( Pr 0 otary /6'42- ,.;) Mj(. WRIT OF POSSESSION (Ejectment Proceedings PRep 3160 - 316'::' etc.) U.S. BANK, NATIONAL ASSOCIATION, IN THE'COURT OF' COMMoN PLEAS OF CUMBERL;\ND CO{JN"l Y, PENNSYLVANIA , AS TRUSTEE, ETAL. No. 06-553-CIVIL TERM Term vs. No. Term Costs Att'y. $ Pl'ff (s) $ Prothy. $ WILLIAM VAITKUNAS, THOMASMARSISE 191.42 OR OCCUPANTS 1.00 . COMMONWEALTII OF PENNSYLVANIA: COUNTY OF CUMBERLAND: To the Sheriff of CUMBERLAND County, Pennsylvania ~1) To sa~sfy the judgmentJ?~ P?S~~o~lit:l8~E>I~sW8:l~ftdW, arlsd~ifi~ ~~i( ~MfIRt the followmg described property to: AND SERVICING AGREEMENT DATED AS OF JUNE 1, 2003, AMONG CREDIT- BACKED ASSET SERVICING AND SECURITIZATION LLC, MERRILL LYNCH MORTGAGE INVESTORS, INC., LITTON LOAN SERVICING LP AND U.S.. BANK NATIONAL ASSOCIATION, C-BASS MORTGAGE LOAN ASSET BACKED CERTIFICATES, SERIES 2003-CB3 ~. , Plaintiff (s) being: (Premises as follows): 417 FOURTH STREET~ . NEW CUMBERLAND, PA 17070 ",' ";"G",~ 'I ^;' \l > ,~ ,j" ~ in .". -,' c .L I ~r" ',' 'J :J'.{ di~: f.....~tt,j ~ ,,!- .''1'..,.'- , .1"",-.,." ,'-,1 i"'-:.."~,"."':~" ('I. ~ax~~-,: ,o"d ,,.ll'~jn..~i' ,:'<'1_"'~~ . '- rtft. ~ n 'b .zft~~~:J:~'r (2) To satisfy the costs against the defendant (s) you are directed to levy upon any property of the defen- dant (5) and sell hislher (or their) interest therein. ohotary, Common Pleas Court ofCwn County, Pennsylvania ho, c_y .~///U1v;- Deputy (SEAL) ~: Date II,pri1 5. 2006