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Home My WebLink About07-0178UDREN LAW OFFICES, P.C. BY: Mark J. Udren, Esquire ATTY I.D. N0. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 pleadings@udren.com Deutsche Bank Trust Company Americas as Trustee f/k/a Bankers Trust Company as Trustee 2711 North Haskell, Suite 900 Dallas, TX 75204-2915 Plaintiff ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION Cumberland County v. Dixie Lee Runk 531 North West Street Carlisle, PA 17013 Defendant (s ) COMPLAINT IN MORTGAGE FORECLOSURE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TARE 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 YOII 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. LAWYERS REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 AVISO Le han demandado a usted en la torte. 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. Hate falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la torte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se dafiende, la Corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso 0 notificacion. Ademas, la torte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEblANDA A UN ABOGADO IMMEDIATAMENTE, SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 800-990-9108 NOTICE The amount of your debt is as stated in the attached document. The name of the creditor to whom the debt is owed is as named in the attached document. Unless you notify us within 30 days after receipt of this Notice and the attached document that the validity of the stated debt, or any portion of it, is disputed, we will assume that the debt is valid. If you do notify us in writing of a dispute within the 30 day period, we will obtain verification of the debt or a copy of a judgment against you, and mail it to you. If you do not dispute the debt, it is not an admission of liability on your part. Also, upon your written request within the 30 day period, we will provide you with the name and address of the original creditor if different from the current creditor. If you notify us in writing within the 30 day period as stated above, we will cease collection of your debt, or any disputed portion of it, until we obtain the information that is required and mail it to you. Once we have mailed to you the required information, we will then continue the collection of your debt. This law firm is deemed to be a debt collector and this Notice and the attached document is an attempt to collect a debt, and any information obtained will be used for that purpose. UDREN LAW OFFICES, P.C. /s/ Mark J. Udren, Esquire Woodcrest Corporate Center 111 Woodcrest Road, Suite 200 Cherry Hill, NJ 08003-3620 (856) 669-5400 1. Plaintiff is the Corporation designated as such in the caption on a preceding page. If Plaintiff is an assignee then it is such by virtue of the following recorded assignments: Assignor: Crusader Bank, F.S.B. Assignments of Record to: Deutsche Bank Trust Company Americas as Trustee f/k/a Bankers Trust Company as Trustee Recording Date: 2/10/03 Book: 694 Page: 1340 2. Defendant(s) is the individual designated as such on the caption on a preceding page, whose last known address is as set forth in the caption, and unless designated otherwise, is the real owner(s) and mortgagor(s) of the premises being foreclosed. 3. On or about the date appearing on the Mortgage hereinafter described, at the instance and request of Defendant (s) , Plaintiff (or its predecessor, hereinafter called Plaintiff) loaned to the Defendant(s) the sum appearing on said Mortgage, which Mortgage was executed and delivered to Plaintiff as security for the indebtedness. Said Mortgage is incorporated herein by reference in accordance with Pa.R.C.P. 1019 (g). The information regarding the Mortgage being foreclosed is as follows: MORTGAGED PREMISES: 531 North West Street MUNICIPALITY/TOWNSHIP/BOROUGH: Borough of Carlisle COUNTY: Cumberland DATE EXECUTED: 11/23/99 DATE RECORDED: 11/29/99 BOOK: 1584 PAGE: 484 The legal description of the mortgaged premises is attached hereto and made part hereof. 4. Said Mortgage is in default because the required payments have not been made as set forth below, and by its terms, upon breach and failure to cure said breach after notice, all sums secured by said Mortgage, together with other charges authorized by said Mortgage itemized below, shall be immediately due. 5. After demand, the Defendant(s) continues to fail or refuses to comply with the terms of the Mortgage as follows: (a) by failing or refusing to pay the installments of principal and interest when due in the amounts indicated below; (b) by failing or refusing to pay other charges, if any, indicated below. 6. The following amounts are due on the said Mortgage as of 12/18/06: Principal of debt due $92,643.89 Unpaid Interest at 9.25% from 8/1/06 to 12/18/06 (the per diem interest accruing on this debt is $23.48 and that sum should be added each day after 12/18/06) 3,287.20 Title Report 325.00 Court Costs (anticipated, excluding Sheriff's Sale costs) 280.00 Escrow Overdraft/(Balance) (The monthly escrow on this account is $133.70 and that sum should be added on the first of each month after 12/18/06) 25.93 Late Char es hl (mont yy Late charge of $41.13 should be added in accordance with the terms of the note each month after 12/18/06) 164.52 Suspense Balance (295.70) Attorne s Fees (anticipated and actual to 5% o~ principal) 4,632.19 TOTAL $101,063.03 7. The attorney's fee set forth above are in conformity with the mortgage documents and Pennsylvania law, and will be collected in the event of a third party purchaser at Sheriff's Sale. If the mortgage is reinstated prior to the sale, reasonable attorney's fees will be charged in accordance with the reduction provisions of Act 6, if applicable. 8. The combined notice specified by the Pennsylvania Homeowner's Emergency Mortgage Assistance Program, Act 91 of 1983 and Notice of .Intention to Foreclose under Act 6 of 1974 has been sent to each defendant, via certified and regular mail, in accordance with the requirements of those acts, on the date appearing on the copy attached hereto as Exhibit "A", and made part hereof, and defendant(s) have failed to proceed within the time limits, or have been determined ineligible, or Plaintiff has not been notified in a timely manner of Defendant(s) eligibility. WHEREFORE, the Plaintiff demands judgment, in rem, against the Defendant(s) herein in the sum of $101,063.03 plus interest, costs and attorneys fees as more fully set forth in the Complaint, and for foreclosure and sale of the Mortgaged premises. Mark J. Udren, ~ E Q~-UIRE UDREN LAW OFFICES, P.C. Attorney for Plaintiff Attorney I.D. No. 04302 1lLL L„it'6 srskad+o #rarC 4! laed tri'ti~ thi ~ 'I~eroek eli+esie{! w~.#YD!! 3n tDe mrsY~ pi' e~.na~r~,, C~n~ ~r 'wilrtL„ DaYMSd ~ d~roalbe~ as Jdalf~rai ".~#1i DT- '~ 8rat ^'lde a! h Yrs# 8lreet air c~oa:wn i-! 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This discharge affects only your personal liability with respect to this loan. The lender retains certain rights, including the right to foreclose on its lien on the property if the loan is in default. A default e>asts under the above referenced Mortgage/Deed of Trust loan agreement. The action required to cure the default is the payment of all sums due under the Mortgage/Deed of Trust loan agreement. As of the date of this letter the total amount due is $ 3,728.95. That sum includes the following: 3 payments totaling: $ 2,869.14 Late charges: $ 1,103.07 Other fees and/or costs: $ 45.00 Unapplied Funds $ 288.26 The total amount due, shown above, is subject to further increases for addifional monthly payments, late charges, attorney fees and/or other fees and costs which may become due after the date of this letter. Hence, if the amount shown above is paid, an adjustment may be necessary after we receive the payment, in which event we will inform you before depositing the payment. If there is any doubt as to the amount necessary to cure the default, you should contact us at 1.800.206.2901. TO CURE THIS DEFAULT, SEND YOUR PAYMENT BY November 04, 2006 USING A CASHIER'S CHECK, CERTIFIED CHECK, OR WESTERN UNION IN THE AMOUNT OF $ 3,728.95, PLUS ANY ADDITIONAL AMOUNTS WHICH MAY HAVE BECOME DUE, TO THE FOLLOWING ADDRESS: P.O. Box 78426 Phoenix, AZ 85062-8426 OR OVERNIGHT TO: 1820 East Sky Harbor Circle South, Suite 100 Phoenix, AZ 85034-9700. If the default is not cured within thirty (30) days of the mailing of this letter, the lender, without further notice or demand, will accelerate the maturity date of the Note and declare all sums secured by the Mortgage/Deed of Trust to be immediately due and payable. The lender then intends to have the property sold at a public foreclosure sale. After acceleration, a curing of the default and reinstatement of the loan may be permitted up to the time of sale by paying the past due monthly payments and other sums then due under the Mortgage/Deed of Trust loan agreement and by complying with all terms of reinstatement. We are entitled to collect all expenses that we incur in pursuing these remedies, including but not limited to reasonable attorneys fees and costs, trustee's fees, and expenses pertaining to documentary evidence, abstracts and title reports. If the loan is accelerated, you may have the right to reinstate the loan after acceleration. You have the right to assert in the foreclosure proceeding, and/or the right to bring a court action to assert, the non- e>astence of a default or any other defense you may have to the acceleration of the loan and sale of your property. ~X~ilBl~r ,~ We are committed to working with you to resolve this matter. A Homecomings Loan Counselor may be able to provide assistance, and can be reached at the number below. If you are in need of financial advice, you may contact the Federal Department of Housing and Urban Development (HUD) to obtain a list of approved loan counseling agencies. HUD may be reached, toll free, at 800-569-4287. If the delinquency is due to disability or death and you purchased life and/or accident/health insurance on the injured or deceased party, contact us immediately so that a claim evaluation can be inifiated promptly. Please give this matter the attention it warrants. This is not an attempt to collect a debt from you personally but is sent to notify you that acceleration and foreclosure will occur if the default is not cured Loan Counseling Department Homecomings Financial 800.799.9250 'Homeownership counseling is available to you through the 'Cred'R Counseling Resource Center (CCRC), an alliance of consumer credit counseling agencies. The CCRC has been retained by Homecomings Financial to provide advice to you on credit issues, including how to reduce debt and improve cash flow management capabilities. You may contact them at 1.877.808.0775 for assistance at no cost to you, or you may wish to contact HUD-approved housing counseling agency by calNng 1.800.569.4287 for further informatan. ACT 97 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE 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. This is an official notice that the mortgage on your home is in default. and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works. To see if HEMAP can help, you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 30 DAYS OF TH DATE OF THIS NOTICE. Take this notice with you when you meet with the Counseling Agencv. The name, address and phone number of Consumer Credit Counseling Agencies serving vour County are listed at the end of this Notice. If you have any questions. you may call the Pennsylvania Housing Finance A~encv toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar associafion may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION IMMEDIATAMENTE LLAMANDA ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. Date: October O5, 2006 TO: Dixie L Runk 531 North West Street Carlisle, PA 17013 Premises: 531 North West Street Carlisle, PA 17013 Re: Loan Number: 0431677293 FROM: Homecomings Financial HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELPYOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSITANCE ACT OF 1983 (THE "ACT's, YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL, IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE -Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time, you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THE NEXT 30 DAYS. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names, addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the properiv is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default.) If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face- to-face meeting LENDER CONTACT IN REGARDS TO PENNSYLVANIA HOUSING FINANCIAL ASSISTANCE Homecomings Financial Attn: Ryan Ramos 9350 Wabe Way Ste. 100 San Diego, CA. 92123 Fax: 858-514-5516 ALL CORRESPONDENCE REGARDING PHFA ASSISTANCE SHOULD BE FORWARDED TO THE ABOVE REFERENCED ADDRESS. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has surly (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSTRUED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy you can still apply for Emergency Mortgage Assistance.) HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT -The MORTGAGE debt held by the above lender on your properly located at: 531 North West Street ,Carlisle, PA 17013 IS SERIOUSLY IN DEFAULT because: YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly payments from 08/01 /06 to 10/01 /06 totaling: $ 2,869.14 Late Charges: $ 1,103.07 Other fees and/or costs Including NSF charges and property inspections): $ 45.00 LESS: Unapplied Funds: $ 288.26 TOTAL $ 3,728.95 HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the date of this Notice BY PAYING THE TOTAL AMOUNT DUE TO THE LENDER, WHICH IS $ 3.728.95. PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash. cashier's check. certfied .check or money order made payable and sent to: Homecomings Financial, P.O. Box 78426 Phoenix, AZ 85062-8426 OR OVERNIGHT TO: 1820 East Sky Harbor Circle South, Suite 100 Phoenix, AZ 85034-9700. IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its right to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately and you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorney to start legal action to foreclose upon your mortgaged property. IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attomey, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attomey's fees actually incurred by the lender, even if they exceed $50.00. Any attomey's fees will be added to the amount you owe the lender, which may also include other reasonable costs. N you cure the default within the THIRTY (30) DAY period you will not be required to oav attorney's fees. OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal balance and all other sums due underthe mor~a~7e. RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun you still have the right to cure the default and prevent the sale at any time up to one hour before the Sheriff's Sale You may do so by pawns the total amount then past due plus anv late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and anv other costs connected with the Sheriff's Sate as specified in wrfinp by the lender and by performing anv other requirements under the mortaaae Curing vour default in the manner set forth in this Notice will restore vour mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - ft is estimated that the earliest date that such a Sheriffs Sale of the mortgaged properly could be held would be approximately six (6) months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sate. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Homecomings Financial 2711 N. Haskell, Suite 900 Dallas, TX 75204 Attn: Loan Counseling Department Phone: 1.800206.2901 EFFECT OF THE SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of the morkgaged properly and your right to occupy it. If you continue to live in the property afterthe Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE -You may be able to sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. Sincerely, Loan Counseling Department Enclosure(s) List of Counseling Agencies i V E R I F I CAT I O N Mark J. Udren, Esquire, hereby states that he is the attorney for the Plaintiff, a corporation unless designated otherwise; that he is authorized to take this Verification and does so because of the exigencies regarding this matter, and because Plaintiff must verify much of the information through agents, and because he has personal knowledge of some of the facts averred in the foregoing pleading; and that the statements made in the foregoing pleading are true and correct to the best of his knowledge, information and belief and the source of his information is public records and reports of Plaintiff's agents. The undersigned understands that this statement herein is made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. \\ _~..~,t ~ . ~ui~u.' ~S~UlRE UDREN LAW OFFICES, P.C. ~. " i 1 P ~ ~ `~ '~ (!Z ~ ~ '"~ ~ -f~-~ C? yip'; r~ f- ._~ ~_ r.~== --, --~: r,.a ~-~ c_.. O ~~ -~ t'r' -~~ ,.-~ z"_~ c"~ ~~ ~~ ..~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-00178 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DEUTSCHE BANK TRUST COMPANY VS RUNK DIXIE LEE JESSICA HERMANSEN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon RUNK DIXIE LEE the DEFENDANT at 1855:00 HOURS, on the 12th day of January 2007 at 531 NORTH WEST STREET CARLISLE, PA 17013 DIXIE LEE RUNK by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.0 0 ~~~`"''~ Service 4.40 -~i~~~ . Affidavit . 00 ~~ Surcharge 10.00 R. Thomas Kline .00 32.40 01/17/2007 (,aq,~'~ UDREN LAW OFFICE Sworn and Subscibed to ~~ By: ~ ___- before me this day Dep t Sheriff of A.D. UDREN LAW OFFICES, P.C. ATTORNEY FOR PLAINTIFF BY: Mark J. Udren, Esquire ATTY I.D. NO. 04302 WOODCREST CORPORATE CENTER 111 WOODCREST ROAD, SUITE 200 CHERRY HILL, NJ 08003-3620 856-669-5400 Deutsche Bank Trust Company :COURT OF COMMON PLEAS Americas as Trustee f/k/a :CIVIL DIVISION Bankers Trust Company as :.Cumberland County Trustee Plaintiff v. Dixie Lee Runk €NO. 07-178 Defendant PRAECIPE TO DISCONTINUE WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly mark the above DISCONTINUED WITHOUT PREJUDICE, upon payment of your costs only. ~~ Mark J. Udren, Esquire UDREN LAW OFFICES, P.C. Attorney for Plaintiff DATED: February 28, 2007 m~ti oc~i2o45°7 c ~ . ~. -c}~ ~ ~~ .~ ~ ~ ~ rrs ~_ ~.> ~ f ' ~ , 4 ~ ~ ~ ~` g V