Loading...
HomeMy WebLinkAbout07-0248PHELAN HALLINAN & SCHMIEG, LLP LAWRENCE T. PHELAN, ESQ., Id. No. 32227 FRANCIS S. HALLINAN, ESQ., Id. No. 62695 ONE PENN CENTER PLAZA, SUITE 1400 PHILADELPHIA, PA 19103 (215) 563-7000 146659 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff V. WILLIAM G. KEMP LISA M. KEMP 748 WEST NORTH STREET CARLISLE, PA 17013 Defendants ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM J NO. 07 - ??U ?lUt1. CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD`TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800)990-9108 File #: 146659 IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15 U.S.C. § 1692 et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE, NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY (30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU`REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUk RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. File #: 146659 Plaintiff is - COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 2. The name(s) and last known address(es) of the Defendant(s) are: WILLIAM G. KEMP LISA M. KEMP 748 WEST NORTH STREET CARLISLE, PA 17013 who is/are the mortgagor(s) and real owner(s) of the property hereinafter described. 3. On 02/20/2004 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. ASA NOMINEE FOE AMERICA'S WHOLESALE LENDER which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Book: 1855, Page: 2299. PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due,09/01/2006 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 146659 6. The following amounts are due on the mortgage: Principal Balance $119,892.50 Interest 3,015.53 08/01/2006 through 01/08/2007 (Per Diem $18.73) Attorney's Fees 1,250.00 Cumulative Late Charges 142.76 02/20/2004 to 01/08/2007 Cost of Suit and Title Search 550.00 Subtotal $ 124,850.79 Escrow Credit 0.00 Deficit 68.02 Subtotal 68.02 TOTAL $ 124,918.81 7. The attorney's fees 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 Sheriffs Sale. If the Mortgage is reinstated prior to the Sale, reasonable attorney's fees will be charged. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the>mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. This action does not come under Act 6 of 1974 because the original mortgage amount exceeds $50,000. WHEREFORE, PLAINTIFF demands an in rem Judgment against the Defendant(s) in the sum of $ 124,918.8 1, togetherwith interest from 01/08/2007 at the rate of $18.73 per diem to the date of Judgment, and other costs and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN ALLINAN & SCHMI G, LLP By: /s/Francis S. all' n LAWRENCE T. PHELA , ESQUIRE FRANCIS S. HALLINAN, ESQUIRE Attorneys for Plaintiff File #: 146659 LEGAL DESCRIPTION ALL THAT CERTAIN tract of land with the improvements thereon erected, situate on the south side of West North Street in the Borough of Carlisle, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the south side of West North Street, in the dividing line between Lots Nos. 33 and 34 of Block Won the hereinafter mentioned plan of lots; THENCE in a southerly direction by said dividing line and by the line of land now in tenure of Gary L.'Matthews et ux, two hundred forty feet (240 feet), more or less, to the northern line of Locust Alley as shown on said plan of lots; thence in a westerly direction by the northern line of said Locust Alley, fifty feet (50 feet) to a point in the dividing line between Lots Nos. 31 and 32 of Block B' on said plan of lots; thence in a northerly direction by said dividing line and by the line of land in tenure of James D. Griest et ux, two hundred forty feet (240 feet), more or less, to the southerly line of West North Street; thence by the southerly line of West North Street in an easterly direction, fifty feet (50 feet) to the place of BEGINNING. BEING Lots Nos. 32 and 33 of Block 'B' of a plan of lots known as the Bretz Tract, which plan is of record in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle, Pennsylvania, in Plan Book 2, at Page 81. BEING improved with a one and one-half story frame dwelling house and two car garage known and municipally numbered as 748 West North Street, Carlisle, Pennsylvania. BEING the same premises which William S. Diehl, Jr. and Tamara L. Diehl, his wife, by deed dated October 13, 1993, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book O, Volume 36, Page 1049, granted and conveyed to William G. Kemp and Lisa M. Kemp, Grantors herein. PROPERTY BEING: 748 WEST NORTH STREET File #: 146659 FRANCIS S. HALLINAN, ESQUIRE hereby states that he is attorney for PLAINTIFF in this matter, that Plaintiff is outside the jurisdiction of the court and or the Verification could not be obtained within the time allowed for the filing on the pleading, that he is authorized to make this verification pursuant to Pa. R. C. P. 1024 ( c ) and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of his knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. '4 ) ka&"' FRANCIS S. HALLINAN, ESQUIRE Attorney for Plaintiff DATE: N c? . ? t (^f1 3 (mil ,, v^^ J _Zt f? 6? ? PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE PLANO, TX 75024 Plaintiff, V. CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-248 CIVIL TERM WILLIAM G. KEMP LISA M. KEMP Defendant(s). PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter an in rem judgment in favor of the Plaintiff and against WILLIAM G. KEMP and LISA M. KEMP, Defendant(s) for failure to file an Answer to Plaintiff s Complaint within 20 days from service thereof and for Foreclosure and Sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint Interest from 1/9/07 to 2/26/07 TOTAL $124,918.81 $917.77 $125,836.58 I hereby certify that (1) the addresses of the Plaintiff and Defendant(s) are as shown above, and (2) that notice has been given in accordance with Rule 237.1, copy attached. 71?DANIEL G. SCHMIEG, ES IRE Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: ?t 2Dr77 PRO OTHY 146659 PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (215) 563-7000 COUNTRYWIDE HOME LOANS,INC. Plaintiff Vs. WILLIAM G. KEMP LISA M. KEMP COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY :NO. 07-248-CIVIL TERM Defendants TO: LISA M. KEMP 748WEST NORTH STREET CARILSLE, PA 17013 DATE OF NOTICE: FEBRUARY 1-1, 2007 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 AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATIC)IJ la 11 32 SOUTH BEDFORD STREET -VIL[ UUM CARLISLE, PA 17013 (? (800)990-9108 11 S. HALLINAN, ESQUIRE for Plaintiff PHELAN HALLINAN & SCHMIEG, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 ATTORNEY FOR PLAINTIFF Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Philadelphia, PA 19103 (215) 563-7000 COUNTRYWIDE HOME LOANS,INC. : COURT OF COMMON PLEAS Plaintiff Vs. WILLIAM G. KEMP LISA M. KEMP Defendants CIVIL DIVISION CUMBERLAND COUNTY :NO. 07-248-CML TERM TO: WILLIAM G. KEMP 748 WEST NORTH STREET CARLISLE, PA 17013 DATE OF NOTICE: FEBRUARY 13, 2007 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 AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 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 PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (800)990-9108 1% a S. HALLINAN, ESQUIRE for Plaintiff PHELAN HALLINAN & SCHMIEG, L.L.P. By: DANIEL G. SCHMIEG Identification No. 62205 ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE Plaintiff, V. WILLIAM G. KEMP LISA M. KEMP Defendant(s). ATTORNEY FOR PLAINTIFF CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION NO. 07-248 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE DANIEL G. SCHMIEG, ESQUIRE, hereby verifies that he is attorney 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 the 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 Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant WILLIAM G. KEMP is over 18 years of age and resides at, 748 WEST NORTH STREET, CARLISLE, PA 17013. (c) that defendant LISA M. KEMP is over 18 years of age, and resides at, 748 WEST NORTH STREET, CARLISLE, PA 17013. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DANIEL G. SCHMIEG, QUIRE Attorney for Plaintiff z w <a O F C? ? 01, W (Rule of Civil Procedure No. 236) - Revised IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COUNTRYWIDE HOME LOANS, INC. 7105 CORPORATE DRIVE CUMBERLAND COUNTY COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION V. NO. 07-248 CIVIL TERM WILLIAM G. KEMP LISA M. KEMP Defendant(s). Notice is given that a Judgment in the above-captioned matter has been entered against you on ciL??2 200 By: If you have any questions concerning this matter, please contact: DANIEL G. SCHMIEG, QUIRE Attorney for Plaintiff ONE PENN CENTER AT SUBURBAN STATION 1617 JOHN F. KENNEDY BLVD., SUITE 1400 PHILADELPHIA, PA 19103-1814 (215) 563-7000 "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 REAFFIRMED, 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." CASE NO: 2007-00248 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS KEMP WILLIAM G ET AL MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon T=MD T.TTT.T.TAM n the DEFENDANT , at 2115:00 HOURS, on the 22nd day of January-, 2007 at 748 WEST NORTH STREET CARLISLE, PA 17013 by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 4.40 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 32.40? 01/23/2007 r? PHELAN HALLINAN SCHMIEG Sworn and Subscibed to By: before me this day D put Sheriff of A.D. SHERIFF'S RETURN - REGULAR CASE NO: 2007-00248 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COUNTRYWIDE HOME LOANS INC VS KEMP WILLIAM G ET AL MARK CONKLIN CARLISLE, PA 17013 Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon =Mn T TL'T M the DEFENDANT , at 2115:00 HOURS, on the 22nd day of January-, 2007 at 748 WEST NORTH STREET WILLIAM KEMP, HUSBAND Sheriff or Deputy Sheriff of by handing to a true and attested copy of COMPLAINT - MORT FORE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 ;?Service .00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 / 16.00/ 01/23/2007 PHELAN HALLINAN SCHMIEG Sworn and Subscibed to ovb By: ;-vv before me this day Dep y heriff of A.D. PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: (List the within matter for the next Argument Court.) CAPTION OF CASE (entire caption must be stated in full) CALABRESE & SONS, INC. VS. LENAPE FORGE, INC. and LENAPE FORGED PRODUCTS CORPORATION No 248 2007 Term 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendant's demurrer to complaint, etc.): Plaintiff's Preliminary Objections to the Amended New Matter 2. Identify all counsel who will argue cases: (a) for plaintiffs: David A. Fitzsimons, Esquire, Martson Law Offices Name and Address) 10 East High Street, Carlisle, PA 17013 (b) for defendants: Steven E. Ostrow, Esquire; Joseph G. Gibbons, Esquire, White &nd Williams (Name and Address) 1800 One Liberty Place, Philadelphia, PA 19103 3. 1 will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: July 9, 2008 By-2 I,jt4? Signature Seth T. Mosebey, Esquire Print your name Plaintiff Date: 6/2/2008 Attorney for INSTRUCTIONS: 1. Two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) before argument. 2. The moving party shall file and serve their brief 12 days prior to argument. 3. The responding party shall file their brief 5 days prior to argument. 4. If argument is continued new briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary) after the case Is relisted. C") r Aa ° C3 r; - --t