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HomeMy WebLinkAbout07-3489GOLDBECK McCAFFERTY & McKEEVER BY: JOSEPH A. GOLDBECK, JR. ATTORNEY LD. #16132 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. TERRI A. SHIRLEY ALAN D. SHIRLEY Mortgagors and Real Owners 213 S. Penn Street Shippensburg, PA 17257 Defendants Term No. CIVIL ACTION: MC?RTCAG~ ~E~~'CI.Q~~URIw 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 the 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 maybe entered against you by the Court without further notice for any money claim in the Complaint of 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 OR CANNOT AFFORD ONE, 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARR DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243- 9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Call the Plaintiff (your lender) at 800-211-6926 and ask to speak to someone about Loss Mitigation or Home Retention options. 5). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a~goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 53167FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE, 505 City Parkway West, Suite 100 Orange, CA 92868. 2. T'he names and addresses of the Defendants are TERRI A. SHIRLEY, 213 S. Penn Street, Shippensburg, PA 17257 and ALAN D. SHIRLEY, 213 S. Penn Street, Shippensburg, PA 17257, who are the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On November 23, 2004 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to AMERIQUEST MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1890, Page 2022. The mortgage has been assigned to: WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property„). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for January O1, 2007 and each month thereafter and by the terms the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$107,839.78 Interest from 12/01/2006 through 06/30/2007 at 9.9900% .... ...................$6,345.15 Per Diem interest rate at $29.93 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$5,391.99 Late Charges from 01/01/2007 to 06/30/2007 ....................... ......................$344.45 Monthly late charge amount at $57.41 Costs of suit and Title Search ................................................ ......................$900.00 Escrow Advance .................................................................... ......................$181.17 Fees ........................................................................................ ........................$60.00 Recoverable Balance .............................................................. ........................$29.25 Monthly Escrow amount $290.84 $121,091.79 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above maybe less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiffdemands a de terris judgment in mortgage foreclosure in the sum of $121,091.79, together with interest at the rate of $29.93, per day and other expenses, costs and charges incurred by the Plaintiffwhich are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property. By. , ~~ L BECK McCAFFERTY & McKEEVER BY: 70SEPH A. GOLDBECK, 7R., ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, j~jy Radom as the representative of the Plaintiff corporation within named do hereby-verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the enalt' s of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: #0100660745 - TERRI A. SHIRLEY and ALAN D. SHIRLEY ._ ~FiiditA • ALt. the following described real estate lying and being situate in the Borough of Shippensburg, Cumberland - Coupty, Pennsylvania, more particularly described as follows: TRACT No. 1: ON the West formerly by an extension of South Penn Street, now South Penn Street, and a public road leading to the farm now or formerly of the Borough of Shippensburg; on the South by lands, being Tract No. 2 herein; on the East by an alley; on the North by a lot of ground now or formerly of Wallace Holtry, said lot having a depth from Penn Street to the alley on the East of 256 feet, more or Less, and in breadth on the West along Penn Street, 50 feet, more or less, whereon now is enacted atwo-story frame weather boarded dwelling house. TRACT No. 2: Being all that certain piece of ground situate on the East side of South Penn Street, and being South of Tract No. 1 herein, as follows; ON the West by South Penn Street; on the South by lands now or formerly of the heirs of William Melly; on the East by an alley; and on the North by Tract No. 1 herein, said lot having a ftontage on South Penn Street of 32 feet, and a depth to the alley of 256 feet, more or less. Parcel #33-34-2415-170 1 Certify this to be recorded 7n Ct.tmberland County PA •:' ~~, K , ~. ~;.~,~ ~• Recorder of Deeds {2004110218.PFD/1004110218/20) 8~ 1890PG2038 ~Fii6it ~ ...._ INIIII~A~I~IIIIIIIVlI 1 1 1 1 1.~; 11 ~ `V MORTGAGE SERVICES 7nne 02, 2006 ALAN D SHIRLEY TERRI A SHIRLEY 213 S PENN ST SHIPPENSBURG, PA 17257 n. ~ .,~ ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE Loan Number: 0100660745 Property Address: 213 S PENN ST, SHIPPENSBURG PA, 17257 Original Lender: AMC Mortgage Services, lnc. Cnrre~ Lender/Servicer: AMC Mortgage Sen~ices, lac. Tffi6 FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOII IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN AND ANY INFORMATION OBTAINED FROM YOII WILL BE IISED FOR THAT PIIRPOSE. IF YOII HAVE PREVIOIISLY RECEIVED A DISCHARGE IN BANHRIIPTCY, TffiS CORRESPONDENCE IS NOT AND SHOIILD NOT BE CONSTRIIED TO BE AN ATTEMPT TO COLLECT A DEBT, BIIT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY. Thin is u official notice that the morttate on'our home is in defaak. ud the knder intends to foreclose. ~ific information abort the natare o[ the de[ult is provided is the attached Hates. The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) ma' be abk to help to save voar home. This Notice eztslains how the protram works. To see if HEMAP can help, •oa mast MEET WITH A CONSIIMER CREDIT COIINSELING AGENCY WITHIN 30 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with von when vos meet with the Counselint Atencv. The name. adders ud phone number of Consamer Credit Cosnedint Atescpes servint voar Cosnty are listed at the end of this Notice. It von have uv questions. von may call the Pennsvlvuia Hossint Finuce Atenev toll free at i-800,342-2397 (Persons with impaired heariat eu call 1717) 7ti0-1869). This Notice contains important legal information. If yon have uy questions, representatives at the Gossamer Credit Connsdins Agency may be able to help a=plain it. Yoe may also vast to contact as attorney is yoar area. The local bar association may be able to hdp yos Find a lawyer. LA NOTIFICACION EN ADJIINTO ES DE SIIMA 1MPORTANCIA, PIIES AFECTA SII DERECHO A CONTINIIAR YIVIENDO EN SII CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA IINA TRADIICCION 1NMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOIISING FINANCE AGENCY) SIN CARGOS AL NIIMERO MENCIONADO E06A"1°16'°` Also doing bnainesa as Delaware AMC Mortgage 5ervicea, Inc., in the stelae of Texas, Rhode Island, and New Hampshire. ARRIBA. PiTEDES SER ELEGIBLE PARR IIN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSLSTANCE PROGRAM" EL CIIAL PIIEDE SALVAR SII CASA DE LA PERDIDA DEL DERECHO A REDl1VIIR SII HIPOTECA. HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOII MAY BE ELIGIBLE FOR FINANCW. ASSISTANCE WffiCH CAN SAVE YOIffR HOME FROM FORECLOSIIRE AND HELP YOII MAKE FIITIIRE MORTGAGE PAYMENTS 1F YOII COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOII MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: z 1F YOIIR DEFAIILT HAS BEEN CAIISED BY CIRCIIMSTANCES BEYOND YOIIR CONTROL, z IF YOII HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOiTR MORTGAGE PAYMENTS, AND x IF YOII MEET OTHER ELIGIBILITY REQIIIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOIISING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSIIRE -Under the Act, yon are entitled to a temporary stay of foreclosure on year mortgage for thirty (30) days from the date of this Notice. Doring that time yon mast arrange and attend a facx-to-face meeting with one a~f the consumer credit counseling agencies listed at the end of this Notice. Tffi3 MEETING MIIST OCCIIR WTTHllN THE NE%T (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. CONSIIMER CREDIT COIINSELING AGENCIES - If yon meet with o~ of the oonsrmer credit oornsei5ng -04encv listed at the end of this notice the lender may NOT take action a~sinst yon 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 property is located are set forth at the end of this Notice. It is only necessary to schefirle one face-to-face meeting. Advise y~r lender immediately of your intentions. APPLICATION FOB MORTGAGE ASSISTANCE -Your mortgage is in a default for the reasons set forth later in this Notice (see folbwing pages for specific information about the nature of your default.) If yon have tried and are unable to resolve this problem with the kndcr, yon have the right to apply for financial assistance from the Homoownet+s Emergency Mortgage Assistance Pmgram. To do so, yon mast fill ort, sign and file a completed Homeownet's Emergency Assistance Program Application with o~ of the designated consumer credit counseling age~les listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program and they will assist yon in submitting a complete application to the Pennsylvania Horsing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOII MIIST FILE YO17R APPLICATION PROMPTLY. IF YOII FAIL TO DO SO OR 1F YOII DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH 1N TffiS LETTE$ FORECLOSIIRE MAY PROCEED AGAINST YOIIR HOME lM1YIEDIATELY AND YOIIR 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 Fimnce Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be prrsued against yon if yon have met the time requirements set forth above. Yon will be notified drrectly by the Pennsylvania Horsing Finance Agency of its decision on your application. Ecow.Yrcriz-as Jane 02, 2006 Loan Number: 0100660745 NOTE: lF YO17 ABE CURRENTLY PROTECTED BY THE FII.ING OF A PETITION IN BANKRIIPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOB INFORMATION PIIRPOSES ONLY AND SHOIILD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (It you have filed buknptcy yon cu still apply for Emergency Mort=age Assistanca) HOW TO CIIRE YOIIR MORTGAGE DEFAIILT Brim it ao to date) NATURE OF THE DEFAULT -The MORTGAGE debt by the above lender on your property located at: 213 S PENN ST, SHIPPENSBURG, PA 17257 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amon~s are now past due: 04/01/06 thra 06/01/06 at 5928.69 per month Monthly Payments plus Iate charge or other fees: 52413.01 Total Amount to Care Defult: 52413.01 B. YOII HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use it not applicable): N/A HOW TO CIIRE THE DEFAIILT -Yon may care the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST D1UE TO THE LENDE$ WHICH IS 52413.01 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments mast be made either by cash cashier's check, certified check or money order made payable ud sem to: AMC Mortgage Sen*ioes SOS City Parkway West, Spite 1f100 Otuge, CA 92868 Yon can care any other default by taking the following action within THIRTY (30) DAYS a~f the date of this letter. (Do not use if not applicable.) N!A IF YOII DO NOT CIIRE THE DEFAIILT-If yon do not care the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to a:ereise its d~lits to accelerate the mort=a=e debt. This means that the entire o~standing baluce of this debt will be considered due immediately and yon may lose the chance to pay the mortgage in momhly installments. If fall payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to inslrad its attorneys to start legal action to foreclose npoi your morttated p~• 1F THE MORTGAGE IS FORECLOSED IIPON -The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. Tf the lender refers your case to ita attorneys. b~ yon care the delinquency before the lender begins legal proceedings against yon. yon w>71 still be required to pay the reasonable attorncy's fees that were actaaliy incurred, np to SS0.00. However, if legal proceedings are started against yon, yon will have to pay all reasonable attorney's foes actually incurred by the lender even if they exceed 550.00. Any attorncy's fees will be added to the amount yon owe the lender, which may 81so inchzde other reasonable costs. If von cure the default within the THIRTY (30) DAY period, you will not be required to pal attorney's fees. OTHER LENDER REMEDIES -The lender may also sae yon persomlly for the unpaid principal baluce and all other sours due ender the mortgage. RIGHT TO CURE THE DEFAIILT PRIOR TO SHERIFF'S SALE - If yon have ~ cured the default within the THIRTY (30) DAY period and foreclosure proccedings have begun, yon still have the right to care the default and prevent the sale at any time np to one hoar before the Sheriffs Sale. Yon may do so by paying the total amount Wen past due plus any late or other charges then due, reasonable attorney's foes and costa coffiocted with the forecbsare sale and any older costs connected with the Sheriff s Sale as specified in writing by the lender and by ~.~.~~-„ performing another reaniremeats ender the mortgage. Caring yoar ddult ist the muner set fortb it this aotice w01 restore yoar mort=ase to the same position as if you bad sever dduked. EARLIEST POSSIBLE SHERIFF'S SALE DATE -- It is estimated that the earliest dale that each a Sheriffs Sale of the mortgaged property cold be held world be approximately (6) MONTHS from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to yon before the sale. Of course, the amount needed to care the default will increase the longer yon wait. Yon may find oat at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER AMC Mort=ase Services 1°O Bo:11000 Suta Asa, CA 92711-1000 Pbone Number 800-430-5262 Fa: Number 714-347-5037 EFFECT OF SHERIF'F'S SALE -Yon should realize that a Sheriffs Sale will end your ownership a~f the mortgaged property and your right to occopy it. If yon continue to live in the property after the Sheriff s Sale, a lawsuit to remove yon and your fnrniahings and other belongings could be started by the lender at a~ time. ASSIIIYIPTION OF MORTGAGE --Yon may or R may not (CHECK ONE) sell or transfer your home to a buyer or transferee who will assmne the mortgage debt, provided that all the ordstanding paymeds, 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. YOII MAY ALSO HAVE THE RIGHT: z 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. z TO HAVE THIS DEFAULT CURID BY ANY THIRD PARTY ACTING ON YOUR BEHALF. z 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 TIINES IN ANY CALENDAR YEAR) z TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCiTMENTS, z TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER z TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSIIMER CgEDIT COIINSELING AGENCIES SERVING YOIIR COIINTY ABE ATTACHED Yery Truly Yours, AMC Mortgage Services Co; AMC Mortgage Services Attn: Collections Department Loan Number: 0100660745 Mailed by 1st Class Mail sad by Certified Mail [vao4xcvYi-ae Homeowners' Emergency Assistance Program CUMBERLAND COUNTY Adams County Interfaith Housing Authority 40 E High Street Gettysburg, PA 17325 (717) 334-1518 CCCS of Western PA 2000 Linglestown Road Harrisburg, PA 17102 1-888-511-2227 Community Action Commission of Captial Region 1514 Derry Street Harrisburg, PA 17104 (717) 232-9757 Loveship, Inc. 2320 North 5th Street Harrisburg, PA 17110 (717) 232-220? Maranatha 43 Philadelphia Avenue Waynesboro, PA 17268 (717) 762-3285 PHFA 211 North Front Street Harrisburg, PA 17110 1-800-342-2397 ~vwailHerlx~as i ,~ N b d n C~, .~ N t_ ~7 .~ ~..._ _:~ ~. W C7 G.7 {~ m _:.j :.~) ti;- _~ : j ~,`T3 '~J -'G ~~ '' CASE NO: 2007-03489 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS SHIRLEY TERRI A ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE SHIRLEY TERRI A the DEFENDANT at 2037:00 HOURS, on the 3rd day of July 2007 at 213 S PENN STREET SHIPPENSBURG, PA 17257 was served upon by handing to ALAN SHIRLEY, HUSBAND 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 19.2 0 °~`", ~''~ ; 6 -~,•%~~ Affidavit .00 ":` '~~~y r Surcharge 10.00 R. T omas Kline .00 ~~~~d7 ~ 47.20 07/05/2007 GOLDBECK MCCAFFERTY MCKEEVER Sworn and Subscibed to By: before me this day Deputy Sh iff of A.D. '+ M CASE NO: 2007-03489 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WM SPECIALTY MORTGAGE LLC VS SHIRLEY TERRI A ET AL GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon SHIRLEY ALAN D the DEFENDANT at 2037:00 HOURS, on the 3rd day of July 2007 at 213 S PENN STREET SHIPPENSBURG, PA 17257 ALAN SHIRLEY 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: Docketing 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 ~,C~i'r ~ C.~,~.. 16.0 0 Sworn and Subscibed to before me this of So Answers: ~..~'' i R. Thomas Kline 07/05/2007 GOLDBECK MCCAFFERTY MCKEEVER By: day Deputy Sher' f A.D. 4 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL MCKEEVER, ESQUIRE Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Mazket Street Philadelphia, PA 19106-1532 215-627-1322 WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE Plaintiff vs. TERRI A. SHIRLEY and ALAN D. SHIRLEY (Mortgagors) and (Record Owners) 213 S. Penn Street Shippensburg, PA 17257 Defendant(s) ATTORNEY FOR PLAINTIFF In the Court of Common Pleas of Cumberland County Civil Action -Law Action of Mortgage Foreclosure Term No. 07-3489 SUGGESTION OF BANKRUPTCY TO THE CLERK OF THE COURT: L7 c na ~ ~ -~~ ~~ ~w ~, c„ ~-~; ~ rn r r~ r- ~D w ;v ~t~ r-- ~ --a o -r- v~ ~ z o m°- c-z ~ C ~, ~,' ~, ~' Please take note that Defendant TERRI A. SHIRLEY and ALAN D. SHIRLEY filed a Chapter 13 Bankruptcy on July 11, 2007 in the United States Bankruptcy Court for the Middle District of Pennsylvania at Case Number 07-02 1 1 8-Middle. Accordingly, the above captioned matter should be deferred until the conclusion of the bankruptcy proceedings. GOLDBECK McCAFFERT & McKEEVER BY: Michael McKeever, Esquire Attorney for Plaintiff r, CERTIFICATE OF SERVICE Michael McKeever, Esquire, hereby certifies that on September 20, 2010 he did serve true and correct copies of the within Suggestion of Bankruptcy by first class mail, postage pre- paid upon the following: TERRI A. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 ALAN D. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 GOLDBECK, McCAFFERTY & McKEEVER BY: G~~~c~c-U~~ Michael McKeever, Esquire Attorney for Plaintiff KML LAW GROUP, P.C. o Ohl lC Suite 5000—BNY Mellon Independence Center s 0 r/1 R 701 Market Street 'EP —3 AM 10: 09 Philadelphia,PA 19106 215-627-1322 PENS CQ1J r Attorney for Plaintiff S YL VA MIA WM SPECIALTY MORTGAGE LLC,WITHOUT RECOURSE 505 City Parkway West IN THE COURT OF COMMON PLEAS Suite 100 Orange,CA 92868 OF Cumberland COUNTY Plaintiff vs. CIVIL ACTION—LAW TERRI A. SHIRLEY ACTION OF MORTGAGE FORECLOSURE ALAN D. SHIRLEY (Mortgagor(s)and Record Owner(s)) 213 S.Penn Street No.07-3489 Shippensburg,PA 17257 Defendant(s) PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF UNDER Pa.R.C.P.2352 TO THE PROTHONOTARY: Kindly file of record the Praecipe of JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC for Voluntary Substitution under Pa.R.C.P. 2352 due to change of name and attached Statement of Material Facts in Support of Voluntary Substitution,Verification, Certification of Service. The address for the new Plaintiff is JPMC SPECIALTY MORTGAGE,LLC, F/K/A WM SPECIALTY MORTGAGE,LLC. By: KML LWGAW,Michael 6129 Jay E.Kivitz Pa. ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Till P.Jenkins Pa.ID 306588 Ml , 9 SQ pd Q9 Alyk L.Oflazian Pa.ID 312912 / Attorneys for Plaintiff 7 9 Sg y' ags►y� KML LAW GROUP,P.C. Suite 5000–BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff WM SPECIALTY MORTGAGE LLC,WITHOUT RECOURSE IN THE COURT OF COMMON PLEAS 505 City Parkway West Suite 100 OF Cumberland COUNTY Orange,CA 92868 Plaintiff CIVIL ACTION–LAW VS. ACTION OF MORTGAGE FORECLOSURE TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s)and Record Owner(s)) No.07-3489 213 S.Penn Street Shippensburg,PA 17257 Defendant(s) STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.R.C.P.2352 JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC, by counsel,hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: I. The above-captioned Action of Mortgage Foreclosure relates to a property located at 213 S.Penn Street Shippensburg,PA 17257("Property"). 2. Plaintiff holds a mortgage on the Property which is recorded at Mortgage Book 1890,Page 2022 in the Office of the Recorder of Deeds for Cumberland County. 3. The original Plaintiff in this action is WM SPECIALTY MORTGAGE LLC,WITHOUT RECOURSE. 4. JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC is the successor in interest due to change of name of Plaintiff and is hereby voluntarily substituted as Plaintiff in the above-captioned matter. Respectfully submitted, By: KML LAW v;G .C. Michael Mcke!er P MID 56129 —Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 -David Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 _Jill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Attorneys for Plaintiff KML LAW GROUP, P.C. SUITE 5000—BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 215-627-1322 ATTORNEY FOR PLAINTIFF WM SPECIALTY MORTGAGE LLC, WITHOUT RECOURSE 505 City Parkway West TINTBE T OF COMMON PLEAS Suit e 100 Orange, CA 92868 erland COUNTY Plaintiff CTION-LAW vs.TERRI A. SHIRLEY OF MORTGAGE ALAN D. SHIRLEY FORECLOSURE (Mortgagor(s)and Record Owner(s)) Term 213 S. Penn Street No. 07-3489 Shippensburg,PA 17257 Defendant(s) CERTIFICATE OF SERVICE Doris Guzman, hereby certifies that he/she did serve true and correct copies of Praecipe for Voluntary Substitution and all supporting papers attached hereto upon Defendant, by first class mail,postage pre-paid, on .A ( l 13 TERRI A. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 ALAN D. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 By: KML aw roup,P.C. Barbara Hand,Legal Assistant bhand@kmllawgoup.com 215-825-6320(Direct Phone) In the Court of Common Pleas of Cumberland County JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM M tl SPECIALTY MORTGAGE,LLC a l 505 City Parkway West CDT Suite 100 No.07-343 Orange,CA 92868 C-) Plaintiff =o � vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s)and Record Owner(s)) 213 S.Penn Street Shippensburg,PA 17257 Defendant(s) PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against TERRI A. SHIRLEY and ALAN D. SHIRLEY by default for want of an Answer. Assess damages as follows: $209,003.29 Debt Interest from 8/21/2013 to Date of Sale per diem at$29.93 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or deliver,11 to the party against whom judgment is to be entered and to his attorney of record,if any,after the defa=ce a ast ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P.23 By: KML LA P, _Michael Mc ever Pa.ID 56129 Jay E.Kivitz Pa ID 26769 _Lisa Lee Pa.ID 78020 \ S C Kristina Murtha Pa.ID 61858 _David Fein Pa.ID 82628 L c _Thomas Puleo Pa.ID 27615 C F► �415R09 V Q 09 Joshua I.Goldman Pa.205047 Jill Jenkins Pa.ID \ _Andrere w F.Gornall Pa..ID ID 92 92382 Attorneys for Plaintiff AND NOW Se Z�6 13 ,Judgment is entered in favor of JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC@iLnd against TERRI A. SHIRLEY and ALAN D. SHIRLEY by default for want of an Answer and damages assessed in the s of 003. per the above certification. Prothono Rule of Civil Procedure No.236—Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,PENNSYLVANIA CIVIL ACTION-LAW JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC 505 City Parkway West Suite 100 Orange,CA 92868 Plaintiff No.07-3489 vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagors and Record Owner(s)) 213 S.Penn Street Shippensburg,PA 17257 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D.Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle,PA 17013 Prothonotary By: Deputy If you have any questions concerning the above,please contact: KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 53167FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE`� D FROM YOU WILL COLLECT B LU ED FOR THE OWED TO OUR CLIENT.ANY INFORMATION POSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: August 8,2013 TO: TF.RPJ A.SIMLEY 213 S.Penn Street Shippensburg,PA 17257 In the Court of Common Pleas WM SPECIALTY MORTGAGE LLC,WITHOUT RECOURSE of Cumberland County .505 City Parkway West Suite 100 CIVIL ACTION-LAW Orange,CA 92868 Plaintiff VS. Action of TERRI A:SHIRLF,Y Mortgage Foreclosure ALAN D.SHIRLEY (Mortgagor(s)and Record Owner(s)) No.07-3489 213 S.Penn Street Shippensburg,PA 17257 Defendant(s) TO: TERRI A.SHlltLEY 213-S.Penn Street Shippensburg,PA 17257 nVVWORTANT NOTICE WRITTEN YOU ARE IN DEFAULT BECAUSE YOU HAT F O T YOUR DEFENSES OR OBJEC"IIIO S TO TBE LAMA OR BY ATTORNEY AND FILE IN WRITING WITH SET FORTH AGAINST YOU. UNLESS YOU WITtHOUT A BEARING ANDY U MAY D SE YOUR THIS PROPERTY OR JUDGMENT MAY BE ENTERED AGAINST YOU OTHER IMPORTANT RIGHTS- YOU SHOULD FFI THIS ET FORTH B L W. THI OFFICE CAN PROVIDE YOU WITH HAVE A LAWYER,GO TO OR TELEPHONE THE INFORMATION ABOUT HIRING A LAWYER- ON ABOUT AGENCIES THAT MAY OFFER�LEGIALO SERVICES TO ABLE TO PROVIDE YOU WITH INFO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC A Irvine Row Carlisle,PA 17013 717-243-9400 By: KML LAW ROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.11D 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Ji11 P.Jenkins Pa.1D 306588 2 fZk L.Otlazian Pa.ID 312912 Salvatore Filippello Pa.lD 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff 53I67FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEIST. DATE OF TIIIS NOTICE: August 8,2413 TO: ALAN D.SHIRLEY 213 S.Perm Street Shippensburg,PA 17257 In the Court of WM SPECIALTY MORTGAGE LLC,WITHOUT RECOURSE Common Pleas 505 City Parkway West of Cumberland County Suite 100 Orange,CA 92868 Plaintiff CIVIL ACTION-LAW vs. TERRI A.SHIRLEY Action of ALAN D. SHIRLEY Mortgage Foreclosure (Mortgagor(s)and Record Owner(s)) 213 S.Penn Street No.07-3489 Shippensburg,PA 17257 Defendant(s) TO: ALAN D.SIIIRLEX 213 S.Penn Street Shippensburg,PA 17257 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 (10) DAYS FROM THE DATE OF TIRS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSF,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. CUMBFRLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SFRVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 By: , KML LAW GROUP,P.C. Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Pulco Pa.ID 27615 ill P.Jenkins Pa.ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello Pa.ID 313897 Michael J.Coskey Pa ID 311835 215-627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC Plaintiff vs. NO.07-3489 TERRI A.SHIRLEY ALAN D.SHIRLEY Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group,P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https://www.dmdc.osd mil/a */scra/scraHome do) for the following individual(s): TERRI A. SHIRLEY, has a last known residence of 213 S. Penn Street, Shippensburg, PA 17257. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X_Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 490 rela 'ng to unsworn falsification to t rities Date By: KML LAW OUP,PLt. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gomall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff :51:26 Department of Defense Manpower Data Center Results as of:Aug-20-2013 50 SCRA 3.0 Status Repun €t ;` Pursuant to;service-members Civil lief Act Last Name: SHIRLEY First Name: TERRI Middle Name: A. Active Duty Status As Of: Aug-20-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA r No NA This response reflects the individuate active duty status based on the Active Duty Status Date t Left Active Duty Within 367 Days of Active Duty Status Date Active Duly Start Date Active Duty End Date Status Service Component NA NA t - No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or Hie/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Nolifiication Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual orhis/her unit has received early notiflcatiori to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. 0112 Fit Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 i I The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil"URL:hftp://www.defenselink.mil/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 387 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Carps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: W4J2H6E3V021440 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC Plaintiff VS. NO.07-3489 TERRI A.SHIRLEY ALAN D.SHIRLEY Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEM13ERS CIVIL RELIEF ACT AS AMENDED L The undersigned attorney with KML Law Group,P.C., as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(hops://www.dmdc.osd.mil/appi/scra/scraHome.do) for the following individual(s): ALAN D. SHIRLEY, has a last known residence of 213 S. Penn Street, Shippensburg, PA 17257. The following information was used to search the DMDC (check all that apply): • Last Name • First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 490�rely to unsworn falsification to aut Zorities. Date By: KMM LAW GIV Michael Mc eever a.ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 -David Fein Pa. ID 82628 Thomas Puleo Pa.ID 27615 Jay Kivitz Pa. ID 26769 -Andrew Gomall Pa. ID 92382 Joshua I. Goldman Pa. ID 205047 Salvatore Filippello Pa. ID 313897 Y--Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff Department of Defense Manpower Data Center Results as of:Aug-20.201350:32:31 SCRA 3.0 status Repolt Pursuant to Scrviccmeo ben Civil Relief Act Last Name: SHIRLEY First Name: ALAN Middle Name: D. Active Duty Status As Of: Aug-20-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date status Service Component NA NA r No NA This response reflects the individuals'active duty status based on the Active Duty Status Date t ` t Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA - - No NA This response reflects where the individual left active status within 387 days preceding the Active Duty Status Date _ f The Member or His/Her Unit Was Notified of a Future Cali-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA N. No NA This response reflects whether the individual or histher unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Xh, tr Mary M.Snavety-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 The Defense Manpower Data Center(DMDC)is an organization of the Department of Defense(DoD)that maintains the Defense Enrollment and Eligibility Reporting System(DEERS)database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'and Sailors'Civil Relief Act of 1940). DMDC has issued hundreds of thousands of"does not possess any information indicating that the individual is currently on active duty"responses,and has experienced only a small error rate. In the event the individual referenced above,or any family member,friend,or representative asserts in any manner that the individual was on active duty for the active duty status date,or is otherwise entitled to the protections of the SCRA,you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mii"URL:hftp://www.defenselink.mif/faq/pis/PC09SLDR.htmi. If you have evidence the person was on active duty for the active duty status date and you fail to obtain this additional Service verification,punitive provisions of the SCRA may be invoked against you. See 50 USC App.§521(c). This response reflects the following information: (1)The individual's Active Duty status on the Active Duty Status Date(2)Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date(3)Whether the individual or his/her unit received early notification to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(f)for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARS),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration(NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA,as defined in accordance with 10 USC§101(d)(1). Many times orders are amended to extend the period of active duty,which would extend SCRA protections.Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name,SSN/date of birth,and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: 646AD593KOE5HFO KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC IN THE COURT OF COMMON PLEAS 505 City Parkway West Suite 100 of Cumberland County Orange,CA 92868 Plaintiff vs. CIVIL ACTION LAW TERRI A. SHIRLEY ALAN D. SHIRLEY ACTION OF MORTGAGE FORECLOSURE (Mortgagor(s)and Record owner(s)) 213 S.Penn Street Shippensburg,PA 17257 No.07-3489 Defendant(s) ORDER FOR JUDGMENT Please enter Judgment in favor of JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC,and against TERRI A. SHIRLEY and ALAN D. SHI EY for failur to file an Answer in the above action within(20)days from the date of service of the Complaint, in'The s f 2 003. By: 11� 61"111 14 - I All ifill t, KML LAW G Michael McKe ver Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC 505 City Parkway West Suite 100 Orange,CA 92868 and that the name(s)and last known address(es)of th�,bFfendait( )is/ e TERRI A. SHIRLEY,213 S. I s' Penn Street Shippensburg,PA 17257 and ALAN D. SHIRLEY,213 S.P S eet Shlppe urg,PA 17257; By:_ n�)71 KML LAW U)kbdl, Michael McKeever Pa.r56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristin Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 --r--Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $107,839.78 Interest from 12/01/2006 through $73,478.14 08/20/2013 Reasonable Attorney's Fee $1,300.00 Late Charges $4,592.79 Escrow Payments Due 74 X$290.84 $21,522.16 Escrow Advance $181.17 Fees $60.00 Recoverable Balance $29.25 $2@9 00 .29 r By: KML LA 'G ,P. . Michael Keever Pa.ID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua 1. Goldman Pa.205047 )Gill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff AND NOW,this day of ,2013 damages are assessed as above. q Pro Prot y 07-3489/53167FC a W C/i f's"f r = 'O r d PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOS ! 'cam P.R.C.P 3180-3183 r—C' KML Law Group,P.C. =CD Suite 5000-BNY Independence Center 701 Market Street w Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC 505 City Parkway West IN THE COURT OF COMMON PLEAS Suite 100 Orange, CA 92868 of Cumberland County Plaintiff vs. CIVIL ACTION—LAW TERRI A. SHIRLEY ACTION OF MORTGAGE FORECLOSURE ALAN D. SHIRLEY CD Mortgagor(s)and Record Owner(s) 213 S.Penn Street ' No. 07-3489 , ^T Shippensburg,PA 17257 rte►a 4c/) ITl w Defendant(s) —q �3 Cc CD CD n PRAECIPE FOR WRIT OF EXECUTION =.C, r~ TO THE PROTHONOTARY: � w --c Issue Writ of Execution in the above matter: Amount Due $209,003.29 Interest from 8/21/2013 to Date of Sale per diem at $29.93 (Costs to be added) Jj ` By: n } KML LA 0eeverP4a. ;56129 C 20 � Michael �� Jay E.Kivitz Pa.ID 26769 d� Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 •Sb�► David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 • Q Joshua 1.Goldman Pa.205047 '��•Of) Jill P.Jenkins Pa.ID 306588 �a�S. drew F. Gornall Pa.ID 92382 •�l.V ttorneys for Plaintiff No. 07-3489 IN THE COURT OF COMMON PLEAS JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC vs. TERRI A. SHIRLEY and ALAN D. SHIRLEY (Mortgagor(s)and Record Owner(s)) 213 S.Penn Street Shippensburg,PA 17257 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) KML Law Group,P.C. Attorney for Plaintiff KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 i� ALL the following described real estate lying and being situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more particularly described as follows: TRACT No. 1: ON the West formerly by an extension of South Penn Street,now South Penn Street, and a public road leading to the farm now or formerly of the Borough of -Shippensburg; on the South by lands, being Tract No. 2 herein; on the East by an alley; on the North by a lot of ground now or formerly of Wallace Holtry, said lot having a depth from Penn Street to the alley on the East of 256 feet,more or less, and in breadth on the West along Penn Street, 50 feet, more or less,whereon now is erected a two-story frame weather boarded dwelling house. TRACT No.2: Being all that certain piece of ground situate on the East side of South Penn Street, and being South of Tract No. I herein, as follows; ON the West by South Penn Street; on the South by lands now or formerly of the heirs of William Meily; on the East by an alley; and on the North by Tract No. I herein, said lot having a frontage on South Penn Street of 32 feet, and a depth to the alley of 256 feet,more or less. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Borough of Shippensburg BEING PREMISES: 213 S. Penn Street Shippensburg PA 17257 SOLD as the property of ALAN D. SHIRLEY and TERRI A. SHIRLEY,husband and wife TAX PARCEL#33-34-2415-170 BEING the same premises which Marion G. Reeder, single woman by deed dated 7/5/99 and recorded 8/2/99 in Cumberland County in Deed Book Volume 205 at Page 39 granted and conveyed unto Alan D. Shirley And Terri A. Shirley,his wife AqWi KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street FI ED-O FIC(7 Philadelphia,PA 19106 .�� THE �R of H otq.D TA JR tit. 215-627-1322 ,�� Attorney for Plaintiff `3 AM 10- 3 JPMC SPECIALTY MORTGAGE,LLC,K44NUTOUNTY SPECIALTY MORTGAGE,LLC YLW NIA, IN THE COURT OF COMMON PLEAS 505 City Parkway West Suite 100 of Cumberland County Orange, CA 92868 Plaintiff vs. CIVIL ACTION-LAW TERRI A. SHIRLEY ALAN D. SHIRLEY ACTION OF MORTGAGE FORECLOSURE (Mortgagor(s)and Record Owner(s)) 213 S. Penn Street Shippensburg, PA 17257 Defendant(s) No. 07-3489 AFFIDAVIT PURSUANT TO RULE 3129 JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC,Plaintiff in the above action,by counsel,KML Law Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 213 S.Penn Street Shippensburg,PA 17257 LName and address of Owner(s)or Reputed Owner(s): TERRI A. SHIRLEY 213 S.Penn Street Shippensburg,PA 17257 ALAN D. SHIRLEY 213 S.Penn Street Shippensburg,PA 17257 2.Name and address of Defendant(s)in the judgment: TERRI A. SHIRLEY 213 S.Penn Street Shippensburg,PA 17257 ALAN D. SHIRLEY 213 S.Penn Street Shippensburg,PA 17257 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 213 S.Penn Street Shippensburg,PA 17257 1 verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false state ents herein are made subject to the penalties of 18 Pa.C.S. Section,904 relating to unsworn falsification to authorities. DATED: <� r7)1 Z' By: KMLLAW,4A0UJF',71VC. Michael MclZeever Pa.VID 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Till P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff r . t 07-3489 KML Law Group,P.C. .r i11 E-J) Suite 5000-BNY Independence Center 701 Market Street �`Q ��j TA h'y Philadelphia,PA 19106 3 SEP —3 � + (215)627-1322 f Attorney for Plaintiff $ER(. frD Coiwrt JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM A CIA SPECIALTY MORTGAGE,LLC IN THE COURT OF COMMON PLEAS 505 City Parkway West Suite 100 of Cumberland County Orange, CA 92868 Plaintiff CIVIL ACTION-LAW vs. ACTION OF MORTGAGE TERRI A. SHIRLEY FORECLOSURE ALAN D. SHIRLEY Mortgagor(s)and Record Owner(s) 213 S.Penn Street Shippensburg, PA 17257 Docket No. 07-3489 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SHRLEY,TEM A. TERRI A. SHIRLEY 213 S.Penn Street Shippensburg,PA 17257 Your house at 213 S.Penn Street,Shippensburg,PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday;December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$209,003.29 obtained by JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC,the back payments,late charges,costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 07-3489 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale.(See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the ftill amount due in the sale.To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the fall amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hLtp://www.philadelphiafed.orgiforeclosure 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 07-3489 Resources available for Homeowners in Foreclosure ACT NOW! , Even though your lender(and our client)has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website, http://www.phfa.org/consumers/homeowners/real.aWx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentiongkmllawgroui).com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 53167FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. , r i-4 07-3489 KML Law Group,P.C. OF FILED-OF w r, Suite 5000-BNY Indpendence Center � �- P ©TH�f�< C1Pd�TA R, 701 Market Street ��i t'� Philadelphia,PA 19106 ' SEP "3 AN la. P 4 (215)627-1322 Attorney for Plaintiff DER�4IUD C� NIA JPMC SPECIALTY MORTGAGE,LLC,F/K/A SPECIALTY MORTGAGE,LLC IN THE COURT OF COMMON PLEAS 505 City Parkway West Suite 100 of Cumberland County Orange,CA 92868 Plaintiff CIVIL ACTION-LAW vs. ACTION OF MORTGAGE TERRI A. SHIRLEY FORECLOSURE ALAN D. SHIRLEY Mortgagor(s)and Record Owner(s) 213 S. Penn Street Shippensburg,PA 17257 Docket No. 07-3489 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SHIRLEY,ALAN D. ALAN D. SHIRLEY 213 S.Penn Street Shippensburg,PA 17257 Your house at 213 S.Penn Street, Shippensburg,PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$209,003.29 obtained by JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. i 07-3489 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriff s Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: hqp://www.philadelphiafed.org/foreclosure/ 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 07-3489 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default..Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentiongkmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 5316717C. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 2007-3489 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMC SPECIALTY MORTGAGE,LLC,F/K/A WM SPECIALTY MORTGAGE,LLC Plaintiff(s) From TERRI A. SHIRLEY,ALAN D.SHIRLEY (1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL DESCRIPTION. (2) You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: and to notify the garnishee(s)that: (a)an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant (s)or otherwise disposing thereof; (3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due: $209,003.29 L.L.: $.50 Interest FROM 8/21/13 TO DATE OF SALE PER DIEM AT$29.93 Atty's Comm: Due Prothy: $2.25 Atty Paid:$196.20 Other Costs: Plaintiff Paid: Date: SEPTEMBER 3,2013 �J4� David D.Buell,Prothonota (Seal) Deputy REQUESTING PARTY: Name:JILL P.JENKINS,ESQUIRE Address: KML LAW GROUP,P.C. 701 MARKET STREET SUITE 5000-BNY INDEPENDENCE CENTER PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 306588 wrr►vu-r CCv(42Sl,;- 0�- 3 8 vs Case No. -TttZ� A 5A lg.LEV 4,v,)-N ALAS A 5XLI�j zz; r1i Statement of Intention to Proceed :` <� C:) To the Court: G -c:>�.... intends to roceed w' h the above captioZdMattgr-, -, Print Name Sign Name Date: Attorney for �GA-I Al Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. I.Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v.Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision(a)of that rule continues to be applicable. II Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court.'After giving notice of intent to terminate an action for inactivity,the course of the procedure is with the parties. If the parties do not wish to pursue the case.they will take no action and"the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter,he or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Rule230(d)for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket,subdivision(d)(2)provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision(d)(3)requires that the plaintiff must make a showing to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision(d)(2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2. Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY r--or r pt ciinottv . OFfICEOF !<E sE 1 e 1 3: ,,J L CUMBERLAND COUNTY PENI SYLVA}flA JPMC Specialty Mortgage LLC vs. Terri A Shirley (et al.) Case Number 2007 -3489 SHERIFF'S RETURN OF SERVICE 09/23/2013 12:04 PM - Deputy Jason Kinsler, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 213 South Penn Street, Shippensburg - Borough, Shippensburg, PA 17257, Cumberland County. 11/22/2013 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 2/5/2014 01/15/2014 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/9/2014 03/31/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed ", per letter of instruction from Attorney. SHERIFF COST: $944.29 SO ANSWERS, March 31, 2014 R NY R ANDERSON, SHERIFF c.C.6 j/ 303 PAS` c) auntySute Sheri eleosoft. ''KML Law Group, P.C., Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106 215- 627 -1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE, LLC, F/K/A WM SPECIALTY MORTGAGE, LLC 505 City Parkway West Suite 100 Orange, CA 92868 vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s) and Record Owner(s)) 213 S. Penn Street Shippensburg, PA 17257 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE AFFIDAVIT PURSUANT TO RULE 3129 No. 07 -3489 JPMC SPECIALTY MORTGAGE, LLC, F/K/A WM SPECIALTY MORTGAGE, LLC, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 213 S. Penn Street Shippensburg, PA 17257 1.Name and address of Owner(s) or Reputed Owner(s): TERRI A. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 ALAN D. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 2. Name and address of Defendant(s) in the judgment: TERM A. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 ALAN D. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 3. Name6and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105 -2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS /OCCUPANTS 213 S. Penn Street Shippensburg, PA 17257 I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I understand that false state ents herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. �9 DATED: KML LAW i RO , ..C. Michael Mc eever Pa. 1P 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gomall Pa. ID 92382 Attorneys for Plaintiff KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627 -1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE, LLC, F/K/A SPECIALTY MORTGAGE, LLC IN THE COURT OF COMMON PLEAS 505 City Parkway West Suite 100 of Cumberland County Orange, CA 92868 Plaintiff CN1L ACTION - LAW 07 -3489 vs. ACTION OF MORTGAGE TERRI A. SHIRLEY FORECLOSURE ALAN D. SHIRLEY Mortgagor(s) and Record Owner(s) 213 S. Penn Street Shippensburg, PA 17257 Docket No. 07 -3489 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SHIRLEY, TERRI A. TERRI A. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 Your house at 213 S. Penn Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, December 04, 2013, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $209,003.29 obtained by JPMC SPECIALTY MORTGAGE, LLC, F/K/A WM SPECIALTY MORTGAGE, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMC SPECIALTY MORTGAGE, LLC, F /K/A WM SPECIALTY MORTGAGE, LLC, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215- 825 -6329 or 1- 866 - 413 -2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 07 -3489 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of 717- 240 -6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd out if this has happened, you may call the Sheriff of 717 - 240 -6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http:// www. philadelphiafed .org/foreclosure/ 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717- 243 -9400 07-3489 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 2 15-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 53167FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 07-3489 KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE, LLC, F/K/A SPECIALTY MORTGAGE, LLC IN THE COURT OF COMMON PLEAS 505 City Parkway West Suite 100 of Cumberland County Orange, CA 92868 Plaintiff CIVIL ACTION - LAW VS. ACTION OF MORTGAGE TERRI A. SHIRLEY FORECLOSURE ALAN D. SHIRLEY Mortgagor(s) and Record Owner(s) 213 S. Penn Street Shippensburg, PA 17257 Docket No. 07-3489 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFFS SALE OF REAL PROPERTY TO: SHIRLEY, ALAN D. ALAN D. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 Your house at 213 S. Penn Street, Shippensburg, PA 17257 is scheduled to be sold at Sheriffs Sale on Wednesday, December 04, 2013, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $209,003.29 obtained by JPMC SPECIALTY MORTGAGE, LLC, F/K/A WM SPECIALTY MORTGAGE, LLC against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMC SPECIALTY MORTGAGE, LLC, F/K/A WM SPECIALTY MORTGAGE, LLC, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 07 -3489 3. You, may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on bow to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may fmd out the price bid price by calling the Sheriff of 717- 240 -6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717 - 240 -6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http: / /www. phi ladelphiafed.org /foreclosure/ 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 LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717 - 243 -9400 07-3489 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at hOmeretention@kmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 53167FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL the following described real estate lying and being situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more particularly described as follows: TRACT No. 1: ON the West formerly by an extension of South Penn Street, now South Penn Street, and a public road leading to the farm now or formerly of the Borough of Shippensburg; on the South by lands, being Tract No. 2 herein; on the East by an alley; on the North by a lot of ground now or formerly of Wallace Holtry, said lot having a depth from Penn Street to the alley on the East of 256 feet, more or less, and in breadth on the West along Penn Street, 50 feet, more or less, whereon now is erected a two-story frame weather boarded dwelling house. TRACT No.2: Being all that certain piece of ground situate on the East side of South Penn Street, and being South of Tract No. 1 herein, as follows; ON the West by South Penn Street; on the South by lands now or formerly of the heirs of William Meily; on the East by an alley; and on the North by Tract No. 1 herein, said lot having a frontage on South Penn Street of 32 feet, and a depth to the alley of 256 feet, more or less. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Borough of Shippensburg BEING PREMISES: 213 S. Penn Street Shippensburg PA 17257 SOLD as the property of ALAN D. SHIRLEY and TERRI A. SHIRLEY, husband and wife TAX PARCEL #33-34-2415-170 BEING the same premises which Marion G. Reeder, single woman by deed dated 7/5/99 and recorded 8/2/99 in Cumberland County in Deed Book Volume 205 at Page 39 granted and conveyed unto Alan D. Shirley And Terri A. Shirley, his wife LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2007-3489 Civil Term JPMC SPECIALTY MORTGAGE LLC vs. TERRI A. SHIRLEY, Alan D. Shirley Atty.: Alan D. Shirley ALL the following described real estate lying and being situate in the Borough of Shippensburg, Cumber- land County, Pennsylvania, more particularly described as follows: TRACT No. 1: ON the West for- merly by an extension of South Pe Street, now South Peim Street, and a public road leading to the farm now or formerly of the Borough of Ship- pensburg; on the South by lands, being Tract No. 2 herein; on the East by an alley; on the North by a lot of ground now or formerly of Wallace Holtry, said lot having a depth from Penn Street to the alley on the East of 256 feet, more or less, and in breadth on the West along Penn Street, 50 feet, more or less, whereon now is erected a two-story frame weather boarded dwelling house. TRACT No.2: Being all that certain piece of ground situate on the East side of South Penn Street, and be- ing South of Tract No. 1 herein, as follows; ON the West by South Penn Street; on the South by lands now or formerly of the heirs of William Melly; on the East by an alley; and on the North by Tract No. 1 herein, said lot having a frontage on South Penn Street of 32 feet, and a depth to the alley of 256 feet, more or less. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Borough of Ship- pensburg. BEING PREMISES: 213 5. Penn Street Shippensburg PA 17257. SOLD as the property of ALAN D. SHIRLEY and TERM A. SHIRLEY, husband and wife. TAX PARCEL #33-34-2415-170. 109 BEING the same premises which Marion G. Reeder, single woman by deed dated 7/5/99 and recorded 8/2/99 in Cumberland County in Deed Book Volume 205 at Page 39 granted and conveyed unto Alan D. Shirley And Tern A. Shirley, his wife. PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss• COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 11, October 18 and October 25, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation,' and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. jisa Marie Coyne Editor SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Patriot-News Co' 2020 Technology Pkwy 5uite��� Mechanicsburg, PA 17050 Inquiries -717-255-8n'13 CUMBERLAND CO. SHERFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 Zhe atriogews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth af Pennsylvania, Courty of Dauphin} ss 'Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300. in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th. 1949, respectively, and aU have been continuously pubHshed ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauph n in Miscellaneous Book "M", Volume 14, Page 317. �--_----'—__-_ LLC vs. Alan 0 Shirley • Any; Alan D Shirley ALL the following described real estate 15ing and being situate in the Borough of Shippensburg, Cumberland County, Pennsylvania, more particularly described as TRACT No. 1: ON the West formerly by an extension of South Pe Street, now South '-- —, -- a public road leading to the farm now or fomierly of the Borough of oN, Shippensburg; on the South by lands, being ;p 11-act No. 2 herein; on the East by an alley; on td the North by a lot of ground now or formerly J of Wallace Holtry, said lot having a depth g from Penn Street to the afley on the East of ,j 256 feet, more or )ess, and itt breadth on the o West along Peno Street, 50 feet, more or Iess, n whereon now is erected a two-st frame o weather boarded dwelling house. TRACT j No.2: BeiBeing all that certain pie� of ground n siluate on the � and ociouSoRth of 'Big������*��x on the South by lands now or formerly of the heirs of William Meily; on the East by an This ad ran on the date(s) shown below: 10/13/13 10/20/13 10/27/13 Sworn o and subscribed before m his 1 day of Nove ber, 20 ublic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Tvvp., Dauphin County A.D. KML LAW GROUP, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff 2114 /f4 elk/1i NHS L Vq,11 ��/ },. JPMC SPECIALTY MORTGAGE, LLC, F/K/A WM SPECIALTY MORTGAGE, LLC 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s) and Record owner(s)) 213 S. Penn Street Shippensburg, PA 17257 TO THE PROTHONOTARY: Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County PRAECIPE TO VACATE JUDGMENT Kindly vacate the judgment upon payment of your costs only. By: No. 07-3489 �L LAGROUP, P.C. Mic ael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello, Attorney ID 313897 Attorneys for Plaintiff Q n41- q.apd a) 004 KML LAW GROUP, P.C. SUITE 5000 — BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 ATTORNEY FOR PLAINTIFF JPMC SPECIALTY MORTGAGE, LLC, F/K/A WM SPECIALTY MORTGAGE, LLC Plaintiff vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s) and Record Owner(s)) Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-3489 CERTIFICATE OF SERVICE Angela M. Smith , hereby certifies that he/she did serve true and correct copies of Praecipe to Vacate Judgment and all supporting papers attached hereto upon Defendant, by first class mail, postage pre -paid, on LI 021—ley TERRI A. SHIRLEY 157 W. Louther St. Carlisle, PA 17013 ALAN D. SHIRLEY 157 W. Louther St. Carlisle, PA 17013 TERRI A. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 ALAN D. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 By: KML LA GROUP, P.C. Angela M. Smith , Legal Assistant asmith@kmllawgroup.com 215-825-6325 (Direct Phone) KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 ry ii �!•:..._,1���. Fri 27 P , JPMC SPECIALTY MORTGAGE, LLC, F/K/A WM SPECIALTY MORTGAGE, LLC 505 City Parkway West Suite 100 Orange, CA 92868 Plaintiff vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s) and Record owner(s)) 213 S. Penn Street Shippensburg, PA 17257 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 07-3489 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER 600 By: chael McKeever Pa. ID 56129 ay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello, Pa. ID 313897 Jennifer Lynn Frechie, Pa. ID 316160 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106 (215) 627-1322 Attorney for Plaintiff JPMC SPECIALTY MORTGAGE, LLC, F/KIA WM SPECIALTY MORTGAGE, LLC Plaintiff vs. TERRI A. SHIRLEY ALAN D. SHIRLEY (Mortgagor(s) and Record Owner(s)) Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 07-3489 CERTIFICATE OF SERVICE Angela M. Smith , hereby certifies that he/she did serve true and correct copies of Praecipe to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class mail, postage pre -paid, on TERRI A. SHIRLEY 157 W. Louther St. Carlisle, PA 17013 ALAN D. SHIRLEY 157 W. Louther St. Carlisle, PA 17013 TERRI A. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 ALAN D. SHIRLEY 213 S. Penn Street Shippensburg, PA 17257 KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & By: KEEVER Ange f . Smith , Lega Assistant asmith@kmllawgroup.com 215-825-6325 (Direct Phone)