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Home My WebLink About08-56740/ , GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866)413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF WASHINGTON MUTUAL BANK S/B/M PNC MORTGAGE CORPORATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. REID III Mortgagors and Real Owners 2201 Pine Road Newville, PA 17241 Term 01'V' No. Q f ' <& 7(-( CIVIL ACTION: MORTGAGE NOTICE FORF-CLOSURE 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 may be 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. Defendants CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 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. PARA 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. 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT Y 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 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 htip://www.phfa.orp-/consumers/homeowners/real.asi)x. 5). Call the Plaintiff (your lender) at 866-926-8937 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 homeretentionna 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 65802FC. 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 WASHINGTON MUTUAL BANK S/B/M PNC MORTGAGE CORPORATION, 7255 Baymeadows Way, Jacksonville, FL 32256. 2. The names and addresses of the Defendants are JAMES L. REID III, 2201 Pine Road, Newville, PA 17241, who is the mortgagors and real owners of the mortgaged premises hereinafter described. 3. On December 16, 1994 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to WASHINGTON MUTUAL BANK S/B/M PNC MORTGAGE CORPORATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1919, Page 0522. 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 01, 2008 and each month thereafter and by the terms of 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 .......................................................................... ..$46,577.78 Interest from 12/01/2007 through 07/31/2008 at 8.2500% .......................$2,566.87 Per Diem interest rate at $10.52 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$2,328.89 Late Charges from 01/01/2008 to 07/31/2008 .............................................$149.59 Monthly late charge amount at $21.37 Costs of suit and Title Search ......................................................................$900.00 Monthly Escrow amount $163.01 $52,523.13 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be 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 Sheriffs 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 date of the postmark on the Notice was the same as the date of the Notice. The Defendants had the required face to face meeting within the required time and Plaintiff has been advised that the Defendants filed an application for mortgage assistance with the Pennsylvania Housing Finance Agency, the Plaintiff has been advised by the Pennsylvania Housing Finance Agency that the Defendants' application has been rejected. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $52,523.13, together with interest at the rate of $10.52, per day and other expenses, costs and charges incurred by the Plaintiff which 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:-ft G LDBECK McCAFFERTY & WKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF 4 . VERIFICATION I, O V ?k V ry l o f-"N , 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 penalties of 18 Pa. C.S. 4904 relating to unworn falsification to authorities. Date: Yips President 5903678307 JAMES L. REID III E.xhibitA EXH W W ALL TI([FOLLDWM(0 da Wd b(d W*wd N - fit Mrs VOW of Hap (from Ps Tows hk% Cambsrbsd CawkF, Pwmsybards. bssndW wrd dwor-, n blom b Mk t1iAMN110 u sP * oN asrsw d Ilapsbls as d. bsran • Pbw fl" f1I1m by -m m W M pak Iasd to hm" . d/1dy swrse (M)? dgsw 61s1 • dbbiws a q lwr py bat b a pant, M hAusw -, d s ^W sls4 bdbM bsm fiw Fb+s flea/ b Mu WYlA babas rAb wad; Some by asst m* sbww (11) dip"= 11bas (IQ mbL4w gods dbbn d pwoWy. aar (T1) lesl b s pelnf; tl?ww+ deny bsde,raw w bb d FNe11 tfaab ewh spMra+n (aq dgnss Miq (?1 aaesba Wwal s diMMOS d airtllM) bat b ss ran ptpsi drnas abq prapwll lronr R lala d tMaldn Moak p11? 1rs (!p dpNS Mall (? mMrbs Mba • dlMwm d ssrwryik (M fad b s pobd In 1b sPA% road Ind tlw pbos d tigMf M10. CWAMaO sM s*a ba, mws or law i 1 a*aar?s 3 ? t?ntarrlwrd 3 lv ofibre (or Mr reowdlm of Ostia land Gou Vw. VnT- - Pgw #dJ5 ! ' + nyl sdof 'A1 fisool jw co, ip . 1245 MUM E..X,ehibit B Washington Mutual Mailstop JAXA2031 P.O. Box 44090 Jacksonville, FL 32231-4090 7100 4047 5100 4429 8186 January 16, 2008 JAMES L REID III 2201 PINE RD NEWVILLE PA 17241 002365 /PC 5903678307 WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 5903678307 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. PA ACT 91 HOMEOWNER'S NAME(S): James L. Reid III PROPERTY ADDRESS: 2201 Pine Road Newville PA 17241 LOAN ACCT. NUMBER: 5903678307 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN AVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY TAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice. During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MIiST OCCUR WITHIN THE NEXT (3W DAYS IF YOU DO NOT APPLY FOR EMER ,E.NCY MORT A ASSISTANCE YOU MIJ T BRING YOUR MORTGAGE P TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONS iM R EDIT COUNSELING A N I S - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated Ana +m r re?1. r unseli g agencies for the county in which he nr pcny is lasted are set forth a h end of this NotirL It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). If you have tried and are unable to resolve this problem with the lender, you have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. Your application MUST be filed or postmarked within thirty (30) days of your face-to-face meeting. YOU MUST FILE YOUR APPLICATION PROMPTLY. IF YOU FAIL TO DO SO OR IF YOU DO NOT FOLLOW THE OTHER TIME PERIODS SET FORTH IN THIS LETTER, FORECLOSURE MAY PROCEED AGAINST YOUR HOME IMMEDIATELY, AND YOUR APPLICATION FOR MORTGAGE ASSISTANCE WILL BE DENIED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) 002365/CO826 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE. OF THE. DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 2201 Pine Road Newville PA 17241 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 11/01/2007 $590.48 12/01/2007 $590.48 01/01/2008 $590.48 Other charges (explain/itemize): Uncollected Late Charges $42.74 Uncollected Fees: $0.00 Less Credits $000 TOTAL AMOUNT PAST DUE: $1814.18 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1814.18, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Faymen s must mad either by cash cashier's check certified check or money order made payable and sent to- Washington Mutual Bank Cash Processing P.O. Box 41275 Jacksonville, FL 32203 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise i s ripltts to accelerate h mortgage debt This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon your mmo 1gigepropuly NE THE MORTGAGE I'S FOR d'LOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attonery's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fives will be added to the amount you owe the lender, which may also include other reasonable costs. If Ion .r the default within the THIRTY (30 DAY period. you will not be renn4red to pay attorney's fees OTHER LENDER RFMFDIFQ - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. PA ACT 91 RIGHT TO CURE. THE DEFAULT PRIOR TO SH RIFFS SALF - If you have not cured the default within the THIRTY (30) DAY and foreclosure proceedings have begun, you may still have the right to cure the default and prevent the sale at anv time un to one the lender and by performing any other requirements under the mortpgg, Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender: Washington Mutual Bank Address: 7255 Baymeadows Way Jacksonville, FL 32256 Phone Number: 866-926-8937 Fax Number: 904281-3914 Contact Person: Collection Department Email Address: www.wamuhomeloans.com EFFECTS OF SHERIFF'S SALE: - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You may or -X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. PA ACT 91 Gam. P -?U AZ` c? N ct'? .L . Q _n F SHERIFF'S RETURN - REGULAR CASE NO: 2008-05674 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WASHINGTON MUTUAL BANK VS REID JAMES L III SHAWN HARRISON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon A''Tn TAMP T. TTT the DEFENDANT , at 2006:00 HOURS, on the 29th day of September, 2008 at 2201 PINE ROAD NEWVILLE, PA 17241 by handing to JAMES REID III 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 18.00 Service 12.00 Affidavit .00 Surcharge 10.00 / 00 /0104(04 ?^- a 4 Sworn and Subscibed to before me this day of , So Answers: R. Thomas line 10/01/2008 GOLDBECK By: A. D. "BECK McCAFFERTY & MCKEEVER GOL BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attnrnev for Plaintiff WASHINGTON MUTUAL BANK SB/M PNC MORTGAGE CORPORATION 7255 Baymeadows Way Jacksonville, FL 32256 plaintiff vs. JAMES L. REID III (Mortgagor(s) and Record owner(s)) 2201 Pine Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-5674 PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PLAINTIFF UNDER Pa.R.C.P. 2352 TO THE PROTHONOTARY: Kindly file of record the Praecipe of for Voluntary Substitution under Pa.R.C.P. 2352 and attached Statement of Material Facts in Support of Voluntary Substitution, Verification, Certification of Service. The address for the Plaintiff JPMorgan Chase Bank, National Association, as purchaser of the loans and other assets of Washington Mutual Bank, F/K/A Washington Mutual Bank, FA, 7255 Baymeadows Way, Jacksonville, FL 32256. AICEL T. MCKEEVER, ESQUIRE C'? +v C) cz? ,`... ,C'I. C r ?' `•C GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 WASHINGTON MUTUAL BANK SB/M PNC MORTGAGE CORPORATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. REID III (Mortgagor(s) and Record Owner(s)) 2201 Pine Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-5674 STATEMENT OF MATERIAL FACTS IN SUPPORT OF VOLUNTARY SUBSITTUTION UNDER Pa.RC.P. 2352 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, by counsel, hereby voluntarily substitutes itself as Plaintiff in the above-captioned matter and in support thereof represents as follows: The above-captioned action is one in mortgage foreclosure regarding the premises as noted in the caption. 2. The subject of the above-captioned action is a first mortgage on said premises recorded at Mortgage Book 1919, Page 0522 in the Office of the Recorder of Deeds for this County. 3. The original Plaintiff is WASHINGTON MUTUAL BANK SB/M PNC MORTGAGE CORPORATION. 4. JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA is the successor in interest to the Plaintiff by Assignment lodged for recording in the Office of the Department of Records and is hereby voluntarily substituted as Plaintiff in the above-captioned matter. 5. The real party in interest in the proceeding is JPMorgan Chase Bank, National Association, as purchaser of the loans and other assets of Washington Mutual Bank, formerly known as Washington Mutual Bank, FA (the "Savings Bank") from the Federal Deposit Insurance Corporation, acting as receiver for the Savings Bank and pursuant to its authority under the Federal Deposit Insurance Act, 12 U.S.C. § 1821(d). Respectfully submitted, PC EL T. PMM 9TEEVER, ESQUIRE C-) C ^' I; t"" CJ a? ? Ql GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (215) 627-1322 A,T-rnPMPV MR PLAINTIFF WASHINGTON MUTUAL BANK SB/M PNC MORTGAGE CORPORATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. REID III (Mortgagor(s) and Record Owner(s)) 2201 Pine Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-5674 CERTIFICATE OF SERVICE Michael T. McKeever, Esquire, hereby certifies that he 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 October 28, 2008. JAMES L. REID III 2201 Pine Road Newville, PA 17241 ?Yl X00 ?fi??1?? Michael T. McKeever, Esq. C? rv -o rT`I 7 C°r ro W Co '^C GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-5674 PRAECIPE TO CORRECT SCRIVENER'S ERROR Kindly correct the action to reflect the correct scrivener information. The incorrect Mortgage Book 1919, Page 0522 was referenced in paragraph #3 of the complaint. Please correct to Book 1245, Page 1195. Respectfully submitted, GOLDBECK, McCAFFERTY & McKEEVER By" ? ,. Michael T. McKeever, Esquire Attorney for Plaintiff C Ujo LjjCt- LU is Lt- (D ° c ? . 4 In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. REID III (Mortgagor(s) and Record Owner(s)) 2201 Pine Road Newville, PA 17241 Defendant(s) PRAECIPE FOR JUDGMENT No. 08-5674 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 JAMES L. REID III by default for want of an Answer. Assess damages as follows: Debt Interest from 11/04/2008 to Date of Sale per diem at $10.52 Total (Assessment of Damages attached) $54,097.04 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 delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 Michael T. McKeever Attorney for Plaintiff I.D. #56129 AND NOW bumb>er- T A 0080 , Judgment is entered in favor of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, ASP RCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA and against JAMES L. REID III by default for want of an Answer and damages assessed in the sum of $54,097.04 a&per the above Artification. Prothonotary 65802FC 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. TO: JAMES L. REID III 2201 Pine Road Newville, PA 17241 WASHINGTON MUTUAL BANK S/B/M PNC MORTGAGE CORPORATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. REID III (Mortgagor(s) and Record Owner(s)) 2201 Pine Road Newville, PA 17241 Defendant(s) TO: JAMES L. REID III 2201 Pine Road Newville, PA 17241 DATE OF THIS NOTICE: October 21, 2008 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Tenn No. 08-5674 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 THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, JAMES L. REID III, is about unknown years of age, that Defendant's last known residence is 2201 Pine Road Newville, PA 17241, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: /?/J o f ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $46,577.78 Interest from 12/01/2007 through $3,566.27 11/03/2008 Reasonable Attorney's Fee $2,328.89 Late Charges $235.07 Costs of Suit and Title Search $900.00 Escrow Payments Due 3 X $163.01 $489.03 $54,097.04 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this 0 day of A)pV , 2008 damages are assessed as above. AkA Pro A r-a 4 ?r t LIJ CD . 4 Rule of Civil Procedure No. 236 -- Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff No. 08-5674 vs. JAMES L. REID III (Mortgagors and Record Owner(s)) 2201 Pine Road Newville, PA 17241 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 tter red against you. u o Prot onotary By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-5674 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 11/04/2008 to Date of Sale per diem at $10.52 $54,097.04 (Costs to be added) GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff [/l ?, Ot?ww Z dQ?W 00 ?'?00 ? dP' xx ? x33 O a r ? N d W o d O R A 4? W 60 04 W ? O H o? W ? 0 v O? v a O? W ? N V W aP- A? aO 0 N w N ?a } H v W N ,,W U U ? O ? N Q N [!] 4d+ r y ? ? R N 0 ?o 10- •+Cr o 0 0 00 00 t C? C?. c? ALL THE FOLLOWING described lot of ground situated in the Village of Hays Grave, Penn Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a point in the center of the public road, known as Pine Road; thence by center of a public road five hundred eighty-seven (587) degrees East a distance of eighty-four (84) feet to a point, the intersection of a public road, leading from the Pine Road to the Walnut Bottom public road, thence by same north eleven (11) degrees fifteen (15) minutes East a distance of seventy-one (71) feet to a point; thence along lands now or late of Frank Keck north eighty-five (85) degrees thirty (30) minutes West a distance of ninety (90) feet to an iron pipe; thence along property now or late of Charles Meek, South five(5) degrees thirty (30) minutes West a distance of seventy-six (76) feet to a point in the public road and the place of BEGINNING. CONTAINING 8395 square feet, more or less. TAX PARCEL# 31-12-0328-020 BEING KNOWN AS: 2201 Pine Road, Newville, PA 17241 Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY NO. 08-5674 I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. Michael T. McKeever Attorney for plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE ra ` "' ? - r 7 , cp 1 t A Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. REID III (Mortgagor(s) and Record Owner(s)) 2201 Pine Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-5674 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 2201 Pine Road Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): JAMES L. REID III 2201 Pine Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: JAMES L. REID III 2201 Pine Road Newville, PA 17241 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 A, 4. Name and address of the last recorded holder of every mortgage of record: BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA 419 Village Drive Suite 2 Carlisle, PA 17013 BENEFICIAL CONSUMER DISCOUNT COMPANY 961 Weigel Drive Elmhurst, IL 60126 BENEFICIAL CONSUMER DISCOUNT COMPANY P.O. Box 9068 Brandon, FL 33509 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 2201 Pine Road Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 3, 2008 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff c-? r`' . I. CD f-7.7 " f r-- CD J GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff 08-5674 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 vs. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 Plaintiff Defendants Term No. 08-5674 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: REID III, JAMES L. JAMES L. REID 111 2201 Pine Road Newville, PA 17241 Your house at 2201 Pine Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, March 04, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $54,097.04 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, FWA WASHINGTON MUTUAL BANK, FA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE To prevent this Sheriffs Sale you must take immediate action: 08-5674 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, 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. 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 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. 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 08-5674 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 866-926-8937 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 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 65802FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-5674 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, As purchaser of the loans and other assets of WASHINGTON MUTUAL BANK, f/k/a WASHINGTON MUTUAL BANK, FA, Plaintiff (s) From JAMES L. REID III (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 $54,097.04 L.L. $.50 Interest from 11/04/08 to Date of Sale per diem at $10.52 Atty's Comm % Due Prothy $2.00 Atty Paid $159.00 Plaintiff Paid Date: 11/04/08 (Seal) REQUESTING PARTY: Other Costs Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 ,r' GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 Term No. 08-5674 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Offico4mvpetent pin S?+sAit 4s So f 1 /t too m ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, J T z --•- = BY: Michael T. McKeever, Esquire Attorney for Plaintiff 65802FC CF: 09/25/2008 SD: 03/04/2009 $54,097.04 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE .y ~• ? O C o - - I ---- O ,n d li O W p N 0>0o S U I (L ? N ?I t?11 0c) '4 LL N O g? 4 L s ? cnvn NO C) 0 (D E a? W ~ z z Q ?0 02 Z) O Z) O m Q m o- U_ ? o o a a) v? WWJ W W V) - ? Z) D o c =u?iE am°:? 16?i Z W Q O n Cl) Z e- O Z NN p ce N E-0 O'D YX 2 0 m j O >? C) co c i Oti CU ° yyy?t o? LL Q000 }} Q Q > - pQ 75 J C) ill ? Q ? Q-000 a_O -7 0) a 7 1 -7 m a) U- Q Q =_ 12 Z> N LL a) Z Q- - a) E2 LL 3: L Z O O co e C > m N w00, =3 m W W O m c) O CD o c a° co U C) U co ? W co ? m N Z c m L C N o E i i o a? E Z W a? Q U U _ J 79 a) ? n A W I t C CV J -o o N o 7 C Co CC G W ch ? E ? 01 p? fJ p N N N 0 o a U N 5 C O C (? O - U L O n E F 17 F 1 El LL rl- U) n. r p) N > .2 0 0 CL CO u) 2 E H M - CL O N ° J C) zU)rlo_ w r E L) I- > y ` C y (D i- 04 M Ll C, Q p C n o O a? U U O W $ U) H x aj a ????? m v? WO Co - m m 000 co Q3a) m 5 ° U DUaU dcOS 2 a w y U ?O a 0 0 a E 2 > E 1?0 2 N 1 W (1) Z cn w Q O a ~ Q w n a F- m c OYOWa.N n Q UoYJt7 g a cWLf) Q 0 ET L CD W Qcfl - ? Z ° E H JO Z95O=O N M Ln CO I? O ?? F°J C d CL c 0 io m O C u: 3 CL T H T N m a E O U N O a) m ?o N O O N 7 a) t- oo m O O O N O M O m (0 U) > c D O U c cu ?C C 7 U U LL N O 00 LO co 0 W J W Q GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 Term No. 08-5674 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 2201 Pine Road Newville, PA 17241 I.Name and address of Owner(s) or Reputed Owner(s): JAMES L. REID III 2201 Pine Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: JAMES L. REID III 2201 Pine Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: BENEFICIAL CONSUMER DISCOUNT COMPANY 961 Weigel Drive Elmhurst, IL 60126 BENEFICIAL CONSUMER DISCOUNT COMPANY P.O. Box 9068 Brandon, FL 33509 BENEFICIAL CONSUMER DISCOUNT COMPANY DB/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA 419 Village Drive Suite 2 Carlisle, PA 17013 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 2201 Pine Road Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. DATED: February 10, 2009 ?,A , A / -JCI?(?-?-? ?-? I - `? I? GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff C') +v r Y- fT? P )p r Y' , N JP Morgan Chase Bank, National In The Court of Common Pleas of Association as Purchaser of the Loans Cumberland County, Pennsylvania And Other Assets of Washington Mutual Writ No. 2008-5674 Civil Term Bank f/k/a Washington Mutual Bank, FA VS James L. Reid, III Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on November 18, 2008 at 1014 hours, she served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: James L. Reid, III, by making known unto Thurteen Reid, adult in charge, at 2201 Pine Road, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. William Cline, Deputy Sheriff, who being duly sworn according to law, states that on January 13, 2009 at 1650 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the :property of James L. Reid, III located at 2201 Pine Road, Newville, Cumberland County, Pennsylvania according to law. R. Thomas Kline, Sheriff, who being duly sworn according to law, states he served the above Real Estate Writ, Notice, Poster and Description in the following manner: The Sheriff mailed a notice of the pendency of the action to the within named defendant, to wit: James L. Reid, III, by regular mail to his last known address of 2201 Pine Road, Newville, PA 17241. This letter was mailed under the date; of January 9, 2009 and never returned to the Sheriffs Office. R. Thomas Kline, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED. Sheriff's Costs: Docketing 30.00 Poundage 16.70 Posting Bills 15.00 Advertising 15.00 Law Library .50 Prothonotary 2.00 Milage 21.60 Levy 15.00 Surcharge 20.00 Post Pone Sale 40.00 Y Law Journal 355.00 Patriot News 345.50 Share of Bills 15.52 891.82 So Ans rs R. Thomas Kline, Sheriff ?JCLUd-?- Real Estate Coordinator ? 7/e plc `K '4-' ..u f _'t r -G r L? ,2 G? r CK2 7 B4 I ?? 5 1?;--, J? v le Goldbeck McCafferty $ McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 --- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff vs. JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 JAMES L. REID III (Mortgagor(s) and Record Owner(s)) 2201 Pine Road Newville, PA 17241 No. 08-5674 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULL 1129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION. /\S PURCIIASER OI, THL I-O:WS AND OTFIFR ASST:-I S 01 WASHINGTON MU-IUAL BANK, F%K ,A WASHINGTON MUTUAL BANK F.A. Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at- 2-20 1 Pine Road Newv illc. PA 17241 I.Name and address of O%V11cr(s) ur Reputed O%vner(s): JAIVIFS L. REID III 2201 Pine Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: JAMES L. REID III 2201 Pine Road Newville. PA 17241 3. Name and last known address of everyjudgment creditor whose judgment is a record tier on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle. PA 17013 PA DEPARTIVIFN"I OF PUBLIC WELFARE - Bureall of Child Support Enforcement Health and Welfare Bldg. - Room 4-;2 P.O. Box 2675 Harrisburg, PA 17105-2675 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - I,AW ACTION OF MORTGAGE FORECLOSURE. 'e i 4. Name and address of the last recorded holder of every mortgage of record: BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA 419 Village Drive Suite 2 Carlisle, PA 17013 BENEFICIAL CONSUMER DISCOUNT COMPANY 961 Weigel Drive Elmhurst, IL 60126 BENEFICIAL CONSUMER DISCOUNT COMPANY P.O. Box 9068 Brandon, FL 33509 5. Name and address of every other person who has an,,, 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 ?v-hom the plaintiff has knowledge who has any interest in the property which inay be affected by the sale. F1 NANTS OC C'(IPAN IS 2201 Pine Road Newyille, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidaVrt are true and correct to the best of n-iy personal knowledge or information and belief. I understand that false statements herein are made suhicct to the penalties of 13 Pa. C .S. Section 4904 relating to unsworn falsification to authorities. DATED: November 3. 2008 60 1 - J)BLCK NlcC.;\I- FRTY R NIcKFL?'ER BY: [Michael T. McKeever, Esq. lttorrnca for Plaintiff 08-5674 GOLDDECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney LD.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK. F/K/A WASHINGTON MUTUAL BANK, FA 7255 Bavmeadows Way .lacksonville, FL 32256 vs. JAMES L. REID III Mortgagor(s) and Rccord Owner(s) 22O I fine koad Ne\vville, PA 17241 Plaintiff Defcndant(s', Term No. 08-5674 THIS LAW FIRM[ IS A DEBT COLLECTOR AND WE ARE ATTEMI[PTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTENIPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROtII YOU ??'[T:1. BI; USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL, PROPERTY 1 0: RFID III. JAMFS L_ JAMES L. REID 111 2201 Piue Road Newville, PA 17241 four house at 2201 Pine Road, Newville, PA 17241 is scheduled to be sold at Shcrit't's Sale on Wednesday. March 04, 2009. at 10:00 AM. in Commissioners Hearing 12m 2nd Ff. Courthouse to enforce the court judgment of 554,097.04 obtained by.IPM0 1WAN CIIASE BANK, NATIONAL ASSOCIATION, AS PURCHASER Of THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, EX/A WASHINGTON MU"IUAL BANK. FA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE r IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE I o prevent this Sheriffs Sale you must take immediate action: 08-5674 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, 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. 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 INJAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. I . 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. Ilie sale will go through only if the hovel- pays the Sheriff the full anxount due in th?? sale. To find out if this has happeued. you may call the Shrriff of 717 240-6390. 4. If the anunmt 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 ri(ht to remain in the property until the full amount due is paid to the Sheritt and the Sheriff gives a deed to the buver. At that time. the buyer may firing legal proceeding,; to evict vou. (,. You mat° be entitled to a share ()f the Illom hich was paid loo your house. A SCho;]uIC of distribution of the money bid for your house will be filed b,,the Sheriff within thirty (30) days from the date of the Sheriffs Sale. -phis schedule ??-ill state ho will be rcceivul" that money. "I lie money will be paid out in accordance with this schedule unless exceptions (reasons vy by the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. You may also have other rights and defenses, or u<lys of gettin your house back, if vou act immediately after the sale. YOU SHOULD FAKE THIS PAPER 10 YOUR t.AWYLR A I UN(1IF l'OU DO NoI 1LAVE A LANVYER OR CANNON AFFORD ONE_ 60 TO OR TLLEPHONE T11L UFFICL LISTED BELOW TO FIND OUT \VHFRF_, YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY 13AR ASSOCIATION 2 Libertv Avenue Carlisle. PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, P:1 17013 717-243-9400 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. 08-5674 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. rov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan prof gams that may assist homeowners in default. Please See the PHFA website http://vvvvw.i)hfa.or,g/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at 866-926-8937 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 pavotf,the mortgage or request a Loan Workout / Home Retention Package. Call our toll lice number at 1-866-413-2311 or via email at homeretention(cr-,t,,olcibecklavv.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 inConnation. 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 65802FC. Para ini6 rmacion cn cspanol pucdc co nununicarse con Loretta al 21 5-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 08-5674 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, As purchaser of the loans and other assets of WASHINGTON MUTUAL BANK, f/k/a WASHINGTON MUTUAL BANK, FA, Plaintiff (s) From JAMES L. REID III (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 garnishhee(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 $54,097.04 L.L. $30 Interest from 11/04/08 to Date of Sale per diem at $10.52 Atty's Comm % Due Prothy $2.00 Atty Paid $159.00 Other Costs Plaintiff Paid Date: 11/04/08 4u?t*s. Long, Prothonotary (Seal) BY GL Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 Real Estate Sale #31 On November 12, 2008 the Sheriff levied upon the defendant's interest in the real property situated in Penn Township, Cumberland County, PA Known and numbered as 2201 Pine Road, Newville more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: November 12, 2008 t 4'_`Mr._'L By: Real Esta e Sergeant 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: January 30, February 6, and February 13, 2009 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. isa Marie Covie. Editor SVh16RN TO AND SU11SCRIBED before me this 13 day of February 13 2009 Notary --?--o.. -.-..®._.-- NOTARIAL SEAL DEBORAH A COLLINS N;,tary Public CARLISLE BORO, CUMBERLAND COUINTY My Commission Expires Apr ;28, ?.010 REAL ESTATE SALE NO. 31 Writ No. 2008-5674 Civil JPMorgan Chase Bank, National Association, as Purchaser of the Loans and Other Assets of Washington Mutual Bank f/k/a Washington Mutual Bank, FA vs. James L. Reid, III Atty.: Michael McKeever ALL THE FOLLOWING described lot of ground situated in the Village of Hays Grave, Penn Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a point in the cen- ter of the public road, known as Pine Road; thence by center of a public road five hundred eighty-seven (587) degrees East a distance of eighty-four (84) feet to a point, the intersection of a public road, leading from the Pine Road to the Walnut Bottom public road, thence by same north eleven (11) degrees fifteen (15) minutes East a distance of seventy-one (71) feet to a point; thence along lands now or late of Frank Keck north eighty-five (85) degrees thirty (30) minutes West a distance of ninety (90) feet to an iron pipe; thence along property now or late of Charles Meck, South five (5) degrees thirty (30) minutes West a distance of seventy-six (76) feet to a point in the public road and the place of BEGINNING. CONTAINING 8395 square feet, more or less. TAX PARCEL# 31-12-0328-020. BEING KNOWN AS: 2201 Pine Road, Newville, PA 17241. Trot' Patriot-News Co. . 812 Market St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND COUNTY SHERIFFS OF CUMBERLAND COUNTY COURT HOUSE i4ePatriot-News Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Joseph A. Dennison, being duly sworn according to law, deposes and says: That he 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 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, 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 all have been continuously published 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/ Metro editions which appeared on the date(s) indicated below. That neither he 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 he 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 Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY REAL ESTATE SALE NO. 31 Writ No. 2008-5674 CiviYTerm JPMorgan Chase Bank, National Association, as Purchaser of the Loans and other Assets of Washington Mutual Bank f/kfa Washington Mutual Bank, FA VS James L. Reid, III Attorney Michael McKeever LEGAL DESCRIPTION ALL THE FOLLOWING described lot of ground situated in the Village of Hays Grave, Penn Township, Cumberland County. Pennsylvania, bounded and described as follows to wit: BEGINNING at a point in the center of the public road, known as Pine Road; thence by center of a public road five hundred eighty-seven (587) degrees East a distance of eighty-four (84) feet to a point, the intersection of a public road, leading from the Pine Road to the Walnut Bottom public road, thence by same north eleven (11) degrees fifteen (IS) minutes East a distance of seventy-one (71) feet to a point; thence along lands now or late of Frank Keck north eighty-five (85) degrees thirty (30) This ad ran on the date(s) shown below: 01 /21 /09 01/28/09 02/04/09 Sworn to an 'sub ibed before me this 25 day of February, 2009 A.D. Notary Public minutes West a distance of ninety (90) teet to an iron pipe; thence along property now or late of Charles Meck, South five(5) degrees thirty (30) minutes West a distance of seventy-six (76) feet to a point in the public road and the place of BEGINNING. CONTAINING 8395 square feet, more or less. TAX PARCEL# 31-12-0328-020 BEING KNOWN AS: 2201 Pine Road, Newville, PA 17241 COMMONWEAI._Tl 0PENe SYLVANi,tk Sherrie L. KiSrisr, Notary Public Clly Of Harrisbur, , 0 uphin County My Co wniSsion F xpires Nov. 26, 2011 Member, Pennsylvania PbnF,00atlon of NOtaMS PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Goldbeck, McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL IN THE COURT OF COMMON PLEAS BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way of Cumberland County Jacksonville, FL 32256 vs. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 TO THE PROTHONOTARY: Plaintiff Defendant(s) CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-5674 0 o ?n ZT y; C N J tit PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: Pd ? ?? 1 .?'{ • U a, 5-'j T6 as R X78 • SO cdc4-5 B.F ou u s ?y ob g yo, ad ?? " N P J ;L •3a Amount Due Interest from 11/04/2008 to Date of Sale per diem at $10.52 (Costs to be added) $54,097.04 By: /7 GOIZBECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 D vid Fein Pa. ID 82628 omas Puleo Pa. ID 27615 Attorneys for Plaintiff a?,dd D--e, Co w d o ww ? v ai a a0 4Q ? 3 r. W c o r• ? L ?o dQ?? ?, 7 Z ??a ? 3 a O ? ? co W ZW2'Z V1 ? •-• ^' O `y HN ? C a dH00 m aai d a°A z t W! C7 L7 O ? C) o G, w W xWLn U?QQ H zx33 ? 0a d C "c ?I J U t= r ,Q N ? o N d 1 r -A U -. s - r ty ?n O ? ALL THE FOLLOWING described lot of ground situated in the Village of Hays Grave, Penn Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a point in the center of the public road, known as Pine Road; thence by center of a public road five hundred eighty-seven (587) degrees East a distance of eighty-four (84) feet to a point, the intersection of a public road, leading from the Pine Road to the Walnut Bottom public road, thence by same north eleven (11) degrees fifteen (15) minutes East a distance of seventy-one (71) feet to a point; thence along lands now or late of Frank Keck north eighty-five (85) degrees thirty (30) minutes West a distance of ninety (90) feet to an iron pipe; thence along property now or late of Charles Meek, South five(5) degrees thirty (30) minutes West a distance of seventy-six (76) feet to a point in the public road and the place of BEGINNING. CONTAINING 8395 square feet, more or less. TAX PARCEL# 31-12-0328-020 BEING KNOWN AS: 2201 Pine Road, Newville, PA 17241 GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQ. ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 08-5674 CERTIFICATION AS TO THE SALE OF REAL PROPERTY C) ? -o co cn ?r fa rn -a Ln w Plaintiff, by counsel, hereby certifies that it has complied with the provisions of Act 91 of 1983 and/or the real property in question is not subject to the Act. By: GOLDBECK McCAFFERTY & McKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 vid Fein Pa. ID 82628 lomas Puleo Pa. ID 27615 Attorneys for Plaintiff Goldbeck, McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, FIKIA WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. REID HI (Mortgagor(s) and Record Owner(s)) 2201 Pine Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-5674 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the d ate the praecipe for the writ of execution was filed the following information concerning the real property located at: 2201 Pine Road C -^ Newville, PA 17241 'Q tz a"i "b T =., LName and address of Owner(s) or Reputed Owner(s): JAMES L. REID III 2201 Pine Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: JAMES L. REID III 2201 Pine Road Newville, PA 17241 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: BENEFICIAL CONSUMER DISCOUNT COMPANY 961 Weigel Drive Elmhurst, IL 60126 BENEFICIAL CONSUMER DISCOUNT COMPANY P.O. Box 9068 Brandon, FL 33509 BENEFICIAL CONSUMER DISCOUNT COMPANY D/B/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA 419 Village Drive Suite 2 Carlisle, PA 17013 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 2201 Pine Road Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: September 2, 2010 li?% a "?-o ?CLA GOLDBECK McCAFFERTY & MCKEEVER BY: tinamarie boschetti 08-5674 00 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 VS. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 Plaintiff Defendant(s' of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 08-5674 v -n rn[3: cam. ? C) L CD tV 2i cst p 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 SHER]IFF'S SALE OF REAL PROPERTY TO: REID III, JAMES L. JAMES L. REID 111 2201 Pine Road Newville, PA 17241 Your house at 2201 Pine Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $54,097.04 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE IN THE COURT OF COMMON PLEAS To prevent this Sheriffs Sale you must take immediate action: 08-5674 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, 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. 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 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: hq:Uwww.philadelphiafed.orgjforeclosure/ 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue 08-5674 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: 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). 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.gpx. 5). Call the Plaintiff (your lender) at 866-926-8937 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 homeretentionkgoldbecklaw.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 65802FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N008-5674 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WAHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA Plaintiff (s) From JAMES L. REID III (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$54,097.04 L.L. Interest FROM 11/04/2008 TO DATE OF SALE PER DIEM AT $10.52 Atty's Comm % Atty Paid $1,072.32 Plaintiff Paid Date: SEPTEMBER 9, 2010 Due Prothy $2.00 Other CostsTO BE ADDED Da v* , Pr onotary (Seal) By: Deputy REQUESTING PARTY: Name THOMAS PULED, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER, SUITE 500 - MELLON INDEPENDENCE CENTER, 701 MARKET STREET, PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 27615 GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center • 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 FILED-OFFICE OF THE PROTHONOTARY 1010 NOV 30 AM 11: 30 65802FC CF: 09/25/2008 SD: 12/08/2010 $54,097.04 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 Defendant(s) 1BERLASIftWT OF COMMON PLEAS PENNSYLVANIA of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-5674 CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Keith C. Halili, an employee of Goldbeck McCafferty & McKeever, counsel for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/coat-?copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriffs Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted :Keith C. Hahh Legal Secretary ? O <4S'CO ?? ? ? /? n i ? S77 s?" tP it ?? m ?t,p?' IN ? +? ;,. ,ii• y? d?•UtJ!1 o c. $ ? C O C m E O O Q 0 > O >0 O 0 v O Q 2 w D ? ? V] m m v W W co m = v _ m- m r ? ? m E c v - 0.°0`0?° Z N O Z O m > ? U -C p o ap LL t- cc x 0 J m Q J Q 4 n ljj 3: LL d CO WO WOE 6 C, o ? a CCaiW mU? ) , 4 c `m U c ? a m 25 Z p w Q o U CS Er $01a? -2 E- a A IJ - N W mN W m m c C cc aN `a 3: c E C U U a E ???? 0 J P ° j LL O m W CD U > p Q M :9 z O U W i-7 m Z CD ? ? `r o4 C o C4? g! M W-0 N 2 Lo W ? t Z m E =p P O 0 0 d'4vN C f6 p aj U ? co d nm m 11000 L w ? in LL] Z >C C 2:3 aj C a U V (Q 0 0? U o v dmY? n . a 00 a E ? z ? `m E f- W m Z v? W Q f, cr- a m ¢ Q i Y-iN U° a o W ,$ N m MLo E Z O Q p 1- r N ch sf L6 CO r-_: co fi P C m a c O Y C m CL H .C m m CL Q o U p _N co O N m 0 W co cm J- O ? O U a c N f6 O M N p E 2 U O J U- co N o W LL 0 a 0 ? SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff of tumiM ?tititp rl - Jody S Smith ?a p,?d : , Chief Deputy ; •' Richard W Stewart Solicitor OFY-ICE OF THE SKEW* JPMorgan Chase Bank, NA Case Number vs. James L Reid 2008-5674 SHERIFF'S RETURN OF SERVICE 10/14/2010 03:10 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on 10-14-10 at 1310 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of James L. Reid, located at, 2201 Pine Road, Newville, Cumberland County, Pennsylvania accerding..to law. 10/25/2010 08:30 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 10/25/10 at 2030 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: James L. Reid, by making known unto, James L. Reid, personally, at, 2201 Pine Road, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $898.42 October 27, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cl Gamtysune Stielifi, Telaoso9, Inc GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 08-5674 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 2201 Pine Road Newville, PA 17241 I .Name and address of Owner(s) or Reputed Owner(s): JAMES L. REID III 2201 Pine Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: JAMES L. REID III 2201 Pine Road Newville, PA 17241 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 addressee-1 st rcaaWc4 holder of every mortgage of record: BENEFICIAL CONSUMER DISCOUNT COMPANY 961 Weigel Drive Elmhurst, IL 60126 BENEFICIAL CONSUMER DISCOUNT COMPANY P.O. Box 9068 Brandon, FL 33509 BENEFICIAL CONSUMER DISCOUNT COMPANY DB/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA 419 Village Drive Suite 2 Carlisle, PA 17013 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 2201 Pine Road Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of ? 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: November 24, 2010 & GOLDBECK McCAFFERTY & McKEEVER BY: Keith C. Halili Legal Secretary SHERIFF'S OFFICE OF CUMBERLAND COUNTY 1'"LJ- Ronny R Anderson Sheriff a Jody S Smith } FR 24T AN F,: u , Chief Deputy C',JMBERd' "'? f Richard W Stewart c M a .i+ e Solicitor JPMorgan Chase Bank, NA Case Number vs. 2008-5674 James L Reid SHERIFF'S RETURN OF SERVICE 10/14/2010 03:10 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on 10-14-10 at 1310 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the property of James L. Reid, located at, 2201 Pine Road, Newville, Cumberland County, Pennsylvania according to law. 10/25/2010 08:30 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on 10/25/10 at 2030 hours, he served a true copy of the within Real Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: James L. Reid, by making known unto, James L. Reid, personally, at, 2201 Pine Road, Newville, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 12/06/2010 As directed by Thomas Puleo, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/5/2011 01/04/2011 As directed by Thomas Puleo, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/2/2011 02/23/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney Gary McCafferty on 2/23/11. SHERIFF COST: $743.48 SO ANSWERS, February 23, 2011 RON R ANDERSON, SHERIFF a ss?s? Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMES L. REID III (Mortgagor(s) and Record Owner(s)) 2201 Pine Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) No. 08-5674 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 2201 Pine Road Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): JAMES L. REID III 2201 Pine Road Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: JAMES L. REID III 2201 Pine Road Newville, PA 17241 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 addr.:c of the last recorded holder of every mortgage of record: BENEFICIAL CONSUMER DISCOUNT COMPANY 961 Weigel Drive . Elmhurst, IL 60126 BENEFICIAL CONSUMER DISCOUNT COMPANY P.O. Box 9068 Brandon, FL 33509 BENEFICIAL CONSUMER DISCOUNT COMPANY DB/A BENEFICIAL MORTGAGE COMPANY OF PENNSYLVANIA 419 Village Drive Suite 2 Carlisle, PA 17013 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 2201 Pine Road Newville, PA 17241 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities. DATED: September 2, 2010 GOLDBECK McCAFFERTY & MCKEEVER BY: tinamarie boschetti 08-5674 GOLDBECK McCAFFERTY & McN EEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 7255 Baymeadows Way Jacksonville, FL 32256 VS. JAMES L. REID III Mortgagor(s) and Record Owner(s) 2201 Pine Road Newville, PA 17241 IN THE COURT OF COMMON PLEAS Plaintiff Defendants of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 08-5674 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: REID III, JAMES L. JAMES L. REID 111 2201 Pine Road Newville, PA 17241 Your house at 2201 Pine Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on Wednesday, December 08, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $54,097.04 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA 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: 08-5674 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WASHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA, 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. 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 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. You may contact the Foreclosure Resource Center: hU://www.philadelphiafed.orwforeclosure/ 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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue 08-5674 Carlisle, PA 17013 08-5674 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: 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). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the P14FA website http://www.phfa.orgiconsumers/homeowners/real.gpx. 5). Call the Plaintiff (your lender) at 866-926-8937 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(c,g_oldbecklaw.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 65802FC. Para informacon en espanol puede communicarse con Loretta al 215-825-6344. ALL THE FOLLOWING described lot of ground situated in the Village of Hays Grave, Penn Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a point in the center of the public road, known as Pine Road; thence by center of a public road five hundred eighty-seven (587) degrees East a distance of eighty-four (84) feet to a point, the intersection of a public road, leading from the Pine Road to the Walnut Bottom public road, thence by same north eleven (11) degrees fifteen (15) minutes East a distance of seventy-one (71) feet to a point; thence along lands now or late of Frank Keck north eighty-five (85) degrees thirty (30) minutes West a distance of ninety (90) feet to an iron pipe; thence along property now or late of Charles Meck, South five(5) degrees thirty (30) minutes West a distance of seventy-six (76) feet to a point in the public road and the place of BEGINNING. CONTAINING 8395 square feet, more or less. TAX PARCEL# 31-12-0328-020 BEING KNOWN AS: 2201 Pine Road, Newville, PA 17241 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERDAND) N008-5674 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS PURCHASER OF THE LOANS AND OTHER ASSETS OF WAHINGTON MUTUAL BANK, F/K/A WASHINGTON MUTUAL BANK, FA Plaintiff (s) From JAMES L. REID III (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$54,097.04 L.L. Interest FROM 11/0412008 TO DATE OF SALE PER DIEM AT $10.52 Atty's Comm % Atty Paid $1,072.32 Plaintiff Paid Date: SEPTEMBER 9, 2010 Due Prothy $2.00 Other CostsTO BE ADDED Dav' , Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name THOMAS PULEO, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER, SUITE 500 - MELLON INDEPENDENCE CENTER, 701 MARKET STREET, PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 27615 On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Penn Township, Cumberland County, PA, Known and numbered as, 2201 Pine Road, Newville, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: UA? Real Estate Coordinator The Patriot-News Co. 202CI Technology Pkwy Suite 300 • - Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE Zhe Patr1*0t1WX(W5 Now you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin) ss Holly Blain, being duly sworn according to law, deposes and says: That she is a Staff Accountant 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 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, 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 all have been continuously published 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/ Metro 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 Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 10/15/10 10/22/10 10/29/10 -? 0-1 bscribed befa?e i Notary Fu COMMONWEALTH OF PENNSYLYAN[A Notarial Seal Sherrie L K&w, Notary public Lower Paxton TWP., Dauphin County l My ComrnL,W n EScplres Nov. 26, 2011 Member, Penns\AWnla Associatinn of Notaries November, 2010 A.D. 20OB-5674 CWH Teem iruo"10" WNW 600L. Mk as Pure oew of Vw Leans a w Ottwr Assets of illwr>hlnpign Mutual Sank, Min W"I ttgton Mudul Bar*, FA Vs James L Reid Mr. Thomas Pitt o ALL THE FOLLOWING described lot of ground situated in the Village of Hays Grave, Penn Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a point in the center of the public road, known as Pine Road; thence by center of a public road be hundred eighty- seven (587) dWm East a dish of eighty- four (84) feet to a point the intersection of a public road, leading from the Pine Road to the Walnut Bottom public road, thence by same north eleven (11) degrees fifteen (15) minutes East a dunce of seventyo= (71) feet to a point; thence along lands now or late of Frank Keck north eighty-five (85) degrees thirty (30) minutes West a distance of ninety (90) feet to an iron pipe; thence along property now or late of Charles Meck, South fw*5) degrees thirty (30) minutes West a diet n of seventy-six (76) feet to a point in the public mad and the place of BEGINNING. CONTAINING 8395 square feet, more or less. TAX PARCEL* 31-12-0328-02D BEING MOWN AS: 2201 Pine Road, Nmille, PA 17241 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 22, October 29, and November 5, 2010 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. sa Marie Coyne, Edito SWORN TO AND SUBSCRIBED before me this 5 da of November, 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 26, 2014 CUMBERLAND LAW JOURNAL Writ No. 2008-5674 civil JPMorgan Chase Bank, NA, as Purchaser of the Loans and Other Assets of Washington Mutual Bank, f/k/a Washington Mutual Bank, FA VS. James L. Reid Atty.: Thomas Puleo ALL THE FOLLOWING described lot of ground situated in the Village of Hays Grave, Penn Township, Cumberland County, Pennsylvania, bounded and described as follows to wit: BEGINNING at a point in the cen- ter of the public road, known as Pine Road; thence by center of a public road five hundred eighty-seven (587) degrees East a distance of eighty-four (84) feet to a point, the intersection of a public road, leading from the Pine Road to the Walnut Bottom public road, thence by same north eleven (11) degrees fifteen (15) minutes East a distance of seventy-one (71) feet to a point; thence along lands now or late of Frank Keck north eighty-five (85) degrees thirty (30) minutes West a distance of ninety (90) feet to an iron pipe; thence along property now or late of Charles Meck, South five(5) degrees thirty (30) minutes West a distance of seventy-six (76) feet to a point in the public road and the place of BEGINNING. CONTAINING 8395 square feet, more or less. TAX PARCEL# 31-12-0328-020. BEING KNOWN AS: 2201 Pine Road, Newville, PA 17241. 102