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HomeMy WebLinkAbout09-0736GOLDBECK 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 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMESON E. CHRISTOPHER Mortgagor and Record Owner 131 East Louther Street Carlisle, PA 17013 Defendant Term // No. Q/ 7 3 6 0v,-1 ?,ML. ACTION: MORT(;;-,?=I~: P',-7 FGLOftRF NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment 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. 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, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE 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 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. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still 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 hqp://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). Foreclosure Resource Center: htip://www.philadelphiafed.orwforeclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a?goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is Courtenay Dunn who can be reached at 215-825-6311 or Fax: 215-825-6411. Please reference our Attorney File Number of 78062FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., 7255 Baymeadows Way, Jacksonville, FL 32256. 2. The names and addresses of the Defendant is JAMESON E. CHRISTOPHER, 821 Factory Street, Carlisle, PA 17013, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On March 18, 2003 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to BROADVIEW MORTGAGE COMPANY, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book: 1801 Page: 2767. The mortgage has been assigned to: WASHINGTON MUTUAL BANK F.A. by assignment of Mortgage March 20, 2003 as Book 695, Page 2676. 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 October 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 ....................................................................................$52,073.96 Interest from 09/01/2008 through 01/31/2009 at 8.1250% .......................$1,773.26 Per Diem interest rate at $11.59 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$2,603.70 Late Charges from 10/01/2008 to 01/31/2009 ............................................. $174.88 Monthly late charge amount at $20.42 Costs of suit and Title Search ......................................................................$900.00 Fees ..............................................................................................................$228.65 Monthly Escrow amount $134.07 $57,754.45 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 Sheriff s Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has 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 Defendant 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 Defendant have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $57,754.45, together with interest at the rate of $11.59, 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 Sheriff s Sale of the Property. G By GOLDS C McC F ERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Enso Ustovic , 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 unsworn falsification to authorities. Date: V' - 04 _z©© q, JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Enso Ustovic specialist #78062FC JAMESON E. CHRISTOPHER 131 East Louther Street Carlisle, PA 17013 Eys,hi6itA LEGAL DESCRIPTION ALL that certain tract of had situated in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by East Loather Street; on the East by property now or formerly of John Wardecker and now or formerly of John D. Mock; on the North by Locust Alley; and on the West by property now or formerly of George N. Schuchmatn; CONTAINING 15 feet In front of said East Louther Street and extending back, at that width, 120 feet, and from thence at the width of 30 feet, the distance of 124 feet to said alley, the western line being straight. OKI801P62783 Ex,ohibit B Washington Mutual PO Box 44118 Jacksonville, FL 32231-4118 December 16, 2008 JAMESON E CHRISTOPHER 131 E LOLITHER ST CARLISLE PA 17013 000763 /PC 0605888528 ® Washington Mutual HOME LOANS NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 0605888528 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose. Specific information about the nature of the default is provided in the attached oages. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) maybe able to help to save your home. This Notice explains how the Rrogram works. To see if HEMAP can MIRvou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name address and Rhone number of Consumer Credit Counseling Agencies serving jour County are listed at the end of this Notice If you have any Questions, yoQu may call the PennVjyA k Housing Finance A=gy toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. N 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, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CURL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. I?IIIIIYIIInllelllllMEN ll ,.ee 4047 ..oo 63=6 2e27 C0826 Washington Mutual PO Box 44118 Jacksonville, FL 32231-4118 7100 4047 5100 6356 2010 December 16, 2008 JAMESON E CHRISTOPHER 821 FACTORY ST CARLISLE PA 17013 000762 /PC HOME LOANS 0605888528 ® Washington Mutual NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 0605888528 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose Specific information about the nature of the default is provided in the attached oa&u. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies sere. EQur County are listed at the end of this Notice If ypu have any questions. yo u m call the Pennsylvania Housing Finance Agency toll free at 1-800-342-2397 (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE 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. C0826 HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NUMBER: ORIGINAL LENDER: Jameson E. Christopher 131 E. Louther St. Carlisle PA 17013 0605888528 Vhl CURRENT LENDER/SERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE 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 STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). 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. TI3IS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses, and telephone numbers of designated consumer credit counseling agencies for the county in which the proReny is located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). 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. To stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEM" APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU IL4yE THE RIGHT TO FILE A HEM-AP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. 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.) 000762ico826 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: 131 E. Louther St. Carlisle PA 17013 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: 10/01/2008 $542.45 11/01/2008 $542.45 12/01/2008 $542.45 Other charges (explain/itemize): Uncollected Late Charges $134.04 Uncollected Fees: $217.80 Less Credits $0.00 TOTAL AMOUNT PAST DUE: $1979.19 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if 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 $1979.19, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash, cashier's check. 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 its rights to accelerate the m2d age 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 mortgaged property. *IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its 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 attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If-vQusurre the default within the THIRTY (30) DAY period, you will not be required to nay attorney's fees. R LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. C0826 DAY period and foreclosure proceedings have begu - If you have not cured the default within the THIRTY (30) your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never EARLIEST POSSIBLE SH . RIFFS 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 Sheriff's 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. HOW TO CONTACT THE LENDER: Name of Lender: Washington Mutual Home Loans, Inc. Address: 7255 Baymeadows Way Jacksonville, FL 32256 Phone Number: 866-926-8937 Fax Number: 904-281-3914 Contact Person: Collection Department Email Address: www.wamuhomeloans.com EFFECTS OF SHERIFF'S SALE: - You should realize that a Sheriff's 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 Sheriff's 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. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE 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 ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. 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. C0826 r, r i ' Jrr F p? b SHERIFF'S RETURN - REGULAR CASE NO: 2009-00736 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JPMORGAN CHASE BANK N A VS CHRISTOPHER JAMESON E KENNETH E GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - MORT FORE was served upon CHRISTOPHER JAMESON E the DEFENDANT , at 0018:55 HOURS, on the 11th day of February-, 2009 at 821 FACTORY ST CARLISLE, PA 17013 by handing to JAMESON CHRISTOPHER DEFENDANT 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 Service Affidavit Surcharge Sworn and Subscibed to before me this of So Answers: 18.00 4.50 .00 10.00 R. Thomas Kline .00 32.50 02/12/2009 GOLDBECK MCCAFFERTY MCKEEVER By: day eput rbi?iff A.D. C - ITI f CA ti In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMESON E. CHRISTOPHER (Mortgagor(s) and Record Owner(s)) 131 East Louther Street Carlisle, PA 17013 Defendant(s) PRAECIPE FOR JUDGMENT No. 09-736 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. Answer. Enter the Judgment in favor of Plaintiff and against JAMESON E. CHRISTOPHER by default for want of an Assess damages as follows: Debt Interest from 03/19/09 to Date of Sale per diem at $11.59 Total (Assessment of Damages attached) $58,503.37 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 ac> Judgment is entered in favor of JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. and against JAMESON E. CHRISTOPHER by default for want of an Answer and damages assessed in the sum of $58,503.37 as per the above certification. Pr onotary . Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY,'PENNSYLVANIA CIVIL ACTION - LAW JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff No. 09-736 VS. JAMESON E. CHRISTOPHER (Mortgagors and Record Owner(s)) 131 East Louther Street Carlisle, PA 17013 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Curt Long Prothonotary 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 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, JAMESON E. CHRISTOPHER, is about unknown years of age, that Defendant's last known residence is 821 Factory Street Carlisle, PA 17013, 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. f (?' igI d Date: LWW 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, JAMESON E. CHRISTOPHER, is about unknown years of age, that Defendant's last known residence is 821 Factory Street Carlisle, PA 17013, 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. r Date: 310 cl l Q kl t 78062FC 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. DATE OF THIS NOTICE: March 4, 2009 TO: JAMESON E. CHRISTOPHER 131 East Louther Street Carlisle, PA 17013 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMESON E. CHRISTOPHER (Mortgagor(s) and Record Owner(s)) 131 East Louther Street Carlisle, PA 17013 Defendant(s) TO: JA117ESON E. CHRISTOPHER 131 East Louther Street Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Tenn No. 09-736 DRORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FU E 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 1?I?cKegver Mk&ael T. GOLDBECK McCAFFERTY & MCKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Market Street. Philadelphia, PA 19106 215-825-6318 78062FC 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. DATE OF THIS NOTICE: March 4, 2009 TO: JAMESON E. C1 821 Factory Street Carlisle, PA 17013 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMESON E. CHRISTOPHER (Mortgagor(s) and Record Owner(s)) 131 East Louther Street Carlisle, PA 17013 Defendant(s) TO: JAMESON E. CHRISTOPHER 821 Factory Street Carlisle, PA 17013 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Term No. 09-736 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 BRING 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 Avenw 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 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, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMESON E. CHRISTOPHER (Mortgagor(s) and Record owner(s)) 131 East Louther Street Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 09-736 ORDER FOR JUDGMENT Please enter Judgment in favor of JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., and against JAMESON E. CHRISTOPHER for failure to file an Answer in the above action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of service of the Complaint, in the sum of $58,503.37. MUWJAQkaM-A..' Michael T. McKeever Attorney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 and that the name(s) and last known address(es) of the Defendant(s) is/are JAMESON E. CHRISTOPHER, 821 Factory Street Carlisle, PA 17013; I W/" M&L zt-" ? GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff ` ASSESSMENT OF DAMAGES TO THE PROTHONOTARY:` Kindly assess the damages in this case to be as follows: Principal Balance $52,073.96 Interest from 09/01/2008 through $2,306.40 03/18/2009 Reasonable Attorney's Fee $2,603.70 Late Charges $122.52 Costs of Suit and Title Search $900.00 Escrow Payments Due 2 X $134.07 $268.14 Fees $228.65 $58,503.37 M u? 4eKawu GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this Z- day of (' l mck '2009 damages are assessed as above. Prothy r-' e-V N 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, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMESON E. CHRISTOPHER Mortgagor(s) and Record Owner(s) 131 East Louther Street Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-736 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 03/19/09 to Date of Sale per diem at $11.59 $58,503.37 (Costs to be added) M w,vt??a ?rwu GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff a p E-y F C? u, 0 O p?C7 a?? f?v ?? za z? ??a o 00a?0 w.. ? W W UE"' UQ ?? ?W U ?d r t1 co 14- i i, C%j 1,a r r r r v F- rn = a dytn3? L4 ? r 1 V .. a. o o ?r ?o a b$ V? e- j Ct M v P J~ ALL that certain tract of land situated in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by East Louther Street; on- the East by property now or formerly of John Wardecker and now or formerly of John D. Meck; on the North by Locust Alley, and on the West by property now or formerly of George N. Schuchman; CONTAINING 15 feet in front of said East Louther Street and extending back, at that width, 120 feet„and from thence at the width of 30 feet, the distance of 120 feet to said alley, the western line being straight. PARCEL #: 02-21-0318-206 PROPERTY ADDRESS: 131 EAST LOUTHER STREET, CARLISLE PA 17013 .. il MUNICIPALITY: BOROUGH OF CARLISLE WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-736 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., Plaintiff (s) From JAMESON E. CHRISTOPHER (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 $58,508.37 L.L. $.50 Interest FROM 3/19/09 TO DATE OF SALE PER DIEM AT $11.59 Atty's Comm % Atty Paid $151.50 Plaintiff Paid Date: MARCH 20, 2009 Due Prothy $2.00 Other Costs Curti R. Long, o ry (Seal) 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 By: Deputy Supreme Court ID No. 56129 y.' k 09-736 GOLDBECK McCAFFERTY &t 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, N.A., AS ACQUIRI OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMESON E. CHRISTOPHER Mortgagor(s) and Record Owner(s) 131 East Louther Street Carlisle, PA 17013 Defendant( Term No. 09-736 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: CHRISTOPHER, JAMESON E. JAMEM M L CHRISTOPHER 821 Factory Street Carlisle, PA 17013 Your house at 131 East Louther Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, September 02, 2009, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $58,503.37 obtained by JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 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: 09-736 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., 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 We 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: h :/ttp /www.2WWeiphiafed.org,/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 09-736 8 Irvine Row Carlisle, PA 17013 717-243-9400 x- 09-736 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 ht!p://www.phfa.or,g/consuiners/homeowners/real.pgx. 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 homeretentionQgoldbecklaw.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 Courtenay Dunn who can be reached at 215-825-6311 or Fax: 215-825- 6411. Please reference our Attorney File Number of 78062FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. t7 C C= -n -TI t ?. cn j Z) CP 4 ?7R Si co { Go,& fek 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, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMESON E. CHRISTOPHER (Mortgagor(s) and Record Owner(s)) 131 East Louther Street Carlisle, PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-736 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER 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: 131 East Louther Street Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): JAMESON E. CHRISTOPHER 821 Factory Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: JAMESON E. CHRISTOPHER 821 Factory Street Carlisle, PA 17013 3. Name and last known address of everyjudgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17.105=2675 MANUFACTURERS AND TRADERS TRUST COMPANY AWAITING FOR LIENHOLDER ADDRESS MANUFACTURERS AND TRADERS TRUST COMPANY C/O Eugene E. Pepinsky Jr. AWAITING FOR ATTORNEY'S ADDRESS 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 131 East Louther Street Carlisle, PA 17013 (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. r DATED: March 18, 2009 ?C4(?, ? A&? w1?x GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Is" -0 A71 ?Z ???' Q ?. CC) PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3 i 83 V Goldbeck, McCafferty & McKeever Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABII.ITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMESON E. CHRISTOPHER Mortgagor(s) and Record Owner(s) 131 East Louther Street Cazlisle, PA 17013 TO THE PROTHONOTARY: Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 09-736 PRAECIPE FOR WRTI' OF EXECUTION Issue Writ of Execution in the above matter: ~y,pp pp q1'I`~ Amount Due 3a.so eBF ~ .50 '~ Interest from ~~ .00 '~ 3/19/2009 to Date of def. 00 '~ Sale per diem at x.50 a $11.59 ' !"15.50 -pp ATn/ (Costs to be added) C) ~ C ~ ~ '=i _,_. - --.n ~ ---~ r C.~l, ~ ~ __ '. U - c;~ VI ~" ~~:. _ . W $58,503.37 ~3.b0 ~l,b ~sa iL a ~"3~r RE ~rt ~ ~ ~~ "1/ By: _ GO ECK MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Li a Lee Pa. ID 78020 'stina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff W a 0 fn ~O ~U HBO za O U w H oFHW x~~''~ W~aow¢ a ~ W V w ~dq~~ a3Qa~a ~Q QOA~Q ¢~~QH ~~~°z WAO~C~7 Q ~ x ~i xi CxjwQOUQ z~~aw3 U Q ~Q~z ozHa~ a~~z '~ w U O H ~~ w a 3 ~ 00 ~ yC W t+ H ' ° v~ o ~ ° i ~ fir C a~ r..~ Q ~ U b o a ~' z^~~ a O U O AM w o ~' ~ w .. a a U ~. ~ ~ ~, y U N ~ M U V ~ ~ ~~~~ ,?~ a~ ~°N a ~ ~ N ~a~~~~ Q N a ~~ ~~'~ o /..,FrO ~N ~ ~ ~ ~o 0 ~° a o a~ C7 a ALL that certain tract of land situated in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by East Lowther Street; on the East by property now or formerly of John Wardecker and now or formerly of John D.1VIeck; on the North by Locust Alley; and on the West by property now or formerly of George- N. Schuchman; CONTAINING 15 feet in front of said East Lowther Street and extending back, at that width, 120 feet, and from thence at the width of 30 feet, the distance of 120 feet to said alley, the western line being straight. PARCEL #: 02-21-0318-206 PROPERTY ADDRESS: 131 EAST LOUTHER STREET, CARLISLE PA 17013 MUNICIPALITY: BOROUGH OF CARLISLE BEING the same premises which Scott S. Hench, married man by deed dated 7/30/1998 and recorded 8/3/1998 in Cumberland County in Deed Book Volume 182 at Page 797 granted and conveyed unto Jameson E. Christopher J GQldbec;k McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Mazket Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F!K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMESON E. CHRISTOPHER (Mortgagor(s) and Record Owner(s)) 131 East Louther Street Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CTVII. ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-736 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., 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: 131 East Louther Street Cazlisle, PA 17013 ~ C. ~ J -, 4='- o --_ 1.Name and address of Owner(s) or Reputed Owner(s): ~~ ? _ _ '~- _'=" ~; _.. - - JAMESON E. CHRISTOPHER - . , . ~ - , __. c= • - 821 Factory Street _ ., .~.' - Cazlisle, PA 17013 ^= t _ _ ; 2. Name and address of Defendant(s) in the judgment: ` -c` ~ - -= JAMESON E. CHRISTOPHER 821 Factory Street Cazlisle, PA 17013 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 Welfaze Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 MANUFACTURERS AND TRADERS TRUST COMPANY C/O Eugene E. Pepinsky Jr. 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108 MANUFACTURERS AND TRADERS TRUST COMPANY 1 EAST MAIN STREET FREDONIA, NY 14063 MANUFACTURERS AND TRADERS TRUST COMPANY d/b/a M&T Bank, successor in interest to Allfirst Bank, P.O. Box 17103 Baltimore, MD 21203 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 131 East Louther Street Cazlisle, PA 17013 (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 aze made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: Auguust 4, 2010 _~_--- GOLDBECK McCAFFERTY & McK)EVER BY: Barb Hand '. GOLDBECK McCAFFERTY 8~ 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 09-736 JPMORGAN CHASE BANK, N.A., AS ACQUIltE OF CERTAIN ASSETS AND LIABILJTTIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMESON E. CHRISTOPHER IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Mortgagor(s) and Record Owner(s) Docket No. 09-736 ~~~~ 131 East Louther Street '_'~' '- Carlisle, PA 17013 = Defendants , - _~ 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 WII.L BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CHRISTOPHER, JAMESON E. JAMESON E. CHRISTOPHER 821 Factory Street Carlisle, PA 17013 r~ F. ri~ ~: , _A, ~~~ c~ Your house at 131 East Louther Street, Carlisle, PA 17013 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 $58,503.37 obtained by JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 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: -r ---1 :~ . ~~ ~._ ~~~ 09-736 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABII.TTIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., 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 shaze of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.ora/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Cazlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION .~ 09-736 2 Liberty Avenue Cazlisle, PA 17013 ~! 09-736 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.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 78062FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. 09-736 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Mazket Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRE OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON-MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMESON E. CHRISTOPHER Mortgagor(s) and Record Owner(s) 131 East Louther Street Cazlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE ~ t'> r,. ~, =~ T_T ~ ~_ Za-- ~':j -~ CF ~ 1 ~. ~ :: ?:" Docket No 09-736 ~ ~ - - . _. =- ~; , ~: ,s ~.: THLS 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: CHRISTOPHER, JAMESON E. JAMESON E. CHRISTOPHER 131 East Louther Street Carlisle, PA 17013 Your house at 13I East Louther Street, Cazlisle, PA 17013 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 $58,503.37 obtained by JPMORGAN CHASE BANK, N.A., AS ACQUIltER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 09-736 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., the back payments, late chazges, 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 Brice 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 compazed 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 ofthe 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) aze filed-with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.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 Cazlisle, PA 17013 717-243-9400 09-736 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 09-736 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.g_ov 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.nhfa.org/consumers/homeowners/real aux. 5). Call the Plaintiff (your lender) at 8b6-926-8937 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 78062FC. Para information en espanol puede communicarse con Loretta a1215-825-6344. 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, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMESON E. CHRISTOPHER Mortgagor(s) and Record Owner(s) 131 East Louther Street Carlisle, PA 17013 Defendant(s) r-.a C7 a c~ ~ , ~, -:~ < :, - Ly, B °: ~,.,: - f 'r. _ ...v.. .- ._ . _lt `~ ~ . . ~"' R CERTIFICATION AS TO THE SALE OF REAL PROPERTY 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 ~X.'~' By: McCAFFERTY & McKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 'stina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 09-736 Attorneys for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-736 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, N.A., as Acquirer of Certain Assets and Liabilities of WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTIONG AS RECEIVER f/k/a WASHINGTON MUTUAL BANK F.A., Plaintiff (s) From JAMESON E. CHRISTOPHER (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 $58,503.37 L.L. $.50 Interest from 3/19/09 to Date of Sale per diem at $11.59 Atty's Comm % Due Prothy $2.00 Atty Paid $175.50 Other Costs Plaintiff Paid Date: 8/5/10 Da ' .Buell, rothonotary (Seal) By; Deputy REQUESTING' PARTY: Name: DAVID FEIN, 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. 82628 GOLDBECK McCAFFERTY & McKEEVER Suite 5090. Mellon Indepenae`nce Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 78062FC CF: 02/11/2009 FILED-OFFICE SD: 12/08/2010 OF THE P?OTNONOTARy $58,503.37 2010 NOV 30 AM l l : :jn JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON AO# , BANK FROM THE FEDERAL DEPOSIT 1?9Fffk#A CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 vs. JAMESON E. CHRISTOPHER Mortgagor(s) and Record Owner(s) 131 East Louther Street Carlisle, PA 17013 OURT OF COMMON PLEAS CUMBEGM?`ITY PENNIYLVAi mberiand County. CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Plaintiff Term No. 09-736 Defendant(s) 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/cawpewot-&?(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 . r BY: Keith C. Halili Legal Secretary 1 1 arm T tJ ..-?- Za'a.?a oa l o t :2 i M m ?o = m ?c 40i m m w D O C 9 m O a? m -O m Q m s 0 J rn? C4- r: ? ti ?- Cry 1... r r Q J C tN?f rL C3 O CL F3 ul .4 ? d CD F ' 00 i ti a co z C m ED O CU r a? V ? d C p cn i a u o U ?, ? ss- ZN d W W . (7 o ? Z? ? Q lsl is m d J m tt c m o a `L? • 3j T3 N {? } 7- 4 Z U d 71-- d t J?l ? Z m .r C x 40 cn t- j 0 4 1E. 00 00 4s 03 0 cr U1 W m it E ?a 0 „ L CD i,- 4 0 ??LU? Jul o w ?°4? o sn' r ca ci W O cr N Z Z 4 d 1ds? d 4 a m c G M d x 0 XOa (m x A Z C o m 0 co ?,-o ,ri p 0 r 1R 4 V 7 a tl- Y L O a m m C m m a T m T O d C ? O O io O m N ? in as ? m is to o a m ? G O o ° C V U3 z? g ¢ ? ~6 2 U U -0 u. 1,11 w ar ?' U d o rn ? O ?y. z ,? a o? C6 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??%tiq of i"uuabe?$?,3 JP Morgan Chase Bank, NA Case Number vs. 2009-736 Jameson E. Christopher SHERIFF'S RETURN OF SERVICE. 10/0812010 03:36 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1535 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 Jameson E. Christopher, located at, 131 East Louther Street, Carlisle, Cumberland County, Pennsylvania according to law. 10/08/2010 03:31 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1528 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: Jameson E. Christopher, by making known unto, Jameson E. Christopher, personally, at, 821 Factory Street, Carlisle, Cumberland County, Pennsylvania it, contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $898.92 October 26, 2010 SO ANSWERS, 21 RON RANDERSON, SHERIFF (c) CotntYSWte Snenff. Teimso t, t:r, GOLDBECK McCAFFERTY & McKEEVER Suite 5000 - Mellon Independence Center 701 Market Street 215-825-6320 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMESON E. CHRISTOPHER Mortgagor(s) and Record Owner(s) 131 East Louther Street Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-736 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., 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: 131 East Louther Street Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): JAMESON E. CHRISTOPHER 821 Factory Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: JAMESON E. CHRISTOPHER 821 Factory Street Carlisle, PA 17013 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 MANUFACTURERS AND TRADERS TRUST COMPANY C/O Eugene E. Pepinsky Jr. 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108 MANUFACTURERS AND TRADERS TRUST COMPANY 1 EAST MAIN STREET FREDONIA, NY 14063 MANUFACTURERS AND TRADERS TRUST COMPANY d/b/a M&T Bank, successor in interest to Allfirst Bank, P.O. Box 17103 Baltimore, MD 21203 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 131 East Louther Street Carlisle, PA 17013 (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 Ronny R Anderson Sheriff ' Jody S Smith Chief Deputy Richard W Stewart Solicitor JP Morgan Chase Bank, NA vs. Jameson E. Christopher Case Number 2009-736 SHERIFF'S RETURN OF SERVICE 10/08/2010 03:36 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1535 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 Jameson E. Christopher, located at, 131 East Louther Street, Carlisle, Cumberland County, Pennsylvania according to law. 10/08/2010 03:31 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 10-08-10 at 1528 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: Jameson E. Christopher, by making known unto, Jameson E. Christopher, personally, at, 821 Factory Street, Carlisle, Cumberland County, Pennsylvania it., contents and at the same time handing to him personally the said true and correct copy of the same. 12/08/2010 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriff's Sale Continued to 2/212011 01/31/2011 As directed by Michael McKeever, Attorney for the Plaintiff, Sheriffs Sale Continued to 3/212011 03/01/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney on 3/1/11. SHERIFF COST: $709.11 SO ANSWERS, (,iZ March 01, 2011 RON RANDERSON, SHERIFF s-01 & 6 /11-y j 24 CR , A I Grunty&, iie Shentt. Tee;: 't, In,: 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, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMESON E. CHRISTOPHER (Mortgagor(s) and Record Owner(s)) 131 East Louther Street Carlisle, PA 17013 No. 09-736 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., 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: 131 East Louther Street Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): JAMESON E. CHRISTOPHER 821 Factory Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: JAMESON E. CHRISTOPHER 821 Factory Street Carlisle, PA 17013 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 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE hh- DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 MANUFACTURERS AND TRADERS TRUST COMPANY C/O Eugene E. Pepinsky Jr. 210 WALNUT STREET PO BOX 11963 HARRISBURG, PA 17108 MANUFACTURERS AND TRADERS TRUST COMPANY 1 EAST MAIN STREET FREDONIA, NY 14063 MANUFACTURERS AND TRADERS TRUST COMPANY d/b/a M&T Bank, successor in interest to Allfirst Bank, P.O. Box 17103 Baltimore, MD 21203 4. Name and address. of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 131 East Louther Street Carlisle, PA 17013 (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: August 4, 2010 GOLDBECK MCCAFFERTY & Mc- EVER BY: Barb Hand 09-736 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, N.A., AS ACQUIRF OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMESON E. CHRISTOPHER Mortgagor(s) and Record Owner(s) 131 East Louther Street Carlisle, PA 17013 Defendant(s; of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 09-736 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: CHRISTOPHER, JAMESON E. JAMESON E. CHRISTOPHER 821 Factory Street Carlisle, PA 17013 Your house at 131 East Louther Street, Carlisle, PA 17013 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 $58,503.37 obtained by JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 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: 09-736 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., 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. 8. You may contact the Foreclosure Resource Center: http://www hip 'ladelpliiafed.oraforeclosure/ 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 09-736 2 Liberty Avenue Carlisle, PA 17013 09-736 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 h!tp://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 78062FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL that certain'tract of land situated in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by East Louther Street; on the East by property now or formerly of John Wardecker and now or formerly of John D. Meck on the North by Locust Alley; and on the West by property now or formerly of George N. Schuchman; CONTAINING 15 feet in front of said East Louther Street and extending back, at that width, 120 feet, and from thence at the width of 30 feet, the distance of 120 feet to said alley, the western line being straight. PARCEL #: 02-21-0318-206 PROPERTY ADDRESS: 131 EAST LOUTHER STREET, CARLISLE PA 17013 MUNICIPALITY: BOROUGH OF CARLISLE BEING the same premises which Scott S. Hench, married man by deed dated 7/30/1998 and recorded 8/3/1998 in Cumberland County in Deed Book Volume 182 at Page 797 granted and conveyed unto Jameson E. Christopher WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-736 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, N.A., as Acquirer of Certain Assets and Liabilities of WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTIONG AS RECEIVER f/k/a WASHINGTON MUTUAL BANK F.A., Plaintiff (s) From JAMESON E. CHRISTOPHER (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 $58,503.37 L.L. $.50 Interest from 3/19/09 to Date of Sale per diem at $11.59 Atty's Comm % Due Prothy $2.00 Atty Paid $175.50 Plaintiff Paid Date: 8/5/10 Other Costs (Seal) REQUESTING PARTY: Name: DAVID FEIN, ESQUIRE Address: GOLDBECK MCCAFFERTY & MCKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 191.06 Attorney for: PLAINTIFF Telephone: 215-627-1322 Deputy Supreme Court ID No. 82628 On September 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Carlisle Borough, Cumberland County, PA, Known and numbered as, 131 East Louther Street, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 22, 2010 By: CQ Real Estate Coordinator -1 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. r- Marie CovneJEditor NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 SWORN TO AND SUBSCRIBED before me this CUMBERLAND LAW JOURNAL Writ No. 2009-736 Civil JP Morgan Chase Bank, NA, As Aquirier of Certain Assets and Liabilities of Washington Mutual Bank from the Federal Deposit Insurance Coproration Acting as Receiver F/K/A Washington Mutual Bank FA VS. Jameson E. Christopher Atty.: Michael McKeever ALL that certain tract of land situated in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by East Louther Street; on the East by property now or formerly of John Wardecker and now or formerly of John D. Meck; on the North by Locust Alley; and on the West by property now or formerly of George N. Schuchman; CONTAINING 15 feet in front of said East Louther Street and extending back, at that width, 120 feet, and from thence at the width of 30 feet, the distance of 120 feet to said alley, the western line being straight. PARCEL #: 02-21-0318-206. PROPERTY ADDRESS: 131 EAST LOUTHER STREET, CARLISLE PA 17013. MUNICIPALITY: BOROUGH OF CARLISLE. BEING the same premises which Scott S. Hench, married man by deed dated 7/30/ 1998 and recorded 8/3/1998 in Cumberland County in Deed Book Volume 182 at Page 797 granted and conveyed unto Jameson E. Christopher. 21 k, the Patriot-News Co. 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 i4t Patr1*otwXews Now you know 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. - 2009-736 Civil Term Morgan Chase Bank, NA, As Aquirler of Certain Assets and This ad ran on the date(s) shown below: Liabilities of Washington Mutual Bank from the Federal Deposit 10/15/10 insurance Coproration Acting as Receiver F/K/A Washington 10/22/10 Mutual Bank FA Vs 10/29/10 Jameson E. Christopher Atty- Michael McKeever ALL that certain tract of land situated in the -.. t__ ! .. . Borough of Carlisle, Cumberland County.- Pennsylvania, bounded and described a, (` .. / follows: Sworn to and ?crib"fore me th?s 10 November, 2010 A. D. ON the South by East Louther Street; on the . East by P1OINrty now or former/ of John Wardecker and now or formerly of John D. Meek; on the North by Locust Alley; and on the ' ?_ , - - West by property now or formerly of George N. Notary Public Schuchman; CONTAINING 15 feet in front of said East Louther Street and extending back, at that width, 120 feet, and from thence at the width of 30 feet, the distance of 120 feet to said COMMONWEALTH OF PENNSYLVANIA alley, the western line being straight. 591 _ PARCEL #: 02-21-0318-206 Notww PROPERTY ADDRESS: 131 EAST Sherrie L Kisser, wry public LOUTHER STREET, CARLISLE PA 17013 Lower Paxton T •, Dauphin County MUNICIPALITY: BOROUGH OF MY CO ?m? E>?res Nov • 2'o 201 CARLISLE Member, Penn"Wan n of Not?rie• BEING the same premises which Scott S. Hench, married man by deed dated 7/30/1998 and recorded 0/1998 in Cumberland County in Deed Book Volume 182 at Page 797 granted and conveyed unto Jameson E. Christopher KML LAW GROUP,P.C. 78062FC Suite 5000 CF: 02/11/2009 BNY Mellon Independence Center F 1 L E 0-OF P!CE"' SD: 06/05/2013 701 Market Street OF THIS PIROTHONOTAW'f $58,503.37 Philadelphia,PA 19106-1532 215-627-1322 2013 MAY 10 PM 3. { 2 Attorney for Plaintiff JPMORGAN CHASE BANK,N.A.,AS CUMBERLA 0 COUN tA THE COURT OF COMMON PLEAS ACQUIRER OF CERTAIN ASSETS AND PENNSYLVANIA LIABILITIES OF WASHINGTON MUTUAL of Cumberland County BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS CIVIL ACTION—LAW RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. ACTION OF MORTGAGE FORECLOSURE 7255 Baymeadows Way Jacksonville,FL 32256 Term Plaintiff No. 09-736 vs. JAMESON E. CHRISTOPHER Mortgagor(s)and Record Owner(s) 131 East Louther Street Carlisle,PA 17013 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c) (2) Robert Murray, an employee of KML Law Group,P.C., counsel of Plaintiff,hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: (X) Personal Service by the Sheriffs Office/competent adult(As per Sherry at the so,def. personally served at 821 Factory St.on 4/5/13). ( ) Certified mail by KML Law Group,P.C. (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by KML Law Group,P.C.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 KML Law Group,P.C. (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 KML Law Group,P.C. (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A. Section 4904. Res e Ily submitted, BY: Robert 1\J ay Legal Assistant i Name aril Address of Sender Crook type of mail or servkre: Affix Stomp Here GOLDBECK (it iss'x'dasa I SUITE 5000 0 CCO ed 0p a�red very 4nta r of l) or for certificate adddilionali ties 701 MARKET STREET ❑Delivery Confirmation O Return Rocalpt forMerchandise of rids bill) PHILADELPHIA,PA ❑ Exibress Mail ❑Signatwe Confirmation Postmark and 19106-1532 dD insured Date of Race Dt 02 1M $42-S4 p Handing "Actual r Q0042f35951'. .DgC1t9 2012 ArUde Number Addresses(Nano,Street,City,State,a-Code) Postage Fee 11yJltl ROlg(Z1ItGi]OE,191A6 chm 1. PA DEPARTMENT OF PUBLIC WELFARE- Bureau of Child Support Enforcement Health and.Welfare Bldg.-Room 432 TENAN SJOCCUP NTS P.O.Box 2875 131 Eas Loather reef 2. ants urg, r e, DOMESTIC RELATIONS OF CUMBERLAND 1ta ��s` COUNTY �2 s 2x 3, Carlisle,PA 17013 o r MANUFACTURERS AND TRADERS TRUST sy COMPANY 1l) ' j i EAST WIN STREE, 4 FREDONIA,NY 14063 MANUFACTURERS AND TRADERS TRUST COMPANY 5 d/b/a M&T Bank successor in interest to Allfirst Bank,P.O.Box 17103 Baltimore,MD 21203 6. COMPANY C/O Eugene E.PePinsky Jr.,Esquire 210 WALNUT STREET PO BOX 11963 HARRISBURG,PA 17108 7. 8. Total Number of Piece Total Number of Recas Postmaster,Par(Name of receiving employee) ustad by sender f Received at oat once See Privacy Act Statement on Reverse PS Form 3877,February 2002(Page 1 of 1) �l Complete by Typew her,InK,or Ball Point Pen 78062FC Cumberland County Safe Date:06/05/2013 JAMESON E.CHRISTOPHER KML LAW GROUP,P.C. Suite 5000—BNY Mellon Independence Center 701 Market Street Philadelphia,PA 19106 215-825-6320 Attorney for Plaintiff JPMORGAN CHASE BANK,N.A.,AS ACQUIRER IN THE COURT OF COMMON PLEAS OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE of Cumberland County FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. CIVIL ACTION-LAW 7255 Baymeadows Way Jacksonville,FL 32256 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. Term JAMESON E. CHRISTOPHER No. 09-736 Mortgagor(s)and Record Owner(s) 131 East Louther Street Carlisle,PA 17013 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK,N.A.,AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A.,Plaintiff in the above action,by and through an authorized employee of its attorneys,KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 131 East Louther Street Carlisle,PA 17013 1.Name and address of Owner(s)or Reputed Owner(s): JAMESON E. CHRISTOPHER 821 Factory Street Carlisle,PA 17013 2.Name and address of Defendant(s)in the judgment: JAMESON E. CHRISTOPHER 821 Factory Street Carlisle,PA 17013 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 MANUFACTURERS AND TRADERS TRUST COMPANY 1 EAST MAIN STREET FREDONIA,NY 14063 MANUFACTURERS AND TRADERS TRUST COMPANY d/b/a M&T Bank, successor in interest to Allfirst Bank,P.O. Box 17103 Baltimore,MD 21203 MANUFACTURERS AND TRADERS TRUST COMPANY C/O Eugene E.Pepinsky Jr.,Esquire 210 WALNUT STREET PO BOX 11963 HARRISBURG,PA 17108 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 131 East Louther Street Carlisle,PA 17013 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: May 8,2013 Law ro C. BY: Robert M ay Legal Assistant SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny n onn R Anderson ;- Sheriff T1 i rot o f�J 0 7 A Jody S Smith Chief Deputy l V ��a�i• 23 Richard W Stewart - IU Ml3tfiLAh'D Solicitor OFFICE OF THE SHERIFF P L NI c V J 1 l,VANIA JP Morgan Chase Bank, NA vs. Case Number Jameson E. Christopher 2009-736 SHERIFF'S RETURN OF SERVICE 04/03/2013 10:21 AM - Deputy Noah Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 821 Factory Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 04/05/2013 09:32 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant, to wit: Jameson E. Christopher at 821 Factory Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 06/05/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on June 5, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Jill Jenkins, on behalf of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $998.03 SO ANSWERS, July 01, 2013 RbNO R ANDERSON, SHERIFF ,04�` LAC 3 -17 (c)CountySuite Sheri H,Teleosoft,Inc. KML Law Group,P'C. Suite 5000—BNY Independence Center 701 Mark&Street , Philadelphia,PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,N.A.,AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF IN THE COURT OF COMMON PLEAS WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION of Cumberland County ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way CIVIL ACTION-LAW Jacksonville, FL 32256 Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JAMESON E.CHRISTOPHER (Mortgagor(s) and Record Owner(s)) 131 East Louther Street No. 09-736 Carlisle,PA 17013 Defendants) AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK,N.A.,AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A.,Plaintiff in the above action,by counsel,KML Law Group, P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 131 East Louther Street Carlisle,PA 17013 l.Narne and address of Owner(s)or Reputed Owner(s): JAMESON E.CHRISTOPHER 821 Factory Street Carlisle,PA 17013 2.Name and address of Defendant(s)in the judgment: JAMESON E.CHRISTOPHER 821 Factory Street Carlisle,PA 17013 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 MANUFACTURERS AND TRADERS TRUST COMPANY I EAST MAIN STREET FREDONIA,NY 14063 MANUFACTURERS AND TRADERS TRUST COMPANY I d/b/a M&T Bank,successor in interest to Allfirst Bank,P.O.Box 17103 Baltimore,MD 21203 MANUFACTURERS AND TRADERS TRUST COMPANY C/O Eugene E.Pepinsky Jr.,Esquire 210 WALNUT STREET PO BOX 11963- HARRISBURG,PA 17108 4.Name and address of the last recorded holder of every mortgage of record: 5.Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7.Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 131 East Louther Street Carlisle,PA 17013 1 verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.Section 4904 relating to unworn falsification to authori s. DATED: By: KML TA-+)GROUP,P.C. Michael McKeever Pa.ID 56129 Jay E. Mvitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristin Murtha Pa.ID 61858 David Fein Pa.ED 82628 Thomas Puleo Pa.ID 27615 —Joshua I.Goldman Pa.205047 —)Ljill P.Jenkins Pa.ID 306588 Attorneys for Plaintiff 09-736 ICVM Law Group,P.C. Suite 5000-BNY Independence Center_ 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,N.A.,AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE IN THE COURT OF COMMON PLEAS FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. of Cumberland County 7255 Bay=adows Way Jacksonville,FL 32256 CIVIL ACTION-LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE JAMESON E. CHRISTOPHER Mortgagor(s)and Record Owner(s) 131 East Louther Street Docket No. 09-736 Carlisle,PA 17013 Defendant(s THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: CHRISTOPHER,JAMESON E. JAMESON E. CHRISTOPHER 821 Factory Street Carlisle.,PA 17013 Your house at 131 East Louther Street,Carlisle,PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday,June 05,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$58,503.37 obtained by JPMORGAN CHASE BANK,N.A.,AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A.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: • 09-736 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK,N.A.,AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER FIK/A WASHINGTON MUTUAL BANK F.A.,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 Sheriff s 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: b=://www.philadelphiafed.ore/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 09-736 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.bud.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 ht!p://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@knfflawuoup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 78062FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL that certain tract of land situated in the Borough of Carlisle, Cumberland County, Pennsylvania, bounded and described as follows: ON the South by East Louther Street; on the East by property now or formerly of John Wardecker and now or formerly of John D. Meck; on the North by Locust Alley; and on the West by property now or formerly of George N. Schuchman; CONTAINING 15 feet in front of said East Louther Street and extending back, at that width, 120 feet, and from thence at the width of 30 feet, the distance of 120 feet to said alley, the western line being straight. TAX PARCEL#: 02-21-0318-206 BEING PREMISES: 131 EAST LOUTHER STREET, CARLISLE PA 17013 MUNICIPALITY: BOROUGH OF CARLISLE IMPROVEMENTS consist of a residential dwelling. BEING the same premises which Scott S. Hench, married man by deed dated 7/30/1998 and recorded 8/3/1998 in Cumberland County in Deed Book Volume 182 at Page 797 granted and conveyed unto Jameson E. Christopher SOLD as the property of JAMESON E. CHRISTOPHER WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 09-736 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,N.A.,AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A.Plaintiff(s) From JAMESON E. CHRISTOPHER (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: $58,503.37 L.L.:$.50 Interest FROM 3/19/2009 TO DATE OF SALE PER DIEM AT$11.59 Atty's Comm: Due Prothy: $2.25 Atty Paid: $910.61 Other Costs: Plaintiff Paid: Date: 12/11/12 David D.Bu 11,Prothonota (Seal) Deputy REQUESTING PARTY: Name: JILL P.JENKINS,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106-1532 Attorney for: PLAINTIFF TRUE COPY FROM'RECORD In Testimony whereof,there unto set.my hand Telephone: 215-627-1322 and the seal of said-C&44 at Carlisle, pa. Supreme Court ID No.306588 This _day'of,:;- � Prolbonotar On March 12, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Borough of Carlisle, Cumberland County, PA, Known and numbered as, 131 East Louther Street, Carlisle, Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 12, 2013 By: Real Est t Coe ordinator qZ. aZ d Z 1 330 1161 CUMBERLAND LAW JOURNAL Writ No. 2009-736 Civil JP MORGAN CHASE BANK, N.A. vs. JAMESON E. CHRISTOPHER Atty.:Jill Jenkins ALL that certain tract of land situated in the Borough of Carlisle, Cumberland County, Pennsylvania, 'bounded and described as follows: ON the South by East Louther .Street; on the East by property now or formerly of John Wardecker and .now or formerly of John D.Meck;on the North by Locust Alley;and on the West by property now or formerly of George N.Schuchman;CONTAINING 15 feet in front of said East Louther 'Street and extending back, at that width, 120 feet, and from thence at the width of 30 feet, the distance of 120 feet to said alley,the western line 'being straight. TAX PARCEL#:02-21-0318-206. BEING PREMISES: 131 EAST LOUTHER STREET, CARLISLE PA 17013. MUNICIPALITY: BOROUGH OF CARLISLE. IMPROVEMENTS consist of a residential dwelling. BEING the same premises which Scott S. Hench, married man by deed dated 7/30/1998 and recorded 8/3/1998 in Cumberland County in Deed Book Volume 182 at Page 797 granted and conveyed unto Jameson E. Christopher. SOLD as the property of JAME- SON E. CHRISTOPHER. 24 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: April 12, April 19 and April 26, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time,place and character of publication are true. r sa arie Coyne, Edito SWORN TO AND SUBSCRIBED before me this dav of April, 2013 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 The Patriot-News Co. -2020 Technology Pkwy ([Of a Suite 300 , Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE 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 Marianne Miller, 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 2020 Technology Pkwy, Suite 300, in the, Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and 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/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s)shown below: - - ---- — - 04116/13 2009.736 Civil J MORGAN CHASE BANK, A 04/23/13 VS. C AMESON E.CHRISTOPHE 04/30/13 Atty. Jill Jenkins ALL that certain tract of land situated in the . . . . . . . . . . . . . . . . . . . . Borough of Carlisle,Cumberland County, Pennsylvania, bounded and described as follows: Sworn to and bscribed before me this 13 day of May, 2013 A.D. ON the South by EastLoutherStreet;on the East by property now or formerly of John Wardecker and now or formerly of John D. Meck;on the North by Locust Alley;and UAt on the West by property now or formerly Public of George N.Schuchman;CONTAINING 15 feet in front of said East Louther Street and extending back,at that width,120 feet, g� and from thence at the width of 30 feet,the distance of 120 feet to said alley,the western line being straight. COMMONWEALTH OF PENNSYLVANIA ' TAX PARCEL#:02-21-0318-206 l Notarial Seal BEING PREMISES: 131 EAST Holly Lynn Warfel,Notary Public y' LOUTHER STREE ,LSAB4SLE PA Washington Twp.,Dauphin County f 17013 My Commission Expires Dec.12,2016 MUNICIPALITY: BOROUGH OF MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES CARLISLE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which Federal National Mtg Assoc is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2013, under and by virtue of a writ Execution issued on the 11th day of December, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 736, at the suit of Washington Mutual Bank Receiver against Jameson E Christopher is duly recorded as Instrument Number 201324170. IN TESTIMONY WHEREOF, I have hereunto set my hand and al of said office this �� day of A.D. c Recorder of Deeds Recorder of ,Cumberland County,Carlisle,PA My Commission Wires the Fust Monday of Jan.2014