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09-5645
GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF 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 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. GEORGE E. SEIDLE JR. Mortgagor and Record Owner 813 Wertzville Road Enola, PA 17025 Defendant Term No. - S(ON Jr CIVIL ACTION: MORTGAGE ROR1F('i-r)!nR ai r eiv;< ?TFrM 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 FtE 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, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS . ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. 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 htip://www.vhfa.org/consumers/homeowners/real.gVx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org;/foreclosure/ 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(Qgoldbecklaw 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 85409FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 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, 7255 Baymeadows Way, Jacksonville, FL 32256. 2. The names and addresses of the Defendant is GEORGE E. SEIDLE JR., 813 Wertzville Road, Enola, PA 17025, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On October 31, 2002 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WASHINGTON MUTUAL BANK FA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1781 , Page 2258. The mortgage has been assigned 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 by assignment of Mortgage. Plaintiff is the real party in interest pursuant to a purchase or transfer of the mortgage obligation from the last record holder and an Assignment of Mortgage to Plaintiff has been and/or will be lodged for recording with the Recorder of Deeds in the ordinary course of business. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for March 01, 2009 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 ....................................................................................$86,549.21 Interest from 02/01/2009 through 07/31/2009 at 6.5000% .......................$2,789.21 Per Diem interest rate at $15.41 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,327.46 Late Charges from 03/01/2009 to 07/31/2009 .............................................$155.50 Monthly late charge amount at $31.10 Costs of suit and Title Search ...................................................................... $900.00 Suspense ..................................................................................................... ($614.74) Escrow Advance .......................................................................................$6,929.69 Other Fees ......................................................................................................$21.70 Monthly Escrow amount $263.30 $101,058.03 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 terns judgment in mortgage foreclosure in the sum of $101,058.03, together with interest at the rate of $15.41, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriffs Sale of the Property. By: VANaLL 11 /J4W(/\ GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION I, Ismeta Dumaniie , as the representative of the servicing agent for 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: 070 ae7,9 /Oeawo i)Wtx ra e'3 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION #85409FC - GEORGE E. SEIDLE JR. 813 Wertzville Road Enola, PA 17025 Prepared By and Return To: Beth Gradel GOLDBECK McCAFFERTY & McKEEVER Mellon Independence Center - Suite 5000 701 Market Street Philadelphia, PA 19106-1532 215-825-6344 3065518163 GMM File Number: 85409FC Parcel ID#: 09-14-0835-057 ASSIGNMENT OF MORTGAGE MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WASHINGTON MUTUAL BANK FA (Assignor), for and inconsideration of the sum of Ten Dollars ($10.00) and other good and valuable consideration, the receipt of which is acknowledged, does grant, bargain, sell, assign and transfer 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. 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 (Assignee), all of its right, title and interest, as holder of, in, and to the following described mortgage, the property described and the indebtedness secured by the mortgage: Executed GEORGE E. SEIDLE JR. , Mortgagor(s); to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WASHINGTON MUTUAL BANK FA. Bearing date of October 31, 2002; Amount Secured: $98,400.00; Recorded on November 07, 2002; in Book 1781, Page 2258; in the Recorder of Deeds Office of Cumberland County, Commonwealth of Pennsylvania ("Mortgage") Property: 813 Wertzville Road, Enola, PA 17025 AS FURTHER DESCRIBED IN EXHIBIT "A", ATTACHED AND INCORPORATED INTO THIS ASSIGNMENT. Together with the note or obligation described in the Mortgage endorsed to the Assignee,("Note") and all moneys due and to become due on the Note and Mortgage, with interest. Assignee its successors, legal representatives and assigns shall hold all rights under the Note and Mortgage forever, subject however, to the right and equity of redemption, if any, of the maker(s) of the Mortgage, their heirs and assigns forever. Assignor, by its appropriate corporate officers, has executed and sealed with its corporate seal this Assignment of Mortgage on this 30 day of _ c/ULY , 2009. MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WASHINGTON MUTUAL BANK FA (Affix Corporate Seal) (SEAL) Name: W t Dalton Title: Vice President 1?amei, (SEAL) t Barbara Hindman Title: "Vice president ss: STATE OF Florida ) COUNTY OF Doran ) BE IT REMEMBERED, that on this 30 day of JULY , 2009, before me, the subscriber, a Notary Public personally appeared Mar aret Dalton • LD/YY officers of Assignor, who I am satisfied are the persons who signed the within instrument and they acknowledged that they signed, sealed with the corporate seal and delivered the same as such officers aforesaid, and that the within instrument is the voluntary act and deed of such corporation made by virtue of a Resolution of its Board of Directors. ---4V,x- Notary blic My c mission expires: I hereby certify the address of the Assignee is: 7255 aym adows Way, dacksonville,FL 32256 30 5518163 WEWYUCEM • . z Notary public - Stab of FlorWa My COMM' UPi?aa An 14.201, I Com '??°„+?`" ` mission +f Do 851748 Case #: 85409FC EythibitA ALL THAT CMZMNM piece or parcel of land situate in the Township of East Pennsbora, Cumberland County, Petomsylvam a, mole particularly bounded and described as follows, to wit: BWnwING at a point on the north side of. the State Highway k =a n as Route No. 944 as shown on the hereinafter mentioned Plan of Lots said point being.350 feet, measured in an eastwardly direction from Carol Lane (40 feet wide) said point also being the dividing line between Lots Nos. 18 and 19, in the plan of Penn Heights, thence north 3 degrees 4 minutes west, along said dividing line, a distance of 186.95 feet to Lot No. 4 on. said plan; thence south 85 degrees 25 minutes east, along-Lots Nos. 4 and 5 on said plan, a distance of 70-feet to lot No. 17 on said plan; thence south 3 degrees 4 minutes east along said Lot No. 17, a distance of 186.08 feet to the north side of the aforesaid State Highway, thence south 84 degrees 42 minutes west along said State Highway, a distance of 70 feet to Lot No. 19, the place of beginning. BEING Lot No. 18 in the Plan of Penn Heights recorded in the Culoerland County Recorder's Office in Plan Book 6, page 28. HAVING thereon erected a single dwelling house known as 813 Wertzville Read. PARCEL, NL14BM 09-14-0835-057 BEING the same premises which Hazel A. Seidle, widow, by Indenture dated May 8, 2002 and recorded August 22, 2002 in the Office of the Recorder of Deeds in and for the County of Cumberland in Deed Book 253 page 1327, granted and conveyed unto George E. Seidle, Jr. 1 Cmtify i?lis to be recorded fit C'=_ n b.; sa-rd Co-anty PA 1101coi-der of Deeds BK 1781 P62274 Ex, hi6it ? Washington Mutual FL5-7730 PO BOX 44090 Jacksonville, FL 32231-4090 June 10, 2009 #BWNCLNN# #0930659518916398# GEORGE E SEIDLE JR 813 WERTZVILLE RD ENOLA PA 17025 000811 /PC/FT 3065518163 WaMu' is becoming CHASE 0 Your house is your home. We want to keep it that way. We need to talk -- call 1-866-926-8937 today. You are going through tough times - we can help. In fact, we believe your home loan may be eligible for a loan modification program - we may be able to change the term of your loan, the interest rate, and maybe even the principal due date, to reduce the monthly payment to an amount you can afford. Call us today at 1-866-926-8937 so we can help you turn things around. We'll discuss your current situation (outlined in the enclosed letter) and the options available to you. But we cannot stress enough that the longer you delay calling us, the fewer chances you may have to keep your home. It will only take a few minutes on the phone - one of our Loan Specialists will work with you to determine the option that best fits your needs. There are several options available - call us now and let us see which one will work best for you. We are committed to working with you to find a way to help you keep your home, but you must call us immediately at 1-866-926-8937 - the longer you delay, the fewer options you may have. Homeowner's Assistance Department Washington Mutual 1-866-926-8937 P. S. The enclosed legal letter outlines in detail, your current situation and the consequences that will occur unless we receive the required financial information from you and can approve you for a modification. Once you call us with the information needed, then we can work together to determine the option that will work best for you. We cannot guarantee that you will be approved, but your only chance of saving your home is by contacting us immediately. Please don't delay - call us now at 1-866-926-8937. Washington Mutual FL5-7730 PO BOX 44090 Jacksonville, FL 32231-4090 June 10, 2009 GEORGE E SEIDLE JR 813 WERTZVILLE RD ENOLA PA 17025 000811 WaMw is becoming CHASE 0 NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 3065518163 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgaagg on your home is in default and the lender intends to foreclose Specific information about he nature of the default is provided in the attached 12ages_ 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 serving your County are listed at the end of this Notice If you have any guestionc y may 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, PLIES 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): George E. Seidle Jr. PROPERTY ADDRESS: 813 Wertzville Rd Enola PA 17025 LOAN ACCT. NUMBER: 3065518163 ORIGINAL LENDER: Sra CURRENT LENDERlSERVICER: 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. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAY 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" EXPLAIN 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 number of designated consumer credit counseling agencies for the county in which the proper 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 HEMAP 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 HAVE THE RIGHT TO FILE A H •MAP APPLI ATION EVEN BEYOND THESE TIME PERIOD 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.) 000811/CO826 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 813 Wertzville Rd Enola PA 17025 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: 03/01/2009 $885.26 04/01/2009 $1472.41 05/01/2009 $1472.41 06/01/2009 $1472.41 Other charges (explain/itemize): Uncollected Late Charges $124.40 Uncollected Fees: $10.85 Less Credits $614.74 TOTAL AMOUNT PAST DUE: $4823 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 $4823, 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 mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upgnn your morteaW 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 you cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. C0826 nlvnl 1 V t, nr. Inr. Lr;rAUL.I. rKl K '1' 'fiERIFF S 'ALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at anv _• , r rr mm n other reQuirements under the mortgagc- Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Fax Number: Contact Person: Email Address: Washington Mutual Home Loans, Inc. 7255 Baymeadows Way Jacksonville, FL 32256 866-926-8937 904-281-3914 Collection Department www.wamuhomeloans.com EFFECTS OF SHERIFF' 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 An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Washington Mutual offers loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at (866) 926-8937 to discuss your options. The longer you delay the fewer options you may have. 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 0 FUD-,OFFICE OF THE PROTHONOTARY, 2W AUG 13 PM 3: 23 CUMBE:aAio Co PEN YU" *73-50 PO 'ATK M 393059 e aa9is9 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor JP Morgan Chase Bank, NA vs. George E. Seidle, Jr. IV C1 C11046", OFFICE OF TI-E "ERIFE OF THt Roll 2009 AUG 19 AM 9: 14 CUWE!'iL.```a.,Lj VVLM PENNSYLVANIA Case Number 2009-5645 SHERIFF'S RETURN OF SERVICE 08/15/2009 12:43 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on August 15, 2009 at 1243 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: George E. Seidle, Jr., by making known unto himself personally, defendantat 813 Wertzville Road Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 August 17, 2009 SO ANSWERS, s R-THOMAS KLINE, SHERIFF ByZ?- Od ?- Deputy Sheriff 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 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. GEORGE E. SEIDLE JR. (Mortgagor(s) and Record Owner(s)) 813 Wertzville Road Enola, PA 17025 Defendant(s) PRAECIPE FOR JUDGMENT No. 09-5645 THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against GEORGE E. SEIDLE JR. by default for want of an Answer. Assess damages as follows: Debt Interest from 09/22/2009 to Date of Sale per diem at $15.41 Total (Assessment of Damages attached) $102,184.85 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 a-s app9 , Judgment is entered in favor of JPMORGAN CHASE BANK, N., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER and against GEORGE E. SEIDLE JR. by default for want of an Answer and damages assessed in the sum of $102,184.85 as per the above certification. P lonotary a r 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, GEORGE E. SEIDLE JR., is about unknown years of age, that Defendant's last known residence is 813 Wertzville Road Enola, PA 17025, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: gIlle 85409FC 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: September 9, 2009 GEORGE E. SEIDLE JR. SEIDLE JR., GEORGE E. 813 Wertzville Road Enola, PA 17025 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 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. GEORGE E. SEIDLE JR. (Mortgagor(s) and Record Owner(s)) 813 Wertzville Road Enola, PA 17025 Defendant(s) TO: GEORGE E. SEIDLE JR. 813 Wertzville Road Enola, PA 17025 In the Court of Common Pleas of Cumberland County CIVIL ACTION - LAW Action of Mortgage Foreclosure Tenn No. 09-5645 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LEGAL SERVICES INC S Irvine Roc Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Libeily Avenue Carlisle, PA 17013 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 0 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 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. GEORGE E. SEIDLE JR. (Mortgagor(s) and Record owner(s)) 813 Wertzville Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 09-5645 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, and against GEORGE E. SEIDLE JR. 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 $102,184.85. 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 7255 Baymeadows Way Jacksonville, FL 32256 and that the name(s) and last known address(es) of the Defendant(s) is/are GEORGE E. SEIDLE JR., 813 Wertzville Road Enola, PA 17025; 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 Interest from 02/01/2009 through 09/21/2009 Reasonable Attorney's Fee Late Charges Costs of Suit and Title Search Escrow Payments Due 1 X $263.30 Suspense Escrow Advance Other Fees $ 86,549.21 $3,590.53 $4,327.46 $217.70 $900.00 $263.30 ($614.74) $6,929.69 $21.70 $102,184.85 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff AND NOW, this o1? day of pQ'f 2009 damages are assessed as above. irk 44 o Prothy --4-/ 0 S1EP 23 i=ii ! : 3 i Nv:il. 7Y 44-00 pa Ar" Co Aewsa e amt 4l0 NnF+e:Q, wulgd 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 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff No. 09-5645 vs. GEORGE E. SEIDLE JR. (Mortgagors and Record Owner(s)) 813 Wertzville Road Enola, PA 17025 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-captione tter r against you. urt Long Prothonota By: Deputy If you have any questions concerning the above, please contact: Michael T. McKeever q/23107 Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. GEORGE E. SEIDLE JR. Mortgagor(s) and Record Owner(s) 813 Wertzville Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 09-5645 RECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due 102.184.85 Interest from 09/22/2009 to Date of Sale per diem at $15.41 (Costs to be added) GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff top ,Vk O r M ? i' _: vow ?6 ci C4 ? tl_ err, -?;, C-4 C U d w a A, z O ?O ? U ?,OO z? O U W x z z ? z w wa•,?Ow a3o? Q Q°Qz wwH ¢HwQ ??ExO x ? Q 0 Uw?U ?QQz xz?¢ o¢?D ?D a? z ^w U z o _ U 0 0 Q o a O V? R; 'N Q w o taw w w ? OC ? ? W .. 0 ? W Q a a U U U ? IQ ?U U ? t 'R y o a a o n, J? .? J - AU THAT CxYtTIM Viege or pairei of land situate irk the rmhip of ftet Pannslxror C*Mty of CM rland and State of Pa ydvania, mere particularly bounded and dAsoribed an lollowr-,., to W#1 8=jubllm at at point flit the mx?th j%idg of o State 73j9 -X At. Rfl4t? No* 944 At Shown on the b+x?tox mentipar Plan of L U i5j4zd F*J.Txt W09 351D feeler McAs red in An eaOW 'dly 4recticm Pram Carol Lae t4(k fmt wide) -said pG>jnt also being the dividing line be"OTC Lots NO$. 38 VZd 19 o In th* plan of Pont Uei ht!?i acre north 3 do rnoi? 4 ainutoss wart, alonLZ suid di.vidintj line, 4 ftst-A tqe of 106.93 ort to Lot No. 4 Oil UoU pIan f ence botath •8S 4e9r0ee 2$ ,neteS easto A.1ohg LOHO . 4 and 5 on SAM LAAnr a 419tA WO Of 70 90*t to Lot . 17 on ftld pioohx thaftoe acuth 3 delse 4 rninut4m a&at Alanq maid rat No. 17, a, distance of 126.09 feer- to th* orth ni,db *9 the aftras&Ld s-t?ato uighwaya Wince south 44 degree& 42 mixatAg west .eons said State Hlgh rayr a distanat cf 70 fret to Lit No W I9,r a 'lace of BECI1 NINC Y Own- Balm Lot wo, A in the 449n Of Pe Ifeighta --acorddRd to the barjand County rAca er's office in Plan Book 6, page 2b. 1V=G tho n flr[ t4ad a single flw,alling houzo. TAX PARCEL #09-14-0835-057 1% BEING KNOWN AS: 813 Wertzville Road, Enola, PA 17025 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 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. GEORGE E. SEIDLE JR. Mortgagor(s) and Record Owner(s) 813 Wertzville Road Enola, PA 17025 Defendant(s) CERTIFICATION AS TO THE SALE OF REAL PROPERTY NO. 09-5645 I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Plaintiff has complied with all the provisions of the Act. IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Michael T. McKeever Attorney for plaintiff C Svc ., Tip t FY 2fl99 SEE 23 PH 1: ?2 C t ??,: 11.0 ••. 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 JPM:ORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER 7255 Baymeadows Way Jacksonville, FL 32256 vs. GEORGE E. SEIDLE JR. (Mortgagor(s) and Record Owner(s)) 813 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-5645 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, 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: 813 Wertzville Road Enola, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): GEORGE E. SEIDLE JR. 813 Wertzville Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: GEORGE E. SEIDLE JR. 813 Wertzville Road Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: EAST PENNSBORO TOWNSHIP 98 South Enola Drive Enola, PA 17025 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE SUDDEN DEATH TERMITE/PEST CONTROL 235 Market Street New Cumberland, PA 17070 ... CITIBANK (SOUTH DAKOTA) NA 701 East 50th Street North Sioux Falls. SD 57117 DISCOVER BANK 6500 New Albany Road New Albany, OH 43054 CAPITAL ONE BANK USA NA 15000 Capital One Drive Richmond, VA 23238 ARROW FINANCIAL SERVICE 5996 West Touhy Avenue Niles, IL 60714 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 THE UNITED STATES OF AMERICA Suite 220 , Federal Building 228 Walnut Street Harrisburg, PA 17108 SOVEREIGN BANK FSB 601 Perm Street Reading, PA 19601 4. Name and address of the last recorded holder of every mortgage of record: HARRIS SAVINGS BANK 235 North Second Street Harrisburg, PA 17101 HARRIS SAVINGS BANK C/O TOM CAPEHART, ESQUIRE GROSS, MCGINLEY 33 SOUTH 7TH STREET ALLENTOWN, PA 18105 COMMERCE BANK/HARRISBURG N.A 100 Senate Avenue Camp Hill, PA 17011 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 813 Wertzville Road t Enola, PA 17025 (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: September 21, 2009 ??/ c GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff FILED F-1, CE OF ? ?G. 2009 SEE 23 PH l : 3-: If s 09-5645 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 ACQUI: OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER 7255 Baymeadows Way Jacksonville, FL 32256 vs. GEORGE E. SEIDLE JR. Mortgagor(s) and Record Owner(s) 813 Wertzville Road Enola, PA 17025 Plaintiff Defendant(s Term No. 09-5645 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: SEIDLE 1R., GEORGE E. GEORGE E. SEIDLE JR. 813 Wertzville Road Enola, PA 17025 Your house at 813 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $102,184.85 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 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: 1 r 09-5645 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, 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: httD://_w_ww.l)hiladelphiafed.orsz/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 09-5645 Carlisle, PA 17013 y V, 09-5645 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 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(ubgoldbecklaw.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 85409FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-5645 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 COPORATION ACTING AS RECEIVER, Plaintiff (s) From GEORGE E. SEIDLE, JR. (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 $102,184.85 L.L. $.50 Interest from 9/22/09 TO Date of Sale per diem at $15.41 -- to be Determined Atty's Comm % Due Prothy $2.00 Atty Paid $160.50 Other Costs Plaintiff Paid Date: 9/23/09 Curtis R. ?*2ry (Seal) By: Deputy REQUESTING PARTY: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 56129 JP MORGAN CHASE BANK, N.A., as IN THE COURT OF COMMON PLEAS OF Acquirer of certain assets and liabilities :CUMBERLAND COUNTY, PENNSYLVANIA of Washington Mutual Bank from the Federal Deposit Insurance Corporation acting as Receiver, Plaintiff v. GEORGE E. SEIDLE, JR. Defendant NO. 09-5645 CIVIL IN RE: EMERGENCY MOTION ONJECTING TO AND REQUESTING STAY/CONTINUANCE OF SHERIFF'S SALE ORDER OF COURT AND NOW, this 25th day of February, 2010, upon consideration of Sovereign Bank, F.S. B.'s, Emergency Motion Objecting to and Requesting Stay/Continuance of Sheriff's Sale, and after an examination of the pleadings in the case, IT IS HEREBY ORDERED AND DIRECTED that Sovereign Bank, F.S.B., Emergency Motion is DENIED. ~ Michael T. McKeever, Esquire David A. Baric, Esquire ~orge E. Seidle, Jr. By the Court, ~~ M. L. Ebert, Jr., J. Cumberland County Sheriff's Dept. - ~A S °a'~ ~ S ~ Ib bas ~r~ c~, ~, ; ~; ,~~- :_-- ._ ~, , -; e~ , :,~ -~ -,-, ~f-~ ,v -r, rn ;_r L7 - v~ ; ~ ~ -- _,., r _, -, ~_ .. . _ ~J ~~ :J...'' Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ,fi4~1~~`~, q~ i:tun~~r~lrr r0 ~r;c s~~wl€€ ,- _ r i ._ t Ci..~J `' ~ '~i~V~1' JP Morgan Chase Bank, NA Case Number vs. George E. Seidle, Jr. 2009-5645 SHERIFF'S RETURN OF SERVICE 12/23/2009 04:31 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on December 23, 2009 at 1631 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 George E. Seidle, Jr., located at, 813 Wentzville Road, Enola, Cumberland County, Pennsylvania according to law. 01/05/2010 04:35 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on January 5, 2010 at 1635 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: George E. Seidle, Jr., by making known unto, Ali MacAdam, fiancee of defendant, at, 813 Wertzville Road, Enola, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy o1 the same. 03/02/2010 Property sale postponed to 5/5/2010. 04/20/2010 Property sale postponed to 7/7/2010. 06/30/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Michael McKeever on 6/30/10 SHERIFF COST: $740.14 SO ANSWERS, June 30, 2010 RON R ANDERSON, SHERIFF ~- po mac, ~'o. ~ L,~. ~ . .~ ~ ~ (~6~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY ... (ci OountySuitc Sheri±f. Te'eosoft. Inc_ t ~~ r Goldbeck I~~Cafferty & McKeever BY: Michael T. DQcKe?,~er Attorney LDS #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 72SS Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. GEORGE E. SEIDLE JR. (Mortgagor(s) and Record Owner(s)) 813 Wertzville Road Enola, PA 17025 No. 09-S64S 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, 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 tiled the following information concerning the real property located at: Defendant(s) 813 Wertzville Road Enola, PA 17025 1.Name and address of Owner(s) or Reputed Owner(s): GEORGE E. SEIDLE JR. 813 Wertzville Road Enola, PA 17025 2. Name and address of Defendant(s) in the judgment: GEORGE E. SEIDLE JR. 813 Wertzville Road Enola, PA 17025 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: EAST PENNSBORO TOWNSHIP 98 South Enola Drive Enola, PA 17025 SUDDEN DEATH TERMITE/PEST CONTROL 23S Market Street New Cumberland, PA 17070 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE CITIBANK (SOUTH DAKOTA) NA '` r 701 East 50th Street North ' Sioux Falls, SD 571 17 DISCOVER BANK 6500 New Albany Road New Albany, OH 43054 CAPITAL ONE BANK USA NA 15000 Capital One Drive Richmond, VA 23238 ARROW FINANCIAL SERVICE 5996 West Touhy Avenue Niles, IL 60714 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 THE UNITED STATES OF AMERICA Suite 220 ,Federal Building , 228 Walnut Street Harrisburg, PA 17108 SOVEREIGN BANK FSB 601 Peml Street Reading, PA 19601 4. Name and address of the last recorded holder of every mortgage of record: HARRIS SAVINGS BANK 235 North Second Street Harrisburg, PA 17101 HARRIS SAVINGS BANK C/O TOM CAPEHART, ESQUIRE GKOSS, MCGINLEY 33 SOUTH 7TH STREET ALLENTOWN, PA 18105 COMMERCE BANK/HARRISBURG N.A 100 Senate Avenue Camp Hill, PA ] 7011 5. Name and address of every other person who has an_y 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 «~ho has any record interest in the property which maybe 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 813 Wertzville Road Enola, PA 17025 (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: September 21 2009 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 09-5645 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 ACQUI OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER 7255 Baymeadows Way Jacksonville, FL 32256 of Cumberland County CIVIL ACTION -LAW Plaintiff vs. GEORGE E. SEIDLE JR. Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 813 Wertzville Road Enola, PA 17025 Defendants Term No. 09-5645 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: SEIDLE 1R., GEORGE E. GEORGE E. SEIDLE JR. 813 Wertzville Road Enola; PA 17025 Your house at 813 Wertzville Road, Enola, PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday, March 03, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $102,184.85 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 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: i f 09-5645 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, 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 orl-86b-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 tln-ough 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 7 ] 7-240-6390. 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 tiled by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. You may contact the Foreclosure Resource Center: ham:/hvww.philadel~hiafed.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. LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue 09-5645 Carlisle, PA 17013 09-5645 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client} has filed an Action of Mortgage Foreclosure against you, you still maybe able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 717-243-9400 or . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud. 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.phfa.org/consumers/homeowners~real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention cr 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 85409FC_ Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the north side of State Highway known as Route No. 944 as shown on the hereinafter mentioned Plan of Lots said point being 350 feet, measured in an eastwardly direction from Carol Lane (40 feet wide) said point also being the dividing line between Lots Nos. 18 and 19, in the plan of Penn Heights; thence north 3 degrees 4 minutes west, along said dividing line, a distance of 186.95 feet to Lot No. 4 on said plan; thence south 85 degrees 25 minutes east, along Lots Nos. 4 and 5 on said plan, a distance of 70 feet to Lot. No. 17 on said plan; thence south 3 degrees 4 minutes east along said Lot No. 17, a distance of 186.09 feet to the north side of the aforesaid State Highway, a distance of 70 feet to Lot No. 19, the place of BEGINNING. BEING Lot No. 18 in the Plan of Penn Heights recorded in the Cumberland County Recorder's Office in Plan Book 6, page 28. Having thereon erected a single dwelling house. BEING KNOWN AS: 813 Wertzville Road, Enola, PA 17025 TAX PARCEL #09-14-0835-057 WRIT OF EXECUTION and/or ATTACHMENT COMMc7NWE1~LTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-5645 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 COPORATION ACTING AS RECEIVER, Plaintiff (s) From GEORGE E. SEIDLE, JR. (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 $102,184.85 L.L. $.50 Interest from 9/22/09 TO Date of Sale per diem at $15.41 -- to be Determined Atty's Comm Atty Paid $160.50 Plaintiff Paid Date: 9/23/09 (Seal) REQUESTING PARTY: Due Prothy $2.00 Other Costs Curtis R. Long, nota By: 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 Deputy Supreme Court ID No. 56129 J - ''' (~~ October 1, 2009 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro Township, Cumberland County, PA, Known and numbered as 813 Wertzville Road, Enola, more fully described on Exhibit "A" - filed with this writ and by this reference incorporated herein. Date: October 1, 2009 Y~ ~.,~~~ .. ~~~ ..c, Real Estate Coordinator r em ~~} ~ _' ~~' ~ °_ = ' - n L = g ~ ~-'-- ~.a PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss. Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: January 22, January 29, and Febru 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. Lisa Marie TO AND SUBSCRIBED before me this 5 day of Februar, ~'C --~~ Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BORO, CUidBERLAND COUNTY My Comrnission Expires Apr 28, X010 ~Yrit lfo. 2009-4646 Civil JP Morgan Chase Bank, NA vs. George E. Seidle, Jr. Atty: Micheal McKeever ALL THAT CERTAIN piece or par- cel of land situate in the Township of East Pennsboro, County of Cumber- landand State of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the north side of State Highway known as Route No. 944 as shown on the hereinafter mentioned Plan of Lots said point being 350 feet, measured in an eastwardly direction from Carol Lane (40 feet wide) said point also being the dividing line between Lots Nos. 18 and 19, in the plan of Penn Heights; thence north 3 degrees 4 minutes west, along said dividing line, a distance of 186.95 feet to Lot No. 4 on said plan; thence south 85 degrees 25 minutes east, along Lots Nos. 4 and 5 on said plan, a distance of 70 feet to Lot. No. 17 on said plan; thence south 3 degrees 4 minutes east along said Lot No. 17, a distance of 186.09 feet to the north side of the aforesaid State Highway, a distance of 70 feet to Lot No. 19, the place of BEGINNING. BEING Lot No. 18 in the Plan of Penn Heights recorded in the Cum- berland County Recorder's Office in Plan Book 6, page 28. Having thereon erected a single dwelling house. BEING KNOWN AS: 813 Wertzville Road, Enola, PA 17025. TAX PARCEL #09-14-0835-057. PROPERTYADDRESS: 813 Wentz- ville Road, Enola, PA 17025. ____- The Patriot-News Co. 812 11~arket St. Harrisburg, PA 17101 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE c~he~latriot News NOw you know CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss 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 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 01 /22/10 ( ~~~ ~/ 01 /29/10 ~" f~ . , " `~ //~~ ~ 02/05/10 Sworn to an u scribed before me this 24~~f February, 2010 A.D. I ~ ~ ~. Notary COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L. Kisnsr, Notary Public City Of Harrisburg; Dauphin County My Carrurtission E~ir~es Nov. 26, 2011 Member, Pennsylvania Association of Notaries Dot~E x!16 CFv11 ~i!~~Ilet~an ~ r~ NA . rs. ~~+~4 ~.~~isklle.dr. Atfy: Mllf Idyl ~i1cKs+-vsr ALL THAI' ~>;Rxw1fi1 piece or ~ tana situate, in the Township. of`Easl Petmsbaro,. Couury+' bf ~»mbedand and State .' of PemissjiVahia, more pmticdlatl}~;Doe4ded and desctib4d''as foliowa, to wit; BBGI4'~Ifl at a point4nf~te nottH aide "of State 13i¢hway Imown as Rotlt~No. 944 as shown on the hdb~ftet meati~ed Plan of Tats' said point bring 350 feet, ttteastired in ao eadtwaidiy dimctiaut`ftoui Carol l ucfe (40 fat' widr~ said'point ~1s° i~g the t`g liaeisetwden Lqs Nas. t8 and~d9; ip the "fin of peon Heights; theory uotth 3 `4~minutea west, eloag said dividia8liue, a ~i~ttde tsf 186.9'3 fetz to Lot No. 4 rie'said p]ae~ tES~e south, 85 dt~rees 7.~ 1~nvtea east, Nos. 4 and 5 an said plea, a' duce of 70 #~ to Lot. No: 17 on said plan; thence soath 3 d~iecs 4 mineaes east along said Lot No. 17 l,~ d9smnce of 186.09 feee tb the north side of vrx afbtraaid State Higinvay, a dista4ce of 7d~ ~Ft to 'Lot. No. 19, than place ,of SE(1.8EII1t3 Lot No, d8 i6 the Plan of Pena ,Heights recotdpd in the, C'~odotdef's t7$tce iA ~'$tlolt 6, 28. ,thereon ete~l`,a's~egYts d'4g horse. BElfiiCr A8: 8131!Vatz~iU'e Road,lPub~i,FA 17025"1"A~C'PARCEi:1109?~14-' Og95 P~.S= g1g lifrlt~le l Pnain:4 PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group,P.C. Suite 5000-BNY 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 IN THE COURT OF COMMON PLEAS FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER of Cumberland County 7255 Baymeadows Way Jacksonville,FL 32256 CIVIL ACTION—LAW Plaintiff vs. ACTION OF MORTGAGE FORECLOSURE GEORGE E. SEIDLE JR. Mortgagor(s)and Record Owner(s)O No. 09-5645 ` 813 Wertzville Road Enola,PA 17025 Defendant(s) 2 r n C= - rY r r cc o c� iCD PRAECIPE FOR WRIT OF EXECUTION < a -1 C7 '. TO THE PROTHONOTARY: ---t C' Issue Writ of Execution in the above matter: " Amount Due $102,184.85 Interest from 9/22/2009 to Date of Sale per diem at $15.41 (Costs to be added) O By: p C`3F LAW GRO C. s Michael McKeever a. 1D 56129 Y o .N 1, - Jay E.Kivitz Pa.ID 26769 Q 0 t• %% Lisa Lee Pa.ID 78020 d ' S L Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 b p a / Thomas Puleo Pa.ID 27615 Joshua 1. Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 ^ `,��Jl • Attorneys for Plaintiff v' a.as SalVa -dre- F, tl'Pf l0 313917 No. 09-5645 IN THE COURT OF COMMON PLEAS 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 VS. GEORGE E. SEIDLE JR. (Mortgagor(s)and Record Owner(s)) 813 Wertzville Road Enola,PA 17025 PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) KML Law Group,P.C. Attorney for Plaintiff KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 / ~ ALLTHATCERTA|Npiereorparce|of|andsituatein-theToxvnshipofEastPennsboro\Cunmbedamd County, Pennsylvania, more particularly bounded and described as follows,to wit: BEGINNING at a point on the north side of the State Highway known as Route No.944 as shown on the hereinafter mentioned Plan ofLots said point being 3SDfeet, measured in an eastvvard/y direction from Carol Lane (4O feet wide)said point also being the dividing line between lots Nos. 18 and 19, in the plan of Penn Heights;thence north 3 degrees 4 minutes west, along said dividing line,a distance of 186.95 feet to Lot No.4 o said plan;thence south OS degrees 25 minutes east,along lots Nos.4 and S on said plan,a distance of 70 feet to Lot No. 17 on said plan;thence south 3 degrees 4 minutes east along said Lot No. 17,a distance of 186.08 feet to the north side of the aforesaid State Highway;thence south 84 degrees 42 minutes west along said State Highway,a distance of 70 feet to Lot; No. 19,the place of beginning. BEING Lot; No. 18 in the plan of Penn Heights recorded in the Cumberland County Recorder's Office in Plan Bock 6, page 28. HAVING thereon erected a single dwelling house known as 813 Wertzville Road. IMPROVEMENTS consist ofa residential dwelling. | MUNICIPALITY Township of East Pennsbnro BEING PREMISES: 813VVertzvi||e Road Eno|aPA17O25 SOLD au the property of GEORGE E.5BDLE,JR. TAX PARCEL#09'14'OD35-O57 BEING the same premises which Hazel A. Seidle, widow by deed dated 5/8/2002 and recorded 8/22/2002 in Cumberland County in Deed Book Volume 253 at Page 1327 granted and conveyed unto George E. Seid|e. Jr. U U F . C"• " " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNS1%&J JPMORGAN CHASE BANK,N.A.,AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON CX MUTUAL BANK FROM THE FEDERAL DEPOSIT t—= r- INSURANCE CORPORATION ACTING AS RECEIVER <� " ' Plaintiff' NO.09-5645 VS. GEORGE E.SEIDLE JR. Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group,P.C.,as the representative for the Plaintiff in the above entitled matter,does hereby state to the best of his/her information and belief,as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense(hops:J/www.dmdc.osd.millappj/scralscraHome do) for the following individual(s): GEORGE E. SEIDLE JR., has a last known residence of 813 Wertzville Road, Enola, PA 17025. The following information was used to search the DMDC (check all that apply): X Last Name X First Name _X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A.4904 relating to unsworn falsification to authorities. Date {) P► By: KML LAW GROUP,P Michael McKeever . ID 561.29 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gomall Pa. ID 92382 Joshua 1. Goldman Pa. ID 205047 (r Salvatore Filippello Pa.ID 313897 Jill P. Jenkins Pa.ID 306588 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff KML Law Group,P.C. Suite 5000–BNY Independence Center *i 701 Market Street :+F Tf t IP OTHONOTA—, Philadelphia,PA 19106-1532 215-627-1322 2013 AUG 28 AN PJ; 52 Attorney for Plaintiff CUMBER[ANQ CmINTy JPMORGAN CHASE BANK,N.A.,AS ACQUIRER ENNSYLVANIA 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 7255 Baymeadows Way Jacksonville,FL 32256 CIVIL ACTION-LAW Plaintiff VS. ACTION OF MORTGAGE FORECLOSURE GEORGE E. SEIDLE JR. (Mortgagor(s)and Record Owner(s)) 813 Wertzville Road Enola,PA 17025 No. 09-5645 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,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: 813 Wertzville Road Enola,PA 17025 1.Name and address of Owner(s)or Reputed Owner(s): GEORGE E. SEIDLE JR. 813 Wertzville Road Enola,PA 17025 2.Name and address of Defendant(s)in the judgment: GEORGE E. SEIDLE JR. 813 Wertzville Road Enola,PA 17025 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: SOVEREIGN BANK FSB 601 Penn Street Reading,PA 19601 CITIBANK(SOUTH DAKOTA)NA 701 East 50th Street North Sioux Falls,SD 57117 �J 1. DISCOVER BANK 6500 New Albany Road New Albany,OH 43054 CAPITAL ONE BANK USA NA 15000 Capital One Drive Richmond,VA 23238 ARROW FINANCIAL SERVICE 5996 West Touhy Avenue Niles,IL 60714 EAST PENNSBORO TOWNSHIP 98 South Enola Drive Enola,PA 17025 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg.-Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 THE UNITED STATES OF AMERICA Suite 220,Federal Building 228 Walnut Street Harrisburg,PA 17108 US TREASURY DEPARTMENT 1000 Liberty Avenue Pittsburgh,PA 15222 SUDDEN DEATH TERMITE/PEST CONTROL ATTN:JAMES CLISHAM 235 Market Street New Cumberland,PA 17070 CITIBANK(SOUTH DAKOTA)NA C/O WILLIAM T MOLCZAN,ESQUIRE/WELTMAN WEINBERG&REIS 1400 KOPPERS BUILDING PITTSBURGH,PA 15219 DISCOVER BANK C/O JAMES C WARMBRODT,ESQUIRE/WELTMAN WEINBERG ET AL 436 SEVENTH AVE STE 1400 PITTSBURGH,PA 15219 CAPITAL ONE BANK USA NA C/O JAMES C WARMBRODT,ESQUIRE/WELTMAN WEINBERG ET AL 436 SEVENTH AVE STE 1400 PITTSBURGH,PA 15219 CAPITAL ONE BANK USA NA C/O William Thomas Molczan,Esquire/WELTMAN WEINBERG&REIS 1.400 KOPPERS BUILDING PITTSBURGH,PA 15219 f + . ARROW FINANCIAL SERVICE c/o PHILIP C WARHOLIC,ESQUIRE PO BOX 294 ENOLA,PA 17025 SOVEREIGN BANK FSB C/O THOMAS A CAPEHART,ESQUIRE/GROSS MCGINLEY LLP 33 S 7TH ST PO BOX 4060 ALLENTOWN,PA 18105 4.Name and address of the last recorded holder of every mortgage of record: COMMERCE BANKJHARRISBURG N.A 100 Senate Avenue Camp Hill,PA 17011 HARRIS SAVINGS BANK 235 North Second Street Harrisburg,PA 17101 HARRIS SAVINGS BANK C/O TOM CAPEHART,ESQUIRE GROSS,MCGINLEY 33 SOUTH 7TH STREET,PO Box 4060 ALLENTOWN,PA 18105 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 813 Wertzville Road Enola,PA 17025 I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. DATED: By: KML LAW GROUP, Michael McKeever Pa. 56129 Jay E.Kivitz Pa.ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 Jill P.Jenkins Pa.ID 306588 Attorneys for Plaintiff P�' 09-5645 r KML Law Group,P.C. s`i' ,0,;:4r ;`l .y.. Suite 5000-BNY Independence Center �� .1 HE Pi MHO N 1 , , . 701 Market Street ���� �� �� �� �• Philadelphia,PA 19106 27-1322 Attorney t1MBERLAN., COUNTY Attorney for Plaintiff JPMORGAN CHASE BANK,N.A.,AS ACQUIRE OF CERTAIN ASSETS AND LIABILITIES OF IN THE COURT OF COMMON PLEAS WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE of Cumberland County CORPORATION ACTING AS RECEWER 7255 Baymeadows Way Jacksonville,FL 32256 CIVIL,ACTION-LAW Plaintiff ACTION OF MORTGAGE VS. FORECLOSURE GEORGE E. SEIDLE JR. Mortgagor(s)and Record Owner(s) 813 Wertzville Road Docket No. 09-5645 Enola,PA 17025 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: SEIDLE JR.,GEORGE E. GEORGE E. SEIDLE JR. 813 Wertzville Road Enola,PA 17025 Your house at 813 Wertzville Road,Enola,PA 17025 is scheduled to be sold at Sheriffs Sale on Wednesday,December 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$102,184.85 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 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: ' 09-5645 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,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 Sheriff s Sale is not stopped,your property will be sold to the highest bidder.You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house.A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: btti)�//www.phdadelphiafed.org/foreclosme YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 09-5645 Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you,you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to'a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Horne Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentiongkmllawgroup.com.com. Call Seth at 215-825-6329 or fax 215-825- 6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215- 825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 85409FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 09-5645 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 Plaintiff(s) From GEORGE E. SEIDLE,JR. (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 GARNISHEES)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: $102,184.85 L.L.: Interest from 09/22/2009 to Date of Sale per diem at$15.41 Atty's Comm: Due Prothy:$2.25 Atty Paid: $92A.14 Other Costs: Plaintiff Paid: Date: August 28,2013 �� �� .0 . �L�I�Q��1� /�,✓ David D. B e11,Prothonotary - ✓�— ''� (Seal) l J Deputy REQUESTING PARTY: Name: SALVATORE FILIPPELLO,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106-1532 Attorney for:Plaintiff Telephone:215-627-1322 Supreme Court ID No. 313897 I KML LAW GROUP,P.C. 85409FC Suite 5000 CF: 08/13/2009 BNY Mellon Independence Center F.t a.. o-`., ''` ' SD: 12/04/2013 701 Market Street i I ~: 'Fi Q 1 G, 0f�,rY;�` $102,184.85 Philadelphia,PA 19106-1532 I Ail 10: 12 215-627-1322 ` ' Attorne for Plaintiff JPMORGAN CHASE BANK,N.A.,AS `jt ($'COURT OF COMMON PLEAS ACQUIRER OF CERTAIN ASSETS AND PE NS Y L' A R I A LIABILITIES OF WASHINGTON MUTUAL of Cumberland County BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS CIVIL ACTION—LAW RECEIVER 7255 Baymeadows Way ACTION OF MORTGAGE FORECLOSURE Jacksonville,FL 32256 Plaintiff Term vs. No. 09-5645 GEORGE E. SEIDLE JR. Mortgagor(s)and Record Owner(s) 813 Wertzville Road Enola,PA 17025 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2 (c) (2) Veronica Cosme, 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(copy of return attached). ( ) 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. Respectfully submitted, Viiieft /' L BY: Veronica Cosme Legal Assistant I CC II_ d 0 0" a) 11112:, 16g:',0 8 � d 2 to I t\`{ uoi 0 y b'es ,„,d —g ..:2. i ce Noa , _ 0Q1INn o o 2 O pe-,.. ....„ . E All-010 m . :z.V.e.# co U f0 1 ' > CL • d J(m O_N E o (OpU E @Oa.•.LYce (0-0112-0= mw V N X 2 t O« N w LI- • O l6 Q c 8 o 0 0.D C N N m a. as a. y C c N a. 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O O o 4 Y''' ° E Z I m w w co U CO o ~ • Q r X ee t/) 3 z W u W w 0000 0 p W w j .a I ■ U Cl 'Z 4 I Id w N€`o m N m STa W NM W OM m O E a a�i0 v x c $ un 2�� >N W >�W a°N A _ U O _ ° W C ao N as Q 00 0' va am m O v co a u N N 3 -0V F'- 3 t°- °o O °� (n a W a y W °� a 2 O Q _ LL o ti o ° V Q�ON aOY J co u- 2 c�OwW� `n 1 47,QI0 a0 e' *J Z ° 00 —EJ� o °a ,- -I Z��°_r c.i ch d ui co : oo a Y to i.O. • IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY PENNSYLVANIA • JPMORCAN CHASE BANK,N.A.,AS ACQUIRER OF CASE and/or DOCKET No.:09-5645 CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT Sheriffs Sale Date: 12/4/2013 INSURANCE CORPORATION ACTING AS RECEIVER;et seq. Plaintiff(Petitioner) V. GEORGE E.SEIDLE JR.;et al. • Defendant(Respondent) • • • AFFIDAVIT OF SERVICE ❑Complaint 0 Summons Li Other:NOTICE OF SALE I,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that served GEORGE E.SEIDLE JR_the above process on the 5 day of September,2013,at 3:45 o'clock,PM,at 813 Wert7ville Road Enola,PA 17025,County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: (3y handing a copy at the residence of the Defendant(s)to an adult member of the family with whom he/she resides or to the adult person in charge • of the residence because no adult family member was found* ri By handing a copy at the residence of the Defendant(s)to the clerk or manager of the hotel,inn,apartment house or other place of lodging at which he/she resides* By handing a copy at the office or usual place of business of the Defendant(s)to the Defendant's(s)agent or to the person for the time being in charge thereof *Name:ASHLEY HANNUM Relationship/Title/Position:Sten-Daughter Remarks: Description:Approximate Age 18-20 I[eight 5'3 Weight 165 Race WHITE Sex FEMALE I lair BLONDE Military Status: J No D Yes Branch: Commonwealth/State of Pa )SS: County of___ ,Jr/ ) Before me,the undersigned notary publi.,:this day,personally,appeared gyve 1414.0 k! _to me known,who being duly sworn according to law,des• e following: // I hereby swear or aftir that: - •sfs set forth in the foregoing Affidavit of Service are true and correct. • Subscribed and sworn to b fore me Signatur- of Affiant) this fr day sr,' ;fee . Fite Number:854')9PC - Case ID#:3749.48 OtA PIONWUAL)11 OP PENNSYLVANIA Notary Public Notariat Seal Eric M.Affierbach,Notary Public Washington Twp.,Barks County My Commission Expires Nov.18,2013 • 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 7255 Baymeadows Way CIVIL ACTION-LAW Jacksonville,FL 32256 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. Term GEORGE E. SEIDLE JR. No. 09-5645 Mortgagor(s)and Record Owner(s) 813 Wertzville Road Enola,PA 17025 Defendant(s) SUPPLEMENTAL 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,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: 813 Wertzville Road Enola,PA 17025 1.Name and address of Owner(s)or Reputed Owner(s): GEORGE E. SEIDLE JR. 813 Wertzville Road Enola,PA 17025 2.Name and address of Defendant(s) in the judgment: GEORGE E. SEIDLE JR. 813 Wertzville Road Enola,PA 17025 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: SOVEREIGN BANK FSB 601 Penn Street Reading,PA 19601 CITIBANK(SOUTH DAKOTA)NA 701 East 50th Street North Sioux Falls, SD 57117 DISCOVER BANK 6500 New Albany Road New Albany,OH 43054 CAPITAL ONE BANK USA NA 15000 Capital One Drive Richmond,VA 23238 ARROW FINANCIAL SERVICE 5996 West Touhy Avenue Niles,IL 60714 EAST PENNSBORO TOWNSHIP 98 South Enola Drive Enola,PA 17025 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg,PA 17105-2675 THE UNITED STATES OF AMERICA Suite 220,Federal Building 228 Walnut Street Harrisburg,PA 17108 US TREASURY DEPARTMENT 1000 Liberty Avenue Pittsburgh,PA 15222 SUDDEN DEATH TERMITE/PEST CONTROL ATTN: JAMES CLISHAM 235 Market Street New Cumberland,PA 17070 CITIBANK(SOUTH DAKOTA)NA C/O WILLIAM T MOLCZAN,ESQUIRE/WELTMAN WEINBERG&REIS 1400 KOPPERS BUILDING PITTSBURGH,PA 15219 DISCOVER BANK C/O JAMES C WARMBRODT, ESQUIRE/WELTMAN WEINBERG ET AL 436 SEVENTH AVE STE 1400 PITTSBURGH,PA 15219 CAPITAL ONE BANK USA NA C/O JAMES C WARMBRODT,ESQUIRE/WELTMAN WEINBERG ET AL 436 SEVENTH AVE STE 1400 PITTSBURGH,PA 15219 CAPITAL ONE BANK USA NA C/O William Thomas Molczan,Esquire/WELTMAN WEINBERG&REIS 1400 KOPPERS BUILDING PITTSBURGH,PA 15219 ARROW FINANCIAL SERVICE c/o PHILIP C WARHOLIC,ESQUIRE PO BOX 294 ENOLA,PA 17025 SOVEREIGN BANK FSB C/O THOMAS A CAPEHART,ESQUIRE/GROSS MCGINLEY LLP 33 S 7TH ST PO BOX 4060 ALLENTOWN,PA 18105 DAVID BENNETT H-3A, 1180 Kingsley Road Camp Hill,PA 17011 CUMBERLAND COUNTY PRISON 1101 Clairmont Road Carlisle,PA 17013 ASSET ACCEPTANCE LLC c/o Edwin A. Abrahamsen&Associates • 120 North Keyser Avenue Scranton,PA 18504 SHANNON BRANNEN 111 Verbeke Street,Apt.A Marysville,PA 17053 4.Name and address of the last recorded holder of every mortgage of record: COMMERCE BANK/HARRISBURG N.A 100 Senate Avenue Camp Hill,PA 17011 HARRIS SAVINGS BANK 235 North Second Street Harrisburg,PA 17101 HARRIS SAVINGS BANK C/0 TOM CAPEHART,ESQUIRE GROSS,MCGINLEY 33 SOUTH 7TH STREET,PO Box 4060 ALLENTOWN,PA 18105 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 813 Wertzville Road Enola, PA 17025 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 12,2013 Law Group,P.C. BY: Veronica Cosme Legal Assistant KML LAW GROUP,P.C. 85409FC Suite 5000 CF: 08/13/2009 BNY Mellon Independence Center `' ' @, �� SD: 12/04/2013 701 Market Street $102,184.85 Philadelphia,PA 19106-1532 t�} 215-627-1322 Attorney for Plaintiff .i ,� 1 AHO 5 � JPMORGAN CHASE BANK,N.A.,AS ` :�j� ;HSY V \ 1t�- IN THE COURT OF COMMON PLEAS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL of Cumberland County BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS CIVIL ACTION—LAW RECEIVER 7255 Baymeadows Way ACTION OF MORTGAGE FORECLOSURE Jacksonville, FL 32256 Plaintiff Term vs. No. 09-5645 GEORGE E. SEIDLE JR. Mortgagor(s)and Record Owner(s) 813 Wertzville Road Enola,PA 17025 Defendant(s) AMENDED CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P.3129.2(c)(2) Veronica Cosme, 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(copy of return attached). ( ) 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. Respectfully submitted, B : Veronica Cosme Assistant H 1 Q c-) co i .- o o Y W ��i 01 rn C W a(9 p a 04 N I < VI 1 O P. u� O�I O LLi. y co O J N cv W y c re '0.thin GO d •1 U7 a ' > •: CI- . as S _a, w T =o .. cL N U _ `C. 13'5 m E c C a - CO• 7 U N N C 0 w. X g'c pY NwO.. — '• m— o to <. •}5o d 0 C 0) a CC H C g v a a •R E ,. To N C m • 2$ o m e Li! (a - S Pp m = a. o U C1=C co W. 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Defendant(Respondent) AFFIDAVIT OF SERVICE ❑Complaint ❑Summons in Other:NOTICE OF SALE •. • I,RYAN MARKS,certify that I am eighteen years of age or older and that I am not a party to the action nor an employee nor relative of a party,and that served GEORGE E.SEIDLE JR_the above process on the 5 day of September,2013,at 3:45 o'clock,PM,at 813 Wertzville Road Enola,PA 17025,County of Cumberland,Commonwealth of Pennsylvania: Manner of Service: is By handing a copy at the residence of the Defendant(s)to an adult member of the family with whom he/she resides or to the adult person in charge of the residence because no adult family member was found* By handing a copy at the residence of the Defendant(s)to the clerk or manager of the hotel,inn,apartment house or other place of lodging at which he/she resides* 0 By handing a copy at the office or usual place of business of the Defendant(s)to the Defendant's(s)agent or to the person for the time being in charge thereof *Name:ASHLEY HANNUM ' Relationship/Title/Position:Sten-l)auahter Remarks: Description:Approximate Age 18-20 I[eight 5'3 Weight 165 Race WHITE Sex FEMALE I lair BLONDE Military Status: El]No ❑Yes Branch: Commonwealth/State of Pic _..- ) )SS: County of_ OsiKf ) aw £41 ('1 to me know Before me,the undersigned notary public„this day,personally,appeared /QY _ known,who being duly sworn according to law,de'' • I,e'following: i'/ / I hereby swear or affi • that,' - efs set forth in the foregoing Affidavit of Service are true and correct 1 ,/Al Subscribed and sworn to efore me . Signatur- ofAffiiant) this b day eir ,2013 . File Number:854'i 9PC Case ID#:3749.'8 t5OMMO W V.AL7H O1 PENNSYLVANIA Notary Public Notarial Seal Eric M.Attierbach,Notary Public Washington Twp.,Berks County My Commission Expires Nov.18,2013 • 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 7255 Baymeadows Way CIVIL ACTION-LAW Jacksonville,FL 32256 Plaintiff ACTION OF MORTGAGE FORECLOSURE vs. Term GEORGE E. SEIDLE JR. No. 09-5645 Mortgagor(s)and Record Owner(s) 813 Wertzville Road Enola,PA 17025 Defendant(s) AMENDED SUPPLEMENTAL 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,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: 813 Wertzville Road Enola,PA 17025 1.Name and address of Owner(s)or Reputed Owner(s): GEORGE E. SEIDLE JR. 813 Wertzville Road Enola,PA 17025 2.Name and address of Defendant(s)in the judgment: GEORGE E. SEIDLE JR. 813 Wertzville Road Enola,PA 17025 3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: SOVEREIGN BANK FSB 601 Penn Street Reading,PA 19601 CITIBANK(SOUTH DAKOTA)NA 701 East 50th Street North Sioux Falls, SD 57117 DISCOVER BANK 6500 New Albany Road New Albany, OH 43054 CAPITAL ONE BANK USA NA 15000 Capital One Drive Richmond,VA 23238 ARROW FINANCIAL SERVICE 5996 West Touhy Avenue Niles;IL 60714 EAST PENNSBORO TOWNSHIP 98 South Enola Drive Enola,PA 17025 DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle,PA 17013 PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O.Box 2675 Harrisburg,PA 17105-2675 THE UNITED STATES OF AMERICA Suite 220 ,Federal Building 228 Walnut Street Harrisburg,PA 17108 US TREASURY DEPARTMENT 1000 Liberty Avenue Pittsburgh,PA 15222 SUDDEN DEATH TERMITE/PEST CONTROL ATTN: JAMES CLISHAM 235 Market Street New Cumberland,PA 17070 CITIBANK(SOUTH DAKOTA)NA C/O WILLIAM T MOLCZAN,ESQUIRE/WELTMAN WEINBERG&REIS 1400 KOPPERS BUILDING PITTSBURGH,PA 15219 DISCOVER BANK C/O JAMES C WARMBRODT,ESQUIRE/WELTMAN WEINBERG ET AL 436 SEVENTH AVE STE 1400 PITTSBURGH,PA 15219 CAPITAL ONE BANK USA NA C/O JAMES C WARMBRODT,ESQUIRE/WELTMAN WEINBERG ET AL 436 SEVENTH AVE STE 1400 PITTSBURGH,PA 15219 CAPITAL ONE BANK USA NA C/O William Thomas Molczan,Esquire/WELTMAN WEINBERG&REIS 1400 KOPPERS BUILDING PITTSBURGH,PA 15219 ARROW FINANCIAL SERVICE c/o PHILIP C WARHOLIC,ESQUIRE PO BOX 294 ENOLA,PA 17025 SOVEREIGN BANK FSB C/O THOMAS A CAPEHART,ESQUIRE/GROSS MCGINLEY LLP 33 S 7TH ST PO BOX 4060 ALLENTOWN,PA 18105 DAVID BENNETT H-3A, 1180 Kingsley Road Camp Hill,PA 17011 CUMBERLAND COUNTY PRISON 1101 Clairmont Road Carlisle,PA 17013 ASSET ACCEPTANCE LLC c/o Edwin A.Abrahamsen&Associates 120 North Keyser Avenue Scranton,PA 18504 SHANNON BRANNEN 111 Verbeke Street,Apt. A Marysville,PA 17053 4.Name and address of the last recorded holder of every mortgage of record: COMMERCE BANK/HARRISBURG N.A 100 Senate Avenue Camp Hill,PA 17011 HARRIS SAVINGS BANK 235 North Second Street Harrisburg,PA 17101 HARRIS SAVINGS BANK C/O TOM CAPEHART,ESQUIRE GROSS,MCGINLEY 33 SOUTH 7TH STREET,PO Box 4060 ALLENTOWN,PA 18105 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 813 Wertzville Road Enola,PA 17025 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 14, 2013 ' � ML Law Group,P.C. BY: Veronica Cosme Legal Assistant ` SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff �m .. ` w �- 4 THE P ROTAON O Jody m Smith 29111 Ann -7 AM.U:. ,`P/ 4 ChiefDeoutv Richard VStewart, PUMA COUNTY Solicitor OFFICE or�fIEm*eIFp PENNSYLVANIA JP Morgan Chase Bank, NA vs. George E. Seidle, Jr. Case Number 2009-5645 SHERIFF'S RETURN OF SERVICE 09/ 27/2013 07:15 PM - Deputy Stephen Bender, 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 813 Wertzville Road, East Pennsboro - Township, Enola, PA 17025, Cumberland County. 11/26/2013 As directed by Thomas I. Puleo, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/8/2014 12/02/2013 As directed by Thomas I. Puleo, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/4/2014 01/07/2014 Property sale removed from 4/4/2014 sale. 01/07/2014 As directed by Thomas I. Puleo, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/9/2014 04/04/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST $895.54 SO ANSWERS, April 04, 2014 `' V� R ANDERSON, SHERIFF 1,c)courityS* eherixreleosmw" ' 74;11..2. ��. �-7'' ~�y�4^ ^�~ ~~ o LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2009 -5645 Civil Term JP MORGAN CHASE BANK, NA vs. GEORGE E. SEIDLE, JR. Atty.: Thomas I. Puleo ALL THAT CERTAIN piece or par- cel of land situate in the Township of East Pennsboro, Cumberland County, Pennsylvania, more par- ticularly bounded and described as follows, to wit: BEGINNING at a point on the north side of the State Highway known as Route No. 944 as shown on the hereinafter mentioned Plan of Lots said point being 350 feet, measured in an eastwardly direction from Carol Lane (40 feet wide) said point also being the dividing line between lots Nos. 18 and 19, in the plan of Penn Heights; thence north 3 degrees 4 minutes west, along said dividing line, a distance of 186.95 feet to Lot No.4 on said plan; thence south 85 degrees 25 minutes east, along lots Nos. 4 and S on said plan, a distance of 70 feet to Lot No. 17 on said plan; thence south 3 degrees 4 minutes east along said Lot No. 17, a distance of 186.08 feet to the north side of the aforesaid State Highway; thence south 84 degrees 42 minutes west along said State Highway, a distance of 70 feet to Lot; No. 19, the place of beginning. BEING Lot; No. 18 in the plan of Penn Heights recorded in the Cum- berland County Recorder's Office in Plan Bock 6, page 28. HAVING thereon erected a single dwelling house known as 813 Wertz - ville Road. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY Township of East Pennsboro. BEING PREMISES: 813 Wertzville Road Enola PA 17025. SOLD as the property of GEORGE E. SEIDLE, JR. TAX PARCEL #09 -14- 0835 -057. BEING the same premises which Hazel A. Seidle, widow by deed dated 5/8/2002 and recorded 8/22/2002 in Cumberland County in Deed Book Volume 253 at Page 1327 granted and conveyed unto George E. Seidle, Jr. 105 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 11, October 18 and October 25, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. isa Marie Coyne, Editor SWORN TO AND SUBSCRIBED before me this — 2 of October 2013 6-Z Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public ARLISLE BOROUGH, CUMBERLAND 2 COUNTY My Commission Expires Apr 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 the patriotNews 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 Marianne Miller, being duly sworn according to law, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and 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 _ 2009 -5645 CMI Term ORGAN CHASE BANK NA vs. GEORGE E. SEIDLE, JR. Atty: Thomas I. Puleo ALL THAT CERTAIN piece or parcel of land situate in the Tbwnship of East Pennsboro, Cumberland County, Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the north side of the State Highway known as Route No. 944 as shown on the hereinafter mentioned Plan of Lots said point being 350 feet, measured in an eastwardly direction from Carol Lane (40 feet widc) said point also being the dividing line between lots Nos. 18 and 19, in the plan of Penn Heights; thence north 3 degrees 4 minutes west, along said dividing line, a distance of 186.95 feet to Lot No.4 on said plan; thence south 85 degrees 25 minutes east, along lots Nos. 4 and S on said plan, a distance of 70 feet to Lot No. 17 on said plan; thence south 3 degrees 4 minutes cast along said Lot No. 17, a distance of 186.08 feet to the north side : `orEsaid State Highway, thence south 84 degrees 42 minutes _west alonL said StateH ebway. dis1?!5 of _ This ad ran on the date(s) shown below: 10/13/13 10/20/13 10/27/13 Sworn bscribed before me th day of November, 2013 A.D. i COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp., Dauphin County My Commission Expires Dec. 12, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES KML LAW GROUP, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106-1.532 215-627-1322 Attorney for Plaintiff 2314 " 10 P/1 1: 04 PENN yNU COUNTY aN/�� 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 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. GEORGE E. SEIDLE JR. (Mortgagor(s) and Record owner(s)) 813 Wertzville Road Enola, PA 17025 TO THE PROTHONOTARY: Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County PRAECIPE TO VACATE JUDGMENT Kindly vacate the judgment upon payment of your costs only. By: No. 09-5645 LA GROUP, ' .C. Mic el McKeever Pa. ID 56129 Jay . Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David. Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello, Attorney ID 313897 Attorneys for Plaintiff ask . SU ti,,, Cit,ti-)6FtLie 1 2:11 36-10» GEORGE E. SE1DLE JR. 813 Wertzville Road Enola, PA 17025 KML LAW GROUP, P.C. Suite 5000 — BNY Mellon Independence Center 701 Market Street '44 Philadelphia, PA 19106-1532 215-6274122 rf IL E0- UI2 THE PROrHoNorAli 204 31,ili Pil•04 CUII8ERLA INNO COON Y PESYLVANIA 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 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. GEORGE E. SEIDLE JR. (Mortgagor(s) and Record owner(s)) 813 Wertzville Road Enola, PA 17025 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 09-5645 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your osts only. KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER By: hael McKee er Pa. ID 56129 I J y E. Kivitz Pa. ID 26769 _tisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 ill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello, Pa. ID 313897 Jennifer Lynn Frechie, Pa. ID 316160 Attorneys for Plaintiff GEORGE E. SEIDLE JR. 813 Wertzville Road Enola, PA 17025