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Home My WebLink About09-7107GOLDBECK 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 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A SB/M HOMESIDE LENDING 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. DEBORAH A. RITZ THOMAS J. RITZ JR. Mortgagors and Record Owners 1152 Kingsley Road Camp Hill, PA 17011 Defendants Term No. dq - 7107 1V1?4 CIVIL qC77ON. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, 0 SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTINGTO 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 htta://www. hn fa.org/consumers/homeowners/real aspx. 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 homeretentionaa,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 88512FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE Plaintiff is JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A S/B/M HOMESIDE LENDING, 7255 Baymeadows Way, Jacksonville, FL 32256. 2. The names and addresses of the Defendants are DEBORAH A. RITZ, 1152 Kingsley Road, Camp Hill, PA 17011 and THOMAS J. RITZ JR., 1152 Kingsley Road, Camp Hill, PA 17011, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On September 07, 2001 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to HOMESIDE LENDING INC., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book#:1733, Page 1688.. 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 June 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 ....................................................................................$51,729.68 Interest from 05/01/2009 through 09/30/2009 at 7.0000% .......................$1,517.76 Per Diem interest rate at $9.92 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$2,586.48 Late Charges from 06/01/2009 to 09/30/2009 .............................................$316.81 Costs of suit and Title Search ......................................................................$900.00 Escrow Advance ..........................................................................................$279.76 Other Fees ......................................................................................................$32.55 Recoverable Balance ......................................................................................$10.85 Monthly Escrow amount $217.47 $57,373.89 7. If the Mortgage is reinstated prior to a Sheriffs 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 Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $57,373.89, together with interest at the rate of $9.92, 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: l f GOLDBECK McCA FERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Enso Ustovic 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 unworn falsification to authorities. Date:pc7oZc=F I49m!7 Z/46- 4-V-7 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION #88512FC - DEBORAH A. RITZ and THOMAS J. RITZ JR. 1152 Kingsley Road Camp Hill, PA 17011 EyhibitA ALL THAT CERTAIN tract or parcel of land and premises, Situate, lying and being in the Township of Lower Allen, County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: BEGINNING at a point on the Eastern side of Kingsley Road, said point being One Thousand Three Hundred Two and Forty-eight One-hundredths feet South of the intersection of Kingsley Road and Norman Road, also at the dividing line between Lots Nos. 39 and 40, Block "Q", on hereinafter mentioned Plan of Lots; thence Eastwardly along the same One Hundred Twenty feet to a point at the dividing line between Lot No. 39 and lands now or late of Elmer E. Zimmerman; thence Southwardly along the same Fifty-eight and Forty-six One-hundredths feet to a point at line of lands now or formerly of Elmer E. Zimmerman; thence Westwardly along the same at right angles to Kingsley Road One Hundred Twenty feet to a point on the Eastern side of Kingsley Road; thence Northwardly along the same Fifty-eight and Forty-six One-hundredths feet to a point, the place of BEGINNING. BEING Lot No. 40, Block "Q", on Plan of Highland Park, recorded in Plan Book No. 5 page 37, Cumberland County Records and surveyed by D.P. Raffensperger, Registered Surveyor dated November 30, 1956. HAVING thereon erected a one story frame dwelling house. BEING Parcel No. 13-23-0545-134. Exhibit (B Washington Mutual FL5-7730 PO BOX 44090 Jacksonville, FL 32231-4090 August 17, 2009 #BWNCLNN# #0984589307944795# THOMAS J RITZ JR 1152 KINGSLEY RD CAMP HILL PA 17011 008211 /PC/FT 8458307447 WaMu' is becoming CHASE O Your house is pour 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 August 17, 2009 THOMAS J RITZ JR 1 152 KINGSLEY RD CAMP HILL PA 17011 008211 WaMu- is becoming CHASE O NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 8458307447 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose Specific information about the nature of the default is provided in the attached pages,. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) mU be able to help to save your home. This Notice explains how the grogram works To see if HEMAP can help. you must MEET WITH A CONSUMER EDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Anne The name. address an phone number of Consumer Credit Counseling At& *e?c cer?g ynnr County are listed at the end of this Notice. If you have any questions. you may call the Pennsylvania Housing Finance ftngy toll free at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMD2 SU HIPOTECA. C0826 HOMEOWNER'S NAME(S): Thomas J. Ritz Jr. PROPERTY ADDRESS: 1152 Kingsley Rd Camp Hill PA 17011 LOAN ACCT. NUMBER: 8458307447 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WIHCH 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 APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATA THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the propertyis located are set forth at the end of this Notice It is only negessary 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 MEE77NG WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AM FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEE77NG, 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 HEMAP APPLICATTON ESN BEYOND THESE TT11IF pFa1nnc ,4 I,,,TE APPLICATION WILL NOT PREVENT THE LENDER FROM STAR77NG A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY 77ME 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 flied bankruptcy, you can still apply for Emergency Mortgage Assistance.) 008211/COe26 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: 1152 Kingsley Rd Camp Hill PA 17011 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: 06/01/2009 $965.30 07/01/2009 $965.30 08/01/2009 $965.30 Other charges (explain/itemize): Uncollected Late Charges $242.03 Uncollected Fees: $21.70 Less Credits $0.00 TOTAL AMOUNT PAST DUE: $3159.63 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 $3159.63, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PEvments must be made either by cash. cashier's check certified check or money order made pavable and cent 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 moues} t. 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 up0your mortgaged yrMIU. *IF THE MORTGAGE W 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 R2dW. you will not be required to M attorney's_ en OTHER LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. C0826 MIUHT TO CURE THE DEFAULT PRIOR TO SHERIFFS SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the ri&ht to cure the default and prevent the sale at anv time u= to one hour before the Sheriff's Sale. You may do so by_pa3ing the total amount then past due. plus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriff Sal as Specified in writing by the lender and by performing aU other requirements under the mortgagg 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 SHERIFFS SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Washington Mutual Home Loans, Inc. Address: 7255 Baymeadows Way Jacksonville, FL 32256 Phone Number: 866-926-8937 Fax Number: 904-281-3914 Contact Person: Collection Department Email Address: www.wamuhomeloans.com EFFECTS OF SHERIFFS 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 Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. 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 Washington Mutual FL5-7730 PO BOX 44090 Jacksonville, FL 32231-4090 August 17, 2009 #BWNCLNN# #0984589307944795# DEBORAH A RITZ 1 152 KINGSLEY RD CAMP HILL PA 17011 008212 /PC/PT 8458307447 WaMu- is becoming CHASE Your house is your home. We want to keen it that wa. 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 August 17, 2009 DEBORAH A RITZ 1152 KINGSLEY RD CAMP HILL PA 17011 008212 WaMw is becoming CHASE 0 NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 8458307447 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mortgage on your home is in default and the lender intends to foreclose Specific information about the nature of he default i provided in the attached 12aggg. The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help save Igur home. This Notice "plains how the program works To see if HEMAP can help. you must MEET WITH A CONSUMER EDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Aucv 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 my questions. you may call the Pennsylvania Housin Finance A nc g ?y toll free at 1-800-342-2397. (Persons with imRaired 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 R"ORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. C0826 HOMEOWNER'S NAME(S): Deborah A. Ritz PROPERTY ADDRESS: 1152 Kingsley Rd Camp Hill PA 17011 LOAN ACCT. NUMBER: 8458307447 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN CALF 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 CUR WITHIN THIR TY-THREE (331 DAYS OF THE DATE OF THIS NC CF_ tF vnt T nn HIT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the prop&y 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 HE~ 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 HEMAP APPLI 47T N EVEN BEYOND WE SE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have riled bankruptcy, you can still apply for Emergency Mortgage Assistance.) 0082 12/C0826 HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it update). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 1152 Kingsley Rd Camp Hill PA 17011 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: 06/0112009 $965.30 07/01/2009 $965.30 08/01/2009 $965.30 Other charges (explain/itemize): Uncollected Late Charges $242.03 Uncollected Fees: $21.70 Less Credits $0.00 TOTAL AMOUNT PAST DUE: $3159.63 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 $3159.63, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. PPay=nts 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 up2yonr mortgaged property. *IF THE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. I£You cure the default within the THIRTY (301 DAY neriod. von will not he reanired to nav attorney's feels. OAR LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. C0826 KIWIT TU CURE THE DEFAULT PRIOR TO SHERIFF' 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 any time un to one hour before the Sheriff's Sale You may do so by paying the total amount then past due. Rlus any late or other charges then due reasonable attorney's fees and costs connected with the foreclosure sale and any other costs connected with the Sheriffs Sale . Vecified in writing by the lender and by performing any other regtirem .nt under the mo g_gg, Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Washington Mutual Home Loans, Inc. Address: 7255 Baymeadows Way Jacksonville, FL 32256 Phone Number: 866-926-8937 Fax Number: 904-281-3914 Contact Person: Collection Department Email Address: www.wamuhomeloans.com EFFECTS OF SHERIFF'S SALE: - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. 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 OF THE 209 OCT 16 PM 2: I '4> cu f .?f R # 7'8.50 PO An-I co Sol 5aa Pr* au 1,53 Sheriff s Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ~~,~nsr ~C ~~~~r~tirt'l~tt~ ~~,: ,.,, , oF~ ~ ~ :; -: ~ ~..~~~~~ . .. F _ ~. .~ _ (~` ~E,r~ ~„ - r 1~~vRfi,.,I ..~ ~~i `;~ -~ - - ~~ ~: JP Morgan Chase Bank, NA Case Number vs. 2009-7107 Deborah H. Ritz SHERIFF'S RETURN OF SERVICE 10/20/2009 07:59 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 20, 2009 at 1959 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Deborah H. Ritz, by making known unto herself personally, at 1152 Kingsley Road Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/20/2009 07:59 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 20, 2009 at 1959 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Thomas J. Ritz, by making known unto Deborah H. Ritz, wife of defendant at 1152 Kingsley Road Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $57.50 SO ANSWERS, ~.~~-~~ ~.a~~ October 21, 2009 R THOMAS KLINE, SHERIFF .--' -/c~ ~' Deputy Sheriff GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 88512FC CF: 10/16/2009 SD: 03/03/2010 $58,252.03 JPMORGAN CHASE BANK, N.A., AS ACQUIltER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A SB/M HOMESIDE LENDING 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. DEBORAH A. RITZ THOMAS J. RITZ JR. Mortgagor(s) and Record Owner(s) 1152 Kingsley Road Camp Hill, PA 17011 Defendant(s) CERTIFICATE OF SERVICE PURSUANT TO Pa.R.C.P. 3129.2 (c) (2) Term No. 09-7107 c'> ~ ~: c~ r-^ "'1 -; ; , rn -, _ ~ ~ r __~_ „~ - -o _, . _„ =cam r-_ =ice ~" r = ~ :-~ w :~ Michael T. McKeever, Esquire, Attorney for Plaintiff, hereby certifies that service on the Defendants of the Notice of Sheriff Sale was made by: Personal Service by the Sheriffs Office/ t (copy of return attached). ( ) Certified mail by Michael T. McKeever (original green Postal return receipt attached). ( ) Certified mail by Sheriffs Office. ( ) Ordinary mail by Michael T. McKeever, Esquire to Attorney for Defendant(s) of record (proof of mailing attached). ( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s) (proof of acknowledgment attached). ( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s) of record. IF SERVICE WAS ACCOMPLISHED BY COURT ORDER. ( ) Premises was posted by Sheriffs Office/competent adult (copy of return attached). ( ) Certified Mail & ordinary mail by Sheriff s Office (copy of return attached). ( ) Certified Mail & ordinary mail by Michael T. McKeever (original receipt(s) for Certified Mail attached). ( ) Published in accordance with court order (copy of publication attached). Pursuant to the Affidavit under Rule 3129 (copy attached), service on all lienholders (if any) has been made by ordinary mail by Michael T. McKeever, Esquire (copies of proofs of mailing attached). The undersigned understands that the statements herein are subject to the penalties provided by 18 P.S. Section 4904. Respectfully submitted, BY: Keith C. Hal Legal Secretary IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE ~ LL O ~ K LL O O 0 O O Z m ~O O LL /AN OI W^~ O ~LL zoo u ~ _~~a a~ o ~ ~ N ~ t Q 4 Q. t ' ~ ~ Y~ 0 ~ Uyy 3 ~ Y~ p ~Q J ~ ~s~~n o o ~ ~ ~ f~. ~, 3 ~ •+ y ~ A f~0`~ZtHd G N r` ~ .0 r a ~~ `,~ a ~. .,~ ~dv ~ ~ g' ~ 'y0i1tl15 tm V ~ fu (n ag =~ ~ v cu =V Z ~- =mE~ -o -m d (LO~ o.~o_~ mm ~ ~O Ev~$= i~a v ULr~ v1N~ w E ° LL U ~¢ X N'- O ~~ y~ m O a ~~bS~~ o'z ~ w ¢cuoo ao N ~- F- C m Z Y n m °' z ~ E N W .- co C u~i a° ~ '- U O c c c ,`g `y U C d O Q ~ O ~ Z w } ~-o OV ~ ~ ~ y ~' ~dm a W J N a d~ 5 q (Y] W N W O v ~'~ °~ ~ ~Ev ~ o 0 s~~in ~ U Up Q o ~ ~ E ~ J O ~ d ~ d O ~w ~ s a ~ cn a ~ ~ N cn a ~ ;; s ~ O p o. m o ~ O o _~ Q ~ H 7~ ~ DOQ gogt~ H c- _ J Z(n ro ~J t U ~ ~ ~ ~ ~ L ~ ~ d ~ J W z E $„-'o~a'd U NOQ ~'ULN6~. QX~ a o fi, O w x w ~ H ~- ~~ Q. Q o ~ x 3 W~ m U U ^w ~ (nH x N a 7~ o~ ~ ~U y >°: W Z ~ U W ti ~ m ~ W _1 `° ~ ~ m . ~ OJ - ~ ~ ~j ~ ~ ~ W m ~ ~~aU D_a02a_S ~NZ a° D N c ~ 2 N W Q ~ o ~a a ~Q W ~Yo dci V O Y W ~ ~ N C w {.4- ~ ~ ~~ N LLI (U ~ ~ ~o ~ r- _ zO~o2~ ~ c7 (~cnr~n N :7 ~^ C f~ CO N W U N `~^ a~_ O ~ a° ~ti ~~ Z~ IL U d N d' c a C O a A m 0 c V .3 H R m m a 0 U 0 O N (`') O f7 0 N in D N ~i ~ ~ N H N _~ O C ~ ~ ~ O cc c0 V C a ~ O o ~ x N ~ _T ~ 7 ~ U ~ LL ti Q ~ _ Q M ~ ~ N O o m LL ~ a o°o ~ Z t I 0 wd I o~ i r SHERIFF'S OFFICE OF CUMBERLAND COUNTY r~ °- Ronny R Anderson Sheriff =o`ti`~ti~, of eam6rr~yQ Jody S Srnith --- ,, Chief Deputy ~ ~ ~ _- `~, ;.~_ :': Edward L Schorpp ~` ~~` gFF~GE 4F ~ ~~ ~hEP.tFF Solicitor JP Morgan Chase Bank, NA Case Number vs. 2~9-7107 Deborah H. Ritz SHERIFF'S RETURN OF SERVICE 12/22/2009 07:10 PM -Michael Barrick, Deputy Sheriff, who being duly swom according to law, states that on December 22, 2009 at 1910 hours, he posted a true copy of the within Real Estate Writ, Notice, Poster and Description, in the above entitled action, upon the properly of Deborah H. & Thomas J. Ritz, located at, 1152 Kingssey Road, Camp Hili, Cumberland County, Pennsylvania according to law. 12/22/2009 07:10 PM -Michael Barrick, Deputy Sheriff, who being duly swom according to law, states that on December 22, 2009 at 1910 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: Deborah H. Ritz, by making known unto, Kerston Ritz, daughter of defendant, at, 1152 Kingsley Road, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 12/22/2009 07:90 PM -Michael Barrick, Deputy Sheriff, who being duly swom according to law, states that on December 22, 2009 at 1910 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: Thomas J. Ritr, by making known unto, Kerston Ritz, daughter of defendant, at, 1152 Kingsley Road, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. ;ci Ga,rrysu~e s~,tt. re+eoson, uw. GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6320 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A SB/M HOMESIDE LENDING 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. DEBORAH A. RITZ THOMAS J. RITZ JR. Mortgagor(s) and Record Owner(s) 1152 Kingsley Road Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-7107 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A SB/M HOMESIDE LENDING, Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 1152 Kingsley Road Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): DEBORAH A. RITZ 1152 Kingsley Road Camp Hill, PA 17011 THOMAS J. RITZ JR. 1152 Kingsley Road Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: DEBORAH A. RITZ 1152 Kingsley Road Camp Hill, PA 17011 THOMAS J. RITZ JR. 1152 Kingsley Road Camp Hill, PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 LOWER ALLEN TOWNSHIP AUTHORITY 120 LIMEKILN ROAD NEW CUMBERLAND, PA 17070 4. Name and address of the last recorded holder of every mortgage of record: 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 1152 Kingsley Road Camp Hill, PA 17011 (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: February 11, 2010 ~~ ~ ; GOLDBECK McCAF RTY & McKEEVER BY: Keith C. Halili Legal Secretary