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Home My WebLink About09-8335GOLDBECK McCAFFERTY & McKEEVER AY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 W W W.GOLDBECKLAW.COM ATTORNEY FOR 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, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. SUNDRA JEAN SOUDER a/k/a SONDRA JEAN SOUDER Mortgagor and Record Owner 2005 Wentworth Drive Camp Hill, PA 17011 Defendant IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. CA-83W Uwi 1 ??t1r1 Ct"L FORT :C? ON. Mp ASE 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 LISTED 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 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 TELL-FOND LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, RSTA 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 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 ho://www.phfa.org /consumers/homeowners/real Wx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: hW://www.Philadell?hiafed.orwforeclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionaa go-ldbecklaw.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 90585FC. 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. Resources available for Homeowners in Foreclosure COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION, 7255 Baymeadows Way, Jacksonville, FL 32256. 2. The names and addresses of the Defendant is SUNDRA JEAN SOUDER a/k/a SONDRA JEAN SOUDER, 2005 Wentworth Drive, Camp Hill, PA 17011, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On July 16, 2003 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1823 Page 2367. 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(8); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for January 01, 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 ....................................................................................$99,702.89 Interest from 12/01/2008 through 11/30/2009 at 5.3750% .......................$5,358.20 Per Diem interest rate at $14.68 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$4,985.14 Late Charges from 01/01/2009 to 11/30/2009 .............................................$337.26 Monthly late charge amount at $30.66 Costs of suit and Title Search ......................................................................$900.00 Pro Rata MIP/PMI .......................................................................................$153.32 Escrow Advance .......................................................................................$1,837.01 Suspense ......................................................................................................... ($1.06) NSF Charges ..................................................................................................$25.00 Recoverable Balance ....................................................................................$189.28 Deficit ........................................................................................................ ($201.97) Monthly Escrow amount $250.70 $113,285.07 7. If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff's Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendant in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendant by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendant have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendant through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $113,285.07, together with interest at the rate of $14.68, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff's Sale of the Property. By: ..1+.. U f n GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VO VERIFICATION I, Pose Hwy er , 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: oZ Q JPMORGAN CHASE BANK, NATIONAL ASSOCIATION #90585FC - SUNDRA JEAN SOUDER aWa SONDRA JEAN SOUDER 2005 Wentworth Drive Camp Hill, PA 17011 ExhibitA Stewart TWO Commbvx t Number A103-279S 3000ER SCNEDtiLE C pRopElm DESCRIPTION The land raferred to in this Commitment is described as Maws: DING the same M nlsee which Robert W. Doke and Mw jode F. Oaks by ktdenbso dated 05.2248 and recor+tted at CaAde in the County of Cumberland on 05-29-98 In Deed Book 118, Papa 96, prettied and Conveyed unto Andrew W. Nortleet and Kimberly A. Nof legit, In fee. AA VMT CL'1k?!= tract or parcel of ground situate in Lower Alien Township, Cumberland County, state of Ponneylvwtia, =to particularly bounded RCand and acco ding Juno to30 -sy of D. P. Raffenapexger, follows, to wit: t33tilisR=G at a point on the southern side of Wentworth Drive two hundred (200) treat vast of the intarsectic a of Ventworth Drive and property line, rojeatod UAtburn road, State highway 021021, also at the dividing line bit Lots Noe. 3 and t on here iaaftat-masstioned Plan of Lots, theacne soutthwardly at right aanagglos to Wentworth Drive, one hundred t3.xty (160) lest to a point ac line of lards now or late of T. S. shatter: chance westwardly along the same sixty (601 feet to a point at the &vidiug line between Lots Mon. 4 and 5 on said Plan; thence northvardly along the saw at might angles to Weentworth 'Drive one hundred sixty (1601 feet: to a point: an the southern side of Wentworth DrIval thence eas:watdly along the same sixty 160) feet to a point, the place of BSGIDAfM. 82=0 Lot: No. s ov Plan of Bighlaad Botates, addition #2, said Plan being recorded ..a Plan Book 5, Gage 51, Cumberland Co=t:y records. HAVING TH>1`l Riff BMTSD a one-stony Pram dwelling !louse, known and numbered as 2005 Wentworth Drive. Ccrti ry liis to be recorded III Cumberland County PA ALTA Con+rnsnant 0. 190UDGM Recorder of Deeds OK 1823PG2385 Ex,hibit (B Washington Mutual FLS-7730 PO BOX 44090 Jacksonville, FL 32231-4090 7100 4047 5100 7593 6083 August 24, 2009 StNNDRA J SOLIDER 2005 WENTWORTH DR CAMP HILL PA 17011 000395 /PC/FT 0646083097 WaNkr b" - - a-Mig CHASE C? Your house is your home. We want to keen it that way. You are going through tough times - we can help. In fact, we believe your home loan. may be ellfbk 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 l-U6-926.8937 so we can help you turn things around. Well 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 24, 2009 SUNDRA J SOLIDER 2005 WENTWORTH DR CAMP HILL PA 17011 000395 V N W is bean i h, CHASE O NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 0646083097 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HO It E FROM FORECLOSURE E S LA NOTIFICACION EN AWUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DBRECRO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFWACION OaTSNGA UNA TRADUCCION 94M MUTRWWN E LLAMANDO ESTA AGENCIA (PENNSYLVANIA EN USDIG FINANCE AGENCY) SIN CARGOS AL NUMXRO MENC11ONAD0 ARRIBA. PUEDE SER ELEGISLE PARA UN PRSSTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL COAL MWE SALVAR SU CASA DE LA PERDIDA DEL DERECSO A REDS IIR SU HIPOTECA. Cosib HOMEOWNER'S NAME(S): Sondra J. Souder PROPERTY ADDRESS: 2005 Wentworth Dr. Camp HUI PA 17011 LOAN ACCT. NUMBER: 0646083097 ORIGINAL LENDER: Sto CURRENT LENDERNERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM 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. TE>ffiN)RARY STAY OF )SUR - Under the Act, you are entity 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 counselint agencies listed at the and of thie Nntirp T"M - 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 HESIAP APPLIC4770N AS C = AS PQ,SSMLE, IF YOU HAVE A MLVE771VG WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF 7NIS NOTICE AA2 FILE AN APPLICATION WITH PHFA WMN 30 DAYS OF 7H4T MEETING, THEN THE LENDER WILL BE 7EWORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, RV THE SECT ION CALLED "TEMPORARY STAY OF FORECLOSURE". .' raceur arr1LK:A IMY avff.N U[iroN? 77if4SE ZZUE E -lam A WE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPUC47YON IS EVENTUALLY APPROVED AT ANY 77ME BEFORE A SHERIFF'S SALE, TILE 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 BANERUM'CY, 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 Med bankruptcy, you can still apply for Emergency Mortgage A ce.) CKWUNER CREDIT COINSALING 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. Ik manes. addressee and teltphon numbers of designated consumer credit ulaiing Aril _fa for the comM in which he 1? RUU is located are set- forth at the end ofthis Notice, It is only necessary to schedule one tace-to-face meeting. Advise your lender imm®diately of your intentions. 000395/CO826 HOW TO CUAR YOUR MORTGAGE =FAULT Mda it up to-date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 2005 Wentworth Dr. 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: 01/01/2009 $863.94 02101/2009 $865.98 03101/2009 $865.98 04101/2009 $865.98 0901/2009 $865.98 06/01/2009 $865.98 07/01/2009 $865.98 08/01/2009 $865.98 Other charges (explain/itemize): Uncollected Late Charges $61.32 Uncollected Fees: $25.00 Less Credits $1.06 TOTAL AMOUNT PAST DUE: $7011.06 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): MR TO_CURR, MLT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING TI1Z TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $7011.06, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Ealments must be made either -by cash- =bier's check- certified check. or money order_ made pgUble and sent to: Washington Mutual Bank Casa Processing P.O. Bon; 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): IFS DO _THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, tine Fier to undue its riehts to amelere? the morha deW 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 1081 action to.hredeae noon v r onB ampady. *IF THE ME?TCAG ffi ,ORMANN tmON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender rtiPeas 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 feces 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 an the de[aYit wian the THRTY (30) DAY period You it mat be rowdred to ga at:Ba='s fees, under - The lender may also sue you personally for the upaid principal balance and all other sums due the mortgage. C0826 period - If you have not cured the default within the THIRTY (30) your default in the nanner ad forth in this notice will restore your mortgage to the same as K you bad never I A SHEREPT'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 Sbe_riffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Name of Lender: Washington Mutual Home Loans, Inc. Address: 7255 Buymeadowt`Way JadrsoavDo, FL 32256 Phone Number: 866.9264937 Fax Number: 904-261-3914 Contact Person: COBOc" D"Wtiment Email Address: www.wamabonaloane.oom ? S OF U: - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other Wongings could be started by the lender at any time. - You may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED An inWortant reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Hmneowner Afibrdmbift and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of nay ergmalwaon that aftampts to dirge a the for housing counseling or modification of a delinquent bun, especially If they require a The In advance." W Mttnal offers bow modification assistance free of charge (i.e., no modification fee required). Please call us inunediately at (866) 926$937 to discuss your options. The longer you delay the fewer options you may have. WE ARE A DEBT COLLECTOR. i 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. 00826 0 FILED--QFI'",E IF IlE PROT ;'NOTARY 2009DEC -2 PH 3: 09 CLIME l =`v'U11` EIN S1'LY1 NA -4-M. 50 ATH a&4-41l In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A ~ WASHINGTON MUTUAL BANK, FA A FEDERAL ri/ ~ ~ ~3 ASSOCIATION ~ ~ ~> 7255 Baymeadows Way .~~ ° ~ Jacksonville, FL 32256 No. 09-8~-;z'. _ ~~'?'- Plaintiff °`' _~;, ~'~ SUNDRA JEAN SOUDER a/k/a SONDRA JEAN SOUDER ~ !"_ ' -} ~~ (Mortgagor(s) and Record Owner(s)) _ ~i-- , - , - `-::' C"~ 2005 Wentworth Drive v L w ' a rn Camp Hill, PA 17011 ~'' ~ ~~ N ~" ~ Defendant(s) N PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against SUNDRA JEAN SOUDER a/k/a SONDRA JEAN SOUDER by default for want of an Answer. Assess damages as follows: Debt Interest from 1/15/2010 to Date of Sale per diem at $14.68 Total (Assessment of Damages attached) $114,508.39 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 M' a . Mc Bever ttorney for intiff I.D. #56129 AND NOW ~ ~?L~/lJ ,Judgment is entered in favor of JPMORGAN CHASE B ~, 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, FA A FEDERAL ASSOCIATION and against SUNDRA JEAN SOUDER a/k/a SONDRA JEAN SOUDER by default for want of an Answer and damages assessed in the sum of $114,508.39 as per the above certification. ~~~~~ ~~ G~~ ~5/39i9 ~'~ ~ 3 ~~ l/~»~~_ u.n. //eJ othonotary SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline SheriS Ronny R Anderson Chief Deputy Jody s smith Civ~ Process Sergeant Edward L Schorpp SoJlcihor ~4~ratr ai ~n+nGcr~~~ C~ -µ~ , ,~ : a s /~r ~; .rte ,-:?.:- QFF~E QF Ttff SH,CRIFF JPMorgan Chase Bank, NA vs. Sondra Jean Souder Case Number 2008-8335 SHERIFF'S RETURN OF SERVICE 12/04/2009 05:14 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to taw, states that on December 4, 2009 at 1714 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to w~: Sondra Jean Souder, by making known unto herself personally, at 2005 Wentworth Drive, Camp Hill, New Cumberland, 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: $41.50 December 07, 2009 SO ANSWERS, R THOMAS 1Q..1NE, SHERIFF BY :%'~c' Deputy Sherif f {c) Co.~tNStjre Stremf. T~saT, In^. 30585FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. TO: SUNDRA JEAN SOUDER a/Wa SONDRA JEAN SOLIDER SOUDER, SUNDRA JEAN a/k/a SONDRA JEAN SOLIDER 2005 Wentworth Drive Camp Hill, PA 17011 DATE OF THIS NOTICE: December 29, 2009 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, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. SUNDRA JEAN SOUDER a/k/a SONDRA JEAN SOUDER (Mortgagor(s) and Record Owner(s)) 2005 Wentworth Drive Camp Hill, PA 17011 Defendant(s) TO: SUNDRA JEAN SOUDER a/k/a SONDRA JEAN SOUDER 2005 Wentworth Drive Camp Hill, PA 17011 In the Court of Common Pleas of Cumberland County CIVIL ACTION -LAW Action of Mortgage Foreclosure Term No. 09-8335 IlVIPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Cazlisle, PA 17013 717-243-9400 Michael T. McKeever GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff Suite 5000 - 701 Mazket Street. Philadelphia, PA 19106 215-825-6318 GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER (Mortgagor(s) and Record owner(s)) 2005 Wentworth Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 09-8335 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 RECENER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION, and against SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER 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 $114,508.39. Mic el T. McKeever orney for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 and that the name(s) and last known address(es) of the Defendant(s) is/are SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER, 2005 Wentworth Drive Camp Hill, PA 17011; LDBECK 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 12/01/2008 through 01/14/2010 Reasonable Attorney's Fee Late Charges Costs ofSuit and Title Search Escrow Payments Due 2 X $250.70 $99, 702.89 $6,018.80 $4,985.14 $398.58 $900.00 $501.40 Pro Rata MIP/PMI Escrow Advance Suspense NSF Charges Recoverable Balance Deficit $153.32 $1,837.01 ($1.06) $25.00 $189.28 ($201.97) $114,508.39 AND NOW, this / 9 ~ day of ~~~,~ GOL ECK MICA ERTY & McKEEVER B .Michael T. McKeever ttorney for Plaintiff 2010 damages are assessed as above. r Prothy 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 Mazket Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER Mortgagor(s) and Record Owner(s) 2005 Wentworth Drive Camp Hill, PA 17011 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE No. 09-8335 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 1/15/2010 to Date of Sale per diem at $14.68 $114,508.39 (Costs to be added) LDBECK Mc AFFERTY & McKEEVER BY: Michael T. McKeever Attorney for Plaintiff F1L~~-~~' ~=sub D ~ i. 2DIII .~~~ 19 ~~ I ~ ~ 22 Ci~iJ~:L ~ _J~,il`~ i v ~- Q~ ~d ~ !,' si ~~~ s~ ~r o? ;Sa '` « 7~~ ~ ~: ,. 06 .~ :, /~ ~.~ ~ ~o. s ~ ~ ~~- o~~W~ ~ Q >w ~ d ~xavQ ~ O a a ¢ Q ~ ¢ z ,,.., '" o ~p~~~ ~ 3 °~ W i ¢~Q~QZ Qp'a;p W u '^~ dF-~wUCGp O oQ~ ~" u Q ~ ,~ •--~ M zaw a ~ ~ o „ U ~~w x~HO~¢ ~ ors: 3a ~Fo w ~ ~, z~ ~zwo~Q A ~~ ~. x z ~ o x~zo° o ~°~ w~ x z~~W~ zo a~~~Q Q ~ ~~ ~~ ~ x U U ~I ~. ~ ~ ~U v ~-vi ~ o o~ ~ ~ ~ N a w ''" .1C c~ N U ~ ~ ~~ ~~~+ ~~ O ~ N .k I ~ O R" ~a a„ c~ ALL THAT CERTAIN tract or parcel of ground situate in Lower Allen Township, Cumberland County State of Pennsylvania, more particularly bounded and described according to survey of D.P.Raffensperger, Registered surveyor, dated June 30, 1953, as follows to wit: BEGINNING at a point on the southern side of Wentworth Drive two hundred (200) feet west of the intersection of Wentworth Drive and property line, projected Lisburn Road, State Highway #21023, also at the dividing line between Lots Nos. 3 and 4 on hereinafter- mentioned Plan of Lots thence southwardly at right angles to Wentworth Drive, one hundred sixty (160) feet to a point at line of lands now or late of T. F, Sheffer; thence westwardly along the same sixty (60) feet to a point at the dividing line between Lots Nos. 4 and 5 on said Plan, thence northwardly along the same at right angles to Wentworth Drive one hundred sixty (160) feet to a point on the southern side of Wentworth thence eastwardly along the same sixty (60) feet to a point, the place of BEGINNING, BEING Lot No.4 on Plan of Highland Estates, Addition #2, said Plan being recorded in Plan Book 5, Page 51, Cumberland County records. HAVING THEREON ERECTED a one story frame dwelling house, known and numbered as 2005 Wentworth Drive. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 2005 Wentworth Drive Camp Hill, PA 17011 SOLD as the property of SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER TAX PARCEL #13-23-0549-189 BEING the same premises which Andrew W. Norfleet and Kimberly A. Norfleet, husband and wife, by Deed dated 7/6/03 and recorded 7/17/03 in Book 258 Page 832 granted and conveyed unto Sundra J. Souder. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N02009-8335 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMorgan Chase Bank, N.A. as Acquirer of certain assets and liabilities of Washington Mutual Bank from the Federal Deposit Insurance Corporation acting as receiver f/k/a Washington Mutual Bank, FA A Federal Association 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff (s) From Sundra Jean Souder a/k/a Sondra Jean Souder 2005 Wentworth Drive Camp Hill, PA 17011 (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$114,508.39 L.L.$.50 Interest from 1/15/2010 to date of sale per diem at $14.68 Atty's Comm % Due Prothy $2.00 Atty Paid $160.50 Plaintiff Paid Other Costs Date: January 19, 2010 (Seal) REQUESTING PARTY: Name Michael T. McKeever, Esq. Goldbeck McCafferty & McKeever Address: Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: (215) 627-1322 Supreme Court ID No. 56129 ~.,r~~~ Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 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 RECENER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. SUNDRA JEAN SOUDER a/k/a SONDRA JEAN SOUDER (Mortgagor(s) and Record Owner(s)) 2005 Wentworth Drive Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-8335 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, FA A FEDERAL ASSOCIATION, 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: 2005 Wentworth Drive Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): SUNDRA JEAN SOUDER a/k/a SONDRA JEAN SOUDER 2005 Wentworth Drive Camp Hill, PA 17011 2. Name and address of Defendant(s) in the judgment: SUNDRA JEAN SOUDER a/k/a SONDRA JEAN SOUDER 2005 Wentworth Drive 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: FILF~~ ;~riCF zQ{~.~~t~~ tg ~~~~~ ~C - ~~~ ~~~~'V~ t'c~ ti~ v~~+~ L11F1!`~~h~ IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: WAYPOINT BANK 449 Eisenhower Boulevard Harrisburg, PA 17111 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 2005 Wentworth Drive 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: January 14, 2010 /~ !/ - GO BECK M AFFERTY & McKEEVER Michael T. McKeever, Esq. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMMONWEALTH OF PENNSYLVANIA CIVIL ACTION 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, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. Term No. 09-8335 ACTION OF MORTGAGE FORECLOSURE SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER 2005 Wentworth Drive Camp Hill, PA 17011 Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER C7 ~ _ Ti ~-~-, o C... ---s J _ f~rf r ! ~ `i S~ < -< : , c_ __ i, `_; M ~ ~ ..-> C~ -- ~ --Z N N Your house (real estate) at (address) 2005 Wentworth Drive Camp Hill PA 17011 is scheduled to be sold at Sheriff's Sale on (date): (time): 10:00 a.m. (place of sale): Commissioners Hearin Room - 2nd floor Cumberland Count Courthouse to enforce the court judgment of $114,508.39, obtained by the judgment creditor against you. 09-8335 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 ;_ ;;LL ZQ~~.~~t~ ~~ ~+t~t~ 22 r - _~ JPMORGAN CHASE BANK, N.A., AS ACQUIRI OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER Mortgagor(s) and Record Owner(s) 2005 Wentworth Drive Camp Hill, PA 17011 Defendants IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-8335 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: SOURER, SUNDRA JEAN a/k/a SONDRA JEAN SOURER SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER 2005 Wentworth Drive Camp Hill, PA 17011 Your house at 2005 Wentworth Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $114,508.39 obtained by JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 09-8335 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION, the back payments, late charges, costs and reasonable attorney's fees due. To fmd out how much you must pay call our office at 215-825-6329 or 1-866-413- 2311. 2. You may be able to stog the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://wwwphiladelphiafed.or~/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue 09-8335 Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 09-8335 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.orglconsumers/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(a,goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure andlor 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 90585FC. Para information en espanol puede communicarse con Loretta a1215-825-6344. Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 1910b 215-627-1322 Attorney for Plaintiff T~~~ F;~" /2'y0f 4 J,~~ t 9 Ff I I~ Z2 r'~i ~! ~ti~ Y L~ r~: ~~u~± 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, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. SUNDRA JEAN SOUDER a/kfa SONDRA JEAN SOUDER Mortgagor(s) and Record Owner(s) 2005 Wentworth Drive Camp Hill, PA 17011 Defendant(s) CERTIFICATION AS TO TIIE SALE OF REAL PROPERTY N0.09-8335 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 Michaei'T. McKeever Attorney for plaintiff FfL~[~ ~:~r;=~~~ '~` EFL" f~~N~`T-.'nn,~r~l,~F?Y SHORT DESCRIPTION ~a~o~~~~ ~~ ~~~~~~ ~z IMPROVEMENTS consist of a residential dwelling. CJt ~(/~~+1 _, ~ y; ;; ,,~1g~yr • 4i~J1V~~ft~ 1 ~'jl.l1 Y5 d ~bf ~~~ A BEING PREMISES: 2005 Wentworth Drive Camp Hill, PA 17011 SOLD as the property of SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER TAX PARCEL #13-23-0549-189 ~A4 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,, Ronny R Anderson _ Sheriff ~. ~ ~ _. ~_: . ," Jody S Smith ~ ; „ Chief Deputy _ ~ `= ~ J ~~'~ Y ~~ ~~ (~; 2 ~ Edward L Schorpp ~~irr , _ , .. `, Solicitor ,'~~ -. ~ ,_, JPMorgan Chase Bank, NA Case Number vs. 2009-8335 Sundra Jean Souder SHERIFF'S RETURN OF SERVICE 04/20/2010 07:04 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 4/20!10 at 1900 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 Sundra Jean Souder, located at, 2005 Wentworth Drive, Camp Hill, Cumberland County, Pennsylvania according to law. 04/20/2010 07:04 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 4/20/10 at 1900 hours, he served a true copy of the within Reaf Estate Writ, Notice and Description, in the above entitled action, upon the within named defendant, to wit: Sundra Jean Souder, by making known unto, Sundra Jean Souder, personally, at, 2005 Wentworth Drive, 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 05/10/2010 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 5/7/10 SHERIFF COST: $713.66 May 24, 2010 SO ANSWERS, r ~.___. RON R ANDERSON, SHERIFF a OD ~:~~ . Cry C'~~ ~ 7~ ~.~~ ~~~~ Goldbeck'P.~IcCafferty & McKeever BY: 'Michael T. Mc~KeevEr Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER (Mortgagor(s) and Record Owner(s)) 2005 Wentworth Drive Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-8335 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, FA A FEDERAL ASSOCIATION, 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: 2005 Wentworth Drive Camp Hill, PA 17011 l.Name and address of Owner(s) or Reputed Owner(s): SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER 2005 Wentworth Drive Camp Hill, PA 17011 2. Narne and address of Defendant(s) in the judgment: SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER 2005 Wentworth Drive Camp Hill, PA ] 7011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA 17013 PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support Enforcement Health and Welfare Bldg. -Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 4. Name and address of the last recorded holder of every mortgage of record: WAYPOINT BANK 449 Eisenhower Boulevard Harrisburg, PA 17111 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 2005 Wentworth Drive 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. 1 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: January 14, 2010 ~~6~~~G j'~ GO BECK M AFFERTY & McKEEVER Michael T. McKeever, Esq. Attorney for Plaintiff ,r 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 09-8335 JPMORGAN CHASE BANK, N.A., AS ACQUIRI OF CERTAIN ASSETS AND LIABILITIES OF WASI-IINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER Mortgagor(s) and Record Owner(s) 2005 Wentworth Drive Camp Hill, PA 17011 Defendants; IN THE COURT OF COMMON PLEAS of Cumberland County CNIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Term No. 09-8335 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: SOUD6R, SUNDRA JEAN a/IJa SONDKA JEAN SOLIDER SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER 2005 Wentworth Drive Camp Hill, PA 17011 Your house at 2005 Wentworth Drive, Camp Hill, PA 17011 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $114,508.39 obtained by JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE .i 09-8335 To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK, FA A FEDERAL ASSOCIATION, the back payments, late charges, costs and reasonable attorney's fees due. To fmd 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 I . If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www philadelphiafed or~/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue 09-8335 Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 09-8335 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.or~/consumers/homeowners/real aspx. S). 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 l -866-413-2311 or via email at homeretention(a~~oldbecklaw tom. 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 90585FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN tract or parcel of ground situate in Lower Allen Township, Cumberland County State of Pennsylvania, more particularly bounded and described according to survey of D.P.Raffensperger, Registered surveyor, dated 3une 30, 1953, as follows to wit: BEGINNING at a point on the southern side of Wentworth Drive two hundred (200) feet west of the intersection of Wentworth Drive and property line, projected Lisburn Road, State Highway #21023, also at the dividing line between Lots Nos. 3 and 4 on hereinafter- mentioned Plan of Lots thence southwardly at right angles to Wentworth Drive, one hundred sixty (160) feet to a point at line of lands now or late of T. F, Shetter; thence westwardly along the same sixty (60) feet to a point at the dividing line between Lots Nos. 4 and 5 on said Plan, thence northwardly along the same at right angles to Wentworth Drive one hundred sixty (160) feet to a point on the southern side of Wentworth thence eastwardly along the same sixty (60) feet to a point, the place of BEGINNING, BEING Lot No.4 on Plan of Highland Estates, Addition #2, said Plan being recorded in Plan Book 5, Page 51, Cumberland County records. HAVING THEREON ERECTED a one story frame dwelling house, known and numbered as 2005 Wentworth Drive. IMPROVEMENTS consist of a residential dwelling. BEING PREMISES: 2005 Wentworth Drive Camp Hill, PA 17011 SOLD as the property of SUNDRA JEAN SOLIDER a/k/a SONDRA JEAN SOLIDER TAX PARCEL #13-23-0549-189 BEING the same premises which Andrew W. Norfleet and Kimberly A. Norfleet, husband and wife, by Deed dated 7/6/03 and recorded 7/17/03 in Book 258 Page 832 granted and conveyed unto Sundra J. Souder. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N02009-8335 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMorgan Chase Bank, N.A. as Acquirer of certain assets and liabilities of Washington Mutual Bank from the Federal Deposit Insurance Corporation acting as receiver f/Wa Washington Mutual Bank, FA A Federal Association 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff (s) From Sundra Jean Souder a/Wa Sondra Jean Souder 2005 Wentworth Drive Camp Hill, PA 17011 (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$114,508.39 L.L.$.50 Interest from l/l5/2010 to date of sale per diem at $14.68 Atty's Comm % Due Prothy $2.00 Atty Paid $160.50 Plaintiff Paid Other Costs Date: January 19, 2010 (Seal) REQUESTING PARTY: Name Michael T. McKeever, Esq. Goldbeck McCafferty & McKeever Address: Suite 5000 -Mellon Independence Center Q~ David D. Buell, Prothonota By: Deputy 701 Market Street Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: (215) 627-1322 Supreme Court ID No. 56129 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as, 2005 Wentworth Drive, Camp Hill, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 By: Real Estate Coordinator g ~ ~ZI c~~ b 1 Nei C G;OZ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 16, Apri123, and Apri130, 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. f,,._-- L' a Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 30 da of April 2010 Notary NOTARIAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commlasla~ Expina Aa 28, 201 Writ No. 2009-8335 Civil JPMorgan Chase Bank, NA vs. Sundra Jean Souder a/k/a Sondra Jean Souder Atty :Michael McKeever ALL THAT CERTAIN tract or par- cel of ground situate in Lower Allen Township, Cumberland County State of Pennsylvania, more particularly bounded and described according to survey of D.P.Raffensperger, Regis- tered surveyor, dated June 30, 1953, as follows to wit: BEGINNING at a point on the southern side of Wentworth Drive two hundred (200) feet west of the intersection of Wentworth Drive and property line, projected Lisburn Road, State Highway #21023, also at the dividing line between Lots Nos. 3 and 4 on hereinafter-mentioned Ylan of Lots thence southwargly at right angles to Wentworth Drive, one hundred sixty (160) feet to a point at line of lands now or late of T. F. Shetter; thence westwardly along the same sixty (60) feet to a point at the dividing line between Lots Nos. 4 and 5 on said Plan, thence northwardly along the same at right angles to Wentworth Drive one hundred sixty (160) feet to a point on the southern side of Wentworth thence eastwardly along the same sixty (60) feet to a point, the place of BEGINNING. BEING Lot No.4 on Plan of High- land Estates, Addition #2, said Plan being recorded in Plan Book 5, Page 51, Cumberland County records. HAVING THEREON ERECTED a one story frame dwelling house, known and numbered as 2005 Went- worth Drive. 7 _. t ~ , ~ ~, c ?„ ; .1. `{^j{ i. ~Y' rap Et "IGZ 1[ ~ ~. . q1Y ' '~4 d, ^i4NMfhR•IY~W.: •...xFrtM1al~Plf4MNe".wulMlf~iw®My •u 4Afr .~..~ ~; .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 c~lle patriot News 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 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 L 04/16/10 04/23/10 -- 04/30/10 to ansl'sub~cribed before me Notary Public 2010 A.D. .,, s~ ~ ~. COMMONWEALTH OF PENNSYLVANIA Noterlal Sesl Sherrie L Klsner, Notary Public Lower Paxton TVVp., Dauphin County My Commhsbn Expires Nov. 26, 2011 Member, Pennsylvania acsoclatlon of Notaries This ad ran on the date(s) shown below: Writ No. X8335 CIvfI Tian .IPMotgtan Ci'~e Bank, NA Vs. _ Swtdfa Jean Souder a/k/a Sondra Jean Souder Atty': Michael McKeever ALL THAT CERTAIN tractor patcel.of ground situate is Lower ABen Township, Cumberland County State of Pennsylvania, mote particularly bouaded and described according to survey of D.P:ltaffenspetger, Registered surveyor, dated lone 30,1953, as Follows to wit: BEGWNING at a point on the southern side of 1Y~+a'di:Dtive two hundred (200) felt west ofl $radaseslkiP of WealwotthDave aadpoopaty ties, praaaefod Lisbern Road, State Highway ML1023, also at the dividiag lyre Tit3erreiea ~# Nos. 3 aad '4 0o haeinaf3a-mgN~d !~ of Lots tltena so~wa~y, of rl~t ~ b Wentworth Drive, one hundred sixty (160) feet to apoint at line of lands now or Lde ofT. F, Shelter; thence westwardly along the same sixty (60) feet to a point.. at the dividing line between l,.ots Nos. 4 and 5 on said Plan; theace northwatdly along the same at right angles to; Wentworth Drive one' hundred sixty (160) feet to a point on the southern side of Wentworth thence eastwatdly along the same shay (60) feeito apoint, the place of BEGINNING, BEING Lot No.4 on Pian of Highland Estates, Addition #2; said Plan being rec9rded in Plan Book 5, Page 51, ~umberlaad County words. HAVING THEREON ERECTED a one story frame dwelling house, lmown and ~mbeted as 2005 Wentworth Drive.