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Home My WebLink About09-8415GOOBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM ATTORNEY FOR PLAINTIFF JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER FWA WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. MICHAEL F. MORAN Mortgagor and Record Owner 500 Thomas Road Camp Hill, PA 17011 Defendant Term OR -8415 CiV'lTer, No. CIVIL ACTION: MORTGAGE r-nPCr%' OSURI= 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 OEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website hLtp://WWW.Dhfa.org/consumers/homeowners/real.4Vx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention&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 91076FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., 7255 Baymeadows Way, Jacksonville, FL 32256. 2. The names and addresses of the Defendant is MICHAEL F. MORAN, 500 Thomas Road, Camp Hill, PA 17011, who is the mortgagor and record owner of the mortgaged premises hereinafter described. 3. On November 15, 2002 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to WASHINGTON SAVINGS BANK FSB, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book#:1783, Page 3416. The mortgage has been assigned to: JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. by assignment of Mortgage September 19, 2003 as Book#:701, Page:4598. 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 August 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 ....................................................................................$73,797.29 Interest from 07/01/2009 through 11/30/2009 at 6.0000% .......................$1,855.89 Per Diem interest rate at $12.13 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph ...................$3,689.86 fro 08/01 /2009 to 11 /30/2009 '0-10140 Late Charges m ............................................. Monthly late charge amount at $25.35 Costs of suit and Title Search ....................... ...............................................$900.00 Suspense ....................................................... .............................................. ($538.82) Pro Rata MIP/PMI ....................................... ..................................................$33.12 Escrow Advance .......................................... ................................................$155.99 Other Fees .................................................... ..................................................$10.85 Recoverable Balance .................................... ..................................................$10.85 Monthly Escrow amount $193.75 $80,016.43 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 $80,016.43, together with interest at the rate of $12.13, 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: ? -T- GOLDBECK McCAFFERTY & McKEEVER BY: MICHAEL T. MCKEEVER, ESQUIRE ATTORNEY FOR PLAINTIFF VERIFICATION Wendy McEwett , as the representative of the servicing agent for the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: ? 0 ° n01J U? 7PMORG CHASE BANK, NATIONAL ASSOC TION Wendy McEw0 Specialist #91076FC - MICHAEL F. MORAN 500 Thomas Road Camp Hill, PA 17011 SCHEDULE C ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of Wormleysburg in the County of Cumberland and Commonwealth of Pennsylvania, more particularly described as follows: IN ACCORDANCE with the Amended Final Subdivision Plan No. 1 entitled "Foxcrofr, prepared by Michael C. D'Angelo, R.S., dated August 7, 1981, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book "46", Page 110, as follows: BEGINNING at a point at the northwestern comer of Lot No. C-9 set at the dividing line between Lots Nos. C-9 and C-8 where said dividing line intersects with line of land designated as F.H.O.A. #2; thence along line of F.H.O.A. #2, North 61 degrees 49 minutes 47 seconds East, a distance of 60.26 feet to a point; thence continuing along line of land designated as F.H.O.A. #2, South 09 degrees 26 minutes 16 seconds East a distance of 95.03 feet to a point; thence continuing along F.H.O.A. #2, South 61 degrees 49 minutes 47 seconds West, a distance of 29.74 feet to the dividing line between Lots Nos. C-9 and C-8; thence along said dividing line and passing through a partition wall. North 28 degrees 10 minutes 13 seconds West, at distance of 90 feet to a point, the Place of BEGINNING. BEING Lot No. C-9 on the above plan; also being known and numbered as 500 Thomas Road. BEING the same premises which Mariellen Carpenter Lee, Executrix of the Will of Lois Jane Carpenter atkta Jane B. Carpenter, by her Deed dated September 20, 2001 and recorded October 2, 2001 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Dead Book 248, Page 3057, granted and conveyed unto Michael F. Moran, in fee. 8KI783PG3430 Washington Mutual FL5-7730 PO BOX 44090 Jacksonville, FL 32231-4090 1111111111111111111111 0609102694 7100 4047 5100 7739 9589 October 15, 2009 MICHAEL F MORAN 500 THOMAS RD CAMP HILL PA 17011 000267 /PC/FT WaMu' is becoming CHASE 0 Your house is your home. We want to keep it that way. We need to talk -- call 1-866-926-8937 today. You are going through tough times - we can help. In fact, we believe your home loan may be eligible for a loan modification program - we may be able to change the term of your loan, the interest rate, and maybe even the principal due date, to reduce the monthly payment to an amount you can afford. Call us today at 1-866-926-8937 so we can help you turn things around. We'll discuss your current situation (outlined in the enclosed letter) and the options available to you. But we cannot stress enough that the longer you delay calling us, the fewer chances you may have to keep your home. It will only take a few minutes on the phone - one of our Loan Specialists will work with you to determine the option that best fits your needs. There are several options available - call us now and let us see which one will work best for you. We are committed to working with you to find a way to help you keep your home, but you must call us immediately at 1-866-926-8937 .- the longer you delay, the fewer options you may have. Homeowner's Assistance Department Washington Mutual 1-866-926-8937 P. S. The enclosed legal letter outlines in detail, your current situation and the consequences that will occur unless we receive the required financial information from you and can approve you for a modification. Once you call us with the information needed, then we can work together to determine the option that will work best for you. We cannot guarantee that you will be approved, but your only chance of saving your home is by contacting us immediately. Please don't delay - call us now at 1-866-926-8937. Washington Mutual FL5-7730 PO BOX 44090 Jacksonville, FL 32231-4090 October 15, 2009 MICHAEL F MORAN 500 THOMAS RD CAMP HILL PA 17011 000267 WaMu- is becoming CHASE 0 NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 0609102694 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 S=iic information about the nature of the default is provided in the attached na= The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to he111 to save your home. This Notice Mlains how the program works To see if HEMAP can helRvou must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with you when you meet with the Counseling Aggncp The name address and Rhone number of Consumer Credit Counseling Agencies servingyour County are listed at the end of this Notice. If you have any questions you may call the Pennsylvania Housing Finance Agency toll free at 1-800 342-2397 (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA RAPORTANCIA, PUES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDUTEMENTE 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 REDAIDi SU HIPOTECA. C0826 HOMEOWNER'S NAME(S): Michael F. Moran PROPERTY ADDRESS: 500 Thomas Rd Camp Hill PA 17011 LOAN ACCT. NUMBER: 0609102694 ORIGINAL LENDER: CURRENT LENDERISERVICER: Washington Mutual Bank HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE- • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. Th names. addresses and telephone numbers of designated consumer credit counseling agencies for the county in which the prone 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 HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE ". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have riled bankruptcy, you can still apply for Emergency Mortgage Assistance.) 000267/co626 HOW TO CURT; 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: 500 Thomas 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: 08/01/2009 $700.67 09/01/2009 $700.67 10/01/2009 $700.67 Other charges (explain/itemize): Uncollected Late Charges $0.00 Uncollected Fees: $0.00 Less Credits $538.82 TOTAL AMOUNT PAST DUE: $1563.19 B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $1563.19, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made savable 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 upon your mortgaged gropt_rty. *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. N "u- cure the default within the THIRTY (30) DAY period you will not be required to pay attorney's fees OTHER LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. CO8z6 RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, ysu still have the right to cure the default and prevent the sale at any your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Washington Mutual Home Loans, Inc. Address: 7255 Baymeadows Way Jacksonville, FL 32256 Phone Number: 8¢6-926.8937 Fax Number: 904-281-3914 Contact Person: Collection Department Email Address: www.wamuhomeloans.com EFFECT'S OF SHERIFF'S SALE: - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or X may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED 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 (ie., 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. 00826 ?D *M.50 po Krtq SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy ~~,~,tiu, of ~:~a,r~b~r~~~~~ ~; _ `+ r- {,{ ~. <<i ~ ~~ ? Q~ ~~~ 5~ Richard W Stewart Solicitor k~~F , F = _ .k~~zi€~ ~ t:'~. 9_~F. ~~ JP Morgan Chase Bank, NA vs. Michael F. Moran Case Number 2009-8415 SHERIFF'S RETURN OF SERVICE 04/09/2010 07:42 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on April 9, 2010 at 1940 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 Michael F. Moran, located at 500 Thomas Road, Camp Hill, Cumberland County, Pennsylvania according to law. 04/23/2010 01:24 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 4/23/10 at 1321 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: Michael F. Moran, by making known unto, Michael F. Moran, personally,at, 500 Thomas 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. 06/03/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Courthouse, Carlisle, Cumberland County, Pennsylvania on June 2, 2010 at 10:00 o'clock A.M. He sold the same for the sum of $1.00 to Attorney Michael McKeever, on behalf of Fannie Mae, P.O. Box 650043, Dallas, TX 75265, being the buyer in this execution, paid to Sheriff Ronny R. Anderson, the sum of $ 888.59 SHERIFF COST: $888.59 June 30, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF a Qo P~ ~ c~ ~~ ~~~~ ~Cj l.,Ol1'li`~JJllf SFeI"'~f(. TF,I E±OSOff, IItG. Goldbeck McCafferty & McKeever BY: Michael T. McKeever Attorney I.D. #561,29 Suite 5000 -Mellon Independe~;.ce Center 701 Market Street Philadelphia, PA 19106 Z1S-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 72SS Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. MICHAEL F. MORAN (Mortgagor(s) and Record Owner(s)) S00 Thomas Road Camp Hill, PA 17011 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 09-841 S CIVII, TERM JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., Plaintiff in the above action, by its attorney, Michael T. McKeever, Esquire, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 500 Thomas Road Camp Hill, PA 17011 1.Name and address of Owner(s) or Reputed Owner(s): MICHAEL F. MORAN 500 Thomas Road Camp Hill, PA 1701 I 2. Name and address of Defendant(s) in the judgment: MICHAEL F. MORAN 500 Thomas Road Camp Hill, PA 1701 l 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 CIVII, 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 LVNV FUNDING LLC 15 South Main Street Greenville, SC 29601 4. Name and address of the last recorded holder of every mortgage of record: COMMERCE BANK/HARRISBURG N.A. 100 Senate Avenue Camp Hill, PA 17011 5. Name and address of every other person who has any record interest in or record lien on the properly 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 500 Thomas 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: January 13, 2010 ~.~ GOL BECK McCAFFERTY & cKEEVER BY: Michael T. McKeever, Esq. Attorney for Plaintiff 09-8415 CIVIL TERM GOLDBFCK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney LD.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRI OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECENER F/K/A WASHINGTON MUTUAL BANK F.A. 72SS Baymeadows Way Jacksonville, FL 32256 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE vs. MICHAEL F. MORAN Mortgagor(s) and Record Owner(s) Term No. 09-841 S CNIL TERM S 00 Thomas Road Camp Hill, PA 17011 Defendants; THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MORAN, MICHAEL F. MICHAEL F. MORAN S00 Thomas Road Camp Hill, PA 17011 Your house at S00 Thomas Road, 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 $80,988.35 obtained by JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 09-8415 CIVIL TERM 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-231 1. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To fmd 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.or2/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 09-8415 CIVIL TERM 8 Irvine Row Carlisle, PA 17013 717-243-9400 09-8415 CIVIL TERM Resource's available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa. org/consumers/homeowners/real. aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or 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 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 91076FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. ALL THAT CERTAIN tract or parcel of land and premises, situate, lying and being in the Borough of Wormleysburg in the County of Cumber/and and Commonwealth of Pennsylvania, more particularly described as follows: IN ACCORDANCE with the Amended Final Subdivision Plan No. I entitled "Foxcroft", prepared by Michael C. D'Angelo, R.S., dated August 7, 1981, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book "46", Page 110, as follows: BEGINNING at-a point at the northwestern comer of Lot No. C-9 set at the dividing line between Lots Nos. C-9 and C-8 where said dividing line intersects with line of land designated as F.H.O.A. #2; thence along line of F.H.O.A. #2, North 61 degrees 49 minutes 47 seconds East, a distance of 60.26 feet to a point; thence continuing along line of land designated as F.B.O.A. #2, South 09 degrees 26 minutes 16 seconds East a distance 0[95.03 feet to a point; thence continuing along F.H.O.A. #2, South 61 degrees 49 minutes 47 seconds West, a distance of29.74 feet to the dividing line between Lots Nos. C-9 and C-8; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of~0 feet to a point; the Place of BEGINNING. Parcel# 47-18-1302-227 Property address: 500 Thomas Road, Camp Hill, Pa 17011 Being the same premises which Mariellen Carpenter Lee, by deed dated 09/20/01 and recorded 10/02/01, in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 248 Page 3057, granted and conveyed unto Michael Moran. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERIAND) ' NO 09-8415 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 F.A., Plaintiff (s) From MICHAEL F. MORAN (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 $80,988.35 L.L. $.50 Interest from 1/14/10 to Date of Sale per diem at $12.13 -- To be Determined Atty's Comm Atty :'aid $160.50 Plaintiff Paid Date: 1/20!10 (Se21) REQUF,STING PARTY: Due Prothy $2.00 Other Costs David D. Buell, Prothonotary By: Name: MICHAEL T. McKEEVER, ESQUIRE Address: GOLDBECK McCAFFERTY & McKEEVER SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Deputy Supreme Court ID No. 56129 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in E_+_ ~ ~. L~ ~ ~~ ~~a':-. ~`ormleysburg Borough, Cumberland County, PA, »~ ~ ~_ G ~., ~- mown and numbered as, 500 Thomas Road, Camp Hill, ~, more fully described on Exhibit "A" filed with this writ and .~ by this reference incorporated herein. Date: March 22, 2010 By: 1~.~ ~71(~1~d duf Real Estate Coordinator 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 April 30, 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. isa Marie Coyne, itor SWORN TO AND SUBSCRIBED before me this 30 day of April. 2010 d Notary NOTARIAL SEAL DEBORAH A COLUNS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 Writ I(o. ZOO9-8415 Civil JP Morgan Chase Bank, NA vs. Michael F. Moran Atty: Michael McKeever ALL THAT CERTAIN tract or parcel of land and premises, situ- ate, lying and being in the Borough of Wormleysburg in the County of Cumber/and and Commonwealth of Pennsylvania, more particularly described as follows: IN ACCORDANCE with the Amended Final Subdivision Plan No. I entitled "Foxcroft", prepared by Michael C. D'Angelo, R.S., dated August 7, 1981, last revised on July 17, 1984 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book "46", Page 110, as fol- lows: BEGINNING at-a point at the northwestern comer of Lot No. C-9 set at the dividing line between Lots Nos. C-9 and C-8 where said divid- ing line intersects with line of land designated as F.H.O.A. #2; thence along line of F.H.O.A. #2, North 61 degrees 49 minutes 47 seconds East, a distance of 60.26 feet to a point; thence continuing along line of land designated as F.B.O.A. #2, South 09 degrees 26 minutes 16 seconds East a distance 0[95.03 feet to a point; thence continuing along F.H.O.A. #2, South 61 degrees 49 minutes 47 seconds West, a distance of29.74 feet to the dividing line between Lots Nos. C-9 and C-8; thence along said dividing line and passing through a partition wall, North 28 degrees 10 minutes 13 seconds West, a distance of90 feet to a point; the Place of BE- GINNING. Parcel# 47-18-1302-227. Property address: 500 Thomas Road, Camp Hill, Pa 17011. Being the same premises which Mariellen Carpenter Lee, by deed dat- ed09/20/01 andrecorded 10/02/01, in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book 248 Page 3057, granted and conveyed unto Michael Moran. t' ,. ~i { `~' '! _. , Patriot-News Co. Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 c~he~lahiot 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 This ad ran on the date(s) shown below: 04/16/10 04/23/10 \, ~ 04/30/10 Sworn t~r~(i subscribed before mis?8 day of May, 2010 A.D. ry Pu COMMBNyyPALTH OP PENNSYLVANIA NOta~a~ ?N) Sherrie 4 Kknsr, Notary PubMc Lower Paxton 1Vvp., OauPhU County ~ ~~n E-xQMes Nov. 26, 2011 Memt~er, PennsVNanta Associatbn of Notaries COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff s Deed in which FANNIE MAE is the grantee the same having been sold to said grantee on the 2ND day of JUNE A.D., 2010, under and by virtue of a writ Execution issued on the 20TH day of JAN, A.D., 2010, out of the Court of Common Pleas of said County as of Civil Term, 2009 Number 8415, at the suit of JPMORGAN CHASE BANK N A against MICHAEL F MORAN is duly recorded as Instrument Number 201018327. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of of Deeds Recorder of DeeQa, Qmbertend Court, Carle, pA Mr Commission E~irea tha Fret Ibnder of Jen. 2oi~