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Home My WebLink About10-03340-- FILEE-U"rE OF THE - 7TARY 2010 AN 12 Fri 3: 10 1 L4, 3???'31 `??iH Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 ,_Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC 3415 VISION DRIVE COLUMBUS, OH 43219 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION V. Plaintiff JASON D. GROB KELLY M. GROB 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 Defendants TERM NO. (0 334 a-,v I L CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE 226446 *Ra.00 Pa ATq Cll:'? 89q ORS RY?' a.3c?? qo File #: 226446 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 this 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 claimed in the Complaint or 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, 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 BEABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 226446 1. Plaintiff is CHASE HOME FINANCE LLC 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name(s) and last known address(es) of the Defendant(s) are: JASON D. GROB KELLY M. GROB 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. On 08/31/2007 mortgagor(s) made, executed and delivered a mortgage upon the premises hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INCORPORATED AS A NOMINEE FOR GRAYSTONE MORTGAGE, LLC which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200734624. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 05/01/2009 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 226446 6 The following amounts are due on the mortgage: Principal Balance $122,848.24 Interest $6,497.92 04/01/2009 through 01 / 11/2010 (Per Diem $22.72) Attorney's Fees $650.00 Cumulative Late Charges $364.86 08/31/2007 to 01/11/2010 Costs of Suit and Title Search $550.00 Subtotal $130,911.02 Escrow Credit $0.00 Deficit $1,122.23 Subtotal $1,122.23 TOTAL $132,033.25 7 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. File #: 226446 Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $132,033.25, together with interest from 01/11/2010 at the rate of $22.72 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ,2'1 rancis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff Bye File #: 226446 LEGAL DESCRIPTION ALL THAT CERTAIN piece of ground situate in the Township of Lower Allen, Cumberland County, Pennsylvania, bounded and described as follow, to wit: BEGINNING at a point on the northerly line of Scarsdale Drive which point is 215 feet westwardly of the northwestly corner of Kensington Drive and Scarsdale Drive Extended, and the dividing line between Lots Nos. 2 and 3, Block 'C', on the hereinafter mentioned Plan of Lots; thence along the northerly line of Scarsdale Drive, South 34 degrees 45 minutes West, 11.25 feet to a point; thence further along the northerly line of Scarsdale Drive in an arc having a radius of 412.76 feet in a southwesterly direction 73.52 feet to a point at the dividing ling between Lots Nos. 3 and 4 on said Plan; thence along said dividing line North 45 degrees 3 minutes West, 128.09 to a point at the dividing ling between Lots Nos. 3 and 29 on said Plan; thence along said dividing line between Lots Nos. 3 and 30, Block 'C', on said Plan, North 47 degrees 44 minutes East, 64.35 feet to a point at the dividing line between Lots Nos. 2 and 3, Block'C', on said Plan; thence along said dividing line South 55 degrees 15 minutes East, 155.41 feet to a point, the place of BEGINNING. Being Lot No. 3, Block'C', on Plan of Lots known as Country and Town Homes, Inc., which Plan is recorded in the Cumberland County Recorder's Office on May 14, 1956, in Plan Book 7, Page 41. BEING known and numbered as 7 Scarsdale Drive, Camp Hill, Pennsylvania BEING THE SAME PREMISES which Mabel P. Richwine, widow, and Rebecca G. Albright, single woman, by Deed dated May 26, 1995, and recorded in the Office of the Recorder of Deeds, Cumberland County, Pennsylvania, in Deed Book 125, Page 735, and recorded July 27, 1995, granted and conveyed unto Rebecca G. Albright, single woman, Grantor herein. PARCEL NO: 13-25-0022-085 PROPERTY ADDRESS: 7 SCARSDALE DRIVE File #: 226446 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. Attorney for Plaintiff DATE: III File 4: 226446 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson I -I'-! T, g, r?R J'tv t c u n brP( rGr , . Jody S Smith40 .. 20 (0 FtB - I f l 6 € : G Chief Deputy Edward L Schorpp Solicitor OFFI -;F TrE ,-E;RIFF Chase Home Finance LLC Case Number vs. 2010-334 Kelly M. Grob SHERIFF'S RETURN OF SERVICE 01/1412010 02:22 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to lawn, states that on January 14, 2010 at 1422 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jason D. Grob, by making known unto himself personally, at 7 Scarsdale Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. 01/26/2010 05:49 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on January 26, 2010 at 1749 hours, she served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Kelly M. Grob, by making known unto Renee Morgan, Mother of defendant at 706 Erford Road, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $71.00 SO A January 27, 2010 RONNY R ANDERSON, SHERIFF By Deputy Sheriff &? 4MZL De ty Sheriff (0) CouniySuite Sheriff, T'eleosoft. Inc. Mc nHE,wr 1918 FEB -4 AM 93 10 0AWL-V4D GOUMY ? eoatv" Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 -francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC Plaintiff VS. JASON D. GROB KELLY M. GROB Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-334 CIVIL TERM CUMBERLAND COUNTY PRAECIPE TO SUBSTITUTE VERIFICATION TO CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE TO THE PROTHONOTARY: PHS #: 226446 Kindly substitute the attached verification for the verification originally filed with the complaint in the instant matter. Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: -- ?' ? La rence T. Phelan, Esq., Id. No. 32227 rancis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Date: 2-01-10 PHS #: 226446 VERIFICATION Beth Cottrell ?' sststa n!. Sevr'U?'t-Rry hereby states that he/she is of CHASE HOME FINANCE LLC, servicing agent for Plaintiff, CHASE HOME FINANCE LLC, in this matter, that he/she is authorized to take this Verification, and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. oA,F??ao?o Name: Beth Cottrell Title: Assistant'aecretar? Company: CHASE HOME FINANCE LLC File #: 226446 Grob Ilictivi D SAN 1 2 2010 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC Plaintiff VS. JASON D. GROB KELLY M. GROB Defendant(s) ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-334 CIVIL TERM CUMBERLAND COUNTY CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff's Praecipe to attach Verification of Complaint was sent via first class mail to the following on the date listed below: JASON D. GROB 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 PHS #: 226446 KELLY M. GROB 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff By: Date: 2-01- ? La rence T. Phelan, Esq., Id. No. 32227 rancis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 PHS #: 226446 26 10 f,,AR -5 r' 'vr,.?? ?} '??IjVJ ?f Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC VS. JASON D. GROB KELLY M. GROB Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS CIVIL DIVISION No. 10-334 CIVIL TERM PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES T/y, 60 ?It 1Z, ?11 &t # 9/9176 R ot X? ry9 / F-44-;res AllQ,/ed F11Fri-tng- 7? 1L F(, ()j'! lni tQPy 4! 110 4 c TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JASON D. GROB and KELLY M. GROB, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint $132,033.25 Interest - 01/12/2010 to 03/02/2010 $1,136.00 TOTAL $133,169.25 I hereby certify that (1) the Defendants' last known addresses are 706 ERFORD ROAD, CAMP HILL. CUMBERLAND COUNTY, PA 17011 and the mortgaged premises 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933, and (2) that notice has been given in accordance with Rule 237.1, copy attached. // /-, i A Lawre e . Phelan, E uire Franc' S. Lie nan, E uire D ' 1 G. squire Michele M. ord, Esquire Judith T. Romano, Esquire Sheetal R. Shah-Jani, Esquire Jenine R. Davey, Esquire Lauren R. Tabas, Esquire Vivek Srivastava, Esquire Jay B. Jones, Esquire Peter J. Mulcahy, Esquire Andrew L. Spivack, Esquire Jaime McGuinness, Esquire fT, hri sovalante P. Fliakos, Esquire shua I. Goldman, Esquire Courtenay R. Dunn, Esquire Andrew C. Bramblett, Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 3 - PHS # 226446 PROTHONOT RY Phelan Hallinan & Schmieg, LLP By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC VS. JASON D. GROB KELLY M. GROB Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 10-334 CIVIL TERM VERIFICATION OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or it Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940, as amended. (b) that defendant JASON D. GROB is over 18 years of age and his last known addresses are 706 ERFORD ROAD CAMP HILL CUMBERLAND COUNTY PA 17011 and the mortgaged premises 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933. (c) that defendant KELLY M. GROB is over 18 years of age and his last known addresses are 706 ERFORD ROAD, CAMP HILL, CUMBERLAND COUNTY, PA 17011 and the mortgaged premises 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. U Lawr e T. Phelan, E q., Id. No. 32227 ? Fran s . Hallinan, q., Id. No. 62695 ? D 1 Schmie sq., Id. No. 62205 ? Michele ord, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney for Plaintiff (Rule of Civil Procedure No. 236) - Revised CHASE HOME FINANCE LLC VS. JASON D. GROB KELLY M. GROB : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION No. 10-334 CIVIL TERM Notice is given that a Judgment in the above captioned matter has been entered against you on 3 By: DEPUTY If you have any questions concerning this matter please contact: ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ElChrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorney or Party Filing 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY. ** CHASE HOME FINANCE LLC v Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-334 CIVIL TERM JASON D. GROB KELLY M. GROB Defendant(s) TO: KELLY M. GROB 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 DATE OF NOTICE: February 17, 2010 CUMBERLAND COUNTY T i THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE 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 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. PHS # 226446 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION I Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 _(717) 249-3166 V\ 1-1 Lawre e Lin.an an, E ., Id. No. 3 2227 Fr' S. , Es .Id. No. 62695 Daniel G. g, q., Id. No. 62205 Michele M, Es q., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 ¢hrisovalante P. Fliakos, Esq., Id. No. 94620 /Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza. Philadelphia, PA 19103 PHS # 226446 CHASE HOME FINANCE LLC COURT OF COMMON PLEAS CIVIL DIVISON V. Plaintiff NO. 10-334 CIVIL TERM JASON D. GROB CUMBERLAND COUNTY KELLY M. GROB Defendant(s) TO: JASON D. GROB 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 DATE OF NOTICE: February 17, 2010 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE 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 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. PHS # 226446 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle, PA 17013 2 LIBERTY AVENUE (717) 240-6195 CARLISLE, PA 17013 (717) 249-3166 By: (e 1. Phelan, EsqId. No. 32227 S. 111allinan. Esq./Id. No. 62695 Daniel G. S ieg, E ., Id. No. 62205 Michele M. B , Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 / hrisovalante P. Fliakos, Esq., Id. No. 94620 /Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza. Philadelphia, PA 19103 PHS 4 226446 CHASE HOME FINANCE LLC V. Plaintiff COURT OF COMMON PLEAS CIVIL DIVISON NO. 10-334 CIVIL TERM JASON D. GROB KELLY M. GROB Defendant(s) TO: KELLY M. GROB 706 ERFORD RPAD CAMP HILL, PA 17011 DATE OF NOTICE: February 17, 2010 CUMBERLAND COUNTY THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPERANCE 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 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. PHS # 226446 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. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: V- c-<7 k Lawrenc helan, Esq Id. No. 32227 Francis . H linan, Es , Id. No. 62695 Daniel G. Sc ie , q., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 C,hrisovalante P. Fliakos, Esq., Id. No. 94620 oshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 226446 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Chase Home Finance LLC vs. Kelly M. Grob (et al.) '6' of u+ 6rr??? OFFICE F,F TkE : Mf7F SHERIFF'S RETURN OF SERVICE Case Number 2010-334 04/16/2010 06:55 PM -Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on 4/16/10 at 1853 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 Kelly M. Grob and Jason D. Grob, located at, 7 Scarsdale Drive, Camp Hill, Cumberland County, Pennsylvania according to law. 04/20/2010 08:22 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 4/20/10 at 2018 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: Kelly M. Grob, by making known unto, Renee Morgan, Mother, at, 706 Erford 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 04/23/2010 Property sale postponed to 1016/2010. 04/24/2010 09:35 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on 4/24/10 at 0936 hours, she 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: , by making known unto, Jason D. Grob, personally, at, 7 Scarsdale Drive, Camp Hill, Cumberland County, Pennsylvania its contents and at the same time handing to him personally the said true and correct copy of the same. 10/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney Daniel Schmieg on 10/5/10 SHERIFF COST: $697.34 October 12, 2010 _FILED-OFFICE CF THE r h,C i HOMO ,."f" R 2910 OCT 13 F11 2: 0 7 CJMC63LAt"10 COU T`;, FFH1`1SY _..VAN 1A SO ANSWERS, RON R ANDERSON, SHERIFF a -00 td. t?o 0 c-1-- jod. Icj CountySuite Shenff, Teleosofl. Inc. CHASE HQME FINANCE LLC Plaintiff +. V. JASON D. GROB KELLY M. GROB Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 10-334 CIVIL TERM CUMBERLAND COUNTY AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE HOME FINANCE LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) JASON D. GROB KELLY M. GROB 2. Name and address of Defendant(s) in the judgment: Name SAME AS ABOVE 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 706 ERFORD RPAD CAMP HILL, PA 17011 Address (if address cannot be reasonably ascertained, please so indicate) 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Namepd 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: NanW Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare United States Internal Revenue Special Procedures Branch Federated Investors Tower U.S. Department of Justice U.S. Attorney for the Middle District of PA 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 13th Floor, Suite 1300 1001 Liberty Avenue Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 Kelly A4. Grob C/O-, Philip M. Intrieri, Esquire Commonwealth of Pennsylvania, Bureau of Individual Tax, Inheritance Tax Division Internal Revenue Service Federated Investors Tower 13TH Floor, Suite 1300 Department of Public Welfare TPL Casualty Unit Estate Recovery Program 615 N. 48`h Street Harrisburg, PA 17111-3625 6th Floor, Strawberry Sq., Dept 28061, Harrisburg, PA 17128 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 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.A. § 4904 relating to unworn falsification to authorities. March 8, 2010 By: Attorney for la' iff Phelan H inan Schmieg, P ? Lawr ce T. elan, Esq., No. 32227 ? Frans S. Hall , Es d. No. 62695 ? Daniel G. Schmieg, sq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? ime McGuinness, Esq., Id. No. 90134 hrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 CHASE HOME FINANCE LLC VS. JASON D. GROB KELLY M. GROB COURT OF COMMON PLEAS Plaintiff CIVIL DIVISION NO. 10-334 CIVIL TERM CUMBERLAND COUNTY Defendant(s) : NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JASON D. GROB KELLY M. GROB 7 SCARSDALE DRIVE 706 ERFORD RPAD CAMP HILL, PA 17011-7933 CAMP HILL, PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933 is scheduled to be sold at the Sheriff's Sale on 06/02/2010 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of 5133,169.25 obtained by CHASE HOME FINANCE LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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. 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 on page two 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 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 by calling 215-563-7000. 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 215-563-7000. 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 the 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 proposed schedule of distribution of the money bid for your house will be prepared by, the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-334 CIVIL TERM CHASE HOME FINANCE LLC VS. JASON D. GROB KELLY M. GROB owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 7 SCARSDALE DRIVE. CAMP HILL. PA 17011-7933 Parcel No. 13-25-0022-085. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $133,169.25 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN piece of ground situate in the Township of Lower Allen, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Scarsdale Drive which point is 215 feet westwardly of the northwesterly corner of Kensington Drive and Scarsdale Drive Extended, and at the dividing line between Lots Nos. 2 and 3, Block'C', on the hereinafter mentioned Plan of Lots; thence along the northerly line of Scarsdale Drive, South 34 degrees 45 minutes West, 11.25 feet to a point; thence further along the northerly line of Scarsdale Drive in an arc having a radius of 412.76 feet in a southwesterly direction, 73.52 feet to a point at dividing line between Lots Nos. 3 and 4 on said Plan; thence along said dividing line, North 45 degrees 3 minutes West, 128.08 feet to a point at dividing line between Lots Nos. 3 and 29 on said Plan; thence along said dividing line and along dividing line between Lots Nos. 3 and 30, Block'C', on said Plan, North 47 degrees 44 minutes East, 64.35 feet to a point at dividing line between Lots Nos. 2 and 3, Block'C', on said Plan; thence along said dividing line South 55 degrees 15 minutes East, 155.41 feet to a point, the place of BEGINNING. BEING Lot No. 3, Block'C', on Plan of Lots known as Country and Town Homes, Inc., which plan was recorded in the Cumberland County Recorder's Office on May 14, 1956, in Plan Book 7, Page 41. TITLE TO SAID PREMISES IS VESTED IN Jason D. Grob and Kelly M. Grob, h/w, by Deed from Rebecca G. Albright, single woman, dated 08/31/2007, recorded 09/05/2007 in Instrument Number 200734623. PREMISES BEING: 7 SCARSDALE DRIVE, CAMP MILL, PA 17011-7933 PARCEL NO. 13-25-0022-085. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMI?ERLAND) NO 10-334 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC, Plaintiff (s) From JASON D. GROB and KELLY M. GROB (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 $133,169.25 L.L.$.50 Interest from 313110 to Date of Sale ($21.89 per diem) -- $2,013.88 Atty's Comm % Due Prothy $2.00 Atty Paid $203.50 Plaintiff Paid Date: 3110110 Other Costs David D. Buell, Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name: JOSHUA I. GOLDMAN, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP ONE PENN CENTER, SUITE 1400 1617 JFK BOULEVARD PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 205047 On March 22, 20 10 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered, 7 Scardsdale Drive, Camp Hill, more fully described on Exhibit "A" filed: with this writ and by this reference incorporated herein. Date: March 22, 2010 By Re Estate oo at 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, April 23, 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. Writ No. 2010-3" ca a isa Marie Co y9/1 Editor ( , Chase Home Finance LLC '11 SIB/ M to Chase Manhattan SWORN TO AND SUBSCRIBED before me this Mortgage Corporation 0 day of Apnl 2010 vs. Kelly M. Grob Jason D. Grob Atty. Daniel Schmieg i Notary on By virtue of a Writ of Execut NO. 10-334 CIVIL, CHASE HOME FINANCE LLC vs. JASON D. GROB, KELLY M. GROB, owner of prop- erty situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, NOTARIAL SEAL Pennsylvania, being 7 SCARSDALE DEBORAH A COLLINS DRIVE, CAMP HILL, PA 17011- Notary Public 7933. CARLISLE BOROUGH. CUMBERLAND CONY Parcel No. 13-25-0022-085. My Commission Expires Apr 28, 201 Improvements thereon: RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $133,169- .25. . 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 Z4 Patti* ot-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 Writ No. 2010.334 Civil Term Chase Home Finance LLC 04/23/10 S/B/M to Chase Manhattan 04/30/10 Mortgage Corpo ration vs. Kelly M. Grob , Jason D. Grob Atty: Daniel Schmieg Sworn to and "subscribed before me this 18 day-of May, 2010 A. D. By virtue of a Writ of Execution NO. 10-334 CIVIL TERM f i CHASE HOME FINANCE LLC vs. Notan/ Public JASON D. GROB KELLY M.GROB owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County. Pennsylvania, beiag (Municipality) COMMONWE Vi'll OF 7 SCARSDALE DRIVE, CAMP HILL, PA ?NNSY YANIA Notarlaf 17011-7933 Sherrie L. K lsner, Seal Parcel No. 13-25-0022.085. Lower Paxton T Notary Publk (Acreage or street address) ? COm rU tW , Dauphin t'ounty M! Improvements thereon: RESIDENTIAL Member, PennonrPS Nov. zh' 2011 DWELLING JUDGMENT AMOUNT: svlvanl2'Yascc'a, an of Notaries $133,169.25 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-334 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CHASE HOME FINANCE LLC Plaintiff (s) From JASON D. GROB AND KELLY M. GROB (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 $133,169.25 L. L. Interest from 03/03/2010 to Date of Sale ($21.89 per diem) Atty's Comm % Due Prothy $2.00 Atty Paid $922.34 Plaintiff Paid Date : 03/23/2011 Other Costs D. Bud ,Prothonotary (Seai) REQUESTING PARTY: Name: WILLIAM E. MILLER, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG LLP 1617 HK BLVD., SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 By: Deputy Supreme Court ID No. 308951 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 CHASE HOME FINANCE LLC Plaintiff v JASON D. GROB KELLY M. GROB Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 03/03/2010 to Date of Sale ($21.89 per diem) TOTAL 0 W PA A, '11.00 tw 01•sq of/ ?t a.ook? 1y. d0%%?r ay. OVA Q Note: Please attach description of property. PHS # 226446 COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-334 CIVIL TERM CUMBERLAND COUNTY ? -I; = = -r-n-?t $133,169.25 ria W te? S 12127.06 C ?' = ?;C ° fi C" $145,296.31 &R??: Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? An C. Bramblett, Esq., Id. No. 208375 ? ison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 .5g. 00 4 ?. (k.# I07MV TZ* a5?q,51 IIUr,+6P- J?e jl,?%uo?44 a? ? ? M M N ? ? ?y? O Ri A O wO Aa ? ?a ?, c?Qa o ? a 3 L1Ax ?O? O> a oa o° O? W U a W x ? Wa AAA za O v w ? C ,p W 0 W U l 0 o, %0 (7) ON r- 00 N?Q00 M O?p?N M?C,4 00O M en (21 M n 00 ZN`' Opp a °bbd . z °ZZZOOz -o yzb ZZ Z -1 w ?E.;A;? ???o? 3 0? ? 3 aW 2 W •U ..fir S m .2 ;a C'n 40000000000000000? LEGAL DESCRIPTION ALL THAT CERTAIN piece of ground situate in the Township of Lower Allen, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Scarsdale Drive which point is 215 feet westwardly of the northwesterly corner of Kensington Drive and Scarsdale Drive Extended, and at the dividing line between Lots Nos. 2 and 3, Block'C', on the hereinafter mentioned Plan of Lots; thence along the northerly line of Scarsdale Drive, South 34 degrees 45 minutes West, 11.25 feet to a point; thence further along the northerly line of Scarsdale Drive in an arc having a radius of 412.76 feet in a southwesterly direction, 73.52 feet to a point at dividing line between Lots Nos. 3 and 4 on said Plan; thence along said dividing line, North 45 degrees 3 minutes West, 128.08 feet to a point at dividing line between Lots Nos. 3 and 29 on said Plan; thence along said dividing line and along dividing line between Lots Nos. 3 and 30, Block'C', on said Plan, North 47 degrees 44 minutes East, 64.35 feet to a point at dividing line between Lots Nos. 2 and 3, Block'C', on said Plan; thence along said dividing line South 55 degrees 15 minutes East, 155.41 feet to a point, the place of BEGINNING. BEING Lot No. 3, Block'C', on Plan of Lots known as Country and Town Homes, Inc., which plan was recorded in the Cumberland County Recorder's Office on May 14, 1956, in Plan Book 7, Page 41. TITLE TO SAID PREMISES IS VESTED IN Jason D. Grob and Kelly M. Grob, h/w, by Deed from Rebecca G. Albright, single woman, dated 08/31/2007, recorded 09/05/2007 in Instrument Number 200734623. PREMISES BEING: 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933 PARCEL NO. 13-25-0022-085. Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC Plaintiff V. JASON D. GROB KELLY M. GROB Defendant(s) TAR "UPP E NSYL%4g"IATY P CERTIFICATION Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION : NO.: 10-334 CIVIL TERM : CUMBERLAND COUNTY The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied ( ) the premises is vacant (X) Act 91 procedures have been fulfilled This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. By: Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua 1. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 F ew C. Bramblett, Esq., Id. No. 208375 on F. Wells, Esq., Id. No. 309519 am E. Miller, Esq., Id. No. 308951 SCHASE HOME FINANCE LLC Plaintiff V. JASON D. GROB KELLY M. GROB Defendant(s) FICE 2011 MAR 23 AM 10'- 31 UM COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CIVIL DIVISION NO.: 10-334 CIVIL TERM CUMBERLAND COUNTY PHS # 226446 AFFIDAVIT PURSUANT TO RULE 3129.1 CHASE HOME FINANCE LLC, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933. 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably ascertained, please so indicate) JASON D. GROB 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 KELLY M. GROB 706 ERFORD RPAD CAMP HILL, PA 17011 2. Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 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: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 Domestic Relations of Cumberland County Commonwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA Kelly M. Grob C/O: Philip M. Intrieri, Esquire Commonwealth of Pennsylvania, Bureau of Individual Tax, Inheritance Tax Division Internal Revenue Service Federated Investors Tower 13TH Floor, Suite 1300 Department of Public Welfare TPL Casualty Unit Estate Recovery Program 13 North Hanover Street Carlisle, PA 17013 P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 Federal Building, P.O. Box 11754 228 Walnut Street Harrisburg, PA 17108 615 N. 48`h Street Harrisburg, PA 17111-3625 6`h Floor, Strawberry Sq., Dept 28061, Harrisburg, PA 17128 1001 Liberty Avenue Pittsburgh, PA 15222 P.O. Box 8486 Willow Oak Building Harrisburg, PA 17105 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.A. § 4904 relating to unworn falsification to authorities. Date: By: A? Attorney for Plaintiff Phelan Hallinan & Schmieg, LLP ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ison F. Wells, Esq., Id. No. 309519 B illiam E. Miller, Esq., Id. No. 308951 CHASE HOME FINANCE LLC COURT OF COMMON PLEAS F;r t'Ri) EiBNt?TA R'' . ?i 117An 23 ??1? 1Q* 31 Plaintiff CIVIL DIVISION vsugiBERLA LYAt61 A TY NO.: 10-334 CIVIL TERM tP;NSY JASON D. GROB KELLY M. GROB CUMBERLAND COUNTY Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JASON D. GROB 7 SCARSDALE DRIVE CAMP HILL, PA 17011-7933 KELLY M. GROB 706 ERFORD RPAD CAMP HILL, PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933 is scheduled to be sold at the Sheriffs Sale on 09/07/2011 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of $133,169.25 obtained by CHASE HOME FINANCE LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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. 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 on page two 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 TAKE PLACE. 1. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 215-563-7000. 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 the 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-334 CIVIL TERM CHASE HOME FINANCE LLC VS. JASON D. GROB KELLY M. GROB owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933 Parcel No. 13-25-0022-085. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING JUDGMENT AMOUNT: $133,169.25 Phelan Hallinan & Schmieg, LLP Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 Philadelphia, PA 19103 215-563-7000 LEGAL DESCRIPTION ALL THAT CERTAIN piece of ground situate in the Township of Lower Allen, Cumberland County, Pennsylvania, bounded and described as follows, to wit: BEGINNING at a point on the northerly line of Scarsdale Drive which point is 215 feet westwardly of the northwesterly corner of Kensington Drive and Scarsdale Drive Extended, and at the dividing line between Lots Nos. 2 and 3, Block'C', on the hereinafter mentioned Plan of Lots; thence along the northerly line of Scarsdale Drive, South 34 degrees 45 minutes West, 11.25 feet to a point; thence further along the northerly line of Scarsdale Drive in an arc having a radius of 412.76 feet in a southwesterly direction, 73.52 feet to a point at dividing line between Lots Nos. 3 and 4 on said Plan; thence along said dividing line, North 45 degrees 3 minutes West, 128.08 feet to a point at dividing line between Lots Nos. 3 and 29 on said Plan; thence along said dividing line and along dividing line between Lots Nos. 3 and 30, Block'C', on said Plan, North 47 degrees 44 minutes East, 64.35 feet to a point at dividing line between Lots Nos. 2 and 3, Block'C', on said Plan; thence along said dividing line South 55 degrees 15 minutes East, 155.41 feet to a point, the place of BEGINNING. BEING Lot No. 3, Block'C', on Plan of Lots known as Country and Town Homes, Inc., which plan was recorded in the Cumberland County Recorder's Office on May 14, 1956, in Plan Book 7, Page 41. TITLE TO SAID PREMISES IS VESTED IN Jason D. Grob and Kelly M. Grob, h/w, by Deed from Rebecca G. Albright, single woman, dated 08/31/2007, recorded 09/05/2007 in Instrument Number 200734623. PREMISES BEING: 7 SCARSDALE DRIVE, CAMP IULL, PA 17011-7933 PARCEL NO. 13-25-0022-085. AFFIDAVIT OF SERVICE (FHI,MC) PLAINTIFF CUMBERLAND COUNTY CHASE HOME FINANCE LLC PHS # 226446 DEFENDANT SERVICE TEAM/ hth JASON D. GROB COURT NO.: 10-334 CIVIL TERM KELLY M. GROB SERVE KELLY M. GROB AT: TYPE OF ACTION rn ' 706 ERFORD RPAD XX Notice of ShedWs Sale CAMP HILL, PA 17011 SALE DATE: 09/07/2011 -C > a **DIVORCE PENDING ONE CAN NOT ACCEPT SERVICE FOR G , THE OTHER** SERVED o Served and made known to KELLY M. GROB , Defendant on the `f day of A A-R C14 20 (1 at r o , , 11:45, o'clock A. M., at ?o 6 Finap RDFrAMP 1H cc a , m the manner described below: ;.; _ Defendant personally saved. N/ Adult family member with whom Defendant(s) reside(s). Relationship is Mo _ Adult in charge of Defendant's residence who refused to give name or relationship. - Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. Other: Description: Age d S Height Weight I 0 Race W Sex Other I, ryRA/ -LD hb Lt- , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this ? ej? of MAftcf /? Nota ry: V V NOT SERVED On the y 20 , at - o'clock_. M., Defendant NOT FOUND because: . cant Does Not Exist Moved _ Does Not Reside (Not Vacant) _ No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of By: Notary: 7LK :OF Y CURTY WR SF-Y XPIRES MARCH 1, 2013 ATTORNEY FOR PLAINTIFF Lswmm T.M I , Esq, Id. NL 32227 Frarlr S. amanng Esq., Id. No. 62695 DadG.sdta1 ,Esq,ld.NL62214 Mkb& M. Bradlra 1, Id. NLi9F9 Jadkb T. Bars, Rml, ld No. 58745 Shedd R. SbbjmK Eoq, Id. Na 81768 Jeeie R Darey, ? Id. NL 87677 Lars R Tabs, Esq,1d. W 93337 Virdc Srirads?a, Esq, Id NL 202331 Jay B. Joao, Fsq, Id. NL 86657 Pdw J. Malady, Fsq., Id. No. 61791 Andrew I.. Spi wk Esq., Id. No. 84439 Chrbwdsna: P. FBdta, rwq., Id. No. 91620 Jabea L GaMman, Fsq, Id. No. 205047 Coaris" R. Duns, Fag, hL No. 20M Andrew C. Brnnbkt16 Esq., Id. NL 208375 Alts F. Wdk, Emil, Id. No. 3M19 W Wss E. M0a•, =11%w 308851 One JP?F.stcauSWis 1617 Iteradr Bird, 9Ae 1408 Pb4ddphls, PA 1910-1810 (215) 563-7000 AFFIDAVIT OF SERVICE (FHLMC) PLAINTH F CUMBERLAND COUNTY CHASE HOME FINANCE LLC PHS # 226446 DEFENDANT SERVICE TEAM/ hdI JASON D. GROB COURT NO.: 10-334 CIVIL TERM " KELLY M. GROB SERVE JASON D. GROB AT: TYPE OF ACTION 7 SCARSDALE DRIVE XX Notice of Sheriffs Sale 3> C:) r3 CAMP HILL, PA 17011-7933 SALE DATE: 09/07/2011 cz; r- **DIVORCE PENDING ONE CAN NOT ACCEPT SERVICE FOR , C-) THE OTHER" ' SERVED Served and made known to JASON D. GROB , Defendant on the $ I STday of kl c(4 , 20 11 , at . So , o'clock P. M., at 7 SrA+Qs 0M-E DQ- &u AA , in the manner described below: ? Defendant personally served. _ Adult family member with whom Defendant(s) reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. _ Manager/Clerk of place of lodging in which Defendant(s) reside(s). _ _ Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. _ Other: Description: Age S Height 6 / ?Weight 50 Race W Sex M Other L ?Rb /4 ErD Md (-L , a competent adult, being duly sworn according to law, depose and state that I personally handed a true and correct copy of the Notice of Sheriff's Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. Sworn to and subscribed before me this 3 161- day of 201( Notary: B L Qi(?? NOT SERVED On the 20--_, at T o'clock _. M., 'Defendant NOT. FOUND because: t Does -Not Exist Moved _ Does Not Reside (Not Vaunt) _ No Answer on at at Service Refused Other: Sworn to and subscribed before me this day of - U By. Notary: ------ - K?N(BERLY" -'y NOTARY PUBLIC STATE OF NEW jER5, CH 71201 3 MY COMMISSION EXp1RES ATTORNEY Lawmkm T. Fidaa,Faq, Y. N& 37227 Freda S. RAWN, Bq., kL Nwf2N5 D=WG. Bdwk&Baq,1d.N&67205 Mkb&eLu 'M *,Bp,Id.Nest! j.m T. Baia, Z"6Id. N& NM5 sred.i B. srri,r, ?, Id. N& 81740 J®OaeR. Daeey, 64, Id. N. M" L MM B. TdM4 Eaq, Id. N&93337 Vitdc Sri Mws, &q, ld. N& L2i31 Jay & Jens; Bp, Id Na asm Pder J. 1ileloir, Esq., N. N& {1791 Andeew L. SpiF464 Esq, Id. N& 044]9 obriaardwkP. Mka4 Faq., Id. Na9"M J,dw, L Geidsaa, Fiq., Id. Na 205017 Ce-ha r R. Dow Btq, IL Na286M Aedaew C Bn=Me t, Eeq, Id. N& 200:{75 ABiaw F. We&, Rail, Id. NM 309519 VYBtluEMier, 1d.Nw300951 OeePseCeKeWal t6re3latl 1617 7a?n F. I:eeeedy Shce 14 1400 P62,ddphia6PA M03.1814 (215) 567-7080 ?-q Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC Plaintiff Vs JASON D. GROB KELLY M. GROB Defendant(s) Attorney For Plaintiff 'n c Court of Common P N s I, -C tv IS -46 Civil Division ° 320 ? vn z :9 - .: C) = C=) ? Cumberland County No. 10-334 CIVIL TERM PRAECIPE FOR VOLUNTARY SUBSTITUTION OF PARTY PLAINTIFF PURSUANT TO Pa.R.C.P., 2352 TO THE PROTHONOTARY: Kindly substitute JIMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M to CHASE HOME FINANCE LLC as successor Plaintiff for the originally named Plaintiff. The material facts on which the right of succession and substitution are based as follows: JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M TO CHASE HOME FINANCE LLC the current Plaintiff in the foreclosure action by virtue of a corporate merger, whereby CHASE HOME FINANCE LLC is now JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M TO CHASE HOME FINANCE LLC Kindly amend the information on the docket accordingly. Date: LLINAN & SCHMIEG, LLP 71)?l B . Y Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 3089R----- Attorneys for Plaintiff PHS # 226446 t?- .? g,oo Pd. a? Ck?! lC?$? L 1 « 3cnmieg, LLP 1617 JPK Rn var Suite 1400 One Penn Center Plaza Philadelphia, P,1 1910, 215_ 563_7000___ CHASE HOME F NAI NC LE LC Plaintiff Vs JASON D. GROG KELLY M. GROB Defendant(s) Attorney For Plaintiff Court of Common Pleas • Civil Division • Cumberland County No. 10-334 CIVIL TERM ENTRY OF AppEA i 1" u' TO THE PROTHONOTARY: RANCE I,-) -v-i? rnm ztT' z? C,O rz !Z C3 Ty n z0 z Please mark the judgment in the above-captioned matter to CHASE BANK, NATIONAL ASSOCIATION, S/B/M t the use of JPMORGAN LLC located at 10790 Rancho Bernardo Road, San Die to CHASE HOME FINANCE Date: go, CA 92127. 17rN? AN & SCHMIEG, LLP B y. Lawrence T. Phelan, Es qq'' Id. No. 32227 Francis S. Hallinan, Es Daniel G. Schmieg, Es ' Id. No. 62695 Michele M. Bradford, Esq.,lId. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 3089Yf' Attorneys for Plaintiff c..n n.) C7 -r; ? c C) fY PHS # 226446 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M to CHASE HOME FINANCE LLC. Date: INAN & SCHMIEG, LLP By. . Phelan, Esq:, Id. No. 32227 C ( Francis S. Hallinan, Esq., Id. No. 62695 III Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 30891 Attorneys for Plaintiff PHS # 226446 PHELAN HALLINAN & SCHMIEG, LLP One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard, Suite 1400 Philadelphia, PA 19103-1814 215 563-7000 CHASE HOME FINANCE LLC Plaintiff Vs JASON D. GROB KELLY M. GROB Defendant(s) ATTORNEY FOR PLAINTIFF Court of Common Pleas Civil Division Cumberland County No. 10-334 CIVIL TERM CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiff's Praecipe to mark judgment to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M to CHASE HOME FINANCE LLC and substitution of party plaintiff was served by regular mail to the person(s) on the date listed below: JASON D. GROB KELLY M. GROB 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933 Date: PHS # 226446 B y: I/ Y/Y(/ ? ? Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 Melissa J. Scheiner, Esq., Id. No. 3089 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL CUMBERLAND COUNTY ASSOCIATION, SB/M TO CHASE HOME FINANCE, LLC COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION V. 7 0 No.: 10-334 CIVIL TERM-?2: JASON D. GROB KELL a ? s? ,- - Y M. GROB = a ) a Defendant(s) ) UM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129 1 °n . . COMMONWEALTH OF PENNSYLVANIA C..) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attache h A., . No.308912 Attorney for Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriffs Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 226446 EXHIBIT A rim ao u a Y c? 0 x CL ii LQ ? ? b Cl) z¢o W a COO N r O 0 f? U va F Vi b d u u w E 0 L 6 L 3(103 dlZ W083 o311bw LLoz U avw ssaccatooo OWN $ VU zo ?+uwe ?aruw G ! o•? 6 c _S O w a ° u •O >, e C0 R •a y h 4 W nN. n ov?F,W d e sdo° +??=NCO W yrie o. ?d E aiNti ' g oF° N u do h y y -+ 7N wr .r % ... p, aa'?•a a> yO d ° oop Q a?'i?Ad c y? o °' .n. dh o+•Q".,n nw a ??uJ L? ?N:a a.. a. ?^ UWw;, o >0 3 > >^' ? c eny"' .. y.-? A. 5dd yw cad a 48 a ei°e 3 ae e d = 5- 0 7'L' od > >dd r?°, ?bU a- d d o a ?ew,n > cL E dom P. o2.•.w- vF, ?x u duo C d A.a. P4 ar"?."a yN °'.C t a 7 3 p,? ?? oF??+uis n ?oav aL LV B , 3wuuJ AGD? ea 0D of ZAG a? 0 8 a a oA e o q00 e e o c L`? *0 'r d q ,?, a oo a.., dam- L. ?.0 V.0 o o ooo a? ? a E wQ.' oO a mddw?oS?POa?aAd3" '3Eaa?^evaa(i,.a°UwP?i3 E ZU E EzZ E C60 d ..Z'ri. B dfri.. d ?- caWmdoa aoavivia00 Ova r ca. ate. ZFnUAU?UU „ A0:3:.°.°'a??wNx^.sa'U oxUraS?°ASw'?aAHwa3x U_ C •• N M ? ? ?o r o0 of a o0 u H 12 1 0 0 u Bx? tJ ? W E '7 H ? 'm c$?wa $ ? ow ypp ? H ?? 0 13 d• ? ? V M N:. ?-. ?a u Eo ?i - x a M d o a 0. 8 ?m a° a4 O 31 O VJ O ? .C y za SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE Sheriff OF THE PROTHIONOTAr y Jody S Smith` Chief Deputy 2911 DEC 22 PM 2= 2 9 Richard W Stewart CUMBERLAND COUNTY Solicitor PENNSYLVANIA Chase Home Finance LLC Case Number vs. Kelly M Grob (et al.) 2010-334 SHERIFF'S RETURN OF SERVICE 06/23/2011 02:47 PM - Deputy Ronald Hoover, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, in the above titled action, upon the property located at 7 Scarsdale Drive, Camp Hill, PA 17011, Cumberland County. 09/07/2011 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 12/7/2011 11/22/2011 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 1/4/2012 12/21/2011 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $701.80 SO ANSWERS, December 21, 2011 ROW R ANDERSON, SHERIFF a 1!!?)o Pel . . ;cj .ountySuite Sherdf. TeleeeotT. Inc. AFFIDAVIT OF SERVICE(FHLMC) PLAINTIFF CUMBERLAND COUNTY JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,S/B/M CHASE HOME FINANCE,LLC PHS#226446 DEFENDANT SERVICE TEAM!Ixh JASON D.GROB COURT NO.:10-334 CIVIL TE ' KELLY M.GROB SERVE JASON D.GROB AT: TYPE OF ACTION 2499 SLATESHIRE DR XX Notice of Sheriffs Sale Zpl— t DUBLIN,OH 43016-9256 SALE DATE: June 5,2013 -<-:I> SERVED Served and made known to JASON D.GROB,Defendant on the da y of%� 1 0 C �- ' O'clock P.M.,at in the manner described below: _Defendant pbrsonally served. R, Adult family member with hom D hnZo'refusedA ndant(s)reside(s). Relationship is Adult in charge of Defendant's res' ame or r elationship. Manager/Clerk of place of Iodging in which Defendant(s)reside(s). _Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age -15 Height 1.1 "1 r Weight /*70 Race W Sex M Other 1, petent adult,being duly sworn according to law,depose and state that I personally handed a true and Aforrect coy of the Notice of Sheriffs Sale in the manner as set fortll herein,issued in the captioned case on the date and at the address indicated above. Pgy,PU",,, : •;:� , .' ,c�- MARIA ONEST Sworn to and subscribed ; =* t= Notary Public,State of Ohio before me this day :t. - mmission Expire 3 02-2014 Of _ 20— Notary: By: NOT SERVED On the day of 20—,at o'clock_.M.,I, a competent adult hereby state that—I)e�`endant NOT FOUND because: _Vacant Does Not Exist _Moved _Does Not Reside(Not Vacant) _No Answer on at at Service Refused Other: Sworn to and subscribed before me this day Of —.20 By: Notary: ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 AFFIDAVIT OF SERVICE(FHLMC) PLAINTIFF CUMBERLAND COUNTY JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SOM CHASE HOME FINANCE,LLC PHS#226446 DEFENDANT SERVICE TEAM/Ish JASON D.GROB COURT NO.:10-334 CIVIL TERM KELLY fv GROB SERVE'KELLY M.GROB AT: TYPE OF ACTION . 706 ERFORD RPAD XX Notice 6f Sheriff's Sate CAMP HILL,PA 17011 SALE DATE: June 5,2013 **DIVORCED-One cannot accept service for the other* SERVED � day of �� 20 -- Served and made known to KELLY M. �ROB�Defendant on the y ----- ata ��o'clock .M.,at'Wo eiLlib"VT-,� ,in the manner described below: fir" �- Defendant ksoaally served Adult family member om Defendant(s)reside(s). Relationship is _Adult in charge of Defendant's residence who refused to give name or relationship. '_0 _ ManagerlClexk•of place of lodging in which Defendants)rc4de(s). " Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age 5 S Height 5._� Weight Race Sex Other I, QGtiG ,a competent adult,hereby verify that I personally handed a true and coma copy of the Notice f Sheriffs Sale in the manner as set forth herein,issued in the captioned can on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec.4904 relating to unsworn falsification to authorities. DATE: ( 2k1(3 NAM$: / PRINTED NAME: 4)6.4AN4 VE L;Fcgj TITLE: �cS t2 NOT SERVED Oathe tated)at ffiday of at o'clock!M,I, a competent adult hereby _Vacant don Does Not Exist _Moved _ Does Not Reside(Not Vacant) _No Answer on at at _Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsificatiotl to authorities. BY: PRINTED NAME: ATTORNEY FORPLA2TIt±F Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 C) w. n PHELAN HALLINAN,LLP Attorney for Plaintiff rn Meredith Wooters,'Esq.,Id.No.307201, t CD 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza C= Philadelphia,PA 19103 © , —P 215-563-7000 � r4l" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL : CUMBERLAND COUNTY ASSOCIATION,S/B/M CHASE HOME FINANCE, LLC COURT OF COMMON PLEAS Plaintiff, CIVIL DIVISION V. No.: 10-334 CIVIL TERM JASON D.GROB KELLY M.GROB Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: . As required by Pa.R.C.P.3129.2(a)Notice of Sale has been given to Lienholders and any known interested party in'the manner required by Pa.R.C.P. 3129.2(c) on each of the persons or parties named,at that address,set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing(Form 3817) and/or Certified Mail Return Receipt stamped by the U.S.Postal Service is attached hereto Exhibit"A". Meredith ooters,Esq.,Id.No.307207 Attorney for Plaintiff Date: 1 IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS#.226446 Name and Phelan Hallinan,L'LP Address 1417 JPK Boulevard,Suite 1400 Of Sender One Penn Center Plaza Philadelphia,PA 19103 AZI IMAN-061115?2013 SALF. ° G a' Line Article Ntanber Name of Addressee Strad,and fast Office Address . Poste a 1]# n°< 1 ••++ TENAM/OCCAMAN'T 91.44 7 WAROMALP."U""F7 Y AMP I1I.LPA 170 i ? i p Z aa�• COMMONWEALTH OF PFAN'NSYLVANIABUREAU OF INDIVIDUAL TAXES INHERITANCETAX DIVISION 6111 FLOOR,S'H2AWBERRY$0. J 50.44 DEPT 2900t HARRISBURG,PA 17178 GCD 3 '+*** CiTEN`1:tHY&TO'.NW 110,NJES INC. t. P.O.Box 111 # 50.44 CAMP HILL.PA 17001 _ A0''00' 4 +�•• DEPARTNIF>ANT OF PtIHLIC VI LFARE.'ML CASUALTY MT.MATEAMM"ERY PROCRAM 77$0.44 P.O.BOX 8496 a wTl.LOw 0AK BUILDING 1ARRISBURG PA 17 OS S *** JASON D.G ROB CO THOMAS 111.CLARK,ESQUIRE COLGAN&ASSOCIATES.LLC SOAd 130 WEST CNURCISIREET.SUITf100 UILLSBURt:.PA 11019 6 +*•+ JASON 0.GROB CXI THOMAS 1t.CLARK.ESQUIRE 50.44, FEDERAL DEPOSIT INSURANCE CORPORATION(FOTC) 3 W srlt AYENtfE,SUITE 1200 �" f NEW VOpx.NV IO1 M1101 _ 7 KF.IA,'V MI.GROB ran PI1t1:1P Si.tNTR1FR1.FSQIIRF 50.44 615 NORTH 4B1'FI STREET • > � 1 ,.- , HARRISBURG.PA 17111,3625 ' 8 +� DON1F.5'1`1CRFLATIOYSOF _. < SO.d4:," ' CUMBERLAND COtrNTV d3 NORT H HANOVER SfRELT 1' CARLISLE,PA 17013 4 •'** COMMONWEALTH OF PENNSYLVANIA' $0.44 D£PARTM ENT OF W ELFARE P_O.BOx 2673 � t HARR15BI1RG.PA 17101 10 **+* INTERNAL RENTNUESERVICEADViSOR# $0.44 1000 LIBERTY AVENUE ROOM 104 ' P/I 1SBURGH,PA 15222 # 11 ►**+ US.DEPART111 EAT OF JUSI'IGE 50.44„ US,.it7Y7R,YET FO1t'171E;MIDDLE D1T>"IltiCl'UPPA FEDERAL BUILDING 228 WAt«NUTSTRECT.SUH'Ex20 PO BOX 11754 HARRICRURG PA 37 MI754 ' i'I JAS t;•NIO�CR08`{�iJJlt13&RIdT�it1 �.� Pri a I o>I.i .#� Sd.Rd TuaD TkmxbcrA - TWtk,uttt srrPrsvvef FatmaticY,4Yr(Narxd ihtf lldMuaiwwafrdue is rcgri,dwa114eweyic wed mlemn;tx.al Iepst<rod mrt T1,s macimam mdrmritY py�bfe Picas La'st<d try C+rrin Re_.-r M M W.CNriv. Rrr.<itias 6Arlalw) far tlt mMtaurutNn N•anndr. stiahk Mamrmh,m5n i=xptca Mal d+ex mesi srca.wxvetirAl iunnrme if 1S00D4 t>h �+ce<su*.O to a Mrrt bf sS0 ow Pct atcarrtt ,7%c ma-imvm ma kmnxy ray*u an F<ptss Mal awax d,'.st is 5FtM1 • - tlrc ataatmutt indemnYY tYY�1t nSIS.CtId fat tegsittsM isail,xA uyh ryx,snA1 titsartiee.Stx IkmsstieMtl rWn+tpl -. f[900 5114 aa!5911 fm limitpwt;a ofwvti Form 3877;Facsimile t Phelan Hallinan, LLP 66 Jonathan Lobb, Esq.,Id. No.312174 2��3 �t� N191 66EY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PE�>�SY� - Jonathan.Lobb @phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, SB/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County V. No.: 10-334 CIVIL TERM JASON D. GROB KELLY M. GROB Defendants PLAINTIFF'S MOTION TO REASSESS DAMAGES Plaintiff, by its Attorneys,Phelan Hallinan, LLP,moves the Court to direct the Prothonotary to amend the judgment in this matter, and in support thereof avers the following: 1. Plaintiff commenced this foreclosure action by filing a Complaint on January 12, 2010. 2. Judgment was entered on March 5, 2010 in the amount of$133,169.25. A true and correct copy of the praecipe for judgment is attached hereto, made part hereof, and marked as Exhibit"A". 3. Pursuant to Pennsylvania Rule of Civil Procedure 1037(b)(1), a default judgment containing a dollar amount must be entered for the amount claimed in the complaint and any item which can be calculated from the complaint, i.e.bringing the interest current. However, new items cannot be added at the time of entry of the judgment. 4. The Property is listed for Sheriffs Sale on June 5, 2013. 226446 5. Additional sums have been incurred or expended on Defendants'behalf since the Complaint was filed and Defendants have been given credit for any payments that have been made since the judgment. The amount of damages should now read as follows: Principal Balance $122,728.51 Interest Through February 28, 2013 $31,756.10 Late Charges $364.86 Legal fees $1,750.00 Cost of Suit and Title $2,536.76 Sheriffs Sale Costs $1,399.14 Property Inspections $532.00 Property Preservation $1,396.14 Mortgage Insurance Premium/Private Mortgage Insurance $2,704.24 Escrow to be paid $731.25 Escrow Deficit $10,388.59 Suspense/Misc. Credits ($833.48) TOTAL $175,454.11 6. Plaintiff paid the following in taxes and insurance during the time the loan was in default: 8/11/2009 ESCROW BALANCE ($376.13) 8/14/2009 SCHOOL TAX . $1,252.52 4/6/2010 TOWNSHIP TAX $682.17 8/3/2010 HOMEOWNERS INSURANCE $449.66 8/17/2010 SCHOOL TAX $1,254.48 9/16/2010 PAYMENT ($285.59) 4/14/2011 TOWNSHIP TAX $731.25 8/2/2011 HOMEOWNERS INSURANCE $455.17 8/16/2011 SCHOOL TAX $1,431.77 4/6/2012 TOWNSHIP TAX $731.25 8/16/2012 SCHOOL TAX $1,482.07 9/5/2012 HOMEOWNERS INSURANCE $1,750.00 3/26/2013 TOWNSHIP TAX $829.97 TOTAL $10,388.59 226446 7. The judgment formerly entered is insufficient to satisfy the amounts due on the Mortgage. 8. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to inclusion of the figures set forth above in the amount of judgment against the Defendants. 9. Plaintiff's foreclosure judgment is in rem only and does not include personal liability, as addressed in Plaintiff's attached brief. 10. In accordance with Cumberland County Local Rule 208.3(9),Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on May 2, 2013May 9, 2013 and requested the Defendants' Concurrence. Plaintiff did not receive any response from the Defendants. A true and correct copy of Plaintiff's letter pursuant to Local Rule 208.3(9)and certification of mailing are attached hereto, made part hereof, and marked as Exhibit `B". 11. No judge has previously entered a ruling in this case. WHEREFORE,Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. Phelan Hallinan,LLP DATE: �;�/ By: Jo han Lobb, Esquire ATTORNEY FOR PLAINTIFF 226446 Phelan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County V. No.: 10-334 CIVIL TERM JASON D. GROB- KELLY M. GROB Defendants MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION TO REASSESS DAMAGES I. BACKGROUND OF CASE JASON D. GROB and KELLY M. GROB executed a Promissory Note agreeing to pay principal, interest, late charges, real estate taxes,hazard insurance premiums, and mortgage insurance premiums as these sums became due. Plaintiffs Note was secured by a Mortgage on the Property located at 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933. The Mortgage indicates that in the event of a default in the mortgage, Plaintiff may advance any necessary sums, including taxes, insurance, and other items, in order to protect the security of the Mortgage. In the instant case,Defendants defaulted under the Mortgage by failing to tender numerous, promised monthly mortgage payments. Accordingly,after it was clear that the default would not be 226446 cured,Plaintiff commenced the instant mortgage foreclosure action. Judgment was subsequently entered by the Court, and the Property is currently scheduled for Sheriffs Sale. Because of the excessive period of time between the initiation of the mortgage foreclosure action, the entry of judgment and the Sheriffs Sale date, damages as previously assessed are outdated and need to be adjusted to include current interest, real estate taxes, insurance premiums, costs of collection, and other expenses which Plaintiff has been obligated to pay under the Mortgage in order to protect its interests. It is also appropriate to give Defendants credit for monthly payments tendered through bankruptcy, if any. II. LEGAL ARGUMENT TO AMEND PLAINTIFF'S IN REM JUDGMENT It is settled law in Pennsylvania that the Court may exercise its equitable powers to control the enforcement of a judgment and to grant any relief until that judgment is satisfied. 20 P.L.E., Judgments § 191. Stephenson v. Butts, 187 Pa.Super. 55, 59, 142 A.2d 319, 321 (1958). Chase Home Mortgage CoKporation of the Southwest v. Good, 537 A.2d 22, 24 (Pa.Super. 1988). The Pennsylvania Superior Court has repeatedly cited the right of a foreclosing creditor to amend its judgment prior to the Sheriff s sale. Nationsbanc Mortgage Corp. v. Grillo, 827 A.2d 489 (Pa.Super. 2003). Morgan Guaranty Trust Co. of N.Y. v. Mowl, 705 A.2d 923 (Pa. Super. 1998). Union National Bank of Pittsburgh v. Ciongoli,407 Pa.Super. 171, 595 A.2d 179 (1991). The Supreme Court of Pennsylvania recognized in Landau v. Western Pa.Nat. Bank,445 Pa. 117, 282 A.2d 335(1971),that the debt owed on a Mortgage is subject to change and, in fact, can be expected to change from day to day because the bank must advance sums in order to protect its collateral. Because a Mortgage lien is not extinguished until the debt is paid,Plaintiff must protect its collateral up until the date of sale. Beckman v. Altoona Trust Co., 332 Pa. 545,2 A.2d 226446 826(1939). Because a judgment in mortgage foreclosure is strictly in rem, it is critical that the judgment reflect those amounts expended by the Plaintiff in protecting the property. Meco Reality Company v. Burns,414 Pa. 495, 200 A.2d 335 (1971). Plaintiff submits that if it goes to sale without the requested amended judgment, and if there is competitive bidding for the Property, Plaintiff will suffer a significant loss in that it would not be able to recoup monies it advanced to protect its interests. Conversely,amending the in rem judgment will not be detrimental to Defendants as it imputes no personal liability. In B.C.Y. v. Bukovich,the Pennsylvania Superior Court reiterated its long standing rule that a Court has the inherent power to correct a judgment to conform to the facts of a case. 257 Pa. Super.'157, 390 A.2d 276 (1978). In the within case,the amount of the original judgment does not adequately reflect the additional sums due on the Mortgage due to Defendants' failure to tender payments during the foreclosure proceeding and the advances made by the mortgage company. The Mortgage plainly requires the mortgagors to tender to the mortgagee monthly payments of principal and interest until the Promissory Note accompanying the Mortgage is paid in fall. The mortgagors are also required to remit to the mortgagee sufficient sums to pay monthly mortgage insurance premiums,fire insurance premiums,taxes and other assessments relating to the Property. The mortgagor s have breached the terms of the Mortgage, and Plaintiff has been forced to incur significant unjust financial losses on this loan. III. THE FORECLOSURE JUDGMENT IS IN REM ONLY The within case is a mortgage foreclosure action, the sole purpose of which is to take the mortgaged property to Sheriffs Sale. Pennsylvania law makes clear that an action in mortgage foreclosure is strictly in rem and does not include any personal liability. Newtown Village 226446 Partnership v. Kimmel,424 Pa. Super 53, 55, 621 A.2d 1036, 1037 (1993). Signal Consumer Discount Company v. Babuscio, 257 Pa. Super 101, 109, 390 A.2d 266, 270 (1978). Pennsylvania Rule of Civil Procedure 1141(a). However, Pennsylvania law requires that the foreclosure action demand judgment for the amount due. Pa.R.C.P. 1147(6). The purpose of the dollar amount in the in rem judgment is for bidding at the Sheriff s Sale. In the event that a third party real estate speculator were to bid on the mortgaged property at the Sheriffs Sale and become the successful purchaser, Plaintiff would receive the amount of the in rem judgment from the Sheriff. IV. INTEREST The Mortgage clearly requires that the Defendants shall promptly pay when due the principal and interest due on the outstanding debt. In addition,the Note specifies the rate of interest to be charged until the debt is paid in full or otherwise satisfied. Specifically, interest from 30 days prior to the date of default through the date of the impending Sheriff's sale has been requested. V. TAXES AND INSURANCE If Plaintiff had not advanced monies for taxes and insurance throughout the foreclosure proceeding, Plaintiff would have risked loss of its collateral. If the Property were sold at a tax sale, Plaintiffs interest very well may be divested,and Plaintiff would sustain a complete loss on the outstanding balance due on the loan. If the Property were damaged in a fire, Plaintiff would not be able to obtain insurance proceeds to restore the Property if it did not pay the insurance premiums. 226446 Most importantly,the Mortgage specifically provides that the mortgagee may advance the monies for taxes and insurance and charge these payments against the escrow account. Plaintiff is simply seeking to have the Court enforce the terms of the Mortgage. VI. ATTORNEY'S FEES The Plaintiffs foreclosure fees are very modest. They cover all of the legal work done throughout the course of the foreclosure action to date, including reviewing the Act 6 or Act 91 letters, loan documents, account records, title reports and supporting documents, preparing and reviewing the mortgage foreclosure complaint, filing and service of the complaint, Rule 237.1 Notice, Department of Defense search, entry of judgment, the writ of execution process, lien holder notices, and all of the other legal work that goes into handling the mortgage foreclosure lawsuit. The Mortgage specifically provides for.Plaintiff's recovery of its attorney fees. The amount of attorney's fees requested in the Motion to Reassess Damages is in accordance with the loan documents and Pennsylvania law. Pennsylvania Courts have long and repeatedly concluded that a request of five percent of the outstanding principal balance is reasonable and enforceable as an attorney's fee. Robinson v. Loomis, 51 Pa. 78 (1865); First Federal Savings and Loan Association v. Street Road Shopping Center, 68 D&C 2d 751, 755 (1974). In Federal Land Bank of Baltimore v. Fetner,the Superior Court held that an attorney's fee of ten percent of the original mortgage amount is not unconscionable. 410 A.2d 344 (Pa. Super. 1979). The Superior Court cited Fetner in confirming that an attorney's fee of ten percent included in the judgment in mortgage foreclosure action was reasonable. Citicorp v. Morrisville Hampton 226446 Realty, 662 A.2d 1120 (Pa. Super. 1995). Plaintiff's legal fees are not a percentage but are significantly less than what is permitted by Pennsylvania law. VII. COST OF SUIT AND TITLE Pursuant to the terms of the mortgage,Plaintiff is entitled to recover all expenses incurred in the foreclosure action. The amount claimed for the costs of suit and title are the expenses Plaintiff paid to date as a result of the mortgage default. The title report is necessary to determine the record owners of the property, as Pa.R.C.P. 1144 requires all record owners to be named as Defendants in the foreclosure action. It is also necessary to determine whether there are any prior liens to be cleared, so that the Sheriff's sale purchaser acquires clear title to the property. It is necessary to determine if there are IRS liens on the property, whether the Defendants are divorced (which could affect service of the complaint), and numerous other legal issues. The title bringdown is necessary to identify any new liens on the property or new owners between the time of filing and complaint and the writ date. The Freedom of Information Act inquiries and the investigation into Defendants' whereabouts are necessary to effectively attempt personal service of the complaint and notice of sale on the Defendant. The notice of sale and Rule 3129 notice are required by Pa.R.C.P.3129.1 and 3129.2 to notify all lienholders, owners, and interested persons of the Sheriff's sale date, as their interests will be divested by the Sheriff's sale. Accordingly, the modest sums Plaintiff has incurred for the costs of suit and title were necessary pursuant to Pennsylvania law. The amounts were reasonable and actually incurred. The mortgage and Pennsylvania law permit Plaintiff to recover these sums through its 226446 foreclosure action. As the foreclosure action is in rem only, Plaintiff recovers its judgment from the sale of the property, not out of the Defendant's pockets. Plaintiff should recover the costs of suit and title in their entirety, which will not cause harm to the Defendants. VIII. PROPERTY INSPECTIONS AND PRESERVATION The terms of the mortgage provide for property inspections and property preservation charges. The lender or its agent may make reasonable inspections of the property pursuant to the terms of the mortgage. When a borrower defaults under the terms of the mortgage,the lender may do, or pay for, whatever is reasonable to protect its interest in the collateral, including property maintenance. Any amounts disbursed by the lender for property inspections and preservation become additional debt of the borrower secured by the mortgage. The lender may charge the borrower for services performed in connection with the default, for the purpose of protecting the lender's interest in the property, including property inspections and valuation costs. When a loan is in default, the lender's risk increases. Mortgage companies typically have a vendor visit the premises to determine if any windows need to be boarded up, if the property is vacant, if the grass needs to be cut, or the snow shoveled. If the property inspection reveals any problems at the mortgaged premises,then the mortgage company may proceed to take whatever steps are necessary to secure the collateral, such as boarding windows, winterizing, removing hazards or debris, etc. The mortgage company generally pays a vendor to handle these tasks, which are referred to in the industry as "property preservation". These services avoid code violations and avoid the property becoming an eyesore in the neighborhood. Property preservation helps maintain property values in the neighborhood. 226446 Accordingly, line items included in Motions to Reassess Damages for property inspections and property preservation represent amounts which the mortgage company has paid out of its pocket to preserve its collateral, consistent with the terms of the mortgage contract. Since the terms of the mortgage provide that such expenses by the mortgage company become part of the borrower's debt secured by the mortgage, those expenses are properly included in the Plaintiff's Motion to Reassess Damages. IX. CONCLUSION Therefore, Plaintiff respectfully submits that if the enforcement of its rights is delayed by legal proceedings, and such delays require the mortgagee to expend additional sums provided for by the Mortgage,then the expenses necessarily become part of the mortgagee's lien and should be included in the judgment. Plaintiff respectfully requests that this Honorable Court grant its Motion to Reassess Damages. Plaintiff submits that it has acted in good faith in maintaining the Property in accordance with the Mortgage, and has relied on terms of the Mortgage with the understanding that it would recover the monies it expended to protect its collateral. WHEREFORE,Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. Phelan Hallinan,LLP DATE: / By: J 4-than Lo , Esquire Attorney for Plaintiff 226446 Exhibit "A" 226446 �M '0,%TARY AM f0: 42 (-n-JN7Y COPY Phelan Hallinan&Schmieg,LLP By: Lawrence T.Phelan,Esq.,Id.No. 32227 Attorney for Plaintiff . Francis S. Hallinan,Esq.,Id.No.62695 Daniel G. Schmieg,Esq.,Id.No. 62205 Michele M.Bradford,Esq.,Id.No. 69849 Judith T.Romano,Esq.,Id.No. 58745 Sheetal R. Shah-Jani,Esq.,Id.No. 81760 Jenne R.Davey,Esq.,Id.No. 87077 Lauren R. Tabas,Esq.,Id.No. 93337 Vivek Srivastava,Esq.,Id.No.202331 Jay B.Jones,Esq.,Id.No. 86657 Peter J. Mulcahy,Esq.,Id.No. 61791 1 i Andrew L. Spivack;Esq.,Id.N#"$4439 Jaime McGuinness,Esq.,Id.No. 9 LE copy. Chrisovalante P. Fliakos,Esq-- . , LE J RN oshua I. Goldman,Esq.,Id.No'-2,t Courtenay R.Dunn,Esq.,Id.No.206779 Andrew C. Bramblett,Esq.,Id.No.208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 1 CHASE HOME FINANCE LLC CUMBERLAND COUNTY vs• C� T OF COMMON PLEAS '� TORNEY FILE CPI i JASON D.GROB �SE RETURVAIVIL DIVISION KELLY M.GROB No. 10-334 CPADL TERM j i PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES f:: TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against JASON D.GROB and KELLY M. GROB,Defendant(s)for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises,and assess Plaintiff's damages as follows: As set forth in Complaint $132,033.25 Interest-01/12/2010 to 03/02/2010 $1,136.00 TOTAL $133,169.25 is I hereby certify that(1)the Defendants'last known addresses are 706 ERFORD ROAD, CAMP HILL,CUMBERLAND COUNTY PA 17011 and the mortgaged premises 7 ; SCARSDALE DRIVE, CAMP HILL PA 17011-7933,and(2)that notice has been given in accordance with Rule 237.1,copy attached. Lawre .Phelan, uire Franc' S. allinan,E uire D 1 G. chmieg squire Michele M. ord,Esquire Judith T.Romano,Esquire Sheetal R. Shah-Jam,Esquire Jenne R. Davey,Esquire I Lauren R.Tabas,Esquire Vivek Srivastava,Esquire Jay B.Jones,Esquire Peter J. Mulcahy,Esquire Andrew L. Spivack,Esquire ` Jaime McGuinness,Esquire MM f.: �Chrisovalante P.Fliakos,Esquire I._.. !Joshua I. Goldman,Esquire Courtenay R.Dunn,Esquire ' Andrew C.Bramblett,Esquire Attorney for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. !- DATE: { PHS#226W PROTHONOTAR Exhibit "B" 226446 PHELAN HALLINAN, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallinan, LLP Representing Lenders in Pennsylvania May 2,2013 JASON D. GROB KELLY M. GROB 7 SCARSDALE DRIVE CAMP HILL,PA 17011-7933 RE: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SB/M CHASE HOME FINANCE,LLC v.JASON D. GROB and KELLY M. GROB Premises Address: 7 SCARSDALE DRIVE CAMP HILL,PA 17011 CUMBERLAND County CCP,No. 10-334 CIVIL TERM Dear Defendants, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9),1 am seeking your concurrence with the requested relief that is,increasing the amount of the judgment.Please respond to me within 5 days, by 5/8/2013. Should you have further questions or concerns,please do not hesitate to contact me: Otherwise,please be guided accordingly. Very t7`Ial.y yours; :lotA. c�&q.,l.d..No.3121.74 Attorney for Plaintiff Enclosure 226446 Name and Phelan Hallinan,LLP Address 1617 JFK Boulevard,Suite 1400 Of Sender One Penn Center Plaza Philadel ilia,PA 19103 KVIM Line C Article Number Name of Addl e5st*e,Street,and Post Office Address Posra�e - 4 _ {s;1 QG o 1 **** JASON D.GROB $0.45 ;,�';'� Lo N j KELLY M.GROB o j 7 SCARSDALG DRIVE t CAMP HILL,PA 17011-7933 2 **** .TASO.N D.GROB $0.45 PO BOX 1442 o CAMP HILL PA 17001-1442 m to 3 **** KELLY M.GROB ( S0.45 706 ERFORD RPAD CAMP HILL,PA 17011 RE:JASON D.GROB CUMBERLAND PITS#226446/1200 Page 1 of 1 j 51.35 v Total Number of Total Number of Pieces Postmaster,Per(Name of The full declaration of value'm mquircd on alt ttsmewc and international registered mail The i w Pieces Listed by Sender Received at Post Office Receiving Employee) for the reconstruction of nonnegotiable documents under Express Mail document reconstructior t , piece subject to a limit of 5500,000 per occurrence, The maximum indemnity payable on Exprt =• The maximum indemnity payable is$25,000 for registered mail,sent with optional insurance, 8400 59.13.and.S921 for limitations of to".-nue. Form 3877 .Facsimile 226446 Phelan Hallinan, LLP Jonathan Lobb, Esq.,Id. No.312174 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb @phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County V No.: 10-334 CIVIL TERM JASON D. GROB KELLY M. GROB Defendants CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Reassess Damages, and Brief in Support thereof, were sent to the following individuals on the date indicated below. JASON D. GROB JASON D. GROB KELLY M. GROB PO BOX 1442 7 SCARSDALE DRIVE CAMP HILL,PA 17001-1442 CAMP HILL,PA 17011-7933 KELLY M. GROB 706 ERFORD RPAD CAMP HILL,PA 17011 Phelan Hallinan,LLP DATE: G,/GI/f By: Jo an Lobb,Esquire ATTORNEY FOR PLAINTIFF 226446 S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County V. No.: 10-334 CIVIL TERM JASON D. GROB KELLY M. GROB Defendants RULE AND NOW,this day of 2013, a Rule is entered upon the Defendants to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendants shall have twenty (20) days from the date of this Order to file a response to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY THE COURT J. C.la, A Y, s /u/13 226446 a ` Jonathan Lobb,Esq.,Id.No312174 Phelan Hallinan,LLP 1617 JFK Boulevard, Suite 1400 Philadelphia,PA 19103 TEL: (215)563-7000 FAX: (215)563-3459 JASON D. GROB JASON D. GROB KELLY M. GROB PO BOX 1442 7 SCARSDALE DRIVE CAMP HILL,PA 17001-1442 CAMP HILL,PA 17011-7933 KELLY M. GROB 706 ERFORD RPAD CAMP HILL,PA 17011 226446 226446 .-FILED-OFFICE OF THE: PROTHONOTARY Phelan Hallinan, LLP 2013 MAY 2 1 AM 10: 53 John D. Krohn, Esq., Id. No.312294)MBERLAND COUNTY ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 PENNSYLVANiA One Penn Center Plaza Philadelphia, PA 19103 johnJuohn@phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County vs. No.: 10-334 CIVIL TERM JASON D. GROB KELLY M. GROB Defendants CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's May 14, 2013 Rule directing the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individuals on the date indicated below. JASON D. GROB JASON D. GROB KELLY M. GROB PO BOX 1442 7 SCARSDALE DRIVE CAMP HILL,PA 17001-1442 CAMP HILL,PA 17011-7933 KELLY M. GROB 706 ERFORD RPAD CAMP HILL,PA 17011 Phelan Hallinan, LILP DATE: 0113 , By: John D4Vohn,1sq.,Id.No.312244 Attorney for Plaintiff 226446 C;r THE PROTP10* GTAR� Phelan Hallinan, LLP V C� Jonathan Lobb, Esq., Id.No.312174 2N3 JUN j All 9*ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 CUMBERLAND cGUNTY One Penn Center Plaza PERNSYLVA141A Philadelphia, PA 19103 Jonathan.Lobb@phelanhalliiian.com 215-563-7000 JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County vs. No.: 10-334 CIVIL TERM JASON D. GROB KELLY M. GROB Defendants MOTION TO MAKE RULE ABSOLUTE JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, S/B/M CHASE HOME FINANCE, LLC,by and through its attorney,hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: 1. A Motion to Reassess Damages was filed with the Court on May 10, 2013. 2. Ifi accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendants on May 2, 2013 and requested the Defendants' Concurrence. Plaintiff did not receive any response from the Defendants..True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and certificate of mailing are attached hereto,made part hereof, and marked as Exhibit A. 3. A Rule was issued by the Honorable Christylee L. Peck on or about May 14, 2013 directing the Defendants to show cause by June 3, 2013 why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit B. 226446 4. The Rule to Show Cause was timely served upon all parties on May 20, 2013 in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit C. 5. Defendants failed to respond or otherwise plead by the Rule Returnable date of June 3, 2013. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant.Plaintiff s Motion to Reassess Damages. Phelan Hallinan, LLP DATE: 7 By: J athan Lobb, Esq., Id. No.312174 Attorney for Plaintiff 226446 Exhibit "A" 226446 PHELAN HALLINAN, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia,PA 1,9103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallinan, LLP Representing Lenders in Pennsylvania May 2,2013 JASON D. GROB KELLY M. GROB 7 SCARSDALE DRIVE CAMP HILL, PA 1.7011-7933 RE: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,S/B/M CHASE HOME FINANCE,LLC v. JASON D. GROB and KELLY M. GROB Premises Address: 7:SCARSDALE DRIVE CAMP HILL,PA 17011 CUMBERLAND County CCP;No. 10-334 CIVIL TERM Dear Defendants; Enclosed please find a true and:correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule.208.3(9),I am seeking your concurrence.with the requested relief that is,increasing the amount of the judgment. Please respond to me within 5 days, by 5/8/2013. Should you.have further questions or concerns,please do not hesitate to contact me. Otherwise,please be guided accordingly. Ver►;b1 u= 1!3.0"':you I S;. t�na11 l b Ls' Io..3121374; Attorney for Plaintiff Enclosure 226446 Name and Phelan Hallinan,LLP Address 1617 JFK Boulevard,Suite 1400 Of Sender One Penn Center Plaza - PhiladeI hia,PA 19103 KVIM Line Article Number Name of Addressee Street and Post Office Address Posta a � ~ I **** JASON D.GROB $0.45 p KELLY M.GROB � � n .rrr,- 7 SCARSDALE DRIVE CAMP HILL,PA 17011-7933 = ;^ " • 2 JASON D.GROB $0.45 ,..„✓ PO BOX 1.442 CAMP HILL,PA 17001-1442 rn g:ch 3 **** KELLY M.GROB 50.45 706 ERFORD RPAD NCO CAMP HILL,PA 17011 v RE:JASON D.GROS G><TlVISERtiA1VD PHS#22644b/1200 I?aoe l of 1 51.35 Total Number of Total Number of Pieces Postmaster,Per(Name of The full declaration of value s tYquiYed on fll c!entcstitt and international registered mail, The t < Pieces Listed by Sender Received at Post Office Receiving Employee) for the reconstruction of nonnegotiable documents under Express Mail document reconstructior piece subject to a limit of 5500,000 per occurrence. The maximum indemnity payable on Expre �? The maximum indemnity payable is$25,000 for registered mail,sent with optional insurance, ; R990 SNIand..S921 for limitations ofettvetit e, Form 3877.Facsimile 226446 -Exhibit "B" 226446 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, SB/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County V.4 No.: 10-334 CIVIL TERM JASON D. GROB KELLY M. GROB Defendants RULE AND NOW,this day of 2013, a Rule is entered upon the Defendants to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. s Defendants,shall have twenty (20) days from the date of this Order to file a response to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY THE COURT M� cn :;O ' p a 226446 Jonathan Lobb,Esq.,Id.No.312174 Phelan Hallinan,LLP 1617 JFK Boulevard, Suite 1.400 Philadelphia,PA 19103 TEL: (215)563-7000 FAX: (215)563-3459 JASON D.GROB JASON D. GROB KELLY M. GROB PO BOX 1442 7 SCARSDALE DRIVE CAMP HILL,PA 17001-1442 CAMP HILL,PA 17011-7933 KELLY M. GROB 706 ERFORD RPAD CAMP HILL,PA 17011 226446 226446 Exhibit. "C" fi ii_tG-ii1= }�,L Phelan Hal linan, LLP John D. Krohn, Es q.,q Id. No.312244 1617 JFK Boulevard Suite 1400 C1jMBt L-A1 } COU�lT�1YI TORNEY FOR PLAINTIFF One Penn Center Plaza ' s Philadelphia,PA 19103 john.krohn @phelanhallinan.com ? 215-563-7000 JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, SB/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County vs. No.: 10-334 CIVIL TERM JASON D. GROB KELLY M. GROB Defendants ,.- t� CERTIFICATION..OF_SERVICE I hereby certify that a true and correct copy of the Court's May 14, 2013 Rule directing the Defendants to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individuals on the date indicated below. JASON D. GROB JASON D. GROB KELLY M. GROB PO BOX 1442 7 SCARSDALE DRIVE CAMP HILL,PA 17001-1442 CAMP HILL,PA 17011-7933 KELLY M. GROB 706 ERFORD RPAD CAMP HILL,PA 17011 Phelan Hallinan, LLP DATE: ' a1 By:. John D �sq.,. 4 o.3 1224 4 Attorney for Plaintiff 226446 Phelan Hallinan, LLP Jonathan Lobb, Esq., Id. No.312174 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 Jonathan.Lobb@phelanhallinan.com 21.5-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SB/M CHASE HOME Court of Common.Pleas FINANCE, LLC Plaintiff Civil Division vs. CUMBERLAND County JASON D. GROB No.: 10-334 CIVIL TERM KELLY M. GROB Defendants CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of Plaintiffs Motion to Make Rule Absolute was served upon the following individuals on the date indicated below. S JASON D. GROB KELLY M. GROB JASON D. GROB 7 SCARSDALE DRIVE PO BOX 1442 CAMP HILL, PA 1 701 1-7933 CAMP HILL, PA 17001-1442 KELLY M. GROB 706 ERFORD RPAD CAMP HILL, PA 17011 Phelan Hallinan, LLP DATE:_� �7 2 By: Jo an Lobb, Esq:,Id. No.312174 Attorney for Plaintiff 226446 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION, SB/M CHASE HOME FINANCE, LLC Civil Division Plaintiff CUMBERLAND County vs. : No.: 10-334 CIVIL TERM JASON D. GROB KELLY M. GROB Defendants ORDER AND NOW, this/3A day of pu— ' 013, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED, that the Rule entered upon Defendants shall be and is hereby made absolute and Plaintiff's Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance $122,728.51 Interest Through February 28,2013 $31,756.10 Late Charges $364.86 Legal fees $1,750.00 Cost of Suit and Title $2,536.76 Sheriffs Sale Costs $1,399.14 Property Inspections $532.00 Property Preservation $1,396.14 Mortgage Insurance Premium/Private Mortgage Insurance $2,704.24 Escrow to be paid $731.25 Escrow Deficit $10,388.59 Cn _ �1 3y R Co 226446 Suspense/Misc. Credits ($833.48) TOTAL $175,454.11 Plus interest at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. BY THE COURT: J. J 1,,11 ��J3113 �� 226446 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson a"ILED~CF FILE Sheriff OF T NE €'ROTNQh�1TAi� o��,�tr cat "ui;7/irtt#, Jody S Smith Chief Deputy :,r r 20 13 AUG 30 AN 8: 21 Richard W Stewart Solicitor OFFICE OF THE SHERIFF CUMBERLAND COUNTY PENNSYLVANIA JP Morgan Chase Bank, NA Case Number vs. Jason D Grob (et al.) 2010-334 SHERIFF'S RETURN OF SERVICE 04/03/2013 01:04 PM - Deputy Shawn Harrison, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 7 Scarsdale Drive, Lower Allen Township, Camp Hill, PA 17011, Cumberland County. 04/11/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Kelly M. Grob, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 706 Erford Road, Camp Hill, PA 17011, address is that of Kelly M. Grob's Mother, she believed defendant to be at 7 Scarsdale Road, Camp Hill, PA 17011, 7 Scarsdale Road, Camp Hill is vacant. 04/11/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: Jason D. Grob but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as"Not Found"at 706 Erford Road, Camp Hill, PA 17011, address is that of co-defendant Kelly M. Grob's Mother, she believed defendant to be at 7 Scarsdale Road, Camp Hill, PA 17011, 7 Scarsdale Road, Camp Hill is vacant. 06/05/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA on June 5, 2013 at 10:00 a.m. He sold the same for the sum of$1.00 to Attorney Joseph Schalk, on behalf of Federal Home Loan Mortgage Corporation, being the buyer in this execution, paid to the Sheriff the sum of SHERIFF COST: $930.56 SO ANSWERS, August 28, 2013 RbNO R ANDERSON, SHERIFF qf=d© P°/ • &k oqs' (c)CountySuite Sheriff,Teleosoft,Inc. JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION, SB/M TO CHASE HOME FINANCE, LLC CIVIL DIVISION Plaintiff NO.: 10-334 CIVIL TERM V. JASON D. GROB CUMBERLAND COUNTY KELLY M. GROB Defendant(s) PHS #226446 AFFIDAVIT PURSUANT TO RULE 3129.1 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SBIM CHASE HOME FINANCE,LLC,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 7 SCARSDALE DRIVE,CAMP HILL,PA 17011-7933. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained, please so indicate) JASON D.GROB 7 SCARSDALE DRIVE CAMP HILL,PA 17011-7933 KELLY M.GROB 706 ERFORD ROAD CAMP HILL,PA 17011 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) JASON D. GROB 7 SCARSDALE DRIVE CAMP HILL,PA 17011-7933 KELLY M.GROB 706 ERFORD ROAD CAMP HILL,PA 17011 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained,please indicate) None. J0 6. Nan'ie and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address(if address cannot be reasonably ascertained,please indicate) COUNTRY &TOWN HOMES INC P.O. BOX 211 CAMP HILL,PA 17001 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: Name Address(if address cannot be reasonably ascertained,.please indicate) TENANT/OCCUPANT 7 SCARSDALE DRIVE CAMP HILL,PA 17011-7933 COMMONWEALTH OF PENNSYLVANIA 6TH FLOOR,STRAWBERRY SQ. BUREAU OF INDIVIDUAL TAXES DEPT 280601 INHERITANCE TAX DIVISION HARRISBURG,PA 17128 DEPARTMENT OF PUBLIC WELFARE,TPL• P.O. BOX 8486 CASUALTY UNIT,ESTATE RECOVERY WILLOW OAK BUILDING PROGRAM HARRISBURG,PA 17105 JASON D. GROB COLGAN&ASSOCIATES,LLC C/O THOMAS M.CLARK,ESQUIRE 130 WEST CHURCH STREET,SUITE 100 DILLSBURG,PA 17019 JASON D. GROB FEDERAL DEPOSIT INSURANCE C/O THOMAS M.CLARK,ESQUIRE CORPORATION(FDIC) 350 5TH AVENUE,SUITE 1200 NEW YORK,NY 10118-1201 KELLY M. GROB 615 NORTH 48TH STREET C/O PHILIP M. INTRIERI, ESQUIRE HARRISBURG,,PA 17111-3625 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY, 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA • HARRISBURG,PA'17108-1754 FEDERAL BUILDING 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.A. § 4904 relating to unsworn falsification to authorities. Date: 3 By: Ph n Hallinan,LLP Michael Kolesnik,Esq.,Id.No.308877 Attorney for Plaintiff f JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, COURT OF COMMON PLEAS S/B/M TO CHASE HOME FINANCE, LLC CIVIL DIVISION Plaintiff : : NO.: 10-334 CIVIL TERM VS. JASON D. GROB CUMBERLAND COUNTY KELLY M. GROB . Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JASON D. GROB KELLY M. GROB 7 SCARSDALE DRIVE 706 ERFORD'ROAD CAMP HILL,PA 17011-7933 CAMP HILL, PA 17011 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house(real'estate)at 7 SCARSDALE DRIVE,CAMP HILL,.PA 17011-7933 is scheduled to be sold at the Sheriff's Sale on 06/05/2013 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street,Carlisle,PA 17013 to enforce the court judgment of$133,169.25 obtained by JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SB/M CHASE HOME FINANCE,LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. 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: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the 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. 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 on page two 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 TAKE PLACE. 1. If the Sheriff's" Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 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 215-563-7000. 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 the right to remain in the property until the fall 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 proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. 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 filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. 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 CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800) 990-9108 e LEGAL DESCRIPTION ALL THAT CERTAIN piece of ground situate in the Township of Lower Allen, Cumberland County, Pennsylvania,bounded and described as follows,to wit: BEGINNING at a point on the northerly line of Scarsdale Drive which point is 215 feet westwardly of the northwesterly corner of Kensington Drive and Scarsdale Drive Extended,and at the dividing line between Lots Nos. 2 and 3,Block'C', on the hereinafter mentioned Plan of Lots;thence along the northerly line of Scarsdale Drive, South 34 degrees 45 minutes West, 11.25 feet to a point;thence further along the northerly line of Scarsdale Drive in an arc having a radius of 412.76 feet in a southwesterly direction,73.52 feet to a point at dividing line between Lots Nos. 3 and 4 on said Plan;thence along said dividing line,North 45 degrees 3 minutes West, 128.08 feet to a point at dividing line between Lots Nos. 3 and 29 on said Plan; thence along said dividing line and along dividing line between Lots Nos.3 and 30,Block'C',on said Plan, North 47 degrees 44 minutes East,64.35 feet to a point at dividing line between Lots Nos.2 and 3,Block'C', on said Plan;thence along said dividing line South.55 degrees 15 minutes East, 155.41 feet to a point,the place of BEGINNING. BEING Lot No. 3,Block'C',on Plan of Lots known as Country and Town Homes, Inc.,which plan was recorded in the Cumberland County Recorder's Office on May 14, 1956, in Plan Book 7,Page 41. TITLE TO SAID PREMISES VESTED IN Jason D. Grob and Kelly M. Grob, h/w, by Deed from Rebecca G. Albright, single woman, dated 08/31/2007, recorded 09/05/2007 in Instrument Number 200734623. PREMISES BEING: 7 SCARSDALE DRIVE,CAMP HILL,PA 17011-7933 PARCEL NO. 13-25-0022-085. SHORT DESCRIPTION By virtue of a Writ of Execution NO. 10-334 CIVIL TERM JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, S/B/M TO CHASE HOME FINANCE, LLC vs. JASON D. GROB KELLY M. GROB owner(s) of property situate in the TOWNSHIP OF LOWER ALLEN, Cumberland County, Pennsylvania, being (Municipality) 7 SCARSDALE DRIVE, CAMP HILL, PA 17011-7933 Parcel No. 13-25-0022-085. (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING R JDGMENT AMOUNT: $133,169,25 Phelan Hallinan,LLP Attorney for Plaintiff 1617 JFK Boulevard;Suite 1400 Philadelphia, PA 19103 215-563-7000 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 10-334 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,S/BIM TO CHASE HOME FINANCE,LLC Plaintiff(s) From JASON D.GROB,KELLY M. GROB (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 gamishee(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: $133,169.25 L.L.: $.50 Interest FROM 3/3/2010 TO DATE OF SALE($21.89 PER DIEM)$26,070.99 Atty's Comm: Due Prothy:$2.25 Atty Paid: $1,660.64 Other Costs: Plaintiff Paid: Date: 1/24/13 David D. Buell,Prothon ary (Sea]) By: Deputy REQUESTING PARTY: Name: JOHN MICHAEL KOLESNIK, ESQUIRE Address: PHELAN HALLINAN,LLP 1617 HK BOULEVARD,SUITE 1400 ONE PENN CENTER PLAZA PHILADELPHIA,PA 19103 ROM RECORD TRUE COP F Y Attorney for:PLAINTIFF In Testimony Whereof,I here unto set my hand Telephone:215-563-7000 and thO sealof said Court at Carlisle,Pa. 20--- This d of -prothonotary Supreme Court ID No.308877 prothonotary On March 12, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Lower Allen Township, Cumberland County, PA, Known and numbered as, 7 Scarsdale Drive, Camp Hill, Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 12, 2013 By: Real Estate Coordinator SZ NGf OR CUMBERLAND LAW JOURNAL Writ No. 2010-334 Civil JP MORGAN CHASE BANK,N.A. vs. JASON D. GROB, Kelly M. Grob Atty.:Joseph P. Schalk By virtue of a Writ of Execu- tion NO. 10-334 CIVIL TERM, JP- MORGAN CHASE BANK,NATIONAL ASSOCIATION s/b/m TO CHASE HOME FINANCE,LLC vs.JASON D. GROB, KELLY M. GROB owner(s) of property situate in the TOWN- SHIP OF LOWER ALLEN, Cumber- land County, Pennsylvania, being 7 SCARSDALE DRIVE,CAMP HILL,PA 17011-7933. Parcel No. 13-25-0022-085. Improvements thereon:RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT:$133,169- .25. 37 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : 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, April 12, April 19 and,�Lnl 26, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. 6V'a Marie Coy Editor SWORN TO AND SUBSCRIBED before me this 26 day of Aph Notary NOTARIAL SEAL NotarY Public OUNTY CARLISLE BOROUGH,CUMBERLAND C] MV Commission Expires Apr 28,2014 The Co. 2020 �� 14c'�-'`''-'-�� ~��ui8e 300 �atr1*otwXtws Mechanicsburg, PA 17050 ' Now you know Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16. 1S2Q Commonwealth of Pennsylvania, County ofDauphin) ss Marianne Miller, being duly Sworn according bo law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania,with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement mm 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 om the date(s)shown below: 04K�� nm1�mz��m � - OmmAm CHASE BANK, A 04/23113 JASON D GR68 04/30/13 � Kelly»»Grob | �ottV Joseph P.Schalk ^ �m, v« *m^/su�nuonmD�x�»� ^' ' .'7. . . . -' -. . . . . -' '�y ~' ' ' ~- ' ' -- ' ' ' ' ' ' ' ' By ovILTsmm - JPMORGAN CHASE BANK, Svvornto�ndsuboohbad before rnm this 13dayofyNay 2O13 A.[}. NATIONAL ASSOCIATION,o�wzn . CHASE HOME FINANCE,LLC VS. JASON D.ouOB =~ IYUL P KELLY m.000a Public- owner(s) of property situate in the TOWNSHIP OF u)*sa mLan CT Cumberland County,Pennsylvania,being � /uomuumLE DRIVE,CAMP onI`n^ 17011-7e3 ======= COMMONWEALTH OF PENNSYLVANIA Parcel No.a-25{mo-085. Notarial Seal (Acreage or street address) Holly Lynn Warfel,Notary Public Improvements thereon: RESIDENTIAL Washington Twp.,muphin County DWELLING commission Expires Dec.12,2016 �oo��mmos�$/�� m��um�='~~ES � � COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ISS: 1,Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Federal Home Loan Mortgage Con2orati is the grantee the same having been sold to said grantee on the 5th day of June A.D., 2013, under and by virtue of a writ Execution issued on the 24th day of Januga, A.D., 2013, out of the Court of Common Pleas of said County as of CjyU Term, 2010 Number 3 34, at the suit of JPMorgan Chase Bank,National Association S/B/M to Chase Home Finance LLC against Jason D. Grob and Kelly M. Grob is duly recorded as Instrument Number 201328919. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of A.D. Recorder of Deeds