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Home My WebLink About10-0378GOLDBECK McCAFFERTY & McKEEVER 'BY: MICHAEL T. MCKEEVER ATTORNEY I.D. #56129 SUITE 5000 - MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866) 413-2311 WWW.GOLDBECKLAW.COM FILED-0 c?-,1CE OF ?1-{F P t .CNO ARY 2010J1N 15 PM 12:O5 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMES L. MILLER JR. STEPHANIE L. MILLER Mortgagors and Record Owners 296 Old Stone House Carlisle, PA 17013 Defendants IN THE COURT OF OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term . No. /,,g _ 7-6 CIVIL ACTION: MORTGAGE FL1RFrl O'gl)gF' NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 6) CUMBERLAND COUNTY BAR ASSOCIATION q,-),co vt. 2 Liberty Avenue Carlisle, PA 17013. S???ss LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO LE HAN DEMANDADO A USTED EN LA CORTE. SI DESEA DEFENDERSE CONTRA LAS QUEJAS PERESENTADAS, ES ABSOLUTAMENTE NECESSARIO QUE USTED RESPONDA DENTRO DE 20 DIAS DESPUES DE SER SERVIDO CON ESTA DEMANDA Y AVISO. PARA DEFENDERSE ES NECESSARIO QUE USTED, O SU ABOGADO, REGISTRE CON LA CORTE EN FORMA ESCRITA, EL PUNTO DE VISTA DE USTED Y CUALQUIER OBJECCION CONTRA LAS QUEJAS EN ESTA DEMANDA. RECUERDE: SI USTED NO REPONDE A ESTA DEMANDA, SE PUEDE PROSEGUIR CON EL PROCESO SIN SU PARTICIPACION. ENTONCES, LA COUTE PUEDE, SIN NOTIFICARIO, DECIDIR A FAVOR DEL DEMANDANTE Y REQUERIRA QUE USTED CUMPLA CON TODAS LAS PROVISIONES DE ESTA DEMANDA. POR RAZON DE ESA DECISION, ES POSSIBLE QUE USTED PUEDA PERDER DINERO, PROPIEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO CONSEUIR UN ABOGADO. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.Dhfa.orgJconsumers/homeowners/???eal.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: htW://www. hip ladelphiafed org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretentionQp-oldbecklaw com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 92508FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT "IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., 7255 Baymeadows Way, Jacksonville, FL 32256. 2. The names and addresses of the Defendants are JAMES L. MILLER JR., 296 Old Stonehouse Road, Carlisle, PA 17015 and STEPHANIE L. MILLER, 296 Old Stonehouse Road, Carlisle, PA 17015, who are the mortgagors and record owners of the mortgaged premises hereinafter described. 3. On January 25, 2002 mortgagors made, executed and delivered a mortgage upon the Property hereinafter described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., AS NOMINEE FOR WASHINGTON MUTUAL BANK FA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County as Book 1747 Page 4199. The mortgage has been assigned to: JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. by assignment of Mortgage August 07, 2006 as Book 729 Page 1918. The Mortgage and assignment(s) are matters of public record and are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property") 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for September 01, 2009 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage: Principal Balance ..................................................................................$300,070.70 Interest from 08/01/2009 through 12/31/2009 at 4.5000% .......................$5,661.00 Per Diem interest rate at $37.00 Reasonable Attorney's Fee at 5% of Principal Balance as more fully explained in the next numbered paragraph .................$15,003.54 Late Charges from 09/01/2009 to 12/31/2009 .............................................$304.48 Monthly late charge amount at $76.12 Costs of suit and Title Search (Estimated) ...................................................$900.00 Escrow Advance .......................................................................................$2,900.00 Suspense ....................................................................................................... ($90.98) Monthly Escrow amount $414.62 $324,748.74 7. If the Mortgage is reinstated prior to a Sheriff s Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. The Attorney's Fees requested are in conformity with the Mortgage and Pennsylvania law. Plaintiff is entitled to collect Attorney's fees of up to 5% of the remaining principal balance in the event the Property is sold to a third party purchaser at Sheriff s Sale or if the complexity of the action requires additional fees in excess of the amount demanded in the Action. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such notice(s) attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting within the required time and Plaintiff has no knowledge of any such meeting being requested by the Defendants through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer Credit Counseling Agency. WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $324,748.74, together with interest at the rate of $37.00, per day and other expenses, costs and charges incurred by the Plaintiff which are properly chargeable in accordance with the terms of the Mortgage and Pennsylvania law until the Mortgage is paid in full, and for the foreclosure of the Mortgage and Sheriff s Sale of the Property. By: GOLDB CK MC AF ERTY & MCKEEVER Michae cKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 ATTORNEYS FOR PLAINTIFF VERIFICATION Enso UstcMc , as the representative of the servicing agent for the Plaintiff corporation within named do hereby verify that I am authorized to and do make this verification on behalf of the Plaintiff corporation and the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: 0/ Ov 2©/© r JPMORGAN CHASE BANK, NATIONAL ASSOCIATION #92508FC - JAMES L. MILLER JR. and STEPHANIE L. MILLER 296 Old Stone House Carlisle, PA 17013 ?Fci6it A ALL THAT CERTAIN. tract of land situate in Middlesex Township, Cumberland County, Pennsylvania, being identified as Lot 9 as shown on a plan of lots ]mown as Pheasant Crossing prepared for or Realaland; the Inc., by Hoover Engineering Services, Inc., dated August 10, 1998, approved October 7, 1998 by Middlesex Township Board of Supervisors, and recorded November 6, 1998 in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 77, page 128, and being more fully described as follows, to wit. BEGINNING at a point in the centerline of T-591 (Old Stone House Road); thence by Lot 8 of the aforementioned subdivision South thirty-seven (37) degrees fifty-throe (53) minutes six (06) seconds West a distance of five hundred twenty-four and ninety-five Wadredths (524.95) feat to an iron pin; thence by Lot 8 and by Lot 7 of the aforementioned subdivision South fifty-taro (52) degrees six (06) minutes fifty-four (54) seconds East a distance of three hundred fifty (350.00) feet to an iron pin; thence by Lot 6 of the aforementioned subdivision South thirty-seven (37) degrees fifty-three (53) minutes six feet to an iron (06) seconds West a distance of six hundred ninety-one and fifty-nine hundredths (691,59) ?? (88) degrees and fifteen (15) pin; thence by Lot 11 of the aforementioned subdivision South eiglrty?cight ?.?? hundredths minutes zero (00) seconds West a distance of one hundred twenty (127.18) fact to an iron pin; thence by land now or formerly of Robert Line and J. Edward Clouse North one (01) degrees forty-five (45) minutes zero (00) seconds west a distance of seven hundred seventeen and twenty-three hundredths (717.23) feet to an iron pin; thence by Lot 10 of the aforementioned subdivision North eighty-eight (88) degrees fifteen (15) minutes zero (00) seconds East a distance of two hundred sixty and thirty hundredths (260.30) feet to an horn pin; thence by Lot 10 of the aforementioned subdivision North thirty-seven (37) degrees fifty-three (53) minutes six (06) seconds East a distance of five hundred twenty-four and ninety-eight hundredths (524.98) feet to a point in the centerline of T-591; thence in along and through the centerline of T-591 South fifty-two (52) degrees five (05) minutes twenty-four (24) seconds East a distance of fifty (50.00) feet to a point in the centerline of T-591 (Old Stone House Road) the place of BEGINNING. CONTAIlSING 7.281 acres of land as surveyed. BEING the same premises which Realand, Inc., a Pennsylvania corporation, by Deed bearing date of the 1st day of the October 1999, and recorded on the 18th day Deed r, Book 211, 19999 in The Office grantee Recorder of Deeds in and for Cumberland County, Pennsylvania, in and conveyed unto James L. Miller and Stephanie L. Miller, husband and wife. UNDER AND SUBJECT TO restrictions and conditions as now appear of record. Tax Map #21-08-0573-133 this to be recorded ,berland county e Recorder of Deeds OK174 7PG4215 E.)chibit (13 Chase Home Finance LLC FL5-7730 PO BOX 44090 Jacksonville, FL 32231-4090 8459546795 November 16, 2009 CHASE #BWNCLNN# #0984599546979593# JAMES L MILLER 296 OLD STONE HOUSE RD CARLISLE PA 17013 008937 /PC/FT Your house is vow home We want to keen it that way. We need to talk -- call 1-800-848-9380 today. You are going through tough times - we can help. In fact, we believe your home loan may be eligible for a loan modification program - we may be able to change the term of your loan, the interest rate, and maybe even the principal due date, to reduce the monthly payment to an amount you can afford. Call us today at 1-800-848-9380 so we can help you turn things around. We'll discuss your current situation (outlined in the enclosed letter) and the options available to you. But we cannot stress enough that the longer you delay calling us, the fewer chances you may have to keep your home. It will only take a few minutes on the phone - one of our Loan Specialists will work with you to determine the option that best fits your needs. There are several options available - call us now and let us see which one will work best for you. We are committed to working with you to find a way to help you keep your home, but you must call us immediately at 1-800-848-9380 - the longer you delay, the fewer options you may have. Homeowner's Assistance Department Chase Home Finance LLC 1-800-848-9380 P. S. The enclosed legal letter outlines in detail, your current situation and the consequences that will occur unless we receive the required financial information from you and can approve you for a modification. Once you call us with the information needed, then we can work together to determine the option that will work best for you. We cannot guarantee that you will be approved, but your only chance of saving your home is by contacting us immediately. Please don't delay - call us now at 1-800-848-9380. Chase Home Finance LLC FL5-7730 PO BOX 44090 Jacksonville, FL 32231-4090 November 16, 2009 JAMES L MILLER 296 OLD STONE HOUSE RD CARLISLE PA 17013 008937 CHASED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 8459546795 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mort on vour home is in default and the 1 nder intends to foreclose Specific information about the nature of the default is provided in the attached pages. able to help to save your The HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be home. This Notice explains how the program works. To see if HEMAP can help. you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE. Take this Notice with you when you meet with the Counseling Agency. The name address and Rhone number of Consumer Credit Counseling Agencies serving your County are listed at the end of this Notice. If you have any-questions. you may call the Pennsylvania Housing Finance Agency toll free at 1 800-342 2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you rind a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. C0826 HOMEOWNER'S NAME(S): James L. Miller PROPERTY ADDRESS: 296 Old Stone House Rd Carlisle PA 17013 LOAN ACCT. NUMBER: 8459546795 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Chase Home Finance LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WINCH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENT IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITH-1- THIRTY THREE (33' nsvc OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE UP TO DATE THE PART- OF THIS NOTICE CALLED "HOW CO CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSIMR CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names. addresses, and telephone numbers of designated consumer credit counseling agencies for he county in which the propgM i located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETTNG WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATTON WITH PHFA WITHIN 30 DAYS OF THAT MEETTNG, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIOD A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS distance.) ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, y a still apply for Emergency Mortgage 008937/CO828 HOW TO CURE YOUR MORTGAGE DEFAULT Brina it uo to date). N_ATLIItE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 296 Old Stone House Rd Carlisle PA 17013 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: $1937.04 Monthly Installments: 09/01/2009 $1937.04 10/01/2009 $1937.04 11/01/2009 Other charges (explain/itemize): $0.00 Uncollected Late Charges $0.00 Uncollected Fees: $1$0.10 Less Credits $$167.02 TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5644.02, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. P ents must be made either by cash cashiers check certified check or money order made oQvahle and sent to: Chase Home Finance LLC Attn: 0114-7133 3415 Vision Drive Columbus, OH 43219 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DO NOT rnn:F THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender i?rtends to exert" its rights to acceleraty h morWge debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose anon your mortQaaed oronerty. *IF THEM )RTG ;E IS FORECI.M UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which mayvaa?=ne us fees. other reasonable costs. If you r the f within the THIRTY 1301 DAY period you will not be reaui Y OTHER LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. C0826 RIG;'T TO (`IiRF THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, YQU sill have the ri gt?t to cure the default and orevent the sale at anv time.BF ._ __.. ,.,..._ ..ate Ya +hP cl+P*iffs Sale. You may do so by na.^=^? the total amount then ,n??du?..plus anv Is+te or other crv.. ,fib in wiiin b the lender and by nerformine anv other reanireTM?Pn+c ender the mort¢aee. Curing the Shenffc Sale as ,,,?, >:_-3' your default in the manner set forth ?n this notice will restore your mortgage to the same pos?hon as ?f you had never defaui EARI.*pST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER- Name of Lender: Chase Home Finance LLC Address: Mail Code FL5-7317 PO Box 41275 Jacksonville, FL 32203-1275 Phone Number: (904) 886-1308 Toll Free: (800) 848-9380 Contact Person: Kimberly Smith Email Address: kimberly.brownoehase.com FvF?rTe nF SRIFF'S SALE- - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriff's Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. scernylPTION OF MORTGAGE - You _ may or Xmay not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED An important reminder for all our customers- As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Chase offers loan modification assistance free of charge (i e., no modification fee required). Please call us immediately at 1-800-848.9380 to discuss your options. The longer you delay the fewer options you may have. WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. We may report information about your account to edit bureaus. your payments, missed payments or other defaults on your account may be reflected in credit report. C0826 Chase Home Finance LLC FL5-7730 PO BOX 44090 Jacksonville, FL 32231-4090 November 16, 2009 #BWNCLNN# #0984599546979593# STEPHANIE L MILLER 296 OLD STONE HOUSE RD CARLISLE PA 17013 008938 /PC/FT CHASED Your house is your home We want to keep it that way We need to talk -- call 1-800-848-9380 todav. 8459546795 You are going through tough times - we can help. In fact, we believe your home loan may be eligible for a loan modification program - we may be able to change the term of your loan, the interest rate, and maybe even the principal due date, to reduce the monthly payment to an amount you can afford. Call us today at 1-800-848-9380 so we can help you turn things around. We'll discuss your current situation (outlined in the enclosed letter) and the options available to you. But we cannot stress enough that the longer you delay calling us, the fewer chances you may have to keep your home. It will only take a few minutes on the phone - one of our Loan Specialists will work with you to determine the option that best fits your needs. There are several options available - call us now and let us see which one will work best for you. We are committed to working with you to find a way to help you keep your home, but you must call us immediately at 1-800-848-9380 - the longer you delay, the fewer options you may have. Homeowner's Assistance Department Chase Home Finance LLC 1-800-848-9380 P. S. The enclosed legal letter outlines in detail, your current situation and the consequences that will occur unless we receive the required financial information from you and can approve you for a modification. Once you call us with the information needed, then we can work together to determine the option that will work best for you. We cannot guarantee that you will be approved, but your only chance of saving your home is by contacting us immediately. Please don't delay - call us now at 1-800-848-9380. Chase Home Finance LLC FL5-7730 PO BOX 44090 Jacksonville, FL 32231-4090 November 16, 2009 STEPHANIE L MILLER 296 OLD STONE HOUSE RD CARLISLE PA 17013 008938 CHASED NOTICE OF COLLECTION ACTIVITY RE: ACCOUNT # 8459546795 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE This is an official notice that the mo ge o our home default and the 1P*+?er intends to for lose. Specific information about the nature of the default is provided in the attached pages. The HOMEOWNERS EMERGENCY MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able to help to save your home. This Notice explains how the program works To see if HEMAP can help you must MEET WITH A CONSUMER CREDIT COUNSELING AGENCY WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Noticevith you when you meet with the Counseling Agency. The name address and phone number of Consumer Credit Counseling Agencies serving jour County are listed at the end of this Notice If you have any questions you m call the Pennsylvania Housing Finance Agency toll frce at 1-800-342-2397. (Persons with impaired hearing can call (717) 780-1869). This Notice contains important legal information. If you have any questions, representatives at the Consumer Credit Counseling Agency may be able to help explain it. You may also want to contact an attorney in your area. The local bar association may be able to help you find a lawyer. LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUSS AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION INMEDIATEMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO "HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU HIPOTECA. C0826 HOMEOWNERS NAME(S): Stephanie L. Miller PROPERTY ADDRESS: 296 Old Stone House Rd Carlisle PA 17013 LOAN ACCT. NUMBER: 8459546795 ORIGINAL LENDER: CURRENT LENDER/SERVICER: Chase Home Finance LLC HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND HELP YOU MAKE FUTURE MORTGAGE PAYMENTS. IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR EMERGENCY MORTGAGE ASSISTANCE: • IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR CONTROL. • IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR MORTGAGE PAYMENTS, AND • IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE PENNSYLVANIA HOUSING FINANCE AGENCY. TEMPORARY STAY OF FORECLOSURE - Under the Act, you are entitled to a temporary stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three (3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting with one of the consumer credit counseling agencies listed at the end of this Notice. THIS MEETING MUST OCCUR WITHIN THIRTY-THREE (331 DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING YOUR MORTGAGE _UP TO DATE. THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT". EXPLAINS HOW TO BRING YOUR MORTGAGE UP TO DATE. CONSUMER CREDIT COUNSELING AGENCIES - If you meet with one of the consumer credit counseling agencies listed at the end of this notice, the lender may NOT take action against you for thirty (30) days after the date of this meeting. The names- addresses. and telephone numbers of designated consumer credit counseline aogncies for the county in which the prolMr i j_ , located are set forth at the end of this Notice. It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intentions. APPLICATION FOR MORTGAGE ASSISTANCE - Your mortgage is in default for the reasons set forth later in this Notice (see following pages for specific information about the nature of your default). You have the right to apply for financial assistance from the Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and file a completed Homeowner's Emergency Assistance Program Application with one of the designated consumer credit counseling agencies listed at the end of this Notice. Only consumer credit counseling agencies have applications for the program, and they will assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEM" APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF TH4T MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN 7HE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE". YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. AGENCY ACTION - Available funds for emergency mortgage assistance are very limited. They will be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no foreclosure proceedings will be pursued against you, if you have met the time requirements set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application. NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT THE DEBT. (If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.) 008938/C0826 HOW TO CURE YOUR MORTGAGE DEFAULT (Brine it up to date). NATURE OF THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 296 Old Stone House Rd Carlisle PA 17013 IS SERIOUSLY IN DEFAULT BECAUSE: Non-payment A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: Monthly Installments: 09/01/2009 $1937.04 10101/2009 $1937.04 11/01/2009 $1937.04 Other charges (explain/itemize): Uncollected Late Charges $000 $0.00 Uncollected Fees: $1$0 $167.10 Less Credits $ .02 TOTAL AMOUNT PAST DUE: B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not applicable): HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $5644.02, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either by cash cashier's check certified check or money order made payable and sent to: Chase Home Finance LLC Attn: OH4-7133 3415 Vision Drive Columbus, OH 43219 You can cure any other default by taking the following action within THIRTY (30) DAYS of the date of this letter: (Not applicable): IF YOU DON T CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debt. This means that the entire outstanding balance of this debt will be considered due immediately, and you may lose the the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to foreclose upon Your mortgaged property. *IF TIRE MORTGAGE IS FORECLOSED UPON The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed $50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period you will not be Muired to pay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the upaid principal balance and all other sums due under the mortgage. C0826 RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the right to cure the default and prevent the sale at am time up to one hour before the Sheriff's Sale You may do so by ppjdRg the total amount then Host due. alas anv late or other c ar&CS then due rep! =ble attorney's fees and costs connected with the foreclosure sale and anv other costs connected i the Sheriff's Sale as specified in writing bvshe lender and by_tterformmg any other requirements under the mortgage. Curing your default in the manner set forth in this notice will restore your mortgage to the same position as if you had never defaulted. EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriff's Sale of the mortgaged property could be held would be approximately 9 months from the date of this Notice. A notice of the actual date of the Sheriff's Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. HOW TO CONTACT THE LENDER: Name of Lender: Address: Phone Number: Toll Free: Contact Person: Email Address: Chase Home Finance LLC Mail Code FL5-7317 PO Box 41275 Jacksonville, FL 32203-1275 (904)886-1308 (800) 848-9380 Kimberly Smith kimberly.brown@chase.com FFFE.(M OF SHERIFF'S SALE: - You should realize that a Sheriff's Sale will end your ownership of the mortgaged property and your right to occupy it. If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPTION OF MORTGAGE - You _ may or Xmay not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and attorney's fees and costs are paid prior to or at the sale, and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THE DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF. • TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.) • TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS. • TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY THE LENDER. • TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW. CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY ARE ATTACHED An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Chase offers loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 1-800-848-9380 to discuss your options. The longer you delay the fewer options you may have. WE ARE A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. We may report information about your account to credit bureaus. Late payments, missed payments or other defaults on your account may be reflected in your credit report. C0826 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff r Tf < Jody S Smith a Chief Deputy ZG .Ire ti ? u Edward L Schorpp Solicitor -F c F Rr - ; ; ;-v JP Morgan Chase Bank, NA VS. Case Number James L. Miller, Jr. 2010-378 SHERIFF'S RETURN OF SERVICE 01/21/2010 09:53 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 21, 2010 at 0953 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: James L. Miller Jr, by making known unto himself personally, at 296 Old Stone House Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. 01/21/2010 09:53 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on January 21, 2010 at 0953 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Stephanie L. Miller, by making known unto James Miller, Husband of defendant at 296 Old Stone House Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $49.40 SO ANSWERS, January 22, 2010 NY R ANDERSON, SHERIFF By Depu hi'q CoU-ySuite She, ffl 1 eiecso`t. Irc. In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K!A No. 10-378-CIVIL WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff C o ` vs. n L. MILLER JR. - STEPHANIE L. MILLER y' 71 r (Mortgagor(s) and Record Owner(s)) CA ? Q 296 Old Stone House Carlisle, PA 17013 Defendant(s) pct o vm c,a PRAECIPE FOR JUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEM PTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against JAMES L. MILLER JR. and STEPHANIE L. MILLER by default for want of an Answer. Assess damages as follows: Debt Interest from 02/24/2010 to Date of Sale per diem at $36.99 Total (Assessment of Damages attached) $327,726.15 I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his attorney of record, if any, after the default oast ten days prior to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 By: GOLDBEC Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff AND NOW PZ2nC j!S,r ' Judgment is entered in favor of JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. and against JAMES L. MILLER JR. and STEPHANIE L. MILLER by default for want of an Answer and damages assessed in the sum of $327,726.15 as per bove ccrf `cation. «r.o? - C„;( ?Qa `? Prothonotary lz:lk a38'rat JIA«mat( , Rule of Civil Procedure No. 236 - Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. MILLER JR. STEPHANIE L. MILLER (Mortgagors and Record Owner(s)) 296 Old Stone House Carlisle, PA 17013 No. 10-378-CIVIL Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. Prothonotary By: If you have any questions concerning the above, please contact: Michael T. McKeever Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. That the above named Defendant, JAMES L. MILLER JR., is about unknown years of age, that Defendant's last known residence is 296 Old Stonehouse Road Carlisle, PA 17015, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: -14a &Kw?, TINAMARIE BOSCHETTI VERIFICATION OF NON-MILITARY SERVICE The undersigned, as the representative for the Plaintiff corporation within named do hereby verify that I am authorized to make this verification on behalf of the Plaintiff corporation and that the facts set forth in the foregoing verification of Non-Military Service are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. 1. That the above named Defendant, STEPHANIE L. MILLER, is about unknown years of age, that Defendant's last known residence is 296 Old Stonehouse Road Carlisle, PA 17015, and is engaged in the unknown business located at unknown address. 2. That Defendant is not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Action of Congress of 1940 and its Amendments. Date: TINAMARIE BOSCHETTI GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff VS. JAMES L. MILLER JR. STEPHANIE L. MILLER (Mortgagor(s) and Record owner(s)) 296 Old Stone House Carlisle, PA 17013 Defendant(s) ORDER FOR JUDGMENT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 10-378-CIVIL Please enter Judgment in favor of JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., and against JAMES L. MILLER JR. and STEPHANIE L. MILLER for failure to file an Answer in t ab action within (20) days (or sixty (60) days if defendant is the United States of America) from the date of servic t C pl int, in the sum of $327,726.15. By: GOLDBE CC FERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 istina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff 1 hereby certify that the above names are correct and that the precise residence address of the judgment creditor is JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonvill , FL 32 56 and that the name(s) and last known address(es) of the Defendant(s) is/are JAMES L. MILLER JR., 29 ouse Road Carlisle, PA 17015 and STEPHANIE L. MILLER, 296 Old Stonehouse Road Carlisle. PA 17 By: - GOLD K MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 nstma Murtha Pa. ID 61858 David Fein Pa. 1D 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 Michael T. McKeever Attorney I.D.#56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. MILLER JR. STEPHANIE L. MILLER Mortgagor(s) and Record Owner(s) 296 Old Stone House Carlisle, PA 17013 Defendant(s) TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 10-378-CIVIL PRAECIPE FOR WRIT OF EXECUTION Issue Writ of Execution in the above matter: y9 qo Y 4 9a - (V 1q.ov t $1, q0 Arnount Due Interest from 02/24/2010 to Date of Sale per diem at $36.99 (Costs to be added) $327,726.15 rv 0 M -TI, t;; ` -ts cY;, . t c-n xt C_ Q C) By:___ _ - GOLD CK MCCAFFERTY & MCKF,EVER Micha McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attonreys for Plaintiff' 0 "H- -Z20'f8 t 2 ? ? O W d C/1 ? ? W w w (4s] ? ¢ Q ? Z a a3 Q¢¢ CS Q O w C7 OU Uw?OQ. U O H `J U N ? G ho o ? ?: o W W i? W on a a? U N O_ N O ?°o a ?o ALL that certain tract of land situate in MIDDLESEX TOWNSHIP, Cumberland County, Pennsylvania, being identified as Lot 9 as shown on a plan of lots known as Pheasant Crossing prepared for Realand, Inc. by Hoover Engineering Services, Inc., dated August 10, 1998, approved October 7, 1998 by the Middlesex Township Board of Supervisors, and recorded November 6,1998 in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 77 on page 128, and being more fully described as follows, to wit: BEGINNING at a point in the centerline of T-591 (Old Stone House Road); thence by Lot 8 of the aforementioned subdivision South 37 degrees 53 minutes 06 seconds West a distance of five hundred twenty-four and ninety-five hundredths (524.95) feet to an iron pin; thence by Lot 8 and by Lot 7 of the aforementioned subdivision South 52 degrees 06 minutes 54 seconds East a distance of three hundred fifty (350.00) feel to an iron pin; thence by Lot 6 of the aforementioned subdivision South 37 degrees 53 minutes 06 seconds West a distance of six hundred ninety-one and fifty-nine hundredths '(691.59) feet to an iron pin; thence by Lot II of the aforementioned subdivision South SS degree, IS minutes 00 seconds West a distance of one hundred twenty-seven and eighteen hundredths (127.18) feet to an iron pin; thence by land now or formerly of Robert Line & 1. Edward Clouse North 01 degrees 45 minutes 00 seconds West a distance of seven hundred seventeen and twenty-three hundredths (717.23) feet to an iron pin; thence by Lot 10 of the aforementioned subdivision North 88 degrees 15 minutes 00 seconds East a distance of two hundred sixty and thirty hundredths (260.30) feet to an iron pin; thence by Lot 10 of the aforementioned subdivision North 37 degrees 53 minutes 06 seconds East a distance of five hundred twenty-four and ninety-eight hundredths (524.98) feet to a point in the centerline of-F-591; thence in along and through the centerline of T-591 South 52 degrees 05 minutes 24 seconds East a distance of fifty (50.00) feet to a point in the centerline off-591 (Old Stone House Road) and place of BEGINNING. Containing 7.281 acres of land as surveyed. BEING THE SAME PREMISES BY DEED FROM REALAND INC., A PENNSYLVANIA COPRORATION DATED 10/01/99 AND RECORDED 1/18/99 IN BOOK 211 PAGE 793 GRANTED AND CONVEYED UNTO JAMES L. MILLER AND STEPHANIE L. MILLER, HUSBAND AND WIFE. TAX PARCEL NO: 21-08-0573-133 BEING KNOWN AS 296 OLD STONE HOUSE, CARLISLE PA 17013 Goldbeck -McCafferty & McKeever BY:.'Michael T. McKeever Attorney I.D. #56129 Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 vs. JAMES L. MILLER JR. STEPHANIE L. MILLER (Mortgagor(s) and Record Owner(s)) 296 Old Stone House Carlisle, PA 17013 Plaintiff Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129 No. 10-378-CIVIL JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., Plaintiff in the above action, by and through an authorized employee of its attorneys, Goldbeck McCafferty & McKeever, sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 296 Old Stone House Carlisle. PA 17013 I.Name and address of Owner(s) or Reputed Owner(s): JAMES L. MILLER JR. e" + _ 296 Old Stonehouse Road c -- Carlisle, PA 17015 -r} r;:1 o STEPHANIE L. MILLER t:. t 296 Old Stonehouse Road ?s (JI t? Carlisle, PA 17015 rs* -:i l rn 2. Name and address of Defendant(s) in the judgment: r--. Q JAMES L. MILLER JR. w 296 Old Stonehouse Road Carlisle, PA 17,015 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE STEPHANIE L.. MILLER 296 Old Stonehouse Road Carlisle- PA 17015 3. Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold: DOMESTIC RELATIONS OF CUMBERLAND COUNTY PO Box 320 Carlisle, PA. 17013 PA DEPARTMENT OF PUBLIC WELFARE - Bureau of Child Support Enforcement Health and Welfare Bldg. - Room 432 P.O. Box 2675 Harrisburg, PA 17105-2675 MID ATLANTIC CO-OP & AERO ENERGY 230 Lincolnway East New Oxford, PA 17350 DRIVEKORE INC P.O. Box 2004 Mechanicsburg, PA 17055 CARLISLE CEMENT PRODUCTS INC. 510 East North Street P.O. Box 617 Carlisle, PA 17013 DISCOVER BANK 3311 Mill Meadow Drive Hilliard, OH 43026 4. Name and address of the last recorded holder of every mortgage of record: NEW CUMBERLAND FCU 345 Lewisberry Road New Cumberland, PA 17070 5. Name and address of every other person who has any record interest in or record lien on the property and whose interest may be affected by the sale: 6. Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property which may be affected by the sale. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale. TENANTS/OCCUPANTS 296 Old Stone House Carlisle, PA 17013 (attach separate sheet if more space is needed) I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: February 23, 2010 GOLDBECK McCAFFERTY & McKEEVER BY: TINAMARIE BOSCHETTI Goldbeck, McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. MILLER JR. STEPHANIE L. MILLER Mortgagor(s) and Record Owner(s) 296 Old Stone House Carlisle, PA 17013 IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Defendant(s) NO. 10-378-CIVIL CERTIFICATION AS TO THE SALE OF REAL PROPERTY I, Michael T. McKeever, Esquire hereby certify that I am the attorney of record for the Plaintiff in this action, and I further certify that this property is subject to Act 91 of 1983 and the Pl has complied with all the provisions of the Act. By: ?-/-w GOLDBF/K MCCAFFERTY & MCKEEVER Michael McKeever Pa. ID 56129 Gary McCafferty Pa. ID 42386 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Attorneys for Plaintiff c? N L"o trs Lh -, C) 0 d rg t-ri W J* 10-378-CIVIL GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRI OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. MILLER JR. STEPHANIE L. MILLER Mortgagor(s) and Record Owner(s) 296 Old Stone House Carlisle, PA 17013 Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Term No. 10-378-CIVIL THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO 0 COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE s 4 USED FOR THAT PURPOSE. - , -n F N ' :rJ r-3 OTICE OF SHERIFF S SALE OF REAL PROPERTY TO: MILLER, STEPHANIE L C m STEPHANIE L. MILLER 296 Old Stonehouse Road w Carlisle, PA 17015 Your house at 296 Old Stone House, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $327,726.15 obtained by JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE .? 10-378-CIVIL To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be tiled by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses. or ways of getting your house back. if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www.pliiiadelphiafed.ory/foreclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle. PA 17013 Ab, 10-378-CIVIL LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 10-378-CIVIL Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website ht!p://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention a,goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 92508FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 10-378-CIVIL GOLDBECK McCAFFERTY & McKEEVER BY: Michael T. McKeever Attorney I.D.#56129 Suite 5000- Mellon Independence Center 701 Market Street Philadelphia, PA 19106 215-825-6318 Attorney for Plaintiff JPMORGAN CHASE BANK, N.A., AS ACQUIRI OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. MILLER JR. STEPHANIE L. MILLER Mortgagor(s) and Record Owner(s) 296 Old Stone House Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE C7 C C G - _ Term C e rt 71 C No 10-378-CIVIL _F' r , . cr tit...' -^i-- E5 -e ° w THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: MILLER JR., JAMES L. JAMES L. MILLER JR. 296 Old Stonehouse Road Carlisle, PA 17015 Your house at 296 Old Stone House, Carlisle. PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 02, 2010, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $327,726.15 obtained by JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL. BANK F.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE 10-378-CIVIL To prevent this Sheriffs Sale you must take immediate action 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A., the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings 4. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty (30) days from the date of the Sheriffs Sale. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are tiled with the Sheriff within ten (10) days after the schedule of distribution is filed. 7. You may also have other rights and defenses, or ways of getting your house back, if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: http://www philadelphiafed. or /fg orecIosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 10-378-CIVIL LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 10-378-CIVIL Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(a,goldbecklaw.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 9250817C. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717.240.6397 Plaintiff/s: Court Number: JPMORGAN CHASE BANK, N.A., AS ACQUIRER 10-378-CIVIL OF CERTAIN ASSETS AND LIABILITIES OF Expiration Date: WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION Type of Action: ACTING AS RECEIVER "/ A WASHINGTON WRIT OF EXECUTION - and STEPHANIE L. MILLER Serve Upon: JAMES L. MILLER JR. and STEPHANIE L. MILLER Address for Service: 296 Old Stone House Carlisle, PA 17013 Alternate Address for Service: 296 Old Stone House Carlisle, PA 17013 Type of Service: r Personal Adult in Charge r Deputize f Certified Mail Wo Posting (copy of court order required) Special Service Instructions: PLEASE POST HANDBILL **If service is to be made by deputized service to another county please specify which County Filing Attorney's Information: Name: Goldbeck McCafferty & McKeever Address: Mellon Independence Center 701 Market Street Suite 5000 Philadelphia, Pa 19106-1532 Telephone: 215-627-1322 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) N010-378 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMorgan Chase Bank, N.A. as acquirer of certain assets and liabilities of Washington Mutual Bank from the Federal Deposit Insurance Corporation acting as receiver f/k/a Washington Mutual Bank F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff (s) From James L. Miller, Jr. Stephanie L. Miller (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 $327,726.15 L.L. $.50 Interest from 02/24/2010 to date of sale per diem at $36.99 Atty's Comm % Due Prothy $2.00 Atty Paid $181.90 Plaintiff Paid Other Costs Date: 3/5/2010 (Seal) Da-. Buell, Pr onotary By: Deputy REQUESTING PARTY: Name Thomas Puleo, Esq. Address: Goldbeck McCafferty & McKeever Suite 5000 - Mellon Independence Center 701 Market St. Philadelphia, PA 19106 Attorney for: Plaintiff Telephone: 215-627-1322 Supreme Court ID No. 27615 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson (~F ~~ ~'`~ ~1~` ~i 1!a,~Y Sheriff Jody S Smith ~' ~ 20i~j I~~ -y ~,'~ $~ 2~ Chief Deputy '~ ~~~: ,:~ ~~; :~ , Edward L Schorpp CU~~ . ' ~:~ i_ ~ ~..~~~L`t •a~' Solicitor r,K~,cE.-r T~~ ~~EN~~~ '~'~ ~ V~`s..~ff%~'~ir'~ JP Morgan Chase Bank, NA vs. James L. Miller, Jr. (et al.) Case Number 2010-378 SHERIFF'S RETURN OF SERVICE 04/21/2010 10:41 PM -Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on 4/21/10 at 2240 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 James L. Miller Jr. and Stephanie L. Miller, located at, 296 N. Old Stonehouse Road, Carlisle, Cumberland County, Pennsylvania according to law. 04/24/2010 11:45 AM -Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on 4/24/10 at 1145 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: Stephanie L. Miller, Jr., by making known unto, Stephanie Miller, personally, at, 296 N. Old Stonehouse Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy o1 the same. 04/24/2010 11:45 AM -Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on 4/24/10 at 1145 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: James L. Miller, Jr., by making known unto, Stephanie Miller, Spouse, at, 296 N. Old Stonehouse Road, Carlisle, Cumberland County, Pennsylvania its contents and at the same time handing to her personally the said true and correct copy of the same. 06/01/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that this writ is returned STAYED, per letter of instruction from Attorney McKeever on 5/29/10 SHERIFF COST: $1,286.96 June 02, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF . S7~ a ~- ~Zfi 7~~~ ,~` ~~ 3 ~-~ ,( (cj GountySuite Sheriff, Teleosoft. Inc. t Cii~ldh~ck !~1cC'cf~Ccri~ ;`:_ '.1~K~•c~~cr A[tor-nev I.U. ==>612~) Suite x(11)(1 - Mellen Iiul~~hendence Center 7r; I n~a~->;~:~ S(,-~~, Philadelhlua_ PA 1 ~) I U(, 21 ~-62%-l 3~~ Attorney tier Plaintiff JPMORGf\N CIiAS}=: E3ANK, N.A., AS ACQUIRER OF~ CEK"[~AIN ASSE"1~S AND LIABILITIES OF ~'VASIIING"1'ON Mtl"11JAL BANK FROM "hHE FI=DERAL DI~:POSI~~ 1NSURANCh. CORPORA'I~ION ACTING AS KECEIVI~.R FIK!.A WASHINGTON MU1~L`.1L BANK I=..~_ 72„ Bavmeado~rs ~~ a~ Jacksonville. hL 32~(, Plaintilt~ vs. JAMES L. MILLER .IR. ST'LPI-IANIE L MILI_I:K (R9ortgagor(s) and Record O~~~ner(s)) 296 Old Stone I-Fuse Carlisle, PA 17013 Defendant(s) AFFIDA~'1T PURSUAV"1' TO RULE 3129 No. 10-37~-CIVIL JPMORGAN CIi%ASf~: BANK. N.A.. AS ACQUIRER OF CERTAIN ASST:"I~S ANU L1A131L1711~5 OF ~~%ASHINGTUN t~~lU~fl!:A[ BANK 1 RO~~I l HL= IEDI-RAL DE.PUSIT 1NSURANCL CC)RNOR:A~IIUN -\Cl~1N(; =~S REC1-:I~'1R 1 K: A ~~~.=\SIiING"I C)N [~1i1"IUAL B:~NK F.A.. Plaintiff in the above action. by and thmu~~h un authorized emplcwee ul~ its atti~rre~._ Guldberk ;McCafferty ~`~ McKee~rr, sets forth as of the date the praccipe f~c~r the ~~~ri~ c~(esecution ~~as filed the li~llo«in~ inf~orncatiun concerting the real hropert~~ located at. ?y6 O]d Slone I~otse Carlisle_ PA 170li l.Name and addre>s of(h~ner(s) or Reputed (h~°ner(s): J.ARIF:S L. ~~1li.l_{:R .1R. '9(> Uld Stcnu~housu Road Carlisle. PA 1701 SI1-:PIi:-\NIF I_ MILLER ?96 Uld Stc~nehouse Road Carlisle P:1 1?015 2. Name and address cif I)ciendant(s) in the judgment. 1AMFS I_. MiLL.ER.1R. 296 Old Storehouse Road Carlisle_ P.A 170{ IN "hHE CUUR"h (>F COf~1MUN PLEAS of Cumberland Count}~ C1VII_ AC"LION - L.AW ACTION OF MORTGAGI~: FORECLOSUKE S7TPi-IANIE L. MILLLK ?96 Old Storehouse Road Carlisle. P,A 17(1 I ti I! '~amc and last kno~~~n address,oirver~ judgment rr~~lit~_~r .~li,~,~ ~u~l~_ni~ut i~ _i rc~~~r~i lien ~~n lh~ proE~rrt~ io h~ gold: DOi~~it-SI~IC IZI:L.V 1lONti OE Cl ~\IIiFRL:AND COl'V"f~~ PO Box 320 Carlisle. PA 1701 PA DEPARTMI:NI~ Of~ Pi!BLiC \1~ 1 I.I:~~RI~ - Bureau of Child Support Ent~nccment Health and ~Vcll~ire Bld~~. -Room ~_~? P.O. Box 2fi7~ Harrisburg. PA 1710-Z(,7~ N1ID A"FLANTIC CO-UY ~ :AFRO INI.R(_;l~ 230 Lincohiwav East Ne~~~ Oxford. PA 173~U DRI~~'EKORE INC P.O. Box 2004 hlechanicsbur~z_ PA 1?U„ CARLISLE CEMENT PRODliCI S II~'<~. 510 East North Street P.U. Box 617 Carlisle. PA 17013 DISCOVER BANK 3311 Nlili Meado~~ Dri~~e Hilliard. OH 43026 4. Name and address of the last recorded holder of ererv nunt~~a~~e of record: NE~V CUMBL-RI_ANll FCl! 34~ Le~~~isben-y Road Ne~~ Cumherland. P:A I ?0?U >. Name and address of every other pe~srn~ ~~~~ho ha: anv record inters ~t in or record lien on the property and whose interest niav be at7ected by the sale: ~~. Name and address of every other person of ~rhom the plaintiff hay hnowlyd<~c ~~~ho has anv record interest in the property ~~~hich may be affected by the sale. .. Name and address of everv other person uf~rhom the plaimiffha~ hn~~~~~lcd~~e rho ha. an~~ interest in the propcity ~~~hi~h ma~~ be affected by the sale. ~I~L-NAN~fS-OCCUI',aN~1S 296 Old Stone ]louse Carlisle. PA 17013 (attach separate sheet i1 more space is needed) 1 verify that the statements made in this affidavit ure true and correct to the best of my personal knowledge or information and belief. I underst~md that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relatin~~ to unsworn falsil7cation to authorities. ~~i DA"fED: I~ebnlar ~ 23 210 GOLUBECK McCAFEER~TY & McKEE~'ER B1" "1'INAI~1ARl}? BOSCHETTI r io-~~~-Ci~~<<. C;OLDBI;.CIi ~IcC:Ai=I~ER~I'l~ & 11rKEE~~ER Bl`: Michael 7~.~~'1cKee~~er Attoruc~ LD.r>~~129 Suite >1)Illi- h~lelk~n hulependcnce Center ?01 1vlarket Street Philadelphia. P:~ 19106 1 >-~?~-fi3 I R Auornev fur PlafntiLf~ JPMORGAN CIIASC~ I3,~~NK. N.,~., AS AC(~)UIRF. OI~ C'I:RTAIN ASSF:"I~S ANI) LlAI3[L1"1'II.'S OF WASHING"CON h-1UI~U:~L BANK FROI~1 ~CIIE FC:[)I~:RAL DI~:POS1"f [NSURANCE COIZPOR~~~T1ON AC~17NG AS RI~:CEIVER I-`'KiA WASI lIN("ION ~9l_il~l!AL BANK F.A. 72» I3a~ mcado« ; ~~'a~~ .tacksom ille, hL 3226 IN 7~I~E LOUR"T OF COI~~?~9ON PLEAS of Cumberland County CIVIL. AC"LION - I.A~~' Plaintiff ~ ~. .LAMES L. MILLER .IK. S"1'IPI[ANTI L. M1LLC:R 1\7ortl;a~or(s) and Record O~~~ner(s) 296 Old Stone I-louse Carlisle. P:~ 17013 Del~cndant(s ACTION OF MOR7~GAGF. FORECLOSURE "f crn~ No. ]0-378-CIVIL 7~HIS L.~~~~ FIRI~1 IS A Dl?BT COLLEC"hOR AND WE ARE :~"1°Ch:~1P"LING TO COI.LI~:C~C A llH:6"1-. ~1~1IIS NU7~ICE IS SI:N"h 7Y) 1°OU IN ,1N A"I~Th:~1P~h TO COLLEC'1~ :1 llE.6"T. ANY [NEOKI'IA"LION OBT.~INEll FR0~1 YOC; ~~~ILL BE I~SEll FOR'I'fIAT PURPOSE. N01'ICE OF Sl1ERIFH'S 5:1LE OF REAL PROPF.I2TY 1O: ~iII LI:RJK..Jr\~Ik-S L. JAMES L. MILLER JR. X96 (_)Id Stonchouse Road ('arlisle. P.-\ 1701 }'our h~na.e at _'9fi Old Stone Ioouse_ Carlisle. I'-1 17013 is scheduled to be sold at Sheriff's Sale ou b~'cdnesda~~. luny 0"?. 2010_ a~ 10:00 A1~1. in Commissioners Hru-in~ Rm 2nd FL Courthouse to enturce the court judgment of $>27.726. 1 ~ obtained by .IPMURGAN C~IiASE BANK. N.A.. AS ACQUIRER OF Ct=RTA[N ASSEhS ANI~ 1_IABII.1"DIES OF WASHINGTON MU~CUAL BANK FROM 1~FIE FEDERAL UEP(~S17~ ]NSURANCE CORPORA1lON AC"PING; :1S RECh[VER E'Ki~A WASHINGTON MUTUAL BANK 1 _A. a~~ainst vou. NO"TICE OF O~~'NER'S KIGHTS YOU l\9.A~' BE ABLE 7'O PRE~'EN"T TI-115 SIlER1EF'S S:1LE • l~o prevent this Sheriffs Sale you must take im_mc~liat~ acuun: l . The sale L~~ill be cnncellcd it rue par to JI'~~IORGAN CH_~SF I3ANh. N.:y...AS .1L OUIRI~R ~)~ CFR~f:~IN ASSE"I~S AND LI:~E3ILII~IES OF ~~":~SIllNGTON n~l[~~(l~ ~L E3_yNK FROIti~I TILE FEI>ER:~L DIPOS["f INSURANCh CORPURa1~IC)N :~C~1~ING AS lZt_CF~a~`LR I-~K~A 1~`:1SHING~T~UN h1U~ L~AL BANK I=.A.. the back payments. late charges. c<,sts and reasonable attoi7~ev`s fee> due. ~Tu fold out ho~~~ much vuu must par call our utlice at ? } 5-X23-(x,28 ur 1-~~(~~-4I -~? 1 1. ?. ~'ou may be able to stop the sale by iilint* a petition asking the Court to sn~ike or open judgment. it d1e jud~~mcnt ~~~as improperly entered. You ma}~ also ask the Court to postpone the sale fur good cause. 3. You may also be able to ;top the sak through other l~«al proceedings 4. You may need an attor~lev to assert your ri~~hts, l~he ~ooncr ~~uu cont~~ct one. the mine chance you will bare of stopping the sale. (tics notice belo~~~ nn ho~~~ u~ obtain an atu~rney). YOU 1~1AY STILL BE ABLE TO SAVE YOGR PROPERTY ANll YOU HAVE O'I'NER RI[;HTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. if the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-0,390. 2. You may be able to petition the Court to set aside the sale if the bid price tivas grossly inadequate compared to the value of your property. 3. The sale will go through only if the bu}'er pays the Sheriff the toll amount due in the sale. To tied out if this has happened; you may call the Sheriff of 717-240-6390. 4. It the amount due from the l3uver is not paid to the Sherif~l. you ~~~~ill remain the owner of the property as if [he sale never happened. 3. You have a right to amain in the pry>pem until the iull amount due is paid to the Sheriff and the Sheriff giros a deed to the bu}er_ At that true. the hover nriy hrin~a le,~ul proceedings to e~~ict ~~ou. (i. Yon may be entitled to a share uCthe Homey ~yhich was paid for your house. A schedule of distribution of the money bid for your house ~yill be tiled b_v the Sheriff ~i~ithin thirty {3U) days from the date of die Sheriff's Sale. This schedule will ;late ~~~ho will be receiyin~~ that money. The money ~~-ill be paid out in accordance l~l~ith this schedule unless csceptions {reasons lyh}~ the proposed distribution is wrung} arc filed Frith the Sheriff ~yithin ten (! (?) days titter the schedule of distribution is tiled. 7. You may also bare other ri~~ht. and defen;~••. or ~ra_v, of ~cttin~s your house back, ii~ you act immediately after the sale:. K. You may contact the Fureclasure Rcsourre Center: htt~_~~-«_«_phitadel~hiafed.oi~r~tc,rrclgsure,' YOL1 SHOULD "FAKE ll{IS P.~yPER TU l'OUK [_;1~'y'I~;R .Al ONCI~:. IF YOU f~0 NOT HAI~t~ :1 LA~~YER OIZ CANN07~ .AI=FORD ONE GU ~IU UR TILEP}IONE "l~l3E OFFICE I_IS~I ID BI_:L0~1% T(_) F[NU OUf ~1']If~RI~_ l'O[_I CAN GET LI~G.-'~l_ I tl::t_P. CUIv1BERLAND COUNTY BAK ASSO(`(ATION 2 Lihcrty Aycnue Carlisle. PA 17013 I~~-;-~~-(~;~~11. '~ Ir~~in~ Kn~~~ (~arlislr. P:~ I?U1 1 ?-?-4 ;-9-400 C ALL that cerfain trt~ct of land situate in MIDDLESEX TOWNSHIP- Cumberland Count}. Penns~~lvania. being identified as Lot 9 as shown on a plan of lots known as Pheasant Crossing prepared tier Rcalancl. lnc. by Hoover Engineering Services, Inc., dated August l 0, 1998, approved October 7. 199b by the Middlesex Township Board of Supervisors, and recorded November 6,1998 in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 77 on page 128, and being more fully described as follows, to wit: BEGINNING at a point in the centerline of T-591 (Old Stone House Road): thence by Lot 8 of the aforementioned subdivision South 37 degrees 53 minutes 06 seconds West a distance of five hundred twenty-four and ninety-five hundredths (524.95) feet to an iron pin; thence by Lot 8 and by Lot 7 of the aforementioned subdivision South 52 degrees 06 minutes 54 seconds East a distance of three hundred fifty (350.00) feel to an iron pin; thence by Lot 6 of the aforementioned subdivision South 37 degrees ~ 3 minutes 06 seconds West a distance of six hundred .ninety-one and fifty-nine hundredths '(691.59) feet to an iron pin; thence by Lot II of the aforementioned subdivision South SS degree, 1S minutes 00 seconds West a distance of one hundred twenty-seven and eighteen hundredths (127.18) feet to an iron pin; thence by land now or formerly of Robert Line & 1. Edward Clouse North 01 degrees 45 minutes 00 seconds West a distance of seven hwldred seventeen and twenty-three hundredths (7l 7.23) feet to an iron pin; thence by Lot ] 0 of the aforementioned subdivision North 88 degrees 15 minutes 00 seconds East a distance of two hunched sixty and thirty hundredths (260.30) feet to an iron pin; thence by Lot 10 of the aforementioned subdivision North 37 degrees 53 minutes 06 seconds East a distance of five hundred twenty-four and ninety-eight hundredths (524.98) feet to a point in the centerline ofT-591; thence in along and through the centerline of T-591 South 52 degrees OS minutes 24 seconds East a distance of fifty (_50.00) feet to a point in the centerline ofT-591. (Old Stone House Road) and place of BEGINNING. Containing 7.281 acres of land as surveyed. BEING THE SAME PREMISES Bl' DEED FROM REALAND INC., A PENNSYLVANIA COPRORATION DA"['ED 10;01/99 AND RECORDED lll8/99 IN I3O0K 21 1 PAGE 793 GRAN"I~ED AND CONVEYED LiNTO .TAMES L. MILLER AND STEPHANIE L. MILLER. HUSBAND AND WIFE. TAX PARCEL NO: 21-08-0573-133 BEING KNOWN AS 296 OLD STONE HOt1SE, CARLISLE PA 17013 ~, ~ 1O-~~~-CIS"fI. GULUBEt~I: ~IcC.-~h~H~t~:}Z"1~1~ S: ~Ichi;l~;~"I~:FZ BY- ~Iichael'i~. McKcc~~er Attomcti~ I.D_~~h 1 ~~~ Sui~c Si)i)0- ~Itll~~n Independence C~rnicr ?01 Market Strc~ea Philadelphia. PA 1910E r~ttvrne~~ ~in~ Plaintitf JP~1URG~~N ('IIASI~. BANK. N.:1.. AS AC'(1UIIZE OF CF:R~1'AIIy _~SS[~a~S AM) LIABILITIF~:S O}~ WASI IING~i~C)N MU"IU.=~L BANK FRONT ~11IE I~II~IR.-'1L I)1~1'USIT INSUKANCL CORPOKA7~1t )N .~~C7'ING AS RECEIVER F~K-:1 ~~~ASI IINGI~ON MU~I~U,~U~ BANK I.A. 72~~ I3avmcado~~~ ~~'av Jackson ille. FL 322>6 Plaintiff vs. JAMES L. MILLER.IR. S"I'1~PHANIE I,. MILLER Mortal;or(s) and Record O~~~ner(s) 296 Old Stony Fluuse Carlisle. I':1 1?O13 Defatdant(s IN TI-IE COURT OI~ COM~90N PLEAS of Cumberland County CIVIL AC~fIUN - I.A~~ ACTION OF MOR"1'GAGE FORECLOSURE Term No. 10-378-CIVIL 'hHIS I.:~~'1~ FIR~1 IS .~ DI~:BT C011.EC`TOR :AND ~~~E ARE ATTEMPTIN(: "1~0 COI.LI~:C"1~ :~ UI~:B~1 . THIS NOTICE 1S SI~;N7~ 7Y) 1~OU IN AN Al°I'E1lP"I~ ~hO COI,I.F:C"1' ..~ DEB"1'. ANY INFORI~1ATION OBTAINED FROM YOU ~~'ILL BE USED FOR "1'l1AT PUKPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTI' 1 U: b11L1 I~K_ SIEPHAMF f_ STEPHANIE L. MILLER 29f, Uld Stonehuuse Road Carlisle_ P:~ 1701 ~ ~~our house at "29h Old Stone }louse. Carlisle_ PA 1?013 is scheduled to be sold at Sheriff's Sale on ~~'ednrsda~_ lone O2. 2010, at 10:00 .MI, in Commissioners Hearing Rm 2nd FL Courthouse to enforce die court judgnicnt ofS 327,726.15 obtained by.IPMORGAN CHASE BANK. N.A., AS ACQUIRER Of~ CERTAIN .ASSECS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM TIIE FEDERAL DF.POS17~ INSURANCE. CORPORATION ACTING AS RECEIVL-R F~'K!A WASHINGTON MUTUAL BANK F.A. against you. NOTICE OF OWNER'S K1G}ITS 1'OU MAY BE ABLE TO PRE~'EN"1' THIS SHERIFF'S SALE r lei-~~-C~l~~i1. I ~~ 4ireyent this Sheriffs Sale you must take inuncdiatc action L The sale ~~~ill be cancelled if you pay to IY1~~lOK(~.AN CH.-1SE R:~NK. N :A._ :~~~ .ACOUIRLR OF CERT:IIN ASSLI~S .~aNt) LL~IBILI7-1LS OF ~l'ASIIINC;~fON [~~It)TUAL RANK FROA9 17fF_ FEDERAL DLpOSl7~ WSURANCF CORPOKATION .-~C~7~ING :~S RF~_C1:1~%IK FiKA Vd:aSI11NGTON h9U"DUAL RANK F.A.. the beck payments. late charges. costs and reasonable attorney's tees due. To find olit how nnirh you must pa~~ call our office at 21 ~-K~~-hi'9 or I-t;(~(,--413-?ill. 2. You may be able to stop the sale by tiling a petition asking the Court to strike or open judgment. if the judgment ~~~as improperly entered. You may al,o ask dir Court to postpone the sale f~~r ~~ood cause. 3. You may also be able to stop the sale through other ic~anl proceedings. q. ~'ou may need an attorney to assert your ri_~ht:. ~Ilu sooner you contact one. the more chance you will ha~~c of stopping the sale. (See notice bclu~~~ ~,^ ho~~~ to obtain an attorney). YOU 1V'IAY STILL BE ABLE TO SAFE YOUR PROVERTY :1NU YOU HAVE OTNER RIGIITS EVEN IF THE SHERIFF'S SALE DOES N01' TAKE PL.1CE. 1. If the Sheriffs Sale is not stopped. your propert}~ ~~ill he sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-?40-6i9O. 2. You maybe able to petition the Court to set asidr the sale ifthe bid price was grossly inadequate compared to the value of your property. 3. The sale will go tlu-ough only if the buyer pays the Sheriff the fid4 amount due in the safe. To find out if this has happened, you may call the Sheriff of~71?-_'-}0-G;90. 4. if the amount due from the Rover is nod paid to the Sheriff. you ~~~ill remain the o~~~ner of the pmpenv as if the sale never happened. ~. You have a right to remain in the pmpert~~ until the Bill amount due is paid to the Sheriffand the Sherifl~giyes a deed to the buyer.:1t that tinx~_ the huger nni~~ hrin~~ le~~a4 proceedings to e~~ict vou_ 6. ~'ou may be entitled to a sham of the Hume v ~~hich was paid tier your house. A schedule of distrihution of the money bid for your house ~~ill b<• filed h~~ the Sherilt ~~ ithin thirty (30) days from the date of the Sheriffs Sale. This schedule ~~ill state ~yho ~~~ill he recei~ imp that money. The mone~~ will be paid out in accordance ~~~ith this schedule unless exceptions 4 reasons t~~hv the proposed distrihution is tia~rong) are fi4cd with the Sheriff within ten (1O) days ahrr the schedule of disnibutio^ is filed. You may also haee other rights and defense>. or ~~a~~s of grtting your house back. if you act immediately after the sale. K. Y'ou may contact the Foreclosure Resource Centcr~ htt~?:_~~.~~_~~.pliilad~~hiafed.or~~foreclosure' YOU SHOULD ~F:AKE T}I1S P:~PF:R l~0 YUUR L.-1~~~'1~1.1Z ~yl C)N(~4:. ll~ YOLK I)U NUT H.AVI: A LAw'YER OK CANN07- AFFORD ONE. (IU TO OR TEI.EPhIUNE ~1 H}: OFI~ICL LIST f:D BE.:LOw' ~f0 FIND OUT WHERE 1'OU CAN GF:T LK~.~~1 IIELp. CUMBERLAND COUN~h1' R:1R ~\SSOC4ATION Liberty :y~cnur Carlisle. P:A 17U 13 Ii)-~-~-('(\~II LEGAL SLR~'ICLS INC' Ir-cinc Ro~~~ Carlisle. PA 17013 717-243-9400 Iti-,-~-(~(~~1L Resources a~~ailablc liar llome~~~~~ners in Foreclosure .~C:~1~ \O~~'' E~~en though your lender (and our client) has tiled an ~etion of Mortgage Foreclosure against you, you still ma~~ he able to ~:1\'E l"OUR E10!~1E FROM FORECLOSURE. 1). Cal] an attorney. For referrals to a yualiiied attorney call either of the following numbers: or 7 l 7-24 ~-9400. 2j. Call the Consumer Credit Cc,unselin~~ .~~~cnc~ at I-80O-9~9-~~?7 f~~r ii-ee counseling. 3). Visit HUD-S website ~~~w~~~.hucL~o~~ for I lelp for Homeowners I~acin~~ the Loss of Their Homes. ~-~- -- 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA ~~~ebsite http://www.phfa.org/conswners/homeowners!real.as~x. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current. or payoff the mortgage or request a Loan lVurkout ~' Home Retention Package. Call our toll fi-ee number at 1-866-413-231 1 or ~~ia email at homeretention(cc-~oldbecklaw.com. Call Seth at 215-825-6329 or fi-x 2 I ~-825-6420. The figure andior package you requested will be mailed to the address that you request or faxed if you lea~~e a message ~~~ith that infornlation. The attornc~ in charge of our tirm~s }Iome~~~~~ner Retention Department is David Fein who can he reached at ? 15-525-6;18 or Fax: 215-825-6418. Please reterence our Attorney File Number uf92~URFC'. Para information en espanoi puedc communic~u~se con 1_oretta al ? 1>-825-6;44. ALL that certain tract of land situate in MIDDLESEX TOWNSHIP. Cumbei-(and County. Pennsvlvania. being identified as Lot ~) as shown un a plan of lots known as Pheasant Crossing prepared tier Reiland, Inc. by Hoover Engineering Services. Inc., dated August 10, 1998, approved October 7, 1998 by the Middlesex Township Board of Supervisors, and recorded November 6, l 998 in the off ce of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 77 on page l 28, and being more fully described as fi~llows, to ~~~it: BEGINNING at a point in the centerline of T-591 (Old Stone House Road): thence by Lot 8 of the aforementioned subdivision South 37 degrees >> minutes 06 seconds West a distance of five hundred twenty-four and ninety-five hundredths (524.95) feet to an iron pin; thence by Lot 8 and by Lot 7 of the aforementioned subdivision South 52 degrees 06 minutes 54 seconds East a distance of three hundred fifty (350.00) feel to an iron pin; thence by Lot 6 of the aforementioned subdivision South 37 degrees 53 minutes 06 seconds West a distance of six hundred .ninety-one and fifty-nine hunch-edths '(691.59) feet to an iron pin; thence by Lot I I of the aforementioned subdivision South SS degree, ]S minutes 00 seconds West a distance of one hundred twenty-seven and eighteen hundredths (l 27.18) feet to an iron pin; thence by land notiv or formerly of Robert Line & 1. Edward Clouse North Ol degrees 45 minutes 00 seconds West a distance of seven hundred seventeen and twenty-three hundredths (7l 7.23) feet to an iron pin; thence by Lot 10 of the aforementioned subdivision North 88 degrees 15 minutes 00 seconds East a distance of hvo hundred sixty and thirty hundredths (260.30) feet to an iron pin; thence by Lot ] 0 of the aforementioned subdi~~ision North 37 degrees 53 minutes 06 seconds East a distance of five hundred twenty-four and ninety-eight hundredths (524.98) feet to a point in the centerline ofC-591; thence in along and through the centerline ol'T-591 South 52 degrees OS minutes 24 seconds East a distance of fifty (50.00) feet to a point in the centerline ofT-591 (Old Stone House Road) and place of BEGINNING. Containing 7.281 acres of land as surveyed. BEING ~hHE SAME PREMISES BY DEED FROM REALAND INC.. A PF.NNS~'LVAMA COPRORATIUN DATED I U,~O 1 99 AND RECORDED 1 ~ 18;'99 IN BOOK ? 1 1 PAGE 79 ~ GRANTED AND CONVEYED liN"1~0 JAMES L. MILLER AND STEPHANIE L. MILLER. HUSBAND AND WIFE. TAX PARCEL NO: ? 1-O8-U57 ~-133 BEING KNOWN AS ?~)(~ (:)L~D STONE HOUSE CARLISLE PA 17013 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF ~UMB)/RLAND) NO10-378 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMorgan Chase Bank, N.A. as acquirer of certain assets and liabilities of Washington Mutual Bank from the Federal Deposit Insurance Corporation acting as receiver f/k/a Washington Mutual Bank F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff (s) From James L. Miller, Jr. Stephanie L. Miller (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 $327,726.15 L.L. $.50 Interest from 02/24/2010 to date of sale per diem at $36.99 Atty's Comm % Due Prothy $2.00 Atty Paid $181.90 Plaintiff Paid Other Costs Date: 3/5/2010 (Seal) Davi u rothonot ry By: Deputy REQUESTING PARTY: Name Thomas Puleo, Esq. Address: Goldbeck McCafferty & McKeever Suite 5000 -Mellon Independence Center 701 Market St. Philadelphia, PA 19106 Attorney for: Plaintiff Te 1 ephone : 215-627-1322 Supreme Court ID No. 27615 On March 22, 2010 the Sheriff levied upon the defendant's interest in the real property situated in Middlesex Township, Cumberland County, PA, Known and numbered as, 296 Old Stonehouse Road, Carlisle, more fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: March 22, 2010 BY ~~ Real Estate Coordinator S fi ~L ci S - ~J~±f~f 0(OZ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: April 16, Apri123, and Apri130, 2010 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. i~ ~~U`- Lisa Marie Coyne ditor SWORN TO AND SUBSCRIBED before me this 30 da, o~ f April, 2010 J Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 Writ No. 2010-3'78 Civil JP Morgan Chase Bank, NA vs. James L. Miller, Jr. Stephanie L. Miller Atty: Michael McKeever ALL that certain tract of land situate in MIDDLESEX TOWNSHIP, Cumberland County, Pennsylvania, being identified as Lot 9 as shown on a plan of lots known as Pheasant Crossing prepared for Realand, Inc. by Hoover Engineering Services, Inc., dated August 10, 1998, approved October 7, 1998 by the Middlesex Township Board of Supervisors, and recorded November 6,1998 in the of- fice of the Recorder of Deeds in and for Cumberland County, Pennsyl- vania in Plan Book 77 on page 128, and being more fully described as follows, to wit: BEGINNING at a point in the centerline of T-591 (Old Stone House Road); thence by Lot 8 of the afore- mentioned subdivision South 37 de- grees 53 minutes 06 seconds West a distance of five hundred twenty-four and ninety-five hundredths (524.95) feet to an iron pin; thence by Lot 8 and by Lot 7 of the aforementioned subdivision South 52 degrees 06 minutes 54 seconds East a distance of three hundred fifty (350.00) feel to an iron pin; thence by Lot 6 of the aforementioned subdivision South 37 degrees 53 minutes 06 seconds West a distance of six hundred .ninety-one and fifty-nine hundredths `(691.59) feet to an iron pin; thence by Lot II of the aforementioned subdivi- sion South SS degree, IS minutes 00 seconds West a distance of one hundred twenty-seven and eighteen hundredths (127.18) feet to an iron pin; thence by land now or formerly of Robert Line 8s 1. Edward Clouse North O1 degrees 45 minutes 00 seconds West a distance of seven hundred seventeen and twenty- three hundredths (717.23) feet to an iron pin; thence by Lot 10 of the aforementioned subdivision North 88 degrees 15 minutes 00 seconds East a distance of two hundred sixty and thirty hundredths (260.301 feet to an iron pin; thence by Lot 10 of the aforementioned subdivision North 37 degrees 53 minutes 06 seconds East a distance of five hun- dred twenty-four and ninety-eight hundredths (524.98) feet to a point in the centerline off-591; thence in along and through the centerline of T-591 South 52 degrees 05 minutes 24 seconds East a distance of fifty (50.00) feet to a point in the center- line off-591 {Old Stone House Road and place of BEGINNING. Containing 7.281 acres of land as surveyed. BEING the same premises by deed from Realand Inc., a Pennsyl- vania Coproration dated 10/01/94 and recorded 1 / 18/ 99 in Book 211 Page 793 granted and conveyed unto James L. Miller and Stephanie L. Miller, husband and wife. TAX PARCEL NO: 21-OS-0573- 133. BEING KNOWN AS 296 OLD STONE HOUSE, CARLISLE PA 17013. - 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 7cJle ~latriot-News Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Miller, being duly sworn according to law, deposes and says: That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 812 to 818 Market Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Metro editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION COPY This ad ran on the date(s) shown below: 04/16/10 04/23/10 ~_.,... ^, 04/30/10 Sworn to and bscribed before me th~8 day of May, 2010 A.D. ', _ 4 . , , No ary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sherrie L Ktsner, Notary Public Lower Paxton Twp., Dauphin County My Commfssfon Expires Nov. 26, 2011 Member, Pennsvivania Association of Notaries WHt tdo. 201Q378 ChrN Tirm JP Mtxpsn Chw Barely NA Vs. James L. Miller, Jr. Stephanie L. Miller Arty: MlcFtael MciCeeyer ALL THAT CERTAIN tract of land situate in MIDDLESEX TOWNSHIP, C~mberlandCounty, Pennsylvania, being identified as Lot 9 as shown on a plan of lots known as Pheasant Crossing preparedforRealand,Inc. by HooverEngineering Services, Inc., dated August 10,1998, approved October 7, 1998 by the Middlesex Township Board of Supervisors; and recorded November 6,1998 in the office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Plan Book 77 on page 128, and being more full y described as follows, to wit: BEGINNING at a point in the centerline of T-591 (Old-stone House Road); thence by Lot 8 of the aforementianed,subdivision South 37 degrees 53 minutes 06 seconds West a distance of five. hundred twenty-four and niooty-five hundredths (524.95). feet to an iron pin; thence by Lot 8 and. by Lot 7 of the aforementoned subdivision South 52 degrees 06 minutes 54 seconds East a distance of tlueehundred fifty (350.00} feel to an iron pin; thence,by Lot 6 of the aforementioned subdivision South 37 degrees 53 minutes 06 seconds West a distance of six hundred .ninety-one andfifty-nine hundredths `(691.59) feet to an iron pin; thence by Lot II of the aforementioned subdivision South SS degree, I5 minutes 00 seconds West a distance of one hundred.. twenty-seven and eighteen hundredths (127.18) feet to an iron pin; thence by land now or formerly of Robert Line & 1. Edward Clouse North Ol degrees 45 minutes 00 seconds West a distance of seven ,'hundred seventeen and twenty-three hundredths (717.23) feet to an iron pin; thence by I,ot 10 of the aforemen6oced subdivision North 88 degrees }5 minutes 00 seconds East a distance of two hundred sixty and thirty hundredths (260.30) feet to an iron pin; thence by Lot 10 of the aforementioned subdivision North.37 degrees 53 rpinutes 06 seconds`East a distance of Sve hundred tweuty-#our and ninety-eight 1undredths (524.98} feet to apoint urthe centerliaeoff--591; thence in along and though the centerline of T- 5915outh52degrees QSminutes 24 seconds East a distance of fifty (50.00) feet to a point in the centerline ofT--591 (Old Stone House Road) sad place ofBEGINNING. Containing 7.281 acres of land as surveyed. BEING THE SAME PREMISES BY DEED PROM REALAND INC., A PENNSYLVANIA COPRORATION DATED 10/01!99' AND RECORDED 1115/99 ]N BOOK Zl i PAGE 793 GRANTED AND.WNVEYED UNTO JAMES L. MILLER AND STEPHANIE L. MII.LER, HUSBAND AND WIFE. TAX PARCEL NO; 21-08-0573-133 aEaJG.KNOWNAS 296oLD sTONEHOUSE, CARLISLE PA 17013 GOLDBECK McCAFFERTY ~ McKEEVER BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff ~ ..r-, ~-~~. ~tLEt~....;;; r~ iti~~ .Y ~, °: 2010.3U~ -2 P~ ~~ U3 CUFF'' ,. ~:;~~ ~ ~JN~Y ~C1 J~v`~ f`~V't`,',~'e! JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/WA WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 Plaintiff vs. JAMES L. MILLER JR. STEPHANIE L. MILLER 296 Old Stone House Carlisle, PA 17013 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 10-378-CI VI L PRAECIPE TO VACATE JUDC3~~NT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. MICHAEL T. MCKEEVER, ESQUIRE ~~~~ ~3li31 j GOLDBECK McCAFFERTY & McKEEVER ATTORNEY FOR PLAINTIFF BY: Michael T. McKeever Attorney I.D. #56129 Suite 5000 -Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-825-6321 If !!lam C~..~~rli~'";I('~TRRI 2010 Jt,~L -2 P~ ~~ l~~ t~Ci ~~ti~'t'Ltrr+.I~~~1 JPMORGAN CHASE BANK, N.A., AS ACQUIRER OF CERTAIN ASSETS AND LIABILITIES OF WASHINGTON MUTUAL BANK FROM THE FEDERAL DEPOSIT INSURANCE CORPORATION ACTING AS RECEIVER F/K/A WASHINGTON MUTUAL BANK F.A. 7255 Baymeadows Way Jacksonville, FL 32256 vs. JAMES L. MILLER JR. STEPHANIE L. MILLER 296 Old Stone House Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 10-378-CIVIL PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended upon payment of your costs only. ~~~ Michael T. McKeever, Esquire Attorney for Plaintiff