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Home My WebLink About10-1603Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit #7 26074CFC-DD Attorney for Plaintiff Secane, PA 19018 (610) 328-2887 Attorney I.D. #52634 THE HUNTINGTON NATIONAL BANK, AS TRUSTEE FOR FRANKLIN MORTGAGE ASSET TRUST 2009-A 101 Hudson Street 25th Floor Jersey City, NJ 07302 PLAINTIFF V. KENNIE JAMISON, JR. 3789 Spring Road Carlisle, PA 17013 AND UNITED STATES OF AMERICA c/o UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA William J. Nealon Federal Building and Courthouse 235 N. Washington Ave., Suite 311 Scranton, PA 18503 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 10 - 1W3 0,'%, i ( -reran DEFENDANTS CIVIL ACTION - MORTGAGE FORECLOSURE n N _ rn ? t Fn P 3 C? : ca C') You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta a sentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea a visado que si usted no se defiende, la corte toma ra medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades o otros de rechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO VAYA EN PERSONA O TELEFONA A LA OFICINA ESCRITA ABAJO. ESTA OFICINA LE PUEDE PROVEER INFORMACION SOBRE COMO CONTRATAR A UN ABOGADO. SI USTED NO TIENE EL DINERO SUFICIENTE PARA CONTRATAR A UN ABOGADO, LE PODEMOS DAR INFORMACION SOBRE AGENCIES QUE PROVEEN SERVICIO LEGAL A PERSONAS ELEGIBLE PARA SERVICIOS A COSTO REDUCIDO O GRATUITO CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 800-990-9108 V *Qa. oD P A AT r-4 0-yo --,As 19 P`r4.1;WY97 THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED MAY BE USED FOR THAT PURPOSE IF THIS IS THE FIRST NOTICE THAT YOU HAVE RECEIVED FROM THIS OFFICE, BE ADVISED THAT: PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT, 15. U.S.C. §1692, et seq. (1977), DEFENDANT(S) MAY DISPUTE THE VALIDITY OF THE DEBT OR ANY PORTION THEREOF. IF DEFENDANT(S) DO SO IN WRITING WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL OBTAIN AND PROVIDE DEFENDANT(S) WITH WRITTEN VERIFICATION THEREOF; OTHERWISE, THE DEBT WILL BE ASSUMED TO BE VALID. LIKEWISE, IF REQUESTED WITHIN THIRTY (30) DAYS OF RECEIPT OF THIS PLEADING, COUNSEL FOR PLAINTIFF WILL SEND DEFENDANT(S) THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR, IF DIFFERENT FROM ABOVE. THE LAW DOES NOT REQUIRE US TO WAIT UNTIL THE END OF THE THIRTY(30) DAY PERIOD FOLLOWING FIRST CONTACT WITH YOU BEFORE SUING YOU TO COLLECT THIS DEBT. EVEN THOUGH THE LAW PROVIDES THAT YOUR ANSWER TO THIS COMPLAINT IS TO BE FILED IN THIS ACTION WITHIN TWENTY (20) DAYS, YOU MAY OBTAIN AN EXTENSION OF THAT TIME. FURTHERMORE, NO REQUEST WILL BE MADE TO THE COURT FOR A JUDGMENT UNTIL THE EXPIRATION OF THIRTY (30) DAYS AFTER YOU HAVE RECEIVED THIS COMPLAINT. HOWEVER, IF YOU REQUEST PROOF OF THE DEBT OR THE NAME AND ADDRESS OF THE ORIGINAL CREDITOR WITHIN THE THIRTY (30) DAY PERIOD THAT BEGINS UPON YOUR RECEIPT OF THIS COMPLAINT, THE LAW REQUIRES US TO CEASE OUR EFFORTS (THROUGH LITIGATION OR OTHERWISE) TO COLLECT THE DEBT UNTIL WE MAIL THE REQUESTED INFORMATION TO YOU. YOU SHOULD CONSULT AN ATTORNEY FOR ADVICE CONCERNING YOUR RIGHTS AND OBLIGATIONS IN THIS SUIT. IF YOU HAVE FILED BANKRUPTCY AND RECEIVED A DISCHARGE, THIS IS NOT AN ATTEMPT TO COLLECT A DEBT. IT IS AN ACTION TO ENFORCE A LIEN ON REAL ESTATE. Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit #7 Secane, PA 19018 (610) 328-2887 Attorney I.D. #52634 THE HUNTINGTON NATIONAL BANK, AS TRUSTEE FOR FRANKLIN MORTGAGE ASSET TRUST 2009-A 101 Hudson Street 25th Floor Jersey City, NJ 07302 PLAINTIFF V. KENNIE JAMISON, JR. 3789 Spring Road Carlisle, PA 17013 AND UNITED STATES OF AMERICA c/o UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA William J. Nealon Federal Building and Courthouse 235 N. Washington Ave., Suite 311 Scranton, PA 18503 DEFENDANTS 26074CFC-DD Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. CIVIL ACTION - MORTGAGE FORECLOSURE THIS IS AN ATTEMPT TO COLLECT A DEBT ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE 1. Plaintiff is The Huntington National Bank, as Trustee for Franklin Mortgage Asset Trust 2009-A, a bank organized and existing under state law, with offices for the conduct of business at 101 Hudson Street 25th Floor, Jersey City, NJ 07302. 2. Defendant, Kennie Jamison, Jr. is the mortgagor and real owner of premises 3789 Spring Road, Carlisle, PA 17013, hereinafter described, whose last known address is listed in the caption. 3. The United States of America is made a defendant herein by virtue of certain federal tax liens, hereinafter described, which stand against the defendants, Kennie Jamison, Jr. and the United States of America, pursuant to 28 U.S.C. Section 2410. 4. Plaintiff brings this action in mortgage foreclosure against defendant, mortgagor, and real owner, to foreclose a certain indenture of mortgage made, executed and delivered by the above named defendant, mortgagor, and real owner to Mortgage Electronic Registration Systems, Inc., as Nominee for Wilmington Finance, Inc., on December 15, 2006 which mortgage is recorded on December 19, 2006 in the Office of the Recorder of Deeds of Cumberland County in Record Book 1976, Page 3618, secured on premises 3789 Spring Road, Carlisle, PA 17013 a true and correct description of which is attached hereto as Exhibit I. 5. Plaintiff is now the legal owner of the mortgage and is in the process of formalizing an assignment of the mortgage into recordable form. 6. Plaintiff alleges each and every term, condition and covenant in the aforesaid mortgage, and hereby incorporates them herein by reference thereto. 7. The aforesaid mortgage is in default in that monthly installments of principal and interest have not been made in conformity with the terms of the mortgage, from October 2009 and each month thereafter, up to and including the present time. 8. Under the terms of the aforesaid mortgage, upon default of payments set forth in the mortgage documents, the entire principal balance and all interest due thereon are collectible forthwith. 9. The following is an itemized statement of the amount due plaintiff under the terms of the aforesaid mortgage: Principal Balance $ 112,192.44 Interest from 9/1/2009 to 3/2/2010 at $28.43 per diem $ 5,202.69 Accrued late charges $ 235.30 Corporate Advances $ 25.00 Attorney's Fee $ 5,609.62 Title Information Certificate $ 515.00 Escrow Balance $ (2,920.78) Total $ 120,859.27 10. The attorney's fees set forth above are in conformity with the mortgage documents and Pennsylvania Law and will be collected in the event of a third party purchaser at Sheriffs sale. If the mortgage is reinstated prior to the Sheriffs sale, reasonable attorney's fees will be charged based on work actually performed. 11. The defendant United States of America is the holder of a federal tax lien against the defendant, Kennie Jamison, Jr. as follows: Federal Tax Lien# 2009-05954, in the amount of $6,157.62, lodged with the Prothonotary of the Court of Common Please of Cumberland County on August 31, 2009. 12. The above lien, lodged by the District Director of the Internal Revenue Service at Cumberland, Pennsylvania, is against Kennie Jamison, Jr., defendant, mortgagor and real owner herein. 13. A judicial sale of the premises is intended. 14. Plaintiff sent to defendants, mortgagors and real owners a combined Notice and Warning of Intention to Foreclose and Notices of Homeowners' Emergency Mortgage Assistance Act of 1983 advising of rights available under the statutes. To date payments have not been received and Act 91 assistance has not been granted, although the applicable time periods provided by statute have expired (Exhibit II). WHEREFORE, plaintiff demands judgment for foreclosure and sale of the mortgaged premises in the amount of $120,859.27, plus per diem interest at $28.43 from March 3, 2010 to the date of judgment plus costs thereon. Martha E. Von Rosenstiel Attorney for Plaintiff VERIFICATION MARTHA E. VON ROSENSTIEL, ESQUIRE, of full age, verifies that she is the attorney for the plaintiff in the foregoing action; that she is authorized to make this verification on behalf of plaintiff; and that the statements made in the foregoing Complaint in Mortgage Foreclosure are true and correct to the best of her knowledge, information and belief. This verification is being executed by the attorney for plaintiff in accordance with Pa R.C.P. 1024( c ) as a signed verification could not be obtained by plaintiff within the time allowed for filing of the pleading. I understand that false statements herein are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to authorities. Martha E. Von Rosenstiel Attorney for Plaintiff LEGAL DESCRIPTION ALL THOSE two certain tracts of land situate in Middlesex Township, Cumberland County, Commonwealth of Pennsylvania, bounded and described as follows, to wit: TRACT NO. 1 BEGINNING at a point in State Route 34 at lands now or formerly of Stephen V. Shearer and Barbara J. Shearer; thence alo9ng said State Route 34, North 51 degrees East, a distance of 76 feet to a point in said State Road; thence along same, North 53 degrees East, a distance of 99.75 feet to an iron pin; thence along lands now or formerly of Oscar W. Eslinger, South 30 degrees 22 minutes East a distance of 103 feet to an iron pin; thence along same, South 07 degrees 50 minutes East, a distance of 116 feet to an iron pin; thence along land now or formerly of Jill E. Mogel, now known as Jill E. Morrell, married woman, South 81 degrees 05 minutes West, a distance of 164.10 feet to an iron pin; thence along land now or formerly of Stephen V. and Barbara J. Shearer, North 20 degrees, 02 minutes West, a distance of 133.5 feet to the place of beginning. CONTAINING 0.72 acre, more or less. TRACT NO.2 BEGINNING at stones corner of lands now or formerly of Oscar W. Eslinger and lands now or formerly of Thompson Heirs; thence along lands now or formerly of Thomas Heirs, South 82 degrees 45 minutes West, a distance of 128 feet to an iron pin; thence along other lands now or formerly of Stephen V. and Barbara J. Shearer, North 20 degrees, 02 minutes West, a distance of 170 feet to an iron pin; thence along land now or formerly of Jill E. Mogel, now known as Jill E. Morrell, a married woman, North 81 degrees 05 minutes East, a distance of 164.10 feet to an iron pin; thence along lands now or formerly of Oscar W. Eslinger, South 07 degrees 50 minutes East, a distance of 170 feet to the place of beginning. CONTAINING 0.56 acre, more or less. TAX PARCEL #21-04-0373-022 P FRANKUNCRFDIT ._. _..M?....._.._._...... QlNINI CVIIMRAH VM' 11MMM11Kennie M Jamison Jr 3789 Spring Road Carlisle, PA 17013 (Rev. 912008) Date: January 7.2010 ACT 91 NOTICE TAKE ACTION TO SAVE YOUR HOME FROM FORECLOSURE LA NOTIFICACIO'N EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL CONTENIDO DE ESTA NOTIFICACIO'N OBTENGA UNA TRADUCCIO'N INMEDIATAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDE SER ELEGIBLE PARA UN PRE'STAMO 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. D(HI811' 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 Snd a lawyer. Pgge two HOMEOWNER'S NAME(S): PROPERTY ADDRESS: LOAN ACCT. NO.: ORIGINAL LENDER: CURRENT LENDER/SERVICER: Kennie M Jamison Jr 3789 Spring Rd Carlisle, PA 17013 0002467008 Wilmington Franklin Credit Management Corporation HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM 0002467008 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 NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT' EXPLAINS HOW TO BRING YOUR MOKLIUMil;' Ur 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, 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 temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA and received within thirty (30) days of your face-to-face meeting with the counseling agency. YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A.MEETING WITH A COUNSELING AGENCY WITHIN 33 DAYS OF THE POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH PHFA WITHIN 30 DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR PROPERTY, AS EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE." YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED. Pige three 0002467008 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 Emergenc Mortgage Assistance. HOW TO CURE YOUR MORTGAGE DEFAULT (Bring it up to date): NATUR&Qj THE DEFAULT - The MORTGAGE debt held by the above lender on your property located at: 318 pnng Carlisle, FA 17613 IS SERIOUSLY IN DEFAULT because: A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months and the following amounts are now past due: (a) Monthly payments from 10101 /2009: (b) Late charge(s): (c) Other charge(s): NSF and Advances (d) Less: Credit Balance (e) Total amount required as of 01/0612010: $4,340.16 $141.18 $0.00 $0.00 $4,481.34 HOW TO CURE THE DEFAULT - You may cure this default within THIRTY (30) DAYS from the date of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS $4,481.34 PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES (and other charges) WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments must be made either b cash cashier's check certified check or money order made payable and sent to: Franklin Credit Management Corporation PO Box 620444 Indianapolis, IN 46262-0444 IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAYS of date of this Notice, the leader intends to exercise its eight 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 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 mortgaed pro er . IF THE MORTGAGE IS FORECLOSED UPON - The mortgaged property will be sold by the Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even if they exceed 550.00. Any attorney's fees will be added to the amount you owe the lender, which may also include other reasonable costs.If you care the default within the THIRTY (30) DAY period You will not be required to nay attorney's fees. OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. DAY period and foreclosure proceedings have begun, - If you have not cured the default within the THIRTY (30) EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a Sheriffs Sale of the mortgaged property could be held would be approximately five (5) months from the date of this Nodce.A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at any time exactly what the required payment or action will be by contacting the lender. Page four HOW TO CONTACT THE LENDER Name of Lender: Address: Telephone Number: Fax Number: Contact Person: E-mail Address: Loss Mitigation Department: Website: Franklin Credit Management Corporation 101 Hudson Street 25th Floor Jersey City, NJ 07302 1-800-650-7162 1-201-839-4545 James Volinski lossmitigation@fianklincredit.com 1-800.650-7162 www.franklincredit.com 0002467008 EFFECT OF SHERIFF'S SALE - You should realize that a Sheriffs Sale will end your ownership of the mortgaged property and your right to occupy it_ If you continue to live in the property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time. ASSUMPY[ON OF MORTGAGE - You may not sell or transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are satisfied. YOU MAY ALSO HAVE THE RIGHT: • TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEBT. • TO HAVE THIS 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 CAN BE FOUND ON PAGES 5-7. Franklin Credit Management Corporation is attempting to collect a debt, and any information obtained will be used for that purpose. Federal law gives you thirty days after you receive this letter to dispute the validity of this debt or any part of it. Unless you dispute the debt within that 30 day period, we will assume that it is valid. If you notify as in writing at the address below within the thirty day period that the debt, or any portion thereof, is disputed, we will: 1) Provide to you verification of the debt or a copy of any judgment entered against you. 2) Provide to you the name and address of your original creditor, If the original creditor is different from the current creditor. Sincerely, Franklin Credit Management Corporation 101 Hudson Street 25th Floor Jersey City, NJ 07302 Indicates Counties Serviced Acorn Housing Corporation 846 North Broad Street Phlladelphia, PA 19130 (215) 785.1221 'Bucks, Chester, Delaware, Montgomery, Philadelphia Action Housing Inc 425 88r Avenue, Suite 950 PI11"ll, PA 15219 (412) 291-2102 `AUghsny. Seaver, Buller, Fayette, Greene, Washngam.Wasmwrstsnd Adam County haeklatih Housing Authority 40 E High Steal Gettysburg, PA 17325 (717) 3341018 'Adams, Cumberland, Franklin, York Advocates for Financial Independence 1808 S Broad Street Suite 18 Philadelphia, PA 19145 (215) 389-2510 'Phlledeiphle Advocates fox Financial ndepaabnce 202 East Hinkley Avenue Ridgy Park, PA 19078 (215)389.2810 'Delaware Allegheny County Acom 5907 Penn Avenue, Suite 300 Pittsburgh, PA 15206 (412) 441-41551 `Allegheny Arnwicen Credit Counw irg Iretkute 218 Church Skeet West Chaster, PA 193W (8M) 212.6741 'Cheater Arnwkmn Credit Couseling Institute 526-M Dskalb Street Norristown, PA 19401 (610) 971-2210 (5511) ,02-67411 'Montgomery. Delaware American Credit Coureeling nWtule 530 W Street Rood. Suite 201 Ww & stor, PA 18904 (215) 4449429 (8M) 212-6741 'Bucks, Mongorrery, Philadelphia American Credit Courasling Institute 937 North Hanover Street Popstoan,PA 19460 (M)2124741 'Berke, Budas. Montgomery American Credit Counseling Institute 229 East Chasm SYaet Coatesville, PA 19320 (888)212-0741 -Chester, Lancaster American Finencai Counss6ng Services 871 N. Eason Road Glrlelde, PA 19096 (287) 22&7903 "MiSn American Financial Counseling Services 28M Bergey Road Suits 4 Hatfield, PA 19440 (267)228.7903 'Barks, Chester, Montgomery American Fhancia Counseling Servkxre 175 Strafford Avenue, Suits One Wayne, PA 19087 (810)971.2210 (888)212.8741 'Buda, Chester. Delmore, Mongomery, Phitedelphle Anakm Finsnaat Counseling Sormas 908 Penn Avenue Wyomissing. PA 19610 (267)225-7903 (800) 4903039 'Sartre American Fnw¢ial Counseling Services 871 N. Eason Road GlerWde, PA 19038 (287)220.7903 .wry American Financial Counseling Services 1917 Welsh Road Philadelphia, PA 19115, PA 19610 (267) 22&7903 'Bucks, Montgomery, Philadelphia Amedcnn Red Gross - Hanover Chapter 629 Carlisle Street Hanover, PA 17331 (717) 637-3758 'Adams, Franklin, Yak American Red Cross of Chester 1729 F-dgrnont Avenue Chester, PA 19013 (510) 874.1484 'Chests. Delaware APM 2147 Non Sixdr Streat Philadelphw, PA 19122 (215) 2354788 'Chester, Delaware, Philadelphia, Buds Armstrong CO Community Action Agency 124 ArmsdaN Road, Suite 211 Kftnnirg, PA 15201 (724)548.3405 'Anreaong Ben, Inc. 447 South Prince Street Lncester, PA 17603 (717) 392-5467 'Lancaster Blair County Conmunky Acton Agency 2100 Bill Avenue, Sule 102 P.O. Box 1833 Altoona, PA 16602 (814)948.3661 'Blair Bucks County Houetrg Group 2324 Second Sh" Pike. Sidle 17 Wrighletown, PA 18940 (866)668.0290 `Bucks Bucks County Housing Group 470 Old Dublin Pike Ooyleabwn, PA 18801 (8611) 860.02W 'Bucks BUCke County Housing Group 349 Durham Road Pemdel, PA 19047 (am) 86&0280 'Bucks Buda County Housing Group 51S Weal End Blvd OuaWrtown, PA 18951 (8611) 865-0260 'Bucks Budget Counseling Carom 247 North FffSt Sheet Reading, PA 19601 (610)375-78% 'Barka. Cheater, Schuylkill Carrot Park Community Counoll, n0. 5216 Mash Strom Philadelphia. PA 19131 (215) 8T7-1157 'Chester, Delmore, Philadelphia Catholic Social Service Seem Catherine Manor 5 Knox Red Soxallo n. PA 18505 (570)555.3019 -Wyoming, Wayne, Bucks, Lackawanna. Monroe. Philadelphia COGS of Delaware Valley 1230 Now Rodgers Road, Suite F1 Bristol. PA 19007 (215) 663-5685 'Sucks CCCS of Delaware Valley 1777 Santry Parkway W, Suite 200 Blue Bell, PA 19422 (215) 563-MBS 'Momgomery CCCS of Delaware Valley 280 North Providence Road Media, PA 18083 (215) 58351185 'Chester CCCS of Delaware Valley Merstul Building 790 E Model Sk suits 170 Wool Chaster, PA 19352 (215) 5835885 'Cleaer, Bucks CCCS of L*00 Valley 3671 Crescent Coast East Whllste8, PA 1B052 (610)8214011 (800)8314615 'Barks, Bucks, Carbon, Lanmster, Lehigh, "we" wkm Schuylkill CCC9 of Northeastern PA 201 Basin SVOK &Mle 6 Wgsrnsport, PA 17701 (570) 3734877 'Canoe, Clinton, Lycorhing, NortnumbwWnd, Union CCCSofNVtlaastrrrPA 202 W Hennllon Avenue State College, PA 16501 (814) 238-3686 'Bla r, Came, C1ooAekd, Csntorn, Hu ali gdon, JwNete, M1181n CCCS of Northeeslern PA 401 Laurel Skeet Pittston, PA 10640 (SM) OU-2227 'Bradford, Carbon, Columbia, Lackawame. Lyaomirg. Monroe, Moraour. Norlhunbartsnd, Pike, Sullivan, 7koga, Union, s opm Wyornirg CCCS of Nr6asslam PA 411 Man Street, Suits 104 Skoudeburg,PA 18380 (570) 4204M -Bradford, Carbon, Monme, Pike, Wayne COGS of Western PA 1 North Gale Square 12 Gorden Center Or Greensburg. PA 15601 (886) 511-7127 'FayeBa, Greene, ndinor. Soneras4 Washington, Westmoreland COGS or W931001 PA 55 Clover Hill Road DaBsaown,PA 17313 (SM) 511-2227 'Fullon, Cewfed, Lancaster CCCS of Western PA 2000 linglastow Road Hwdmbwg, PA 17102 (BM) 511-2227 'Adams. Cu ibodrkd, Dauphin, FmMdtr4 Perry, Synder, York COGS of Western PA 312 ChaWet SUSK Suite 227 Meadvi8e, PA 16335 (BM) 511.2227 'Lawrence CCCS of Western PA 41 East Chestnut Skeet Washington, PA 15301 (888) 511-2227 *Wesbnoreland CCCS of Western PA 4402 Peach Sleet Fits, PA 16509 (888) 511-ZU7 'Crawford, Eno, Warren Booker T. Wastwitton Center 1720 Holland Stoat Erie, PA 15503 (814)453.5744 'Crawford, Eris, Warren CCCS of Delmar* Valley Catholic Social Services Building 7340 Jackson Street Philadelphia, PA 19136 (215)563.5685 'Bucks. Philadelphia American Financial Counseling Swim Bucks County Hexing Group C:CCS of Delaware Valley 405 Weal Germantown Pile 200 West Bridge Street One Cho" Hill Suite 213 Norristown. PA 19403 Morrisville, PA 19067 Cherry Hip, PA 08002 (267) 228-7903 (888) 888-0280 (215) 563-MM -Mifflin, Montgomery 'Buda -Phladelphis CCCS of Western PA 524 Fedidln Avenue Aliquippa, PA 15001 (888) 511-2227 'Cambria * Indicates Counties Serviced COOS of Western PA 917 A Logan B0lse and Altoona, PA 16602 (868) 511-2227 'Armstrong, Bodland, Blair, Canbde, Centre, Clearfield, Huntingdon. Juniata. Mifflin, Union CCCS of Westem PA Pullman Commence Center 112 Hollywood Dr Buller, PA 16001 (888) 511-2227 *WW, Claaon, Jefferson, Mercer, Venango CCCS of Western PA River Park Commons 2403 Sidney Stred Pittsburgh, PA 15203 (888)511.2227 'Alegbehy Center for Family Services, Inc. 213 Cwde Street Meadville. PA 16335 (614) 337-8450 'CdunDle, Venengo Centro PedrD Cleve, Inc 827 Wael ErleAvenue Philecielpia, PA 19140 (215) 227-7111 -Pitiadsipha Chester Coffer llry InIK velre t Project 412 Avwwe of the States P.O.BOX 541 Chester, PA 19016 (810)675-0663 'Chester. Delaware, Montgomery, PhMdelpNo Comm. On Eoon Opportunity of Luzwm Co. 163 Amber Lae YWksFBsne, PA 18702 (570) 8260510 'Carbon, Luzern,, SotayDA Wyoming Community Action Commission or Capital Region 1514 Dory Street Harrisburg, PA 17094 (717) 232-0757 'Cumbwlerd, Dauphin, Franklin, Perry, Synder Community Action Committee of the Lehigh Valley 1337 East Fifth Street Bethlehe n, PA 18015 (610)691.5820 'Bwks, Carbon, Lehigh. Monroe. Norditempton Community Action Development Comm - CADCOM 113 E Mein Strew Norristown. PA 19401 (610)277-M 'Mompomery Community Action Southwest 150 W Beau SUeel, Sulk 304 Washingon, PA 15301 (724)225.9556 'Mkxeoe Commniry Action Southwest 59 E Greve Street Waynesburg, PA 15370 (724) 862.2993 'Allegheny. York, Feysea, Greene. Washington, Westmoreland Comm. on Econ. Opportunity of Luanne County 163 Amur Lane WdkasBams, PA 16702 (570) 528.11610 (800) 822-0059 "Wyoming Congroso 216 West Somerset Street Philadelphia, PA 19133 (215) 785-6870 •RUlA04'1Dhia Council of Spanish Speaking Organization 705.09 North Franklin St Philadelphia, PA 19123 (215) 627-3100 'Philadelphis Credit CounsWV Center 832 Second Street Pike Richtom. PA 18854 (215)396.1880 'Bucks DNenllled Community Service Dixon House 1920 South 20th Street Philadelphia, PA 19145 (215) 336-5511 'Bucks, Cheater, Delaware, Philadelphia Fair Housing Pat mnft of Greater Plttetxlrgh, Inc. 2840 Litrerfly Ave., Suhe 205 Pittsburgh, PA 15222 (412) 391-2535 'Allegheny Fayette Co. Community Action Agency Inc 13T North Be6ew Avenue Uniontown, PA 15401 (724)437.6050 'Feyetk, Somerset FOB CDC 1201 Weel Only Avenue PNkdelpNa, PA 19141 (215) 549-0755 'Sucks, Chester, Delaware, Philadelphia Ga liew Jubilee Aeaodates 5136 Penn AVW" Pittsburgh, PA 15224 (412) 665-5200 'Allegheny Germantown Settlement 5536 Wayne Avenue Bldg C Phileds4lia, PA 19144 (215) 8493104 'Buda, Chester. Delaware, Montgomery, Philadelphia Greater Erie Cannon. Action Committee 18 Want 91h Street Erie, PA 16501 (614)4594581 'Crawford, Erie, Vemango, Warren HALE 167 W Allegheny Ave., 2nd Floor PhlelelpNa, PA 19140 (215)426.8025 'Bucks, Chester, Delaware, PNledelphia Hispsric Alliance for Community Advancement 2740 Nom Froth Street Philedetphia, PA 19133 (215) 667.8932 'Monroe Housing Assoc of Delaware Valley 656 Nom Wads Sued Philadelphia, PA 19123 (215) 978-0224 'PhNeds"Its, Monroe Housing Opportunities or Beaver Co. 320 College Avenue, Unit 1 Beaver, PA 15009 (724)728.7511 'Beaver, Lawrence Housing Partnership of Chester County 41 Weat Lancaster Ave" Downingtown, PA 19335 (810) 518-1522 'Chester, Deaware, Montgomery Indiana Co. Community Action Prog. 827 Water Sheet Bar 187 Indlane. PA 15701 (724) 465-2657 'Armstrong, Cembda. Clearfield, Indiana, Jefferson, Weetrnoahrd Horchdpuei Family Services Inc, 4225 Chestnut Stress Philadelphia, PA 19104 (215)386-1298 7hiledeiphin Korean Comm. Develop. Services Cwder 6055 Nom 5th Street Philadelphia, PA 18505 (215)276.863D *Philadelphia Lawrence County Soda Services, Inc. 241 West Gran Street P.O. Box 169 Nov Castle, PA 15103 (724) 958-7258 'Lawrence Liberty Rwaaoe8 714 Market Stress, Sues 100 Philadelphia, PA 19105 (215) 634-2000 -PNkaclophla Loveship, Inc. 2320 Nom 5th Sheet Harrisburg, PA 1711 (717) 232-2207 'Cumbedrln4 Dauphin, Perry Lycan-anln Co Cohan for Comm Action 2138 Lincoln Stress P.O. Box 3568 Williamsport, PA 17703 (570)3264AT *Contra, Clinton. Lyowft Union Mlarons6e 43 Philadelphia Avenue Waynesboro, PA 17288 (717) 762.3285 'Adana. Cumberland, Franklin, Felton. Perry Media Fellowship House 302 South Jackson Street Media, PA 19063 (610) 585-0434 *Chesur, Delaware Mon Valley Unenpbynent Conmitlse 1800 Wed SL, 3rd Floor Homestead, PA 15120 (412)462.9982 *Allegheny, Washington, Westmoreland ML Airy, USA 6703 Germantown Ave., Suite 200 Philadelphia, PA 19119 (215) 544-0021 'PhaadWft Nazareth Housing Services 301 Belwne Road Pitabhegk PA 15229 (412) 931.6996 'Allegheny Neighborhood Housing Sardcesof Reeding 213 N 51h SL. Bull* 1030 Reading. PA 19601 (810) 372-6433 *Berks Neighborhood Housing Servlcoo, Inc. 710 5th Avenue, Suite 1000 Pillabigh, PA 15219 (412) 251-0773 *Allegheny New Kemsoon Community Dswlopment 2515 Frenldont Avenue Philadelphia, PA 19125 (215) 427-0350 'VYerren The NORCAM Group 4200 Crerr7srd Averse Sulk 200 Northern Combda, PA 15714 (814)948 4444 •Cwnbnio, Clearfield Northam Tar Community Aalion Corp. 135 West 41h SUVO P.O. Bolt 389 Emporium, PA 13834 (814) 4881161 'Corneron, Elk, Mckeat, Potter Northwest Counseling Service 5001 Note Broad SUeel Philadelphia, PA 19141 (215)324.7500 'kudos, Cheater, DNawee, Mondilmmsry, PhaadNphie Nueva Espersnza 4281 North 51111 Street Phled"Nst, PA 19140 (215) 3244746 •hrtiladalplnle Opportunity Inc. 301 East Market SUM York, PA 17403 (717)424-3845 'Mantgonnsry The Partnership CDC 4020 Mekel Street, Sulk 100 Phis"". PA 19104 (215)652-1612 *Monroe Psmsylvaria Housing Finance Agency 2275 Swallow Hill ft, Bft 200 Pittsburgh, PA 15220 (412) 4292842 *Nfaghsny PHFA 211 Note Fred Street Harrisburg, PA 17110 (500-)342-2397 'Cumberland, Dauphin Indicates Counties Serviced Philadelphia Council for Comm Adw t 100 N 17th SR Suits 800 Philadelphia, PA 19103 (213) 587-7803 (800) 930-4883 'Cheater, Delaware. Montgomery, Phlads"la The Trehab Center of Northeastern PA 144E East Avenue Wdeborc, PA 16901 (570) 7245252 (800) 962-4145 'Tloge Philadailplia Serior Center St19 South Broad Street Philacleom, PA 19147 (215) 548-5879 'Phiadslphie Schuytkl8 Community Action 225 N. Canine Street Po8sv9k,PA 17901 (570) 822-1985 'Berke, Carbon, Lebanon, Le1Ngh, Luzeme, Northumberland, SOKIYV411 Sharango Valley Urban League, Inc. 601 Indiana Avenue Farrell, PA 16121 (724) 9614310 'Crawford, Lawrence, Mercer South Phiatlalphia H.O.M.E.S, 1444 PM Breeze Avenue Phiadelphle, PA 19145 (215) 334-4430 'Ph iac slpMe SoWnaeatCornmuMy Development Corp. 8388 Paschall Avenue PhAndisphie. PA 19142 (215) 729.800 'MaNporrom SL Martin linter 1701 Parade Street Erie, PA 16303 (814) 4328113 'Gswford, Erie, Vanengo, Warren Tableland Ssrvion Inc. 533 East Main Steed Somsrsel, PA 15501 (814)44&9028 'Cambria, Fayette. Somerset Westmoreitnd Tabor Community Services 308 E King Skeat Suite 1 Lanccester, PA 17802 (717)397.5182 (800)788-5082 'Chaster, Lancaster, Lebanon The Tnehab Canby of Northeastern PA 10 Pubic Avenue P.O. Box 368 Mordrdee, PA 18801 (570) 2788338 (11M) 9624045 'Susquehanna The Trehab Canter of Northeastern PA 115 SR 92S Tuckhasroclk, PA 18657 (570) 83843640 (am) 982.1045 The Trehab Center of of NaNraatem PA 1225 Main Skeet Floneadds, PA 18431 (570) 25341941 (800) 9824045 'Bradford, Sullivan, Susquehanna, Tiogs, Wayne, Wyoming The Tro hab Canter of Northeastern PA Garman Sweet P.O. Bce 389 Ovation, PA 18814 (570) 9269867 (800) 882.4045 'Sulivan The Trehab Center of Northeastern PA The Enterprise Center 703 S. Elmer Ave., Sulte M8 Sayre, PA 10840 (570) 888-0412 (am) 982-4045 'Bradford United Commrn0es Southeast PNIe0elph1a 2029 South 8th Skeet Phitldelphle, PA 19146 (215)4878700 'Philadelphia United Neighborhood Cantata of Northeastern PA 425 Alder Skeet Scanlon, PA 18505 (570) 346-0759 'L.adtawanne, Wyoming, Wayne, Luzwne Urban League of Philadelphia 1618 Market Street Philadelphia, PA 19103 (215) 561-6070 'Bucks, Delaware, Philadelphia Urban League of Philadelphia 610 Wood Street Pittsburgh, PA 15229 (412)931.6998 'A119wary Voices far Indapandance 1107 Payne Avenue Erie. PA 15303 (614) 874-0064 (a00)838.9990 'Erie Warrar?Fant Counties Economic OpportwIty Council 1209 Pennsylvania Ave W. P.O. Bch 547 Warren, PA 16385 (614) 728-2400 'Forest When Wed Oak Lars CDC 8259 Lima k n Pike Ptniiadelphia, PA 1914 (215) 224-0680 'Monroe r . ~, `~ . ~ ~ G.~ PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL _ (Under Act No. 587, approved May 16, 1929), P. L.1784 c f1~[: ~ rT~ COMMONWEALTH OF PENNSYLVANIA ~ ~= • -: ~ =~-` COUNTY OF CUMBERLAND ~~ ~. ~ -~rf~ -..t 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 June 18, 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. Lisa Marie Co e, Editor SWORN TO AND SUBSCRIBED before me this 18 day of June, 2010 Notary NOT SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expina Apr 28.2014 ~, CUMBERLAND LAW JOURNAL NOTICE Court of Common Pleas, Cumberland County Case No. 10-1603 THE HUNTINGTON NATIONAL BANK, AS TRUSTEE FOR FRANKLIN MORTGAGE ASSET TRUST 2009-A, 101 Hudson Street, 25th Floor, Jersey City, NJ 07302 Plaintiff vs. KENNIE JAMISON, JR. AND THE UNITED STATES OF AMERICA, 3789 Spring Road, Carlisle, PA 17013 Defendant(s) Defendant(s): Kennie Jamison, Jr. and the United States of America. Type of Action :CIVIL ACTION- MORTGAGE FORECLOSURE. Premises Subject to Foreclosure: 3789 Spring Road, Carlisle, PA 17013. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written ap- peazance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. If YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAW- YER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OF- FERLEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 MARTHA E. VON ROSENSTIEL, ESQUIRE Attorney ID # 52634 MARTHA E. VON ROSENSTIEL, P.C. Attorneys for Plaintiff 649 South Avenue Suite 6 Secane, PA 19018 (610) 325-2887 June 18 ~~j~ ~~~~ PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Iames Kleinklaus, Director of Sales and Marketing, of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 13,1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues`of -_. THE SENTINEL on the following day(s): ~ c ~= Tuly 1, 2010 ~ ; N .. .a _ ., COPY OF NOTICE OF PUBLICATION MARTHA E. VON ROSENSTIEL, P.C. Ariorney for Plaintiff Martha E. Von Rosenstiel, Esquire 649 South Avenue, Suite 6 Secane, PA 19018 (610) 328-2887 Attorney ID # 52634 THE HUNTINGTON NATIONAL BANK AS TRUSTEE FOR FRANKLIN MORTGAGE ASSET TRUST 2009-A 101 Hudson Street 25th Floor Jersey City, NJ 07302 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY Case No: 10-1603 vs. KENN1E JAMiSON, JR. AND THE UNITED: STATES OF AMERICA 3789 Spring Road Carlisle, PA 17013 Defendant(s) Defendant(s): Kennie Jamison, Jr. and the United States of America Type of Action :CIVIL ACTION -MORTGAGE FORECLOSURE Premises Subject to Foreclosure: 3789 Spring Road, Carlisle, PA 17013 Notice You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a wrttten appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO-HIRE A LAWYER, THISS OFFICE MAY BE ABLE"TO PROVIDE YOU SEIRV CES TO ELIG BLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE .CARLISLE, PA 17013 717-249-3166 800-990-9108 ..o ~: v - :'W, Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and me this V ~ V '~~ Notary Public My commission expires: ~~ NOtARtAI SEAL BAMBI ANN NECKENOORN Notary PubBc CARLISLE BOROUGH. CUMBERLAND CNTY My Commission Expires Jan 27, 2014 vk Martha E. Von Rosenstiel, P.C. Martha E. Von Rosenstiel, Esquire 649 South Avenue, Unit 6 Secane, PA 19018 610-328-2887 Attorney I.D.# 52634 926074CAM - DN Attorney for Plaintiff THE HUNTINGTON NATIONAL BANK, COURT OF COMMON PLEAS AS TRUSTEE FOR FRANKLIN CUMBERLAND COUNTY o MORTGAGE ASSET TRUST 2009-A Plaintiff 5b vs. NO: 10-1603 la KENNIE JAMISON, JR. AND THE UNITED : STATES OF AMERICA o Defendant(s) a AFFIDAVIT OF SERVICE OF NOTICES PURSUANT TO RULE 3129.1 MARTHA E. VON ROSENSTIEL, ESQUIRE, attorney for the Plaintiff in the above action, hereby verifies that on S I ? ( !1 , true and correct copies of the Notice of Sheriff s Sale were served upon Defendant, Kennie Jamison, Jr. pursuant to COURT ORDER dated May 19, 2010, and upon recorded lienholders and any known interested parties by regular first class mail, postage prepaid with Certificate of Mailing evidencing said service attached hereto as Exhibit I. 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 author Martha E. Von Rosenstiel Attorney for Plaintiff Dated: August 03, 2010 MAY 18 2010 3 THE HUNTINGTON NATIONAL BANK, AS : COURT OF COMMON PLEAS -, TRUSTEE FOR FRANKLIN MORTGAGE CUMBERLAND COUNTY ASSET TRUST 2009-A 101 Hudson Street 25th Floor „ Jersey City, NJ 07302 ` PLAINTIFF: NO: 10-1603 V. KENNIE JAMISON, JR. 3789 Spring Road Carlisle, PA 17013 AND UNITED STATES OF AMERICA c/o UNITED STATES ATTORNEY FOR THE MIDDLE DISTRICT OF PA William J. Nealon Federal Building and Courthouse 235 N. Washington Ave., Suite 311 Scranton, PA 18503 DEFENDANTS ORDER AND NOW, this day of 2010, upon consideration of Plaintiffs r , Motion for Special Service and any response thereto (if any), it is hereby: ORDERED and DECREED that Plaintiff may obtain service on Kenme Jamison, Jr. by mailing a true and correct copy of the Complaint in Mortgage Foreclosure and all subsequent notices, including but not limited to notice of sheriff's sale, by certified mail and regular, first class mail at the last known address, 3789 Spring Road, Carlisle, PA 17013 and by posting the premises of 3789 Spring Road, Carlisle, PA 17013 BY THE"-COURT: J. co °CA,IfL't,,L[ FA 21t)i Ir Ir 2 Jf i,-44 -, . R O ?1 U C7 M 2 .30 s $ ?f11i / m Kennie Jamison, Jr. ° ° Carlisle, pA Road RA 17093 c? . m°' • , 46?'U4 P, I'U ru 111 P M M \?. M UNITED SATES OF AMERICA C/O UNITED STATES ATTORNEY FOR / p THE MIDDLE DISTRICT OF PA tt ? r WILLIAM J. NEALON FEDERAL BUILDING _v _CQ BTFIOUSE-- 235 N. WASHINGTON AVF . SUITE 311 SCRANTON,'PA'1g50?' ' C lali F €i1i 1{ } iif ')rfci{{r ru ?,1 y ni Q y PA cod' C7 iu M p t `Q Q o rr' The United Q c/o the US States of America CD Attorney for PA C3 10th and constitution Ave. 7 Washington, DC 20530 NVV -Ln irr%.m 1 r. Ut MAILJINU t ! itfia fec hcrt insiamp5 MAY BE USED FOR DOMESTIC AND iMERNh710) A 1 NO, Ot 4Xlcr poslafc and PROVIDE FOR rNSIAANCE-POSTMASTU Rcccr,cd From E? N l tvkt?•PL fcc< . MARTHA VON ROSENS 649 SOUTH AVENUE - UNIT 7 SECANE, PA 19018 Ont Piece of ordirlary mail addreased Ic: e nl a tates o America c/o the US Attorney for PA tb h and Constitution Ave., NW Washington DC 2053n PS Form 3817, Mw.1989 POE! A SERVICE CERTIFICATE OF MAILING i r-tA.Y DF 1)SED FOR DOMESTIC AND WaFNAI10NAL Wi 4)QF.S NW- rrkOVIDLFOR rNSrJRA,NCE-POSTMASTEF. 4 (? I,ccc ivcd From: MARTHA VON ROS 649 SOUTH AVENUE UNIT i SECANE, PA 19018 Onc Diccc of ordinary mail addressed to: 3789 Spring Road Ply CaMsle, I'S Form 3EI i, Mar.19E9 AfFta fee here io 5tamp, 01 -meta P051agc ano 14*1.lr<aik. Ym(0r-bf FoStn?hsw dot rnintnt iC? . k 4( d CK ) c-1> L v E5 t t sERVMCf CERTIFICATE OF MAILING `£'<" feC'ieR ir, 5tamp5 MAY 6E t)-)ED FOR DOMESTIC AND rNTERNAI M ,11 C3ES N0 Ot mein Po5tagc anO ` FdSt mvL. ki?!t SST'` PROv1L7E FOR rNSi)RANCE-POSTMASTER Rcccived From fees g r F; MARTHA VON ROSENS 649 SOUTH AVENUE UNIT "/ SECANE, PA 19018 One piccc of ordinary mail addre55ed to: RTES OF AMERICA C/O UNITED STATES ATTORNEY FOR WILLIAM J. NEALON FEDERAL BUILDING R CtZURTHOIUS€ 235 N. WASHINGTON AVE., SUITE 34 -7 SCRANI A 1Ba03 1'S Form 3S 1't, Mar.198 ?,? (off 40 f t l PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland James Kleinklaus, Director of Sales and Marketing of The Sentinel, of the County and State aforesaid, being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle, County and State aforesaid, was established December 131h, 1881, since which date THE SENTINEL has been regularly issued in said County, and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues 6f THE SENTINEL on the following day(s): - July 1, 2010 COPY OF NOTICE OF PUBLICATION MARTHA E.. VON ROSENSTIEL, P.C. Attorney forpfsintiff Martha E. Von Rosenstiel Esquire 649 South Averlcia, Suite fi Secene; PA 19016- (610) 328-2887` - Attorney ID # 52634 THE HUNTINGTON NATIONAL BANK, CUM jg£pLFq fl COON PLEAS MORTGAGE ASSET TTt USTt2009-A 101 Hudson Street 25th Floor Jersey City. NJ 07302 Case NO; 10=1803 Plaintiff vs. U KENNIE.JAMISQN; JR. AND THE UNITED: t STATES' OF AMERICA 3789 Spring Rd", ?. CarhW4, PA 1701 j, Detendant(s); Kennie Jamison, Jr. and the United States of America Type of Abtion : CIVIL ACTION - MORTGAGE FORECLOSURE Premises Subject to Foreclosure: 3789 Spring Road, Carlisle, PA 17013 NOUG You have bean sued in court, If you wish to defend against the ctlilms set forth the following pages, you must take action within twenty (20) days after this otrOloint and notice are served, by entering a written appearance Personally or by a%orrwy and filing in "ling with the court your defenses or t10 60 sthns to the o the ca" May proceed witMtrt? you. You err warned that if you hik agraInsl you by tfri court h0ut_htrtheryou and a judgment may be entered oOmptairstodoranyout6r0ouorreuot kw "moMYckUmedInthe ; lose money or property or other Iod by the plaintHf. You may J riq?t im?tantl6 you. j 'OU SHOULO TAKE TNj$ PAPER TO 5rt? LI W,it%R AT ONCE. IF YOU ? DO NOT HAVE A LAWY*R aQ TOO" TE"Pp&-t Tiid OFFICE SET E F ?uenwi.....?.. GRTt1 jt"O TIitS qW4 CAbt PROVrNtiE Yditt mast, ____._ Affiant further deposes that he/she is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statement as to time, place and character of publication are true. Sworn to and ! "` (LJ ?t- i me this () ]U Notary Public -- - --- o...v.+ A ncrJUGED FEE OR NO FEIa. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717.249-3166 80o-990-9108 My commission expires: ?r?r?rrw?rr?rr? F OTARIAL SEAL ANN 14ECKENDORN Notary PUWIC OUGH, CUMBERLAND CNTY ion Expires Ian V. 2014 14 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. 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 June 18, 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. Lisa Marie Co e, Editor - ____. r SWORN TO AND SUBSCRIBED before me this 18 day of June. 2010 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public [CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expirss Apr 28, 2014 CUMBERLAND LAW JOURNAL NOTICE Court of Common Pleas, Cumberland County Case No. 10-1603 THE HUNTINGTON NATIONAL BANK, AS TRUSTEE FOR FRANKLIN MORTGAGE ASSET TRUST 2009-A, 101 Hudson Street, 25th Floor, Jersey City, NJ 07302 Plaintiff VS. KENNIE JAMISON, JR. AND THE UNITED STATES OF AMERICA, 3789 Spring Road, Carlisle, PA 17013 Defendant(s) Defendant(s): Kennie Jamison, Jr. and the United States of America. Type of Action : CIVIL ACTION- MORTGAGE FORECLOSURE. Premises Subject to Foreclosure: 3789 Spring Road, Carlisle, PA 17013. NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written ap- pearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. If YOU DO NOT HAVE A LAWYER GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAW- YER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OF- FER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 (800) 990-9108 MARTHA E. VON ROSENSTIEL, ESQUIRE Attorney ID # 52634 MARTHA E. VON ROSENSTIEL, P.C. Attorneys for Plaintiff 649 South Avenue Suite 6 Secane, PA 19018 (610) 328-2887 June 18 ` i. For Accountable Mail - ---- ? N j-- N a D . o j (.O OC - (D CD ° G w - - - CL a 3 CD CD 3" 1 (P CD j N A z D n Q n ? m m 'or0C-) -n -a Zg: =-uW-0 m 4 WOZ?p=vDw? _ -? Cnrn ?llE? ul?0 ?a°?Ooov cDa+?+m Caw c n?T2Cn?-0 ?-UC-icoDC)C?C? D3 Co .0 -I O, w ? O O9 -"wow ? =Dm m c7 -'n + v` Cn ° 3 s- pp m - m c. a cu o y7 x p g o c v c p D Qo x m ? ?o 0, arc U)70 00 _-I QmCnr ?w'? o?covoD3 =.0 3 Z m ?o -I _ m ? `c a Q N o = car n> m (D p cn c o a CD a m o ? k m ? mom p °m`?m? C Cr (D2 Co o c D ? N ? O O m m ? 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(r ?? 7( 26074-DN AFFIDAVIT OF SERVICE {' I a f j- C PLAINTIFF: The Huntington National Bank, as Trustee for Frarddin Mortgage Asset Trust 2009-A COURT OF COMMON PLEA 1 DEFENDANT Cumberland COUNTY Kennie Jamison, Jr. and the United States of America COURT NO. 10.1603 , SERVE UPON: Kemnie Jamison, Jr. TYPE OF ACTION 3788 Spring Road XXX WRIT OF EXECUTION and Notice of Shsrlff's Sale Carlisle, PA 17013 DefMl4ant j rsoasallY served. Adult gAndlY meatier with whom Defendant reaides. MsnagsilCClerk of place of lodging in which pefdadarrtresidea. Relationship is Agent or person in charge of Defendants office Adult is cbarge of Defendant's residence rho ? or ru usual place of business. refused ' - 1>6 STv> to give name relationsh . Description: Age Heigh Weight Race Sex Other 1, Rgum " 1D to LL_. a competent adult, txlog duly sworn ac cordbrg to law, depose and state that 1 personally intended .te Easlub a true and correct copy of the WRIT OF EXECUTION and Notice of Sheriff's Sale issued in the captioned case on the date and at the address indicated above. Sworn to and a KIMBERLY CURTY NOTARY PUBLIC Notary: By_ MY COMMISSION EXMM MARCH 7, 2013 before rne We KUnknown STATE OF NEW )EMY NOT SERV On the 20_, at o'clock _ M., Defendant NOT FOUND because: No Answer Vacant Date of Attempt: before me this day Of . Z00 . Notary: By: ATTORIIEY Martha E. Von Rosenstiel, P.C. 649 South Avenue, Unit 6 Secane, PA 19018 610328-2887 SPECIAL INSTRUCTIONS: please POST pursuent to COURT She ft Sale Date. &ffl fi 0f0 ORDER a 20674CPG-wk (sub plto Martha E. Von Rosenstiel 649 South Avenue Secane, PA 19018 (610) 328-2887 Attorney I.D. #52634 Attorney for Plaintiff/Movant The Huntington National Bank, as Trustee for COURT OF COMMON PLEAS Franklin Mortgage Asset Trust 2009-A Cumberland COUNTY Plaintiff vs. Kennie Jamison, Jr. and the United States of America Defendants 10-1603 C'") ?rn cn r' rr a - > c7 co D C N _O O rn c-? co Zs zr w rn 0 ---1 m-n r- -urn ;000 Qo o? -ice D -c VOLUNTARY SUBSTITUTION OF Wells Fargo Bank, N.A., as Certificate Trustee not in its Individual Capacity, Solely as Certificate Trustee, in Trust for Registered Holders of VNT Trust Series 2010-2 PURSUANT TO Pa RCP 2352(a) TO THE PROTHONOTARY: 1. Wells Fargo Bank, N.A., as Certificate Trustee not in its Individual Capacity, Solely as Certificate Trustee, in Trust for Registered Holders of VNT Trust Series 2010-2 is the assignee of The Huntington National Bank, as Trustee for Franklin Mortgage Asset Trust 2009-A and wishes to substitute itself for plaintiff. 2. The material facts on which the right of succession and substitution is based as as follows: a) The Huntington National Bank, as Trustee for Franklin Mortgage Asset Trust 2009-A, foreclosing plaintiff, assigned its right, title and interest in premises 3789 Spring Road, Carlisle, PA 17013 to Wells Fargo Bank, N.A., as Certificate Trustee not in its Individual Capacity, Solely as Certificate 'HI Trustee, in Trust for Registered Holders of VNT Trust Series 2010-2 by virtue of an assignment dated September 15, 2010, and recorded September 24, 2010, in Instrument Numbered 201026815. 3. Wells Fargo Bank, N.A., as Certificate Trustee not in its Individual Capacity, Solely as Certificate Trustee, in Trust for Registered Holders of VNT Trust Series 2010-2 does voluntarily substitute itself as plaintiff herein. Von Rosenstiel Attorney for Plaintiff Dated: December 7, 2010