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HomeMy WebLinkAbout10-6233Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff V. Y f? t F' 4i f ?_l v? dui n ?I i 'vi ark COUNTY ?f8fr? )V'D ii, 'jjA ATTORNEY FOR PLAINTIFF 250589 DAVID J. KEPNER KATY E. KEPNER A/K/A KATY E. ROMBERGER 40 EAST LOCUST STREET MECHANICSBURG, PA 17055-3838 Defendants COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. ID (001 ,55 Cwi I Tlect CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE 0 49,40 fti AM at 10020tu 00118Qaq File #: 250589 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File N: 250589 Plaintiff is CHASE HOME FINANCE LLC 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name(s) and last known address(es) of the Defendant(s) are: DAVID J. KEPNER KATY E. KEPNER A/K/A KATY E. ROMBERGER 40 EAST LOCUST STREET MECHANICSBURG, PA 17055-3838 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. On 05/16/2008 DAVID J. KEPNER and KATY E. KEPNER made, executed and delivered a mortgage upon the premises hereinafter described to JPMORGAN CHASE BANK, N.A. which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Instrument No. 200818122. The PLAINTIFF is now the legal owner of the mortgage and is in the process of formalizing an assignment of same. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 250589 6. The following amounts are due on the mortgage: Principal Balance $91 862 53 Interest 05/01/2010 through 09/24/2010 , . $2,250.57 (Per Diem $15.31) Attorney's Fees $650 00 Late Charges through 09/24/2010 . $96 09 Mortgage Insurance Premium / . $37 42 Private Mortgage Insurance . Costs of Suit and Title Search $550 00 Escrow Deficit . 145.33 TOTAL $95,591.94 7. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. Notice of Intention to Foreclose as set forth in Act 6 of 1974, Notice of Homeowner's Emergency Assistance Program pursuant to Act 91 of 1983, as amended in 1998, and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon, and the temporary stay as provided by said notice has terminated because Defendant(s) has/have failed to meet with the Plaintiff or an authorized consumer credit counseling agency, or has/have been denied assistance by the Pennsylvania Housing Finance Agency. 9. This action does not come under Act 91 of 1983 because the mortgage is FHA-insured. File #: 250589 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $95,591.57, together with interest from 09/24/2010 at the rate of $15.31 per diem to the date of judgment, and other costs, fees, and charges collectible under the mortgage and for the foreclosure and sale of the mortgaged property. HALLINAN & KHMIEG, LLP By: ? L ence el , Esq., I . No. 32227 ? F cis S. Hallinan, Esq., I . No. 62695 ? D iel G. Schmieg, Esq., Id. No. 62205 ? M' hele M. Bradford, Esq., Id. No. 69849 ? dith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay B. Jones, Esq., Id. No. 86657 ? Peter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Jaime McGuinness, Esq., Id. No. 90134 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 Attorneys for Plaintiff File #: 250589 LEGAL DESCRIPTION ALL THAT CERTAIN house and lot of ground situate in the Borough of Mechanicsburg, County of Cumberland, and State of Pennsylvania, more particularly bounded and described according to a survey of Gerrit J. Betz, Registered Surveyor, dated October 9, 1970, as follows, to wit: BEGINNING at a point marked by a nail in the southern line of East Locust Street at corner of land N/F of Francis L. Lerew, which said point is referenced as being 35.53 feet West of the Southwest corner of said East Locust Street and South Arch Street; thence extending along the Southern line of East Locust Street, South 77 degrees 45 minutes West 15.50 feet to a point on the line passing through the center of the partition wall of the double, two and one-half story frame dwelling house erected in part on the lot hereby described and in part on the lot adjoining on the West; thence extending along the center line of said partition wall and property N/F of James D. B. Herman, South 12 degrees 15 minutes East, 39 feet to a point marked by a nail; thence continuing along the line of said lot N/F of James D. B. Herman, South 20 degrees 14 minutes East, 130.50 feet to a point marked by a hub; thence still by the line of said property N/F of James D. Herman South 16 degrees 41 minutes East, 23.70 feet to a point marked by a hub in the Northern line of St. John's Alley; thence along the northern line of St. John's Alley, North 75 degrees 04 minutes 30 seconds East 16.50 feet to a point marked by a hub at corner of land N/F of Ednor C. Souders; thence along the line of said land N/F of Ednor G. Souders and also land N/F of Francis L. Lerew, aforementioned, North 18 degrees 29 minutes West, 194.24 feet to a nail in the southern line of East Locust Street, aforementioned, at the Point and Place of BEGINNING. HAVING THEREON erected the eastern one-half of a two and one-half story frame dwelling numbered 40 East Locust Street, Mechanicsburg, Pennsylvania. PROPERTY ADDRESS: 40 EAST LOCUST STREET, MECHANICSBURG, PA 17055- 3838 PARCEL # 17-23-0565-029 File 4: 250589 VERIFICATION The undersigned attorney hereby states that I am the attorney for the Plaintiff in this matter, that Plaintiff is outside the jurisdiction of the Court and/or the verification could not be obtained within the time allowed for the filing of the pleading, that I am authorized to make this verification pursuant to Pa.R.C.P. 1024 (c), and that the statements made in the foregoing Civil Action in Mortgage Foreclosure are based upon information supplied by Plaintiff and are true and correct to the best of my knowledge, information and belief. Furthermore, counsel intends to substitute a verification from Plaintiff upon receipt. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsifications to authorities. DATE: ig 1 0 File # 250589 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith 00", Chief Deputy , y Richard W Stewart Solicitor --F Chase Home Finance LLC vs. Case Number David J. Kepner (et al.) 2010-6233 SHERIFF'S RETURN OF SERVICE 09/30/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: David J. Kepner, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 09/30/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Katy E. Kepner a/k/a Katy E. Romberger, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 10/04/2010 07:55 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 4 2010 at 1955 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: David J. Kepner, by making known unto himself personally, at 40 E. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. ROB T BITNER, DEPUTY 10/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Katy E. Kepner a/k/a Katy E. Romberger, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Katy E. Kepner. Request for service at 112 Juniper Drive, Camp Hill, PA 17011 the defendant was not found. 10/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: David J. Kepner, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant David J. Kepner. Request for service at 212 Creekwood Drive, Camp Hill, PA 17011 the defendant was not found. David J. Kepner currently resides at 40 E. Locust Street, Mechanicsburg, PA 17055. 10/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: David J. Kepner, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant David J. Kepner. Request for service at 112 Juniper Drive, Camp Hill, PA 17011 the defendant was not found. David J. Kepner currently resides at 40 E. Locust Street, Mechanicsburg, PA 17055. 10/05/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Katy E. Kepner a/k/a Katy E. Romberger, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Katy E. Kepner. Request for service at 212 Creekwood Drive, Camp Hill, PA 17011 the defendant was not found. (c) CounfySuite Sheriff, ieleosoft. Inc. 10/29/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Katy E. Kepner, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Katy E. Kepner. Request for service at 40 E. Locust Street, Mechanicsburg, PA 17055 the defendant was not found. Deputies were advised, Katy E. Kepner is thought to be residing in Lewisberry, PA. 11/03/2010 York County Return: And now, November 3, 20101, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Katy J. Kepner the defendant named in the within Complaint in Mortgage Foreclosure and that I am unable to find her in the County of Dauphin and therefore return same NOT FOUND. Request for service at 171 Tuckahoe Road, Dillsburg, PA 17019 is vacant. To date the Dillsburg Postmaster has been unable to provide a good forwarding address for Katy J. Kepner. 11/03/2010 York County Return: And now, November 3, 2010 I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for David J. Kepner the defendant named in the within Complaint in Mortgage Foreclosure and that 1 am unable to find him in the County of Dauphin and therefore return same NOT FOUND. Request for service at 171 Tuckahoe Road, Dillsburg, PA 17019 is vacant. To date the Dillsburg Postmaster has been unable to provide a good forwarding address for David J. Kepner. SHERIFF COST: $174.00 November 09, 2010 SO ANSWERS, RONRFY R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft. Inc. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber PETER J. MANGAN, ESQ. Sheriff Solicitor Reuben B Zeager Richard E Rice, II Chief Deputy, Operations Chief Deputy, Administration CHASE HOME FINANACE LLC Case Number vs. DAVID J. KEPNER (et al.) 10-6233 CIVIL SHERIFF'S RETURN OF SERVICE 11/03/2010 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: DAVID J. KEPNER, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE (CIMF) AS "NOT FOUND" AT 171 TUCKAHOE ROAD, DILLSBURG, PA 17019. THIS ADDRESS IS VACANT, POST OFFICE CHECK NOT BACK BY EXPIRATION DATE. 11/03/2010 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: KATY E. KEPNER A/K/A KATY E. ROMBERGER, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE (CIMF) AS "NOT FOUND" AT 171 TUCKAHOE ROAD, DILLSBURG, PA 17019. THIS ADDRESS IS VACANT, POST OFFICE CHECK NOT BACK BY EXPIRATION DATE. SHERIFF COST: $101.88 November 04, 2010 SO ANSWERS, RICHARD E. RICE II, ACTING SHERIFF E- -,t-. RICHARD P KEUERLEBER, SHERIFF NOTARY Affirmed and subscribed to before me this CONAMONVVEAL7?? Or PENNSYLVANIA 4th day of NOVEMBER 2010 NOTARIAL SEAL LISA L THORPE. NOTARY PUBLIC c) 4u+c! uile r • so±t c CITY OF YOR<, YOR< COUNTY J MY COMMISSON EXPIRESAUG. 12, 2013 H PRO HONOTAR"'i Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 20 ! AR 2 3 AN 10: 6 i :1,1MBERLANO COUNT'S' PENNSYLVANIA Attorney for Plaintiff Chase Home Finance LLC Court of Common Pleas Civil Division VS. Cumberland County David J. Kepner No. 2010-6233 Katy E. Kepner A/K/A Katy E. Romberger MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, by its counsel, Phelan Hallinan & Schmieg, L.L.P., moves this Honorable Court for an Order directing service of the Complaint upon the above-captioned Defendant, Katy E. Kepner A/K/A Katy E. Romberger, by first class mail to the last known address, 112 Juniper Drive, Camp Hil, PA 17011; 212 Creekwood Drive, Camp Hill, PA 17011; 171 Tuckahoe Road, Dillsburg, PA 17019, and the mortgaged premises, 40 East Loot Street, Mechanicsburg, PA 17055; posting of the mortgaged premises, 40 East Locxssl Street, Mechanicsburg, PA 17055; and publication pursuant to Pa. R.C.P. 430, and in support thereof avers as follows: 1. Attempts to serve Defendant, Katy E. Kepner A/K/A Katy E. Romberger, personally with the Complaint have been unsuccessful. The Sheriff of Cumberland County attempted to serve the Defendant at the mortgaged premises, 40 East Lo$St Street, Mechanicsburg, PA 17055. As indicated by the Sheriffs Return of Service attached hereto as Exhibit "A", no service was made as the Defendant could not be found. 4 2. The Sheriff of Cumberland County attempted to serve the Defendant at the last known address, 212 Creekwood Drive, Camp Hill, PA 17011. As indicated by the Sheriffs Return of Service attached hereto as Exhibit "A", no service was made as the Defendant could not be found. 3. The Sheriff of York County attempted to serve the Defendant at the last known address, 112 Juniper Drive, Camp Hill, PA 17011. As indicated by the Sheriffs Return of Service attached hereto as Exhibit "A", no service was made as the Defendant could not be found. 4. The Sheriff of York County attempted to serve the Defendant at the last known address, 171 Tuckahoe road, Dillsburg, PA 17019. As indicated by the Sheriffs Return of Service attached hereto as Exhibit "B", no service was made as the Defendant could not be found. 5. Pursuant to Pa. R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendant. An Affidavit of Reasonable Investigation setting forth the specific inquiries made and the results is attached hereto as Exhibit "C". 6. Plaintiff contacted the Prothontary's Office and as of March 21, 2011, no Judge has previously entered a ruling in this case. 7. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its Proposed Motion for Special Service and Order to the Defendant on and requested Defendant's concurrence. Plaintiff did not receive any written response from the Defendant. A true and correct copy of Plaintiff's letter and postmarked certificate of mailing pursuant to Local Rule 208.3(9) attached hereto, made part hereof, and marked Exhibit "D". 5 8. Plaintiff submits that it has made a good faith effort to locate the Defendant, David J. Kepner and Katy E. Kepner A/K/A Katy E. Romberger, but has been unable to do so. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail; posting; and by publication. Respectfully submitted, PHELAN HALLINAN & SCHMIEG, LLP Date: March 21, 2011 By: ,? Lawr ce T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 / Courtenay R. Dunn, Esq., Id No. 20677W Andrew C. Bramblett, Esq., Id No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id No. 308951 Attorneys for Plaintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Chase Home Finance LLC vs. David J. Kepner Katy E. Kepner A/K/A Katy E. Romberger Attorney for Plaintiff COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY NO. 2010-6233 MEMORANDUM OF LAW 1. FACTUAL BACKGROUND Attempts to serve Defendant, Katy E. Kepner AWA Katy E. Romberger, with the Complaint have been unsuccessful. The Sheriff of Cumberland County and York County attempted to serve the Defendant. As indicated by the Return of Service attached hereto as Exhibit "A" and "B", no service was made. Pursuant to Pa.R.C.P. 430, Plaintiff has made a good faith effort to locate the Defendant. An affidavit of due diligence setting forth the specific inquiries as to the Defendant whereabouts and the results thereof is attached hereto as Exhibit "C". Consequently, Plaintiff submits that it has made a good faith effort to locate the Defendant but has been unable to do so. II. LEGAL AUTHORITY Pennsylvania Rule of Civil Procedure 430(a) specifically states: If service cannot be made under the applicable rule, the plaintiff may move the court for a special order directing the method of service. The motion shall be accompanied by an affidavit stating the nature and extent of the investigation which has been made to determine the whereabouts of the defendant and the reasons why service cannot be made. Pa.R.C.P. 430(a) (2009). In particular: 7 An illustration of a good faith effort to locate the defendant includes (1) inquiries of postal authorities including inquiries pursuant to the Freedom of Information Act, 39 C.F.R. Part 265, (2) inquiries of relatives, neighbors, friends, and employers of the defendant, and (3) examinations of local telephone directories, voter registration records, local tax records, and motor vehicle records. Id. at 430(a) n. Similarly, the Pennsylvania Superior Court has gone on to explain that, "While by no means exhaustive, this Note is at least indicative of the types of procedures contemplated by the legislature when enacting Rule 430." Deer Park Lumber, Inc. v. Major, 384 Pa. Super. 625, 633, 559 A.2d 941, 946 (1989), appeal denied, 525 Pa. 582, 575 A.2d 113 (1990). Only after such proof has been offered is the Court authorized to direct another method of substitute service. See id. In the instant case, as indicated by the attached Return of Service, attached hereto and marked as Exhibit "A" and "B", the Sheriff has been unable to serve the Complaint. Plaintiff has made a good faith effort to discover the whereabouts of the Defendant as evidenced by the attached affidavit of due diligence, marked as Exhibit "C". Therefore, Plaintiff respectfully requests an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail, posting, and publication. III. CONCLUSION As indicated by the Return of Service, the Sheriff has been unable to serve the Complaint upon the Defendant. Plaintiff has made a good faith effort to discover the whereabouts of the Defendant as evidenced by its affidavit of due diligence. 8 WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order pursuant to Pa.R.C.P. 430 directing service of the Complaint by first class mail, publication, and posting. Respectfully submitted, PHELAN HALLINAN & SCHMIEG, LLP Date: March 21, 2011 By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua 1. Goldman, Esq., Id. No. 205047 / Courtenay R. Dunn, Esq., Id No. 2067'79 Andrew C. Bramblett, Esq., Id No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esquire 308951 Attorneys for Plaintiff 9 Exhibit "A" 14 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith +E°'?"gyp 4, Chief Deputy Richard W Stewart Solicitor OFFICE OF THE SKgRIFF Chase Home Finance LLC I vs. David J. Kepner (et al.) Case Number 2010-6233 SHERIFF'S RETURN OF SERVICE 09/30/2010 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: David J. Kepner, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Complaint In Mortgage Foreclosure according to law. Ronny R. Anderson, Sheriff who being duly swom according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Katy E. Kepner a/k/a Katy. E. Romberger, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, PA to serve the within Complaint In Mortgage Foreclosure according to law. 10/04/2010 07:55 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on October 4 2010 at 1955 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: David J. Kepner, by making known unto himself personally, at 40 E. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. ROB gT BIER, DEPl1TYY Q10 lRonny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Katy E. Kepner a/k/a Katy E. Romberger, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Katy E. Kepner. Request for service at 112 Juniper Drive, Camp Hill, PA 17b11 the defendant was not found. 10/05/2010 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: David J. Kepner, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant David J. Kepner. Request for service at 212 Creekwood Drive, Camp Hill, PA 17011 the defendant was not found. David J. Kepner currently resides at 40 E. Locust Street, Mechanicsburg, PA 17055. 10105/2010 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: David J. Kepner, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant David J. Kepner. Request for service at 112 Juniper Drive, Camp Hill, PA 17011 the defendant was not found. David J. Kepner currently resides at 40 E. Locust Street, Mechanicsburg, PA 17055. Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Katy E. Kepner a/k/a Katy E. Romberger, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Katy E. Kepner. Request for service at 212 Creekwood Drive, Camp Hill, PA 17011 the defendant was riot found. 5 o ?? (0) COteySuNe Sheriff. TeleosoR, inc. 119.012041 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Katy E. Kepner, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Katy E. Kepner. Request for service at 40 E. Locust Street, Mechanicsburg, PA 17055 the defendant was not found. Deputies were advised, Katy E. Kepner is thought to be residing in Lewisberry, PA. 11103010 York County Return: And now, November 3, 20101, Richard P. Keuedeber, Sheriff of York County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Katy J. Kepner the defendant named in the within Complaint in Mortgage Foreclosure and that I am unable to find her in the County of Dauphin and therefore return same NOT FOUND. Request for service at 171 Tuckahoe Road, Dillsburg, PA. 17019 is vacant. To date the Dillsburg Postmaster has been unable to provide a good forwarding address for Katy J. Kepner. 11/03/2010 York County Return: And now, November 3, 20101, Richard P. Keuerieber, Sheriff of York County, Pennsylvania, do hereby certify and return, that I made diligent search and Inquiry for David J. Kepner the defendant named in the within Complaint in Mortgage Foreclosure and that I am unable to find him in the County of Dauphin and therefore return same NOT FOUND. Request for service at 171 Tuckahoe Road, Dillsburg, PA 17019 is vacant. To date the Dillsburg Postmaster has been unable to provide a good forwarding address for David J. Kepner. SHERIFF COST: $174.00 November 09, 2010 SO ANSWERS, RONNNY R ANDERSON, SHERIFF G (C) CantyW10 Shwttr. TelaosoR, Im a??o j?! Exhibit "B" 15 SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber PETER J. MANGAN, ESQ. Sheriff Solicitor Reuben B Zeager Richard E Rice, II Chief Deputy, Operations Chief Deputy, Administration CHASE HOME FINANACE LLC I Case Number VS. DAVID J. KEPNER (et al.) 10-6233 CIVIL SHERIFF'S RETURN OF SERVICE 11/03/2010 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: DAVID J. KEPNER, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE (CIMF) AS "NOT FOUND" AT 171 TUCKAHOE ROAD, DILLSBURG, PA 17019. THIS ADDRESS IS VACANT, POST OFFICE CHECK NOT BACK BY EXPIRATION DATE. 11/03/2010 I, RICHARD P KEUERLEBER, SHERIFF, WHO BEING DULY SWORN ACCORDING TO LAW, STATES HE MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: KATY E. KEPNER A/K/A KATY E. ROMBERGER, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE (CIMF) AS "NOT FOUND" AT 171 TUCKAHOE ROAD, DILLSBURG, PA 17019. THIS ADDRESS IS VACANT, POST OFFICE CHECK NOT BACK BY EXPIRATION DATE. SHERIFF COST: $101.88 November 04, 2010 SO ANSWERS, RICHARD E. RICE II, ACTING SHERIFF RICHARD P KEUERLEBER, SHERIFF NOTARY Affirmed and subscribed to before me this COMMONWEALTH OF PENNSYLVANIA 4th day of NOVEMBER 2010 NOTARIAL SEAL LISA L. THORPE. NOTARY PUBLIC ^ `c) t1iw+ m n aot c. CITY YORK, YORK COUNTY ?rO ? Q MY COMMIS 1SS`ON EXPIRES AUG. 12, 2013 Y C? Exhibit "C" 16 AFFIDAVIT OF GOOD FAITH INVESTIGATION CF File Number: 250589 Attorney Finn: Phelan, Hallinan & Schmle& LLP Subject: David J. Kepner & Katy E. Kepner Property Address: 40 East Locust Street, Mechanicsburg, PA 17055 Possible Mailing Address: (David J. Kepner) 112 Juniper Drive, Camp Hill, PA 17011 (Katy E. Kepner) 212 Creekwood Drive, Camp Hill, PA 17011 I, being duly sworn according to law, do hereby depose and state as follows, an investigation into the whereabouts of the above-noted individual(s) was conducted and the following has been discovered: 1. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be true and correct David J. Kepner - xxx-xx-0261 Katy E. Kepner - xxx-xx-8375 EMPLOYMENT SEARCH David J. Kepner & Katy E. Kepner - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDIT016 Our inquiry of creditors indicated that David J. Kepner reside(s) at: 112 Juniper Drive, Camp Hill, PA 17011 & Katy E. Kepner reside(s) at: 212 Creekwood Drive, Camp Hill, PA 17011. II. INQUIRY OF TELEPHONE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases, which indicated that David J. Kepner reside(s) at: 112 Juniper Drive, Camp Hill, PA 17011, however had no listing for Katy E. Kepner. On 09-10-10 our office made several telephone calls to the subject's phone number (717) 737-2658 and received the following information: answering machine. On 09-10-10 our office made a telephone call to the subject's phone number (717) 635-8568 and received the following information: not in service. B. On 09-104 our office made several telephone calls to a possible phone number of the subject(s) (717) 982- 0010 and received the following information: answering machine. On 09-10-1.0 our office made a telephone call to a possible phone number of the subject(s) (717) 612-0150 and received the following information: not in service. On 09-10-10 our office made several telephone calls to a possible phone number of the subject(s) (717) 763-0826 and received the following information: answering machine. III. INQUIRY OF NEIGHBORS On 09-10-10 our office made a phone call in an attempt to contact Joe Henry (717) 766-8074,38 East Locust Street, Mechanicsburg, PA 17055: not in service. On 09-10-10 our office made a phone call in an attempt to contact Jr. Trace (717) 7664190, 39 East Locust Street, Mechanicsburg, PA 17055: spoke with an unidentified female who could not confirm that the subjects reside(s) at 40 East Locust Street, Mechanicsburg, PA 17055. On 09-10-10 our office made several phone calls in an attempt to contact John Ashby (717) 458-5656, 42 East Locust Street, Mechanicsburg, PA 1.7055: answering machine. On 09-10-10 our office made several phone calls in an attempt to contact Todd M. Spitman (717) 737-5556,110 Juniper Drive, Camp Hill, PA 17011: answering machine. On 09-10-10 our office made several phone calls in an attempt to contact Barbara Matusheski (717) 975-3971, 111 Juniper Drive, Camp Hill, PA 17011: answering machine. On 09-1.0-1.0 our office made several phone calls in an attempt to contact Anna M. Curly (717) 737-3532, 115 Juniper Drive, Camp Hill, PA 17011.: answering machine. On 09-10-10 our office made a phone call in an attempt to contact Patricia A. Costea (717) 737-0000,208 Creekwood Drive, Camp Hill, PA 17011: spoke with an unidentified female who could not confirm that the subjects reside(s) at 212 Creekwood Drive, Camp Hill, PA 17011. On 09-10-10 our office made several phone calls in an attempt to contact Karyn M. Brenkacs (717) 761-5545,204 Creekwood Drive, Camp Hill, PA 17011: answering machine. On 09-10-10 our office made a phone call in an attempt to contact Jr. Stolp (717) 737-3749,200 Creekwood Drive, Camp Hill, PA 17011: not in service. IV. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 09-10.10 we reviewed the National Address database and found the following information: David J. Kepner -112 Juniper Drive, Camp Hill, PA 17011 & Katy E. Kepner - 212 Creekwood Drive, Camp Hill, PA 17011. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: (David J. Kepner) 112 Juniper Drive, Camp Hill, PA 17011 & (Katy E. Kepner) 212 Creekwood Drive, Camp Hill, PA 17011. V. OTHER INQUIRIES A. DEATH RECORDS As of 09-10-10 Vital Records and all public databases have no death record on file for David J. Kepner & Katy E. Kepner. VI. ADDITIONAL INFORMATION OF SUBJECT A. DATE OF BIRTH David J. Kepner -12-18-1983 Katy E. Kepner - 08-01-1984 A.K.A. David D. Kepner Jr.; David D. Kepner Katy J. Kepner; Katy E. Romberger " Our accessible databases have been checked and cross-referenced for the above named individual(s). Please be advised our database information indicates the subject resides at the current address. I certify that the foregoing statements made by me are true. I am aware that if any of the foregoing states made by me are willfully false, I am subject to punishment. I hereby verify that the statements made herein are true and correct to the best of my knowledge, information and belief and that this affidavit of investigation is made subject to the penalties of 18 Pa C.S. Sec. 4904 relating to unswor fa thur'tk AFFIANT JESSICA M. LUGO ?(?t't `t 4 ! 1D #? 2333078 Sworn to and subscribed before me this day of ?1. PI?fWOFWWJR Cotrrr>ission E1t;16+es 3!5/70'14 The above information is obtained from available public records and we are only liable for the cost of the affidavit. IND Exhibit "D" 17 PHELAN HALLINAN & SCHMIEG, L.L.P. Suite 1400 One Penn Center Plaza at Suburban Station Philadelphia, PA 19103 215-563-7000 Main Fax: 215-563-7009 E-mail cynthia.fenn@fedphe.com Cynthia D. Fenn, Ext. 1560 Service Department Representing Lenders in Pennsylvania and New Jersey March 14, 2011 Katy E. Kepner A/K/A Katy E. Romberger 40 East Lo#t Street Mechanicsburg, PA 17055 RE: Chase Home Finance LLC vs. David J. Kepner and Katy E. Kepner A/K/A Katy E. Romberger Premises Address: 40 East Lot Street, Mechanicsburg, PA 17055 Cumberland County, No. 2010-6233 Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by March 21, 2011. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly yours, ynthia . Fenn For Phelan Hallinan & Schmieg, LLP 13 PHELAN HALLINAN & SCHMIEG, L.L.P. Suite 1400 One Penn Center Plaza at Suburban Station Philadelphia, PA 19103 215-563-7000 Main Fax: 215-563-7009 E-mail cynthia.fenn@fedphe.com Cynthia D. Fenn, Ext. 1560 Service Department Representing Lenders in Pennsylvania and New Jersey March 14, 2011 Katy E. Kepner A/K/A Katy E. Romberger 112 Juniper Drive Camp Hil, PA 17011 RE: Chase Home Finance LLC vs. David J. Kepner and Katy E. Kepner A/K/A Katy E. Romberger Premises Address: 40 East Loh4t Street, Mechanicsburg, PA 17055 Cumberland County, No. 2010-6233 Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by March 21, 2011. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. ly yours, A yn is D. Fenn For Phelan Hallinan & Schmieg, LLP 14 PHELAN HALLINAN & SCHMIEG, L.L.P. Suite 1400 One Penn Center Plaza at Suburban Station Philadelphia, PA 19103 215-563-7000 Main Fax: 215-563-7009 E-mail cynthia.fenn@fedphe.com Cynthia D. Fenn, Ext. 1560 Representing Lenders in Service Department Pennsylvania and New Jersey March 14, 2011 Katy E. Kepner A/K/A Katy E. Romberger 212 Creekwood Drive Camp Hill, PA 17011 RE: Chase Home Finance LLC vs. David J. Kepner and Katy E. Kepner A/K/A Katy E. Romberger Premises Address: 40 East Lool Street, Mechanicsburg, PA 17055 Cumberland County, No. 2011-6233 Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by March 21, 2011. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. Very truly yours, /_'I ;1 Cynthia U Fenn - For Phelan Hallinan & Schmieg, LLP 15 PHELAN HALLINAN & SCHMIEG, L.L.P. Suite 1400 One Penn Center Plaza at Suburban Station Philadelphia, PA 19103 215-563-7000 Main Fax: 215-563-7009 E-mail cynthia.fenn@fedphe.com Cynthia D. Fenn, Ext. 1560 Service Department Representing Lenders in Pennsylvania and New Jersey March 14, 2011 Katy E. Kepner A/K/A Katy E. Romberger 171 Tuckahoe Road Dillsburg, PA 17019 RE: Chase Home Finance LLC vs. David J. Kepner and Katy E. Kepner A/K/A Katy E. Romberger Premises Address: 40 East Locst Street, Mechanicsburg, PA 17055 Cumberland County, No. 2016-6233 Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion for Special Service and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking concurrence with the requested relief that is, Special Service. Please respond to me within one week, by March 21, 2011. Should you have any further questions or concerns, please do not hesitate to contact me. Otherwise, please be guided accordingly. V yours, f _ Cynthi . Fenn For Phelan Hallinan & Schmieg, LLP 16 N O ro -q 0 r z ' N r C ?O Oo -.4 O\ CA A W N C ? M cn M x-? d~ n? n : fox z az cy y ? N ? c P,;, ... lD d' t? ?" a 00 I'd 0 ?' H • ? p Otv ?1 d p ? "'d l D t?1o ~ ~? o a a 0 ?n Sy o ? a (9 y ry (IQ CD 0 M Cb < ' V1 _ ao n co yW EA 7 U ? O ? ?y 8 'D( G 7,0 3 1 N o o " A Oz ?< ? a Q y P. CL - c ov o0 0 ? v 7 A ?. ? gyp' O y y G A Ip G• ? ? _ a? '? C U m o. 02 im $ I 00042772 $ 56 MAILED FRO M ZIP C( H IM ? r9 ? C. ? A 11 w`?f0 t? Q 0 r+ A n A kQ. ? Cq 0 A l17 G o' N ? h C ? b n Q' A Q NF S D1.68o R14 2011 )DE 151103 VERIFICATION The undersigned hereby states that he/she is the Attorney for the Plaintiff in this action, that he/she is authorized to make this Affidavit, and that the statements made in the foregoing MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT are true and correct to the best of his/her knowledge, information and belief. The undersigned understands that the statements made are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Respectfully submitted, PHELAN HALLINAN & SCHMIEG, LLP Date: March 21, 2011 By: Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id No. 308951 Attorneys for Plaintiff 10 Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Attorney for Plaintiff Chase Home Finance LLC Court of Common Pleas Civil Division VS. Cumberland County No. 2010-6233 David J. Kepner Katy E. Kepner A/K/A Katy E. Romberger CERTIFICATION OF SERVICE The undersigned certifies that a copy of the Motion for Service Pursuant to Special Order of Court, Memorandum of Law, proposed Order and attached exhibits have been sent to the individual as indicated below by first class mail, postage prepaid, on the date listed below. 11 Katy E. Kepner A/K/A Katy E. Romberger: 40 East Loot Street Mechanicsburg, PA 17055 112 Juniper Drive Camp Hil, PA 17011 212 Creekwood Drive Camp Hill, PA 17011 171 Tuckahoe Road Dillsburg, PA 17019 cc: David J. Kepner The undersigned understands that this statement is made subject to the penalties of 18 PA C.S. 4904 relating to un-sworn falsification to authorities. Respectfully submitted, PHELAN HALLINAN & SCHMIEG, LLP Date: March 21, 2011 By: La ence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 20677 Andrew C. Bramblett, Esq., Id No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id No. 308951 Attorneys for Plaintiff 12 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Chase Home Finance LLC Civil Division vs. No. 2010-6233 David J. Kepner Katy E. Kepner A/K/A KAty E. Romberger ORDER ? AND NOW, this day of ,/ /" ?&"A ? c cn? _UX rn,w Z ? ? ' ? ?7 t7 r rt a0Q - C Co ° o C Q -p C :)-n 2 a z 63 c ,? rn 2011, upony`° - consideration of Plaintiff s Motion for Service Pursuant to Special Order of Court, it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and all future pleadings on Defendant, Katy E. Kepner A/K/A KAty E. Romberger, by: 1. Posting of the premises: 40 East Loc9t Street, Mechanicsburg, PA 17055 by the Sheriff or a non-party competent adult; 2. First class mail to Katy E. Kepner A/K/A Katy E. Romberger at the last known address, 112 Juniper Drive, Camp Hil, PA 17011; 212 Creekwood Drive, Camp Hill, PA 17011; 171 Tuckahoe Road, Dillsburg, PA 17019, and the mortgaged premises located at 40 East Lo4t Street, Mechanicsburg, PA 17055; and 3. Publication in accordance with PA. R.C.P. 430. 3 2 , l It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. Cc: '/ THE J. David J. Kepner and Katy E. Kepner A/K/A Katy E. Romberger 40 East Lockst Street Mechanicsburg, PA 17055 ? David J. Kepner and Katy E 112 Juniper Drive Camp Hill, PA 17011 212 Creekwood Drive Camp Hill, PA 17011 171 Tuckahoe Road Dillsburg, PA 17019 PHS# 2505891 cdf our ro-Y -R. Dunn pHs Kepner A/K/A Katy E. Romberger 3(, COO 3 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id. No. 206779 Andrew C. Bramblett, Esq., Id. No. 208375 Allison F. Wells, Esq., Id. No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 CHASE HOME FINANCE LLC Plaintiff VS. DAVID J. KEPNER KATY E. KEPNER ROMBERGER Defendants A/K/A KATY E. f'ROTHOIOTAR n,1 Al'R -5 Am", t4 1 ji0ERLAND COUNTY PENNSYLVANIA ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION : CUMBERLAND COUNTY : No. 10-6233-CIVIL TERM PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE Q.vuj?0. bb Fj a erg16-7s8-o 9 lUaS-7 SQA TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the above captioned matter. ' L/AAN HALLINAN & SCHMIEG, LLP PHE/I By: ? - ? Lawrence T. Phelan, Esq., Id. No. 32227 ? Francis S. Hallinan, Esq., Id. No. 62695 ? Daniel G. Schmieg, Esq., Id. No. 62205 ? Michele M. Bradford, Esq., Id. No. 69849 ? Judith T. Romano, Esq., Id. No. 58745 ? Sheetal R. Shah-Jani, Esq., Id. No. 81760 ? Jenine R. Davey, Esq., Id. No. 87077 ? Lauren R. Tabas, Esq., Id. No. 93337 ? Vivek Srivastava, Esq., Id. No. 202331 ? Jay?B. Jones, Esq., Id. No. 86657 eter J. Mulcahy, Esq., Id. No. 61791 ? Andrew L. Spivack, Esq., Id. No. 84439 ? Chrisovalante P. Fliakos, Esq., Id. No. 94620 ? Joshua I. Goldman, Esq., Id. No. 205047 ? Courtenay R. Dunn, Esq., Id. No. 206779 ? Andrew C. Bramblett, Esq., Id. No. 208375 ? Allison F. Wells, Esq., Id. No. 309519 ? William E. Miller, Esq., Id. No. 308951 Attorneys for Plaintiff Date: April 4, 2011 /cdf, Svc Dept. File# 250589 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Chase Home Finance LLC vs. David J. Kepner (et al.) ?t -OFFICC € E!L RO ZDl I APR I I PH 12: 59 CUMBERLAND COUNTY PENNSYLVANIA Case Number 2010-6233 SHERIFF'S RETURN OF SERVICE 04/07/2011 04:15 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on April 7, 2011 at 1615 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Katy E. Kepner, pursuant to order of court by posting the premises located at 40 E. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 with a true and correct copy according to law. SHERIFF COST: $44.00 April 08, 2011 • 7I e-e- TIM MACK, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF CC! C OUritySutte Sheriff. Telec, off, Inc Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Allison F. Wells, Esq. Id No. 309519 William E. Miller, Esq., Id. No. 308951 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Chase Home Finance LLC Plaintiff vs. David J. Kepner Katy E. Kepner A/K/A Katy E. Romberger 1Ir R 19 XM10:G? ;MBERLAND COUNT',( P'ENNSYLVAN1A ATTORNEYS FOR PLAINTIFF COURT OF COMMON PLEAS : CIVIL DIVISION Cumberland COUNTY : NO. 2010-6233 Defendant(s) AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular mail to the following persons, David J. Kepner and Katy E. Kepner A/K/A Katy E. Romberger at 40 East Locust Street, Mechanicsburg, PA 17055; 112 Juniper Drive, Camp Hill, PA 17011; 212 Creekwood Drive, Camp hill, PA 17011; 171 Tuckahoe Road, Dillsburg, PA 17019 on April 18, 2011, in accordance with the Order of Court dated March 25, 2011. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: April 18, 2011 PHELAN Lawrenc helan, E .32227 rancis S. Halli an, Esq., Id. No. 695 Daniel G. Schmieg, Esq., Id. No. 6 205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Allison F. Wells, Esq. Id No. 309519 William E. Miller, Esq., Id. No. 308951 Attorneys for Plaintiff PHS# 250589 Phelan Hallinan & Schmieg, LLP Lawrence T. Phelan, Esq., Id. No. 32227 Francis S. Hallinan, Esq., Id. No. 62695 Daniel G. Schmieg, Esq., Id. No. 62205 Michele M. Bradford, Esq., Id. No. 69849 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 Chase Home Finance LLC VS. David J. Kepner Katy E. Kepner A/K/A Katy E. Romberger LEA C' L. I I ??---R 2 I ? 10'- CUMERLAND COUNT k> SYLVANIA, ATTORNEYS FOR PLAINTIFF : Court Of Common Pleas : Civil Division : Cumberland County No. 2010-6233 AFFIDAVIT OF SERVICE BY PUBLICATION IN ACCORDANCE WITH COURT ORDER I hereby certify that service of the Civil Action Complaint in Mortgage Foreclosure was made in accordance with the Court Order dated MArch 25, 2011 as indicated below: By publication as provided by Pa. R.C.P. Rule 430(b)(1) in The Sentinel on Apari16. 2011 and The Cumberland Law Journal on April 15, 2011 . Proofs of the said publications are attached hereto. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. PHELAN HALLINAN & By; awr Id. No. 32227 Francis S. Hallinan, Esq., 62695 Daniel G. Schmieg, Esq., Id. No. 62 Michele M. Bradford, Esq., Id. No. 6 49 Judith T. Romano, Esq., Id. No. 58745 Sheetal R. Shah-Jani, Esq., Id. No. 81760 Jenine R. Davey, Esq., Id. No. 87077 Lauren R. Tabas, Esq., Id. No. 93337 Vivek Srivastava, Esq., Id. No. 202331 Jay B. Jones, Esq., Id. No. 86657 Peter J. Mulcahy, Esq., Id. No. 61791 Andrew L. Spivack, Esq., Id. No. 84439 Jaime McGuinness, Esq., Id. No. 90134 Chrisovalante P. Fliakos, Esq., Id. No. 94620 Joshua I. Goldman, Esq., Id. No. 205047 Courtenay R. Dunn, Esq., Id No. 206779 Andrew C. Bramblett, Esq., Id No. 208375 Date: April 20, 2011 Attorneys for Plaintiff U PHS# 10 PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox, Retail Sales Manager,, 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 13th, 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): April 6, 2011 COPY OF NOTICE OF PUBLICATION m « = 0 Q . O () o0 - $E% ?Z 0 0C' ¢ 'pQ?'?+? DO r ' m?0 y °ME ?< a m?m? m mo >0 30 rm V ° 3 m=T 3LL ?U) o Z 0 O CD ? r °m Q >w OWE =m x .0zWa m 0)o E o 800 >3 c? > _ m O Z5 mE? TO =? dJ > ~ J Jgi: "o F 0'Q a OW Ow O O C O .Eo0, N T 2. z a r 0 ?o 05 W~ O U coyer m, o .? CJ) oma mO mw Z p u-02?. D ?Ea =Oa ¢U ro y 16 _--, dd y W> N LL c W m ? 2 O 0 O O C p V .V U Q T WW ? O y U y m d s C W m J W > U > U O W Z V rtm¢ U Cm n W V 0 o°mm ZE S ? ? r E „ „ m a m LL O Z ??my m* 0 c.?? W? wLL W caQ ' VO c ?.ro > FO o m c o cm. a i m > m ¢ m T V Nm mU OU N C m J 0 ¢¢ °.'-C W W W C-,C-D 10 =m 'F- m N m g C y ° m F J F 0 CD a E N E°ocn mm a c 0a: =->_¢m 3- mm ? w m .O ° ¢ W amo y 2r= m W 5o 3 o w ¢- r`c '- U W I JE Z m' T Z- = = °m 3 N n=00WQ00W O Z 0 Wf- W is y Din ? -- m 0 f, ac . U 0 ¢LL >- .E(n>c y_mWU X01 j% v LL : ¢70 ca Y Q Y - HO??O¢ a ¢ ¢ mvYv m tN°to - a) -0 == °, lU " .o°?.CYWQWQO Y N OO'00 mn (,• NY 'O m¢hOFZW ¢ C d C =-C NNE = c ° 2 TE"-W?OOW °c N d 9 N C U . .- m ZQZF- O C O O YY LLI LRyTO s'R yc NrOn, F-U¢U 'ui ro E c aZ6 m c, m _ 3 c>;aen-,OCO0 3 W ?.T Y 0m2t ? = W m O:) Wcp0 0Y H > } - > W Cn W a Z O O U 0 F- O U U J J N U C CL N N 0> 2 N L U 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 z O W U F- UOw } > U W Zrtcn¢cn SW¢mno o 0_J <0 c cc CO M < JZQF-t m W W J ¢WOMEno m CC _' F ?WQ }Z00 J N N JW? m U V I 1 Notary Public My commission expires: NOTARIAL SEAL w? BAMBI ANN HECKENDORN Notary Public CARLISLE BOROUGH, CUMBERLAND CNTY My Commission Expires Jan 27, 2014 Sworn to and subscribed before me this R PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 L' a Marie Coyne, E itor SWORN TO AND SUBSCRIBED before me this 15 daX of April, 2011 C-- ? ? 4 / Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2 414 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 April 15, 2011 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 ' CUMBERLAND LAW JOURNAL NOTICE OF ACTION IN MORTGAGE FORECLOSURE In the Court of Common Pleas of Cumberland County, Pennsylvania Civil Action-Law NO. 10-6233 Chase Home Finance LLC vs. David J. Kepner, Katy E. Kepner a/k/a Katy E. Romberger NOTICE TO Katy E. Kepner a/k/a Katy E. Romberger: You are hereby notified that on September 29, 2010, Plaintiff, Chase Home Finance LLC, filed a Mortgage Foreclosure Complaint endorsed with a Notice to Defend, against you in the Court of Common Pleas of Cumber- land County, Pennsylvania, docketed to No. 10-6233. Wherein Plaintiff seeks to foreclose on the mortgage secured on your property located at 40 East Locust Street, Mechan- icsburg, PA 17055 whereupon your property would be sold by the Sheriff of Cumberland County. You are hereby notified to plead to the above referenced Complaint on or before 20 days from the date of this publication or a Judgment will be entered against you. NOTICE If you wish to defend, you must enter a written appearance person- ally or by attorney and file your de- fenses or objections in writing with the court. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you without further notice for the relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS NO- TICE 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 INFORMA- TION 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 RE- DUCED FEE OR NO FEE. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (800) 990-9108 Apr. 15 ' 1 ,1 r.13 E t'r�t f iONO s P3 l R 25 AM 9: 28 JIEt.ftlfl3ll; Ty PENNSYLVANIA PHELAN HALLINAN,LLP Allison F.Zuckerman,Esq.,Id.No.309519 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza ATTORNEY FOR PLAINTIFF Philadelphia,PA 19103 215-563-7000 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO COURT OF COMMON PLEAS CHASE HOME FINANCE LLC 1111 POLARIS PARKWAY CIVIL DIVISION COLUMBUS,OH 43240 TERM Plaintiff V. NO. 10-6233-CIVIL TERM DAVID J.KEPNER CUMBERLAND COUNTY 112 JUNIPER DRIVE CAMP HILL,PA 17011-8326 KATY E.KEPNER A/K/A KATY E.ROMBERGER 40 EAST LOCUST STREET MECHANICSBURG,PA 17055-3838 Defendants AMENDED CIVIL ACTION-LAW COMPLAINT IN MORTGAGE FORECLOSURE File#: 250589 • 1 JPMORGAN CHASE BANK,NATIONAL CIVIL DIVISION ASSOCIATION,SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC NO.: 10-6233-CIVIL TERM 1111 POLARIS PARKWAY COLUMBUS,OH 43240 Plaintiff, VS. DAVID J.KEPNER 112 JUNIPER DRIVE CAMP HILL,PA 17011-8326 KATY E.KEPNER A/K/A KATY E. ROMBERGER 40 EAST LOCUST STREET MECHANICSBURG,PA 17055-3838 Defendants. NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages,you must take action within twenty(20)days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so,the case may proceed without you,and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. File#: 250589 IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800)990-9108 File#: 250589 1. Plaintiff is JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC 1111 POLARIS PARKWAY COLUMBUS,OH 43240 2. The name(s)and last known address(es)of the Defendant(s)are: DAVID J.KEPNER 112 JUNIPER DRIVE CAMP HILL,PA 17011-8326 KATY E.KEPNER A/K/A KATY E.ROMBERGER 40 EAST LOCUST STREET MECHANICSBURG,PA 17055-3838 who is/are the mortgagor(s)and/or real owner(s)of the property hereinafter described. 3. On 05/16/2008 DAVID J.KEPNER and KATY E.KEPNER made,executed and delivered a mortgage upon the premises hereinafter described to JPMORGAN CHASE BANK,N.A.which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Mortgage Instrument No. 200818122. By Assignment of Mortgage recorded 12/16/2010 the mortgage was assigned to CHASE HOME FINANCE LLC,which Assignment is recorded in Assignment of Mortgage Instrument No. 201037199.The mortgage and assignment(s), if any,are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g);which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File#: 250589 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage,upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor,the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 11/30/2012: Principal Balance $91,862.53 Interest $14,238.61 05/01/2010 through 11/30/2012 Late Charges $96.09 Property Inspections $200.00 Property Preservation $285.00 Escrow Deficit $7,160.78 TOTAL $113,843.01 7. Plaintiff is not seeking a judgment of personal liability(or an in personam judgment) against the Defendant(s) in the Action;however,Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s)has/have received a discharge of personal liability in a bankruptcy proceeding,this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy,but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8. The mortgage premises are vacant and abandoned. File#: 250589 WHEREFORE,Plaintiff demands an in rem judgment against the Defendant(s)in the sum of $113,843.01,together with interest,costs,fees,and charges collectible under the mortgage including but not limited to attorney fees and costs,and for the foreclosure and sale of the mortgaged property. PHELAN HALLINA LP By: Alli . .,Id.No.309519 Att ey File#: 250589 LEGAL DESCRIPTION ALL that certain house and lot of ground situate in the Borough of Mechanicsburg,County of Cumberland, and State of Pennsylvania,more particularly bounded and described according to a survey of Gerrit J.Betz, registered surveyor,dated October 9, 1970,as follows,to wit: BEGINNING at a point marked by a nail in the Southern line of East Locust Street,at corner of land N/F of Francis L.Lerew,which said point is referenced as being 35.53 feet West of the Southwest corner of said East Locust Street and South Arch Street;thence extending along the Southern line of East Locust Street, South 77 degrees 45 minutes West 15.50 feet to a point on the line passing through the center of the partition wall of the double,two and one-half story frame dwelling house erected in part on the lot hereby described and in part on the lot adjoining on the West;thence extending along the center line of said partition wall and property N/F of James D.B.Herman,South 12 degrees 15 minutes East,39 feet to a point marked by a nail;thence continuing along the line of said lot N/F of James D.B.Herman,South 20 degrees 14 minutes East, 130.50 feet to a point marked by a hub;thence still by the line of said property N/F of James D.B.Herman South 16 degrees 41 minutes East,23.70 feet to a point marked by a hub in the Northern line of St.John's Alley;thence along the Northern line of St.John's Alley,North 75 degrees 04 minutes 30 seconds East 16.50 feet to a point marked by a hub at corner of land N/F of Ednor C. Souders; thence along the line of said land N/F of Ednor C. Souders and also land N/F of Francis L.Lerew, aforementioned North 18 degrees 29 minutes West, 194.24 feet to a nail in the Southern line of East Locust Street,aforementioned,at the point and place of beginning. HAVING THEREON erected the eastern one-half of a two and one-half story frame dwelling numbered 40 East Locust Street,Mechanicsburg,Pennsylvania. PROPERTY ADDRESS: 40 EAST LOCUST STREET,MECHANICSBURG,PA 17055-3838 PARCEL#17-23-0%"29 File#: 250589 Pennsylvania Verification CAL dxucK ,hereby states thatQshe is Vice President of JPMorgan Chase Bank,N.A.the Plaintiff in this matter,and is authorized to make this Verification. The statements of fact contained in the foregoing Amended Civil Action in Mortgage Foreclosure are true and correct to the best of my information,and belief. I understand that this statement is made subject to the penalties of 18 Pa.C.S. Sec.4904 relating to unswom falsification to authorities. Vice President Date: JA,J4,At'1 '2U/ JPMorgan Chase Bank,N.A. Borrower: DAVID J. KEPNER and KATY E.KEPNER Property Address: 40 EAST LOCUST STREET,MECHANICSBURG,PA 17055-3838 County: CUMBERLAND Last Four of Loan Number: 7971 IN THE COURT OF COMMON PLEAS JPMORGAN CHASE BANK,NATIONAL OF CUMBERLAND COUNTY,PENNSYLVANIA ASSOCIATION,SUCCESSOR BY MERGER TO G CHASE HOME FINANCE LLC C: w Plaintiff(s) M to ,{ Cr1 VS. DAVID J.KEPNER p , KATY E.KEPNER A/K/A KATY E. A C') ROMBERGER �-o Defendant(s) 10-6233-CIVIL TERM , NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action,you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer,you must take the following steps to be eligible for a conciliation conference. First,within twenty(20)days of your receipt of this notice,you must contact MidPenn Legal Services at(717)243-9400 extension 2510 or(800)822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative,you must promptly meet with that legal representative within twenty (20)days of the appointment date.During that meeting,you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto,the legal representative will prepare and a Request for Conciliation Conference with the Court,which must be filed with the Court within sixty(60)days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer,you and your lawyer must take the following steps to be eligible for a conciliation conference.It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative.However,you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf.If you and your lawyer complete a financial worksheet in the format attached hereto,your lawyer will prepare and file a Request for Conciliation Conference with the Court,which must be filed within sixty(60)days of the service upon you of the foreclosure complaint.If you do so and a conciliation conference is scheduled,you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arguments with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME,YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. Respectfully submitted: Date Ilison .Zuc Id.No.309519 Attorney for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket# BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance,your lender must consider your circumstances to determine possible options while working with your counseling agency. Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes El No Listing date: Price:$ Realtor Name: Realtor Phone: Borrower Occupied? YesEl No Mailing Address(if different): City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? Mailing Address: City: State: Zip: Phone Numbers: Home: Office: Cell: Other: Email: #of people in household: How long? First Mortgage Lender: Type of Loan: Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes&Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ❑ No❑ � r s If yes,provide names,location of court,case number&attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile#1:Model: Year: Amount owed: Value: Automobile#2:Model: Year: Amount owed: Value: Other transportation(automobiles,boats.motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Monthly Gross Monthly Net 2. Monthly Gross Monthly Net 3. Monthly Gross Monthly Net Additional Income Description(not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly]Ez nses:(Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mo a Food 2nd mortgage Utilities Car Payment(s) Condo/Neigh.Fees Auto Insurance Med. not covered Auto fuel/repairs Other prop.payment Install.Loan Payment Cable TV Child Su rt/Alim. Spending Money Da /Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income&Expenses: Have you been working with a Housing Counseling Agency? Yes❑ No❑ If yes,please provide the following information: Counseling Agency: Counselor: Phone(Office): Fax: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program(HEMAP)assistance? Yes❑ No❑ If yes,please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes❑ No❑ If yes,please indicate the status of those negotiations: Please provide the following information,if known,regarding your lender and lender's loan servicing company: Lender's Contact(Name): Phone: Servicing Company(Name): Contact: Phone: I/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that Uwe am/are under no obligation to use the counseling services provided by the above named i' t Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to lender and lender's counsel: 2. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation(hardship letter) 6. Listing agreement(if property is currently on the market) s E$ JUL 29 Air 9: :s[it'.1DERLAND PENNSYLVANIA, PHELAN HALLINAN, LLP By: Allison F. Zuckerman, ESQUIRE Identification No. 309519 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103-1814 Attorney for Plaintiff (215) 563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO COURT OF COMMON PLEAS CHASE HOME FINANCE LLC 1111 POLARIS PARKWAY CIVIL DIVISION COLUMBUS, OH 43240 Plaintiff TERM v. NO. 10-6233-CIVIL TERM DAVID J. KEPNER 112 JUNIPER DRIVE CUMBERLAND COUNTY CAMP HILL,PA 17011-8326 KATY E. KEPNER A/K/A KATY E. ROMBERGER 40 EAST LOCUST STREET MECHANICSBURG, PA 17055-3838 Defendants CERTIFICATION OF SERVICE I hereby certify a true and correct copy of Plaintiffs Amended Civil Action Complaint was served by regular and certified mail on the following on the date listed below: David J. Kepner David J. Kepner 212 Creekwood Drive 112 Juniper Drive Camp Hill, PA 17011 Camp Hill, PA 17011 David J. Kepner David J. Kepner 171 Tuckahoe Road 40 East Locust Street Dillsburg, PA 17019 Mechanicsburg, PA 17055 250589 A Katy E. Kepner a/k/a Katy E. Romberger Katy E. Kepner a/k/a Katy E. Romberger 212 Creekwood Drive 112 Juniper Drive Camp Hill, PA 17011 Camp Hill, PA 17011 Katy E. Kepner a/k/a Katy E. Romberger Katy E. Kepner a/k/a Katy E. Romberger 171 Tuckahoe Road 40 East Locust Street Dillsburg, PA 17019 Mechanicsburg, PA 17055 DATE. 4 ,1110111 Allison F. ckerm.n, Esquire Attom- for Pia'- iff 250589 Yrs PHELAN HALLINAN, LLP Attorney for Plaintiff Adam H. Davis, Esq., Id. No.203034 1_(.1 t (,' '+ 1 C t 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Ira! f Philadelphia, PA 19103 t.:-"; ' �"� 2 (� Adam.Davis @PhelanHallinan.com CUMBERLAND COUNTY 215-563-7000 PENNSYLVANIA JPMORGAN CHASE BANK, : CUMBERLAND COUNTY NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO CHASE : COURT OF COMMON PLEAS HOME FINANCE LLC : CIVIL DIVISION vs. : No. 10-6233-CIVIL TERM DAVID J. KEPNER KATY E. KEPNER A/K/A KATY E. ROMBERGER PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against DAVID J. KEPNER and KATY E. KEPNER A/K/A KATY E. ROMBERGER, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $113,843.01 TOTAL $113,843.01 I hereby certify that (1) the Defendants' last known addresses are 112 JUNIPER DRIVE, CAMP HILL, PA 17011-8326, 40 EAST LOCUST STREET, MECHANICSBURG, PA 17055- 3838, 212 CREEKWOOD DRIVE, CAMP HILL, PA 17011-8428, and 171 TUCKAHOE ROAD, DILLSBURG, PA 17019-8715, and(2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date (P721/13 Adam H. Davis, Esq., Id. No.203034 Attorney4er Pia' tiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 0- 1,g w PH#744423 PROTHONOTARY C k *(G. Q abti-I3a31c8 744423 pK:Qcriail„ vvtadpj CIA:a PHELAN HALLINAN,LLP Attorney for Plaintiff Adam H.Davis,Esq.,Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 Adam.Davis@PhelanHallinan.com 215-563-7000 JPMORGAN CHASE BANK, : CUMBERLAND COUNTY NATIONAL ASSOCIATION, : COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO CHASE . HOME FINANCE LLC : CIVIL DIVISION vs. : No. 10-6233-CIVIL TERM DAVID J. KEPNER KATY E. KEPNER A/K/A KATY E. ROMBERGER AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief,he/she has knowledge of the following facts, to wit: (a) that the defendant(s)is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant DAVID J. KEPNER is over 18 years of age and the defendant's last known addresses are 112 JUNIPER DRIVE, CAMP HILL,PA 17011-8326,40 EAST LOCUST STREET,MECHANICSBURG, PA 17055-3838, 212 CREEKWOOD DRIVE, CAMP HILL, PA 17011- 8428, and 171 TUCKAHOE ROAD, DILLSBURG,PA 17019-8715. (c) that defendant KATY E. KEPNER A/K/A KATY E. ROMBERGER is over 18 years of age and the defendant's last known addresses are 40 EAST LOCUST STREET,MECHANICSBURG, PA 17055-3838, 112 JUNIPER DRIVE, CAMP HILL,PA 17011-8326, 212 CREEKWOOD DRIVE, CAMP HILL,PA 17011-8428, and 171 TUCKAHOE ROAD, DILLSBURG, PA 17019-8715. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date 10/2/7A7 Phelan Hallinan,LLP Adam H. Davis, Esq.,Id. No.203034 Attorney for Plaintiff PHELAN HALLINAN,LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza, Philadelphia,PA 19103 215-563-7000 744423 bepartment of Defense Manpower Data Center Results as of:Oct-21-2013 12:32:05 SCRA 3.0 �x« yam € �r ` r Status Report Pursuant to Servieemembers Civil Relief Act Last Name: KEPNER First Name: DAVID Middle Name: J Active Duty Status As Of: Oct-21-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Results as of:Oct-21-2013 12:32:14 Department of Defense Manpower Data Center SCRA 3.0 t Pursuant to Servieernernbers Civil Relief Act Last Name: KEPNER First Name: KATY Middle Name: E Active Duty Status As Of: Oct-21-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects the individuals'active duty status based on the Active Duty Status Data Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received earlynotifcation to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Oviit Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 Department of Defense Manpower Data Center Results as of:Oct-21-2013 12:55:33 SCRA 3.0 , aat & ' d ' ;i Status Report Pursuant to Servieernembets Civil Relief Act Last Name: ROMBERGER First Name: KATY Middle Name: E Active Duty Status As Of: Oct-21-2013 On Active Duty On Active Duty Status Date Active Duty Start Date Active Duty End Date. Status Service Component NA NA No.-.. NA This response reflects the individuals'active duty status based on the Active Duty Status Date Left Active Duty Within 367 Days of Active Duty Status Date Active Duty Start Date Active Duty End Date Status Service Component NA NA No NA This response reflects where the individual left active duty status within 367 days preceding the Active Duty Status Date The Member or His/Her Unit Was Notified of a Future Call-Up to Active Duty on Active Duty Status Date Order Notification Start Date Order Notification End Date Status Service Component NA NA No NA This response reflects whether the individual or his/her unit has received early notification to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Center,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. Ylviloi. 411,44._ictilit;74... Mary M.Snavely-Dixon,Director Department of Defense-Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 (Rule of Civil Procedure No. 236) -Revised JPMORGAN CHASE BANK,NATIONAL : CUMBERLAND COUNTY ASSOCIATION,SUCCESSOR BY MERGER TO CHASE HOME FINANCE : COURT OF COMMON PLEAS LLC vs. : CIVIL DIVISION DAVID J. KEPNER : No. 10-6233-CIVIL TERM KATY E. KEPNER A/K/A KATY E. ROMBERGER Notice is given that a Judgment in the above captioned matter has been entered against you on )Di 9D-\1 . jft er.„03W/4 By: If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** 744423 JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION,SUCCESSOR BY MERGER TO CIVIL DIVISION CHASE HOME FINANCE LLC Plaintiff NO. 10-6233-CIVIL TERM v. DAVID J.KEPNER CUMBERLAND COUNTY KATY E.KEPNER A/K/A KATY E.ROMBERGER Defendant(s) TO: KATY E.KEPNER A/K/A KATY E.ROMBERGER 171 TUCKAHOE ROAD DILLSBURG,PA 17019-8715 DATE OF NOTICE: 1//7// THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,.THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (717)249-3166 By: 1- r 7 ole.4....4 Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PHS#250589 JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION,SUCCESSOR BY MERGER TO CIVIL DIVISION CHASE HOME FINANCE LLC Plaintiff NO. 10-6233-CIVIL TERM v. DAVID J.KEPNER CUMBERLAND COUNTY KATY E.KEPNER A/K/A KATY E.ROMBERGER Defendant(s) TO: KATY E.KEPNER A/K/A KATY E.ROMBERGER 212 CREEKWOOD DRIVE CAMP HILL,PA 17011-8428 DATE OF NOTICE: / t! l I THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFH'ICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OPFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO l'EE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (717)249-3166 By: 'ut En,"4.4• Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PHS#250589 JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION,SUCCESSOR BY MERGER TO CIVIL DIVISION CHASE HOME FINANCE LLC Plaintiff NO. 10-6233-CIVIL TERM v. DAVID J.KEPNER CUMBERLAND COUNTY KATY E.KEPNER A/K/A KATY E.ROMBERGER Defendant(s) TO: KATY E.KEPNER A/K/A KATY E.ROMBERGER 112 JUNIPER DRIVE CAMP HILL,PA 1701111-83226 DATE OF NOTICE: 67/7/13 THIS FIRM IS A DEBT COLLECTOR A'1'1'EMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (717)249-3166 By: 111 revue' Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PHS#250589 JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION,SUCCESSOR BY MERGER TO CIVIL DIVISION CHASE HOME FINANCE LLC Plaintiff NO. 10-6233-CIVIL TERM v. DAVID J.KEPNER CUMBERLAND COUNTY KATY E.KEPNER A/K/A KATY E.ROMBERGER Defendant(s) TO: KATY E.KEPNER A/K/A KATY E.ROMBERGER 40 EAST LOCUST STREET MECHANICSBURG,PA 17055-3838 DATE OF NOTICE: 677 4' THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO PEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (717)249-3166 By .. Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PHS#250589 JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION,SUCCESSOR BY MERGER TO CIVIL DIVISION CHASE HOME FINANCE LLC Plaintiff NO. 10-6233-CIVIL TERM v. DAVID J.KEPNER CUMBERLAND COUNTY KATY E.KEPNER A/K/A KATY E.ROMBERGER Defendant(s) TO: DAVID J.KEPNER 171 TUCKAHOE ROAD DILLSBURG,PA 17019-8715 [ 1 j DATE OF NOTICE: V //i THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (717)249-3166 By: Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PHS#250589 JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION,SUCCESSOR BY MERGER TO CIVIL DIVISION CHASE HOME FINANCE LLC Plaintiff NO. 10-6233-CIVIL TERM v. DAVID J.KEPNER CUMBERLAND COUNTY KATY E.KEPNER A/K/A KATY E.ROMBERGER Defendant(s) TO: DAVID J.KEPNER 212 CREEKWOOD DRIVE CAMP HILL,PA 17011-8428 DATE OF NOTICE: 16 ! 17/ ! THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFF'bR LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 p (717)249-3166 By: G �.tYt�'.1 r Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PHS#250589 JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION, SUCCESSOR BY MERGER TO CIVIL DIVISION CHASE HOME FINANCE LLC Plaintiff NO. 10-6233-CIVIL TERM v. DAVID J.KEPNER CUMBERLAND COUNTY KATY E.KEPNER A/K/A KATY E.ROMBERGER Defendant(s) TO: DAVID J.KEPNER 40 EAST LOCUST STREET MECHANICSBURG,PA 17055-3838 DATE OF NOTICE: l Ai 3 THIS FIRM IS A DEBT COI.LECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN A'1-1'BMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OPFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO PEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (717)249-3166 By: Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PHS#250589 JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION,SUCCESSOR BY MERGER TO CIVIL DIVISION CHASE HOME FINANCE LLC Plaintiff NO. 10-6233-CIVIL TERM v. DAVID J.KEPNER CUMBERLAND COUNTY KATY E.KEPNER A/K/A KATY E.ROMBERGER Defendant(s) TO: DAVID J.KEPNER 112 JUNIPER DRIVE CAMP HILL,PA 17011-8326 DATE OF NOTICE: 6/777/3 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COI.I.RCT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR 'IELEPHONE 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. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (717)249-3166 By: Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 PHS#250589 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCESSOR • COURT OF COMMON PLEAS BY MERGER TO CHASE HOME FINANCE LLC • Plaintiff • CIVIL DIVISION v. NO.: 10-6233-CIVIL TERM DAVID J.KEPNER • KATY E.KEPNER A/K/A KATY E.ROMBERGER CUMBERLAND COUNTY Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due $113,843.01 Interest from 10/23/2013 to Date of Sale $2,541.98 ($18.97 per diem) TOTAL $116,384.99 Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Note: Please attach description of property. PH#744423 c„ _ ttlid rri.11 o CAF "'�- i t— .c W << it - t _ eta DO (t " p. DO it " cri -' ilt 3105. ao at ,a,as a/7x LEGAL DESCRIPTION ALL that certain house and lot of ground situate in the Borough of Mechanicsburg,County of Cumberland, and State of Pennsylvania,more particularly bounded and described according to a survey of Gerrit J.Betz, registered surveyor,dated October 9, 1970,as follows,to wit: BEGINNING at a point marked by a nail in the Southern line of East Locust Street,at corner of land N/F of Francis L.Lerew,which said point is referenced as being 35.53 feet West of the Southwest corner of said East Locust Street and South Arch Street;thence extending along the Southern line of East Locust Street, South 77 degrees 45 minutes West 15.50 feet to a point on the line passing through the center of the partition wall of the double,two and one-half story frame dwelling house erected in part on the lot hereby described and in part on the lot adjoining on the West;thence extending along the center line of said partition wall and property N/F of James D. B.Herman,South 12 degrees 15 minutes East,39 feet to a point marked by a nail; thence continuing along the line of said lot N/F of James D.B.Herman,South 20 degrees 14 minutes East, 130.50 feet to a point marked by a hub;thence still by the line of said property N/F of James D.B.Herman South 16 degrees 41 minutes East,23.70 feet to a point marked by a hub in the Northern line of St.John's Alley;thence along the Northern line of St.John's Alley,North 75 degrees 04 minutes 30 seconds East 16.50 feet to a point marked by a hub at corner of land N/F of Ednor C. Souders;thence along the line of said land N/F of Ednor C. Souders and also land N/F of Francis L.Lerew,aforementioned North 18 degrees 29 minutes West, 194.24 feet to a nail in the Southern line of East Locust Street,aforementioned,at the point and place of beginning. HAVING THEREON erected the eastern one-half of a two and one-half story frame dwelling. TITLE TO SAID PREMISES IS VESTED IN David J. Kepner and Katy E.Kepner,his wife,by Deed from Kevin V.Anderson and Cecelia A.Anderson, (Erroneously called Cecilia A.Anderson in Prior deed),his wife,dated 05/16/2008,recorded 06/02/2008 in Instrument Number 200818121. PREMISES BEING:40 EAST LOCUST STREET,MECHANICSBURG,PA 17055-3838 PARCEL NO. 17-23-0565-029 PHELAN HALLINAN, LLP t : 1 i O I H O O TA r Attorneys for Plaintiff Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 7013 OCT 22 M1 11. 36 One Penn Center Plaza Philadelphia, PA 19103 •E BEEN COUNT T Adam.Davis @PhelanHallinan.com pEt��3SYLV AMI 215-563-7000 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, : COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC Plaintiff : CIVIL DIVISION v. : NO.: 10-6233-CIVIL TERM DAVID J. KEPNER KATY E. KEPNER A/K/A KATY E. ROMBERGER : CUMBERLAND COUNTY Defendant(s) CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned matter and that the premises are not subject to the provisions of Act 91 because: ( ) the mortgage is an FHA Mortgage ( ) the premises is non-owner occupied (X) the premises is vacant ( ) Act 91 procedures have been fulfilled ( ) Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. By: Phelan Hallinan,LLP Adam H. Davis,Esq.,Id.No.203034 Attorney for Plaintiff 1 JPMORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION, SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC CIVIL DIVISION Plaintiff NO.: 10-6233-CIVIL TERM v. DAVID J. KEPNER CUMBERLAND COUNTY KATY E. KEPNER A/K/A KATY E. ROMBERGER Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 40 EAST LOCUST STREET,MECHANICSBURG,PA 17055-3838. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained,please so indicate) DAVID J.KEPNER 112 JUNIPER DRIVE, CAMP HILL,PA 17011-8326 40 EAST LOCUST STREET, MECHANICSBURG,PA 17055-3838 171 TUCKAHOE ROAD, c.n DILLSBURG,PA 17019-8715 -p "``' °r' rn CD CD 212 CREEKWOOD DRIVE, CAMP HILL,PA 17011-8428 c!)t"- N '� KATY E.KEPNER 112 JUNIPER DRIVE, `t C A/K/A KATY E.ROMBERGER CAMP HILL,PA 17011-8326 T"a r' 40 EAST LOCUST STREET, x" r MECHANICSBURG,PA 17055-3838 _1 171 TUCKAHOE ROAD, DILLSBURG,PA 17019-8715 212 CREEKWOOD DRIVE, CAMP HILL,PA 17011-8428 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) SAME AS ABOVE. 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) PENNSYLVANIA STATE EMPLOYEES CREDIT ONE CREDIT UNION PLACE UNION HARRISBURG,PA 17110 PENNSYLVANIA STATE EMPLOYEES CREDIT 126 EAST KING STREET UNION LANCASTER,PA 17602 C/O SHAWN M.LONG,ESQUIRE PH#744423 J 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained,please indicate) BOROUGH OF MECHANICSBURG 36 WEST ALLEN STREET C/O DAVID J.SPOTTS,ESQUIRE MECHANICSBURG,PA 17055 BOROUGH OF MECHANICSBURG 36 WEST ALLEN STREET MECHANICSBURG,PA 17055 BOROUGH OF MECHANICSBURG WEST STRAWBERRY @ NORTH MARKET STREET MECHANICSBURG,PA 17055 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address(if address cannot be reasonably ascertained,please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 40 EAST LOCUST STREET MECHANICSBURG,PA 17055-3838 KATY E.ROMBERGER 147 WEST AIRPORT ROAD C/O KELLY M.KNIGHT,ESQUIRE LITITZ,PA 17543 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE DISTRICT PO BOX 11754 OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: /o/2i/(3 By: )/4 Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff PHELAN HALLINAN,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza,Philadelphia,PA 19103 215-563-7000 PH#744423 f JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, : COURT OF COMMON PLEAS SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC : CIVIL DIVISION Plaintiff : NO.: 10-6233-CIVIL TERM vs. : CUMBERLAND COUNTY DAVID J. KEPNER {_ KATY E. KEPNER A/K/A KATY E. ROMBERGER "? G Defendant(s) l cr11 :e7 Vic^ C NOTICE OF SHERIFF'S SALE OF REAL PROPERTY - .P" N.) TO: DAVID J. KEPNER DAVID J. KEPNER ° = arm.■ KATY E. KEPNER KATY E. KEPNER A/K/A KATY E. ROMBERGER A/K/A KATY E. ROMBERGER 112 JUNIPER DRIVE 40 EAST LOCUST STREET CAMP HILL, PA 17011-8326 MECHANICSBURG, PA 17055-3838 DAVID J. KEPNER DAVID J. KEPNER KATY E. KEPNER KATY E. KEPNER A/K/A KATY E. ROMBERGER A/K/A KATY E. ROMBERGER 212 CREEKWOOD DRIVE 171 TUCKAHOE ROAD CAMP HILL, PA 17011-8428 DILLSBURG,PA 17019-8715 **THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY.** Your house(real estate) at 40 EAST LOCUST STREET,MECHANICSBURG,PA 17055-3838 is scheduled to be sold at the Sheriff's Sale on 03/05/2014 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$113,843.01 obtained by JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 (800) 990-9108 r SHORT DESCRIPTION By virtue of a Writ of Execution No. 10-6233-CIVIL TERM JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC v. DAVID J. KEPNER KATY E. KEPNER A/K/A KATY E. ROMBERGER owner(s) of property situate in the BOROUGH OF MECHANICSBURG, CUMBERLAND County, Pennsylvania, being 40 EAST LOCUST STREET,MECHANICSBURG, PA 17055-3838 Parcel No. 17-23-0565-029 (Acreage or street address) Improvements thereon: RESIDENTIAL DWELLING Judgment Amount: $113,843.01 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL that certain house and lot of ground situate in the Borough of Mechanicsburg,County of Cumberland, and State of Pennsylvania,more particularly bounded and described according to a survey of Gerrit J.Betz, registered surveyor,dated October 9, 1970,as follows,to wit: BEGINNING at a point marked by a nail in the Southern line of East Locust Street,at corner of land N/F of Francis L. Lerew,which said point is referenced as being 35.53 feet West of the Southwest corner of said East Locust Street and South Arch Street;thence extending along the Southern line of East Locust Street, South 77 degrees 45 minutes West 15.50 feet to a point on the line passing through the center of the partition wall of the double,two and one-half story frame dwelling house erected in part on the lot hereby described and in part on the lot adjoining on the West;thence extending along the center line of said partition wall and property N/F of James D.B.Herman,South 12 degrees 15 minutes East,39 feet to a point marked by a nail; thence continuing along the line of said lot N/F of James D.B.Herman,South 20 degrees 14 minutes East, 130.50 feet to a point marked by a hub;thence still by the line of said property N/F of James D.B.Herman South 16 degrees 41 minutes East,23.70 feet to a point marked by a hub in the Northern line of St.John's Alley;thence along the Northern line of St.John's Alley,North 75 degrees 04 minutes 30 seconds East 16.50 feet to a point marked by a hub at corner of land N/F of Ednor C.Souders;thence along the line of said land N/F of Ednor C. Souders and also land N/F of Francis L.Lerew,aforementioned North 18 degrees 29 minutes West, 194.24 feet to a nail in the Southern line of East Locust Street,aforementioned,at the point and place of beginning. HAVING THEREON erected the eastern one-half of a two and one-half story frame dwelling. TITLE TO SAID PREMISES IS VESTED IN David J.Kepner and Katy E.Kepner,his wife,by Deed from Kevin V.Anderson and Cecelia A.Anderson, (Erroneously called Cecilia A.Anderson in Prior deed),his wife,dated 05/16/2008,recorded 06/02/2008 in Instrument Number 200818121. PREMISES BEING: 40 EAST LOCUST STREET,MECHANICSBURG,PA 17055-3838 PARCEL NO. 17-23-0565-029 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 10-6233 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC Plaintiff(s) From DAVID J. KEPNER,KATY E. KEPNER A/K/A KATY E.ROMBERGER (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: $113,843.01 L.L.: $.50 Interest FROM 10/23/2013 TO DATE OF SALE($18.97 PER DIEM)-$2,541.98 Atty's Comm: Due Prothy: $2.25 Atty Paid: $365.00 Other Costs: Plaintiff Paid: Date: 10/22/13 i David D. B ell,Prothono ary (Seal) Deputy REQUESTING PARTY: Name: ADAM H. DAVIS,ESQUIRE Address: PHELAN HALLINAN,LLP 1617 JFK BLVD.,SUITE 1400,ONE PENN CENTER PLAZA PHILADELPHIA,PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 203034 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY • JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC PH#744423 DEFENDANT SERVICE TEAM/lxh DAVID J.KEPNER COURT NO.:10-6233-CIVIL TERM KATY E.KEPNER A/K/A KATY E.ROMBERGER SERVE DAVID J.KEPNER AT: TYPE OF ACTION 1100 PINES RD XX Notice of Sheriff's Sale ETTERS,PA 17319-9202 SALE DATE: March 12,2014 SERVED Served and made known to DAVID J.KEPNER,Defendant on the 12 day of D.4) L. ,20/3,at C)S�) ,o clock/.M.,at// ° pbu-es ,in the manner described below: Defendant personally served. Adult family member with whom Defen t(s)reside(s). -� Relationship is/Z-: e I AJ t y, Adult in charge of Defendant's residence w o refused to give name or relationship. rn rn Manager/Clerk of place of lodging in which Defendant(s)reside(s). 23 L` Agent or person in charge of Defendant's office or usual place of business. > t —'CD an officer of said Defendant's company. r Other: C — > =, _ Description: Age;2 5' Height s b Weight/317 Race 6,1 Sex / Other >—= .. f._ I, ./j Aa J k , a competent adult, hereby verify that I personally handed a true and correct copy thg Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the a&lress indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. o� DATE)'12 3 NAME: [) 1 PRINTED NAME: a.m -T � 1 S� je PIO C TITLE: C'7OX5h,g 2 9 NOT SERVED On the day of ,20 at o'clock .M.,I, ,a competent adult hereby state that Defendant NOT-FOUND because: Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) _No Answer on// -/3 at 00Z- ; -l3 at 13 0b Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 Div PHELAN HALLINAN, LLP '5 10: i Attorney for Plaintiff - u- IA' .Af U COUfray 1617 JFK Boulevard, Suite 1400 PE NNSYE.VANiA One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, NATIONAL • ASSOCIATION, SUCCESSOR BY MERGER TO CUMBERLAND COUNTY CHASE HOME FINANCE LLC • COURT OF COMMON PLEAS Plaintiff • CIVIL DIVISION vs. NO. 10-6233-CIVIL TERM DAVID J. KEPNER KATY E. KEPNER A/K/A KATY E. ROMBERGER Defendants AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P.,404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail,to KATY E. KEPNER A/K/A KATY E.ROMBERGER on NOVEMBER 25, 2013 in accordance with the Order of Court dated MARCH 25, 2011. The property was posted on NOVEMBER 7, 2013. Publication was advertised in THE CUMBERLAND LAW JOURNAL on DECEMBER 6,2013 &in THE SENTINEL on NOVEMBER 27, 2013. 1 The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification to authorities. Phela .lli.. ., LLP DATE: 00 By: John :" ael Kolesnik, Esq., Id. No.308877 Au ey for Plaintiff AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, PH#744423 SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC DEFENDANT SERVICE TEAM/ lxh COURT NO.: 10-6233-CIVIL TERM DAVID J.KEPNER TYPE OF ACTION SERVE AT: XX Notice of Sheriff's Sale Sale Date:March 12,2014 40 EAST LOCUST STREET MECHANICSBURG,PA 17055-3838 SERVED Served and made known to DAVID J.KEPNER,Defendant on the day of ,20 ,at ,o'clock_.M.,at ,in the manner described below: Defendant personally served. _Adult family member with whom Defendant(s)reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age Height Weight Race Sex Other I, , a competent adult,hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: NAME: PRINTED NAME: TITLE: NOT SERVED On the day of 20 ,at o'clock_.M.,I, ,a competent adult hereby state that Defendant NOT FOUND because: _Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) _No Answer on at • at Service Refused — Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: ATTORNEY FOR PLAINTIFF PRINTED NAME: Lawrence T.Phelan,Esq.,Id.No.32227 Francis S.Hallinan,Esq.,Id.No.62695 Daniel G.Schmieg,Esq.,Id.No.62205 Michele M.Bradford,Esq.,Id.No.69849 Judith T.Romano,Esq.,Id.No.58745 Jenine R.Davey,Esq.,Id.No.87077 Lauren R.Tabas,Esq.,Id.No.93337 Jay B.Jones,Esq.,Id.No.86657 Andrew L.Spivack,Esq.,Id.No.84439 Chrisovalante P.Fliakos,Esq.,Id.No.94620 Courtenay R.Dunn,Esq.,Id.No.206779 Mario J.Hanyon,Esq.,Id.No.203993 John M.Kolesnik,Esq.,Id.No.308877 Matthew G.Brushwood,Esq.,Id.No.310592 Zachary J.Jones,Esq.,Id.No.310721 Justin F.Kobeski,Esq.,Id.No.200392 Adam Davis,Esq.,Id.No.203034 Joseph E.DeBarberie,Esq.,Id.No.315421 EMILY M.PHELAN,Esq.,Id.No.315250 One Penn Center at Suburban Station 1617 John F Kennedy Blvd,Suite 1400 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, PH#744423 SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC DEFENDANT SERVICE TEAM/ lxh COURT NO.: 10-6233-CIVIL TERM DAVID J.KEPNER TYPE OF ACTION SERVE AT: XX Notice of Sheriff's Sale 212 CREEKWOOD DRIVE Sale Date:March 12,2014 CAMP HILL,PA 17011-8428 SERVED Served and made known to DAVID J.KEPNER,Defendant on the day of ,20 ,at ,o'clock_.M.,at ,in the manner described below: Defendant personally served. _Adult family member with whom Defendant(s)reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). _Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Other: Description: Age Height Weight Race Sex Other I, ,a competent adult,hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein, issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: NAME: PRINTED NAME: TITLE: NOT SERVED On the day of 20 at o'clock_.M.,I, ,a competent adult hereby state that Defendant NOT FOUND because: Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) No Answer on at • at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. B Y: ATTORNEY FOR PLAINTIFF PRINTED NAME: Lawrence T.Phelan,Esq.,Id.No.32227 Francis S.Hallinan,Esq.,Id.No.62695 Daniel G.Schmieg,Esq.,Id.No.62205 Michele M.Bradford,Esq.,Id.No.69849 Judith T.Romano,Esq.,Id.No.58745 Jenine R.Davey,Esq.,Id.No.87077 Lauren R.Tabas,Esq.,Id.No.93337 Jay B.Jones,Esq.,Id.No.86657 Andrew L.Spivack,Esq.,Id.No.84439 Chrisovalante P.Fliakos,Esq.,Id.No.94620 Courtenay R.Dunn,Esq.,Id.No.206779 Mario J.Hanyon,Esq.,Id.No.203993 John M.Kolesnik,Esq.,Id.No.308877 Matthew G.Brushwood,Esq.,Id.No.310592 Zachary J.Jones,Esq.,Id.No.310721 Justin F.Kobeski,Esq.,Id.No.200392 Adam Davis,Esq.,Id.No.203034 Joseph E.DeBarberie,Esq.,Id.No.315421 EMILY M.PHELAN,Esq.,Id.No.315250 One Penn Center at Suburban Station 1617 John F Kennedy Blvd,Suite 1400 J IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Chase Home Finance L.LC Civil Division vs. No. 2010-6233 David J. Kepner Katy E. Kepner A/K/A KAty E. Romberger ORDER AND NOW,this t;25-44446,(lay cif _ . �'�"'!t 2011,upon consideration of Plaintiff s Motion for Service Pursuant to Special Order of Court,it is hereby ORDERED and DECREED that said Motion is GRANTED. It is further ORDERED and DECREED that Plaintiff may obtain service of the Complaint and all future pleadings on Defendant,Katy E.Kepner A/K/A KAty E. Romberger,by 1. Posting of the premises: 40 East Lot Street,Mechanicsburg, PA 17055 by the Sheriff or a non-party competent adult; 2.First class mail to Katy E.Kepner A/K/A Katy E. Romberger at the last known address, 112 Juniper Drive,Camp Hil,PA 17011;212 Creekwood Drive, Camp Hill,PA 17011; 171 Tuckahoe Road, Dillsburg,PA 17019,and the mortgaged premises located at 40 East Lot Street, Mechanicsburg,PA 17055;and 3. Publication in accordance with PA. R.C.P.430. 2 It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. _. J. Cc: David J.Kepner and Katy E. Kepner A/K/A Katy E.Romberger 40 East Lockst Street Mechanicsburg,PA 17055 David J.Kepner and Katy E. Kepner A/KIA Katy E.Romberger 112 Juniper Drive Camp Hil,PA 17011 212 Creekwood Drive Camp Hill,PA 17011 171 Tuckahoe Road Dillsburg,PA 17019 PHS4 250589/cdf 3 I o r � a r r a g �1 'ti o _. y to F. 00 -,] 0, VI 4a W N r-. .t d r.z N d a 0 ��^ z H til b 0 'v O az 7 � ›' in � � nK z � a IH Cr b j H. n g £� a00 � y � odoo 7 R ° 0 G7 C/� O r; toi cr tt t21 )-e ; --1 ." t" 'll• � y � CrJ � O o C1 1 o w .. ,.<K e i t�J tiJ r i ? G�.p,o t21 1 c O z It s 71 m 71 til C* im b C N g co 01 *4 . "'':' ..3.1-,A,--r-kk. @$ e ilkiaif g ° '� {' ya 003 AFFIDAVIT OF SERVICE PLAINTIFF CUMBERLAND COUNTY JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC PH#744423 DEFENDANT SERVICE TEAM/lxh DAVID J.KEPNER COURT NO.:10-6233-CIVIL TERM KATY E.KEPNER A/K/A KATY E.ROMBERGER SERVE KATY E.KEPNER A/KJA KATY E.ROMBERGER AT: TYPE OF ACTION 40 EAST LOCUST STREET XX Notice of Sheriff's Sale MECHANICSBURG,PA 17055-3838 SALE DATE: March 12,2014 **PLEASE ATTEMPLSER. u. i . s SERVICE IS: 'L •I r.S. ' • . • !• ACCORDANCE WITH COURLORDER*** SERVED Served and made imown to KATY K KEPNER AIK/A KATY E. ROMBERGER,Defendant on the day of t" � C/ ,20‘,,7,at o'clock M,at`f 't.7 ,1— ' `"' 'j ,in the manner described below: Defendant personally served. _Adult family member with whom Defendant(s)reside(s). Relationship is Adult in charge of Defendant's residence who refused to give name or relationship. Manager/Clerk of place of lodging in which Defendant(s)reside(s). Agent or person in charge of Defendant's office or usual place of business. an officer of said Defendant's company. Description: Age Height Weight Race Sex Other I, 1 ,a competent adult,hereby verify that I personally handed a true and correct copy of the Notice of Sheriffs Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa.C.S.Sec.4904 relating to unswom falsification to authorities. 4,1 _1014 DATE: A ( NAME: PRINTED NAME: TITLE: 6(("'4 9 ✓ jd� — NOT SERVED On the day of ,20 at o'clock M.,I, ,a competent adult hereby state that Defendant NOT POUND because : _Vacant _Does Not Exist Moved Does Not Reside(Not Vacant) No Answer on at ; at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Phelan Hallinan,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 (215)563-7000 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 December 6, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement,and that all allegations in the foregoing statements as to time, place and character of publication are true. r i , k L' a Marie Coyne, Edr SWORN TO AND SUBSCRIBED before me this 6 day of December,2013 Notary `.. rNoIARIAL SEAL DEBORAH A COLLINS No'aiy Pubic CPR!1St.E BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE OF SHERIFF'S SALE In the Court of Common Pleas of Cumberland County,Pennsylvania NO. 10-6233-CIVIL TERM JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC vs. DAVID J.KEPNER and KATY E.KEPNER a/k/a KATY E.ROMBERGER NOTICE OF SHERIFF'S SALE OF REAL PROPERTY NOTICE TO:KATY E.KEPNER a/k/a KATY E.ROMBERGER Being Premises:40 EAST LOCUST STREET, MECHANICSBURG, PA 17055-3838. Being in MECHANICSBURG BOR- OUGH, County of CUMBERLAND, Commonwealth of Pennsylvania, 17-23-0565-029. Improvements consist of residen- tial property. Sold as the property of DAVID J. KEPNER and KATY E. KEPNER a/k/a KATY E.ROMBERGER. Your house(real estate)at 40 EAST LOCUST STREET, MECHANICS- BURG,PA 17055-3838 is scheduled to be sold at the Sheriff's Sale on March 12,2014 at 10:00 A.M.,at the CUMBERLAND County Courthouse, 1 Courthouse Square, Room 303, Carlisle, PA 17013, to enforce the Court Judgment of$113,843.01 ob- tained by,JPMORGAN CHASE BANK, NATIONAL ASSOCIATION,SUCCES- SOR BY MERGER TO CHASE HOME FINANCE LLC (the mortgagee), against the above premises. PHELAN HALLINAN,LLP Attorneys for Plaintiff Dec.6 5 � .� PROOF OF PUBLICATION State of Pennsylvania, County of Cumberland Jackie Cox, Director of Sales, 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 13th, 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 SEN'l'1NEL on the following day(s): November 27, 2013 COPY OF NOTICE OF PUBLICATION NOTICE RrMNti!IN. TocOMOpAs,; Affiant further deposes that he/she is not OF CUMBERLAND COUNTY;PENNSYLVANIA' NO.10-6233-CIVIL TERM interested in the subject matter of the JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,SUCCESSOR BY aforesaid notice or advertisement,and that MERGER TO CHASE HOME FINANCE LLC_ Vs DAVID J KEPNER and KATY E.KEPNER A/K/A KATY E.ROMBERGER all allegations in the foregoing statement as NOTICE TO: KATYE KEPNER AIKIA KATY E.ROM BERGER to time, place and character of publication NOTICE OF SHERIFF'S SALE OF REAL PROPERTY are trite, Being Premises:40 EAST LOCUST STREET,MECHANICSBURG,PA 17055-3836 ( Beinoto MEOIIANIC;SBURG BOROUGH,County"crCCUMBERLAND, Ctrrrs€noowaarrih of Pnnsylvania,17�43-0505-a2 Imptevenrents cortslatof residential property. Sold as the property of DAVIO,l KEPNER lo4K,ATYE..KEPNER A/K/AKATY E ROMI3ERGER f Your hotlsa ItOINOAMM)4140 EAST LOCUST STREET MEGHAN,IOSBURO, A1T 5-30381us ohodeledlebe*aidattheSherarsealeon03f1 014' Sworn to and subscribed before me this at f 0.911 AM, ih CUMBERI, ND County Gou ors ,I CoiUiihoueu Squ€€e,Roo Si13,CerIlsle,PA 17013 t+amerce the Coud JU irntot $111,543.01 obtained by.JPMORGAN CHASE BANK,NATION -. ASSOOIATIO14I SUCCESSOR BYMEROERTO CHASE HOME;FINANCE j`1 t +I-1. I Lt0(the rrrottyagee),agdurstthe above' reralses, > ! .(„A-r (.1 _r ■ PHELANHALLINAN,LLP �J Attorney for Plaintiff J1111 t' frij I.1 Notary Public My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Bethany M.Malty,Notary Public Carlisle Boro,Cumberland County My Commission Expires Sept.26,2015 MEMBER,PrflNsYLYANIA ASSSOClAriat4 or tolrift1F PHELAN HALLINAN, LLP John Michael Kolesnik, Esq., Id. No.308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 John.Kolesnik@phelanhallinan.com 215-563-7000 Attorney for P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC Plaintiff, V. DAVID J. KEPNER KATY E. KEPNER AJK/A Defendant(s) TY E. ROMBERGER PRO 2014 flAR 10 Atl 9: 37 ilIBERLAND COUNTY PENNS 'QM WA CUMBERLAND COUNTY COURT OF COMMON PLEAS : CIVIL DIVISION : No.: 10-6233-CIVIL TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required. by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is attached h Ehi1t "A". Date: 7 0/ "chael Kolesnik, Esq., Id. No.308877 orney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PH # 744423 Name and Phelan Hallinan, LLP . Address Of II* 1617 JFK Boulevard, Suite 1400 Sender One Penn Center Plaza , Philadelphia, PA 19103 AilC/DDA - 03/12/2014 SALE Line A Article Number N . Postage ' 2 L ' Z Z **a* T . . 2 • • •*• B , " • • rm 3877 Facsimile ,0 SHERIFF'S OFFICE OF CUMBERLAND COUNTY RonnyRAnderson E LED-OFrIC Sheriff OF THE PROTHONOTARY Jody S Smith Chief Deputy Richard W Stewart Solicitor OFf3C OF' NE RERWF 201R JUL 25 PM 2: 34 CUMBERLAND COUNTY PENNSYLVANIA JPMorgan Chase Bank, N.A. vs. David J. Kepner (et al.) Case Number 2010-6233 SHERIFF'S RETURN OF SERVICE 01/09/2014 11:10 AM - Deputy Ronald Hoover, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 40 East Locust Street, Mechanicsburg - Borough, Mechanicsburg, PA 17055, Cumberland County. 01/09/2014 11:10 AM - Deputy Ronald Hoover, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Katy E. Kepner, pursuant to Order of Court by "Posting" the premises located at 40 E. Locust Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County with a true and correct copy according to law. 01/31/2014 Ronny R Anderson, Sheriff, being duly sworn according to law, states that he made a diligent search and inquiry for the within named Defendant, to wit: David J. Kepner, but was unable to locate the Defendant in his bailiwick. He therefore returns the within Real Estate Writ, Notice and Description, in the above titled action, as "Not Found" at 40 E. Locust Street, Mechanicsburg Borough, Mechanicsburg, PA 17055, property is vacant, defendant did not leave a forwarding address with the post office. 03/12/2014 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 on March 12, 2014 at 10:00 a.m. He sold the same for the sum of $ 63,000.00 to Attorney Joseph Schalk, on behalf of , being the buyer in this execution, paid to the Sheriff the sum of $ 04/11/2014 Proposed Schedule Of Distribution Posted SHERIFF COST: $2,494.50 SO ANSWERS, April 30, 2014 RONNY R ANDERSON, SHERIFF a. 1. 20 ,S7),S7). . /2e. (c) CountvSu e S?serif`. 'T'elecsatt, Inc. On November 7, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Mechanicsburg Borough, Cumberland County, PA, Known and numbered as, 40 East Locust Street, Mechanicsburg, as Exhibit "A" filed with this writ and by this Reference incorporated herein. a: (--- F-: cv CL Date: November 7, 2013 1-GM :r N W Ct Com! .l C By: AS Real Estate Coordinator LXIII 4 CUMBERLAND LAW JOURNAL 01/24/14 Writ No. 2010-6233 Civil Term JPMorgan Chase Bank, N.A. vs. David J. Kepner Katy E. Kepner Atty.: Joseph Schalk By virtue of a Writ of Execution No. 10 -6233 -CIVIL TERM, JPMOR- GAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO CHASE HOME FI- NANCE LLC vs. DAVID J. KEPNER, KATY E. KEPNER a/k/a KATY E. ROMBERGER, owner(s) of property situate in the BOROUGH OF ME- CHANICSBURG, CUMBERLAND County, Pennsylvania, being 40 EAST LOCUST STREET, MECHAN- ICSBURG, PA 17055-3838. Parcel No. 17-23-0565-029. Improvements thereon: RESIDEN- TIAL DWELLING. Judgment Amount: $113,843.01. 46 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: January 24, January 31, and February 7, 2014 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 Coyne, E SWORN TO AND SUBSCRIBED before me this 7 day of February, 2014 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 ')The Patriot -News Co. 2020 Techno&ogy Pkwy Suite 300 ' Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND CO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 the patriotNews 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 the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 3/00, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot -News and The Sunday Patriot -News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot -News and The Sunday Patriot -News were established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement 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. 2010-6233 Civil Term JPMorgan Chase Bank, N.A. Vs David J. Kepner Katy E. Kepner Atty: Joseph Schalk By virtue of a Writ of Execution No. 10 -6233 -CIVIL TERM JP MORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR BY MERGER TO CHASE HOME FINANCE LLC v. DAVID J. KEPNER KATY E. KEPNER AIK/A KATY E. ROMBERGER owner(s) of property situate in the BOROUGH OF MECHANICSBURG, CUMBERLAND County, Pennsylvania, being 40 EAST LOCUST STREET, MECHANICSBURG, PA 17055- 3838 Parcel No. 17-23-0565-029 (Acreage or street addd..Im DENTents AL thereon: DWELLING Judgment Amount: $113,843.01 This ad ran on the date(s) shown below: 01/19/14 01/26/14 02/02/14 1 COMMONWEALTH OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, notary Public Washington Twp., Dauphin County My Commission Expires Dec. 12, 2016 MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND } SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which SRMOF-II 2012-1 Trust is the grantee the same having been sold to said grantee on the 12th day of March A.D., 2014, under and by virtue of a writ Execution issued on the 22nd day of October, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2010 Number 6233, at the suit of JPMorgan Chase Bank, NA against David J. Kepner & Katy E. Kepner a/k/a Katy E. Romberger is duly recorded as Instrument Number 201416262. IN TESTIMONY WHEREOF, I have -�herreunto set my hand and seal of said office this 025 day of Jud ,A.D. 0-01(/ 15 0. (A).z.J147,); D v C .. Recorder of Dleeds Recorder of Deeds, Cumberland Cnunty. Carlisle, PA My Commission, Expires the First n uriday of Jan. 2018