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HomeMy WebLinkAbout12-1002IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYItXANIA C: -- -rl JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t c• CHASE MANHATTAN MORTGAGE NO.: M;p CI?I, ?? sa• CORPORATION, ' n Plaintiff, TYPE OF PLEADING Co vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. TO DEFENDANTS You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF ?'. Jc ATTORNEY FOR PLAINTIFF I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: 3415 Vision Drive Columbus, OH 43219 AND THE DEFENDANTS IS: 345 Fulton Street Enolaaa,, PA 17025 ATTORNEY FOR PLAINTIFF CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS 345 Fulton Street. Township of East Pennsboro (CITY, BORO, TOWNSHIP,WARD) ATTORNEY FOR PLAINTIFF CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSURE FILED ON BEHALF OF PLAINTIFF: JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 CJ .? r- -i Fri 5 d) awk\ 'U 102.-) .s -P 4 n 0k# 1sl IZA- a 703 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE NO.: CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim 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 Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE NO.: CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, by its attorneys, Grenen & Birsic, P.C., files this Complaint in Mortgage Foreclosure as follows: 1. The Plaintiff is JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, which has its principal place of business at 3415 Vision Drive, Columbus, Ohio 43219 and is authorized to do business in the Commonwealth of Pennsylvania. 2. The Defendants, Jared E. Wallace and Kimberly T. Wallace, are individuals whose last known address is 345 Fulton Street, Enola, Pennsylvania 17025. 3. On or about December 9, 1999, Defendants executed a Note in favor of 1St Central Mortgage in the original principal amount of $96,800.00. A true and correct copy of said Note is marked Exhibit "A", attached hereto and made a part hereof. 4. On or about December 9, 1999, as security for payment of the aforesaid Note, Defendant made, executed and delivered to 1St Central Mortgage a Mortgage in the original principal amount of $96,800.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on December 20, 1999 in Mortgage Book Volume 1588, Page 15. A true and correct copy of said Mortgage, containing a description of the premises subject to the Mortgage ("Mortgaged Premises"), is marked Exhibit "B", attached hereto and made a part hereof. 5. On or about December 20, 1999, 1St Central Mortgage assigned all of its right, title and interest in and to the Mortgage and Note to Flagstar Bank pursuant to the terms of a certain Assignment of Mortgage, recorded in the office of the Recorder of Deeds of Cumberland County at Mortgage Book Volume 633, Page 1038. A true and correct copy of said Assignment of Mortgage is marked as Exhibit "C", attached hereto and made part hereof. 6. On or about August 28, 2000, Flagstar Bank assigned all of its right, title and interest in and to the Mortgage and Note to Fannie Mae pursuant to the terms of a certain Assignment of Mortgage, recorded in the office of the Recorder of Deeds of Cumberland County at Mortgage Book Volume 653, Page 613. A true and correct copy of said Assignment of Mortgage is marked as Exhibit "D", attached hereto and made part hereof. 7. On or about March 31, 2004, Fannie Mae assigned all of its right, title and interest in and to the Mortgage and Note to Plaintiff pursuant to the terms of a certain Assignment of Mortgage, recorded in the office of the Recorder of Deeds of Cumberland County at Mortgage Book Volume 707, Page 546. A true and correct copy of said Assignment of Mortgage is marked as Exhibit "E", attached hereto and made part hereof. 8. Defendants are the record and real owners of the aforesaid Mortgaged Premises. 9. Defendants are in default under the terms of the Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. Defendants are due for the September 1, 2009 payment. 10. On or about May 7, 2010, Defendants were mailed Notices of Homeowner's Emergency Mortgage Assistance Act of 1983 ("Act 91 Notices") in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act 91 of 1983, as amended. 11. Plaintiff was not required to send Defendants separate Notices of Intention to Foreclose Mortgage in compliance with Act 6 of 1974, 41 P.S. §101, et seq., as a result of sending the Act 91 Notices. 12. The following amounts are due to Plaintiff on the Mortgage as of October 27, 2011: Principal $ 92,035.01 Interest from 8/1/09 through 10/27/11 $ 16,239.61 Late Charges $ 342.81 Escrow Deficiency $ 4,014.41 Corporate Advances S 286.00 Suspense Balance ( S 58.89) Attorneys' Fees S 650.00 Foreclosure Costs S 342.00 TOTAL $113,850.95 WHEREFORE, Plaintiff demands an in rem judgment against the Defendants in the sum of $113,850.95, together with interest, costs, fees, and charges collectible under the note and mortgage including but not limited to attorneys fees and costs, and for the foreclosure and sale of the mortgaged property. GRENEN & BIRSIC, P.C. BY: P L Kristine M. Anthou, Esquire Brian M. Kile, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" 12/09/1999 11:38 4105618736 FIRST CENTRAL MORTG PAGE 08 NOTE LOW IN ? DmClOtm STm, list RAMNM wzmwYt,VAwia la9l maw 345 VMTOx STR>sr, NMI, agpgn,VAXZ& 17075 ly!eptt AM-4 L NOOMMM'S M%= TO PAY In t== for a !ran do I hue maivad. I promise m psy U.S. S 56, goo. co Ws mom in caw mipal'). On bona. logo order Ode kerbs. The laodet is More Tis laades or I madmtt ml the to ladtr mq undir mfg agyme who ahm dds Nome by mm=fa ad wbD is eaNd m Native P7ee W mode dds Note b Coned the Name solder.' 1. QPHO>dJ T bd-d wen be dmr m wvW poimipd ga0 me NO maame of prladpl hen bag Peid I in w ply in- at a ymedy twte d 7.97 %. The inli= Cone req®e' by raft Secdom 2 b me eke I wM pay bah befog ad afe amy ddmh dmibed im Settles 6(S) of Thu Note. 3. PATAISM W TWO Coed Phmm of Pgmamte 1 will pq pdw*d ad immm by -lift PBJ -2Y mash 1 *0 gift my waft pgmea4 on me 1ST dq of mei eomm bclhm* m PIPMART LOT, 2000. 1 vdf maim t3mw p4mam1 Quay Mmm tame I Due paid as of the pdmelpd ad imwvm ad Coq other doom damtsibwd bdosr tbs t aft me w des sea Note. My aemmty Mmem MR bs WNW to Woman beats pdadpaL If om MOLNIT 1sT, 3030 150 awe ammcte under thin Noce. I wiR pay dime amomm is W as Thar doe, s6kh Y CoHad me Wde ty Date. I WW =b rap mmmly Irymeou at 57 wT T=M= RQAD, Stirs 117, T3310pigt, ND 2,1093 mgm3d by the Nate Holder. of at a diffmmt plies if My 111 peymem wM be In dto emomre of U.S. $ 701. 87 L BORROMM S KlGffr TO PRUAY I hue The debt te amber Paymmte of pia*d u any dens I - I P mey as be. A payment of pigdpN ody is bows = g'pmpgymm[. - WLes I Mk A Paepgye IC I wRI all mm Note solder : wdtly do i = do* Ten. =1 ftb RoI) OF POW Ptspye=m winos PlM Corp PmpwpRm dUlL The Nam Holder wO IM ell of my prepaymema e0 aeiam me agoras of pdoripal ran I an Trade mY NOW. U 1 gslw m p W W peepaymem, ftsm a saw ? is The doe due or In the amass of my m Wdy paymem unlem me Now Homer genera is 5. LOAN CBAIMS If a 4w, which WDU a WE Ism had which Cola mi- bas Oharya. it 9=111 imupaewd s0 and do imtaeu or Omer be chmjm Collected at m be mllemed In eommecdm win di Iom pa=d me peeWd lrTmie. then W may nett km d mp dm bo tw I by de amwm mmemmy to taboo mw sharp iD to pu=*W llolk gad (? any foes dwdy Co9u=d b= am bhkh earamdd rmdmd bolts will be loaded to me. The Note Holder may choom to mate rah wfund by tedodn mo pdm*d i owe wader die Note or by mo km m d'im pymsm to me. If a rem teAamer ptltdpd. Om w6c" will be treated o a pmW pepgynk m. 6. OW20 M'S PAn= 70 PAY AS REQUMED W IoM Charpw hr Ow- Psyssatle V sir Noe Holder hen mt n:d% d dte an mmmnm of may mmmly pemw by *and of OisTpp cdmdm.daye giber dte dog It is do. I wM pay a Yen AW so the Nom Hddet. The Mom of dw dmp vW be 5.000 S of my oven paymem d priuW rod imeom I will pay this tune dmp p =pdy ben poly ma as pole hwe pgmmm. (30 D46mb If I do am pay me fh9 amens of owh mmmty payment on de dens it im dm. I will be in &bgk (C) Not he of Dehmh If I = h ddWk the Note Haider may load me a WAM mti0e Wlipp me mm if 160 we py de ovedme mom by a plain date, &0 Note Holder aaq Invite ma te Pg lmmeaimdy the fen ammam of PdX*d whir! hen goer bees POW ad aR me ills" mat I owe m mm =amt. Tbs dam ra=t be a lean 30 dap aft de bat on whkh, the Mum is denvald of mdlod to ere. (D) No Wdvmr By Nth Holder nvun if. rat a rive whm 1= iO &Wt. IM NOW Hold" dog mm sprig me m pay kmoedWy in aR m dm tPmd Am. de Nog: Folder wM rant Love me 0* m do so if I = in dram[ s m brae time. (1) Pq=rot d Nab WWs Cow ODd Comm If de Nom Hddw I m to , I m to ply i= Wiatdy m an m desaibd about, rte Note Hamer wiR hue de d* Ten be paW b=k by Coo fa an of its omm no egg ms in=ftcim dug Nose to mw macs mot ptohmimd by mw%c*k law. mmu Corpsmen iadode. for atample, teuomme somaaeys, fem. MMTWATi P= RAZE R07i . lk& Rely - FPDcAmMAW memGmm natml p"M "IG1G - unlym hp l stf yatte am um gee h4 Ptem tent, 12/09/1999 11:30 0105610736 FIRST CENTRAL MCRTG PAGE 09 7 GIVRY(i OF NO'17(]fS LOAt =6 000030923 Ud- Mokable tar tagd- A digetee medal. aq - dat son t be Flan to no aada Mis Nob vM b Om by ddly dxo It tr by mnlot it by &u don m7 so we at de Peopyly Addeea !bow OF at a &ffmw W&M it I Flve d. Note Nokia a nodm of my &D am Adh=. Any so" "mast be Om m dw Noce Ndda mda tbb NM will be given u t it by that d= mail eo de Nab HoMa a tba addtem Mod is Swdw 3(A) above or a a dlffaeat aft= I st I am Fivm a antloe of tbst dffT address R ORUGAIJamS OF PXRSOW UNDER 7M NOTE if mote dm ane r taw din Ntu, each Pwua b Aft and pbamauy MiSSIM m beep as of da peoaaiua Maude in dim Nob ldu4 do pawim io pq the top =saw owad. Any pmaa ska Y a 0aaaamw, auNy or aalmmr of dis Nob Is do obllFard b do des *b$L Any pemon who W= ova do= obNpdms, bdit to aiiipdm of a Fnwwor. An1y Of nmema Of dk Nob, b AW tdlipwl m beep 60 of do poOMdM nails in d s Nob, 7b New Hilda may ads= up dies seder ibis Nob spiut each ptssm ledlvidaslly of spiaat all of ON bFadw. Tsds MOMS dtw aq aoe of u may be Mpi ed to pay aD of de pewee owed %aft ilia Nm. f. WAiVW On don Qat mad votice oo(Mftm . 201200 to dot b repbe Nabdk Hilda dowised Ps w Ok=. arum rho rich 4 setpwe *a Now Hddw b Five !aloe to otbw per of m wb 'n odoe a ot dltboaorm do !parr rica e baro ttatbem paid. 10 . MWORbt WCEMW NOU This Nab b a mifotm issrsmee WA limbed vukdou in some judodkdou, is addltian b bM pabdlo m Sim ao de NM Nddr ssdQ tbt NOW, s MWOP, Deed of 71ut or Sa Deed (du 'Secvthy baasaaeMO'), dried de same dab u d do Nab, Ptoenob do Nwe Hdda am peaft wen wbkh Misu nab U I do trot bap the pMMiM MW* I ends in this Noto. Tint 9-ity Wousu at &wdbia bow mad UAW mW cowdedop I my be tegaited m m b itmeedire pay== In hD of an =own I owe nda rib Now Some of MOON coodifions as daubed u foDows: T am der at the Faapaty or a Bewdtlal latatad in samowwr. If Au or any pot of do Pmpaty Or aaw iOMM In it is add or aaaafeued (a Ha besefidd ismon is B=oww is soM at uaa des" am summa b Mc a sew d Pasch) widmi E=Ws pow ,edam ooana. Lemur may. at IN opdm, eagoha immedw pymmt in lbn Of A MOM seemed by dt Se-oo batmum. Nomura ds opim dull mat be eaetNSud by Lads H erMeiMa is Pwhibiwd by feduml law u of de due of this Saewity beta meat. If Lerch tam dim aploa, Lpder tdmU SM Barom mdu of mo an. 77e wtice *d provide s Pedal of as IMO des 30 days Sam de 4W d• nmiea Is &Avaod OF madm widen WWd lonOmar smrl pq an sm aeead by do &o mty lon m . if Sonoma Sit w pay dun sums piw w de cgdrWm of dt period, Lsma mq kvabe 07 9*MM w pamittod by dis Setwity bauomem Wldoat finder aauu w dtmam aft Sonoma. WIrNBSS THB HAND(S) AND $BAI.(S) OF TM UNDERSI s. WALLACS -Sonoma _Ba vo? d) Ad) .sonowa ISuq .Bweowec ''Seaq -Bonower -Boemwer Paz 70 2W CUM Oi:ll:i1WYM BJIIti •='lMM MMac? -?- Vv- M iJDIV1INT INC. By; :? PAY TO THE ORDER OF 1 RECOURSE a BA\:C F S U AATC30 - Mr119A lNEW Oe S&d Ohl F&M lsw U M bow revs Mq arc. FWKWHE ORDER OF FFLAAGSTAR BANK, FSB -.76e BY FLAGSTAR F A IN FACT U/P/A DATE P' B,r• Chw* S&Atrby AaalslMd VIbM PreWenl 998030923 345 Ful(m Emlc m im Z EXHIBIT "B" / v 7 7 AFTER RECORDING MAIL TO: 1sT"=ZMIVAL NMMVaai, IM. 57 MST TDOMMU ROAD SUITZ 217 T111s1NICM DID- LOAN NO. i [epaoe R08EO %?uMCFocDrP 0rlOF OCeo Above This Line For Recording Data] N S MMTGAM IUEC ?n v"' r' PA THIS MORTGGY ("Security Inatrnmant") is given on December 9, 1999. The mortgagors aren/7 1I Jared i. Wallace and Kimberly T. Wallace ("Borrower"). This Security Instrument is given to 1st 30 Central Mortgage, Inc. whom are organized and existing under the laws of the State of Maryland, and whose address is 57lfest Timonium Rd., Suite 217, Tinonium, ND 21093 (Lender). Borrower owes Lender the principal sum of Ninety Six Thousand Eight Hundred and no/100 (U.S. $96,800.00). This debt is evidenced by Borrowers' note dated the acme date as this Secuzity Instrument (Note), which provides for nrnnthly payments, with the full debt, if not paid earlier, due and payable on January 1, 2030. This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the Note; (b) the payment of all other sumo, with interest, advanced under paragraph seven (7) to protect the security of this Security Instrument; and (c) the performance of Borrowers' covenants and agreements under this Security Instrument and the Note. For this purpose, Borrowers do hereby mortgage, grant and convey to Under the following described property locited in Cumberland County, Pennsylvania: Please air attached Legal Description. which has the address of 395 Hilton Street Enola , Pennsylvania, 17025 (Street) (City) TOGETHER WITH all the improvements now or hereafter erected on the property, and all easements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and additions shall also be covered by this Security Instrument. All of the foregoing is referred to in this Security instrument as the "Property". BORROWERS COVENANT that Borrowers are lawfully seised of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record. Borrower warrants and will defend generally the title to the Property against all claims and demands, subject to any encumbrances of record. THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform covenants with limited variations by 3urisdiction to constitute a uniform security instrument covering zeal property. UNIFORM COVENANTS. Borrower and Lender covenant and agree as follows: 1. Paymemet of Principal and Interest; Pzvpayment and Late Charges. Borrower shall promptly pay when'due the principal of and interest on the debt evidenced by the Note and any prepayment and late charges due under the Note. 2. 7unds for Taxes and Insuranoe. Subject to applicable law or to a written waiver by Lender, Borrowers shall pay to Lender on the day monthly payments are due under the Note, until the Note is paid in full, a sum ('Funds") for: (a) yearly taxes and assessments which my attain priority over this Security Instrument as a lien on the Property; (b) yearly leasehold payments or ground rents on the Property, if any; (c) yearly hazard or property insurance premiums; (d) yearly flood insurance premiums, if any; (e) yearly mortgage insurance premiums, if any; and (f) any suss payable by Borrowers to Lender, in accordance with the provisions of Paragraph eight (8), in lieu of the payment of mortgage insurance premiums. These item are called 'Escrow Items". Lender may, at any time, collect and hold Funds in an amount not to exceed the maximum amount a lender for a federally related mortgage loan may require to Borrower's escrow account under the federal Real Estate Settlement Procedures Act of 1979 as amended from time to time, 12 U.S.C. 2601 at seq. ("RESPA"), unless another law that applies to the Fu Ax sets a lesser amount. If so, Lender may, at any time, collect and hold Funds in an amount not to exceed the lesser amount. Lender may estimate the amount of Fluids due on the basis of current data and reasonable estimates of expenditures of future Escrow Items or otherwise in accordance with applicable law. The Funds shall be held in an institution whose deposits are insured by a federal agency, instrumentality, or entity (including Lender, if Lender is such an institution) or in any Federal Home Loan Bank. Lender shall apply the Funds to pay the Escrow Items. Lender may not charge Borrowers for holding and applying the Funds, annually analyzing the escrow account, or verifying the Escrow Items, unless Lender pays Borrowers interest on the Funds and applicable law permits Lender to make such a charge. However, Lender may require Borrower to pay a one-time charge for an independent real estate tax reporting service used by Lender in connection with this loan, unless applicable law provides otherwise. Unless an agreement is made or applicable law requires interest to he paid, Lender shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender may agree in writing, however, that interest shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual accounting of the Funds, showing credits and debits to the Funds and the purpose for which each debit to the Funds was made. The Funds, showing credits and debits to the Funds and the purpose for which each debit to the Funds was made. The Funds are pledged as additional security for all sums secured by this security instrument. If the Funds held by Lender exceed the amounts permitted to be held by applicable law, Lender shall account to Borrower for the excess Funds in accordance with the requirements of applicable law. If the amount of the Funds held by Lender at any time is not sufficient to pay the Escrow Items when due, Lender may so notify Borrower in writing, and in such case Borrower shall pay to Lender the amount necessary to make up the deficiency- Borrower shall make up the deficiency in no more than twelve monthly payments, at Lender's sole discretion- Upon payment in full of all sums secured by this Security Instrument, Lender shall promptly refund to Borrower Funds held by Lender. If, under paragraph 21, Lender shall acquire or sell the Property, Lender, prior to the acquisition or sale of the Property, shall apply any Funds held by Lender at the time of acquisition or sale as a credit against the sum secured by this Security instrument. 3. Application of Payments. Unless applicable law provides otherwise, all payments received by Lender under paragraphs 1 and 2 shall be applied: first, to any prepayment charges due under the Note; second, to amounts payable under paragraph 2; third, to interest due; forth, to principal duet and last, to any late charges due under the Note. 1. Marque; Liens. Borrower shall pay all taxes, assessments, charges, fines and imq;03lt3.0ns attributable to the Property which may attain priority over this Security Instrument, and leasehold payments or ground rents, if any. Borrower shall pay these obligations in the manner provided in paragraph 2, or if not paid in that manner, Borrower shall pay them on time directly to the person wed payment. Borrower shall promptly furnlsh to Lender all notices of amounts to be paid under this paragraph. If Borrower makes these payments directly, Borrower shall promptly furnish to Lender receipts evidencing the payments. Borrower shall promptly discharge any lien which has priority over this security Instrument unless borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner eood588 vac¢ . 15 acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal' proceedings which in the lender's opinion operate to prevent the enforcement of the lien; or (c);aeowres from the holder of the lien an agreement satisfactory to Lender subordinating the lien to this security Instrument. If Lender determines that any part of the Property is subject to a lien which may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. S. Renard or Property Insurance. Borrower skull keep the improvements now existing or hereafter erected on the Property insured against loss bi fire, hazer" included within the term "extended coverage" and any other hazards, including floods or flooding, for which leader requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's approval which shall not be unreasonably withheld. If Borrower fails to maintain coverage described above, Lander may, at Lender's option, obtain coverage to protect Lender's lights in the Property in accordance with paragraph I. All insurance policies and renewals shall be acceptable to Lender and shall include a standard mortgage clause. Lender shall have the right to hold the policies and renewals. If Lender requires, Borrower shall promptly give to Lender all receipts of paid premiums and renewal notices. In the event of loss, Borrower shall give prompt notice to the insurance carrier and Lender. Lender may make proof of loss if not made promptly by Borrower. Unless Lender and Borrower otherwise agree in writing, insurance proceeds shell be applied to restoration or repair of the Property damaged; if the restoration or repair is econoxucally feasible and Lender's security is not lessened. If the restoration or repair is not economically feasible or Lender's security would be lessened, the insurance proceeds shall be applied to the sums secured by this Security Instrument, Anther or not then due, with any excess paid to Borrower. If Borrower abandons the Property, or does not answer within 30 days a notice from Lender that the insurance carrier has offered to settle a claim, then Lender may collect the insuzancelproceeds. Lender may use the proceeds to repair or restore the Property or to pay sums secured by this security Instrument, whether or not then due. The 30-day period will begin when the notice is given. Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal shall not extend or postpone the due data of the monthly payments referred to in paragraphs 1 and 2 or change the amount of the payments. If under paragraph 21 the Property is acquired by Lender, Borrower's right to any insurance policies and proceeds resulting from damage to the Property prior to the acquisition shall pass to Lender to the extent 'of the sum secured by this Security Instrument immediately prior to the acquisition. 6. Ocaup-May, Preservation, Mmunteusuce and Proteotzon of the Property; Borrower's Loan Application; Leaaebolds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument and shall continue to occupy the Property as Borrower's principal zesidencelfor at least one year after the date of occupancy, unless Lander otherwise agrees in writing which consent shall not be unreasonably withheld, or unless extenuating circumstances exist which are beyond Borrowers control. Borrower shall not destroy, damage or impair the Property, allow the Property to deteriorate, or commit waste on the Property. Borrower shall be in default if any forfeiture action or proceeding,` whether civil or criminal, is begun that in Lender's good faith judgment could result in forfeiture of the Property or otherwise materially impair the lien created by this Security Instrument or Lender's security interest. Borrower may cure such a default and reinstate, as provided in paragraph 10, by causing the action or proceeding to be dismissed with a ruling that in Lender's good faith determination, precludes forfeiture of the Borrower's interest in the Property or other material impairment of the lien crested by this Security Instrument or Lender's security interest. Borrower shall also be in defoultlif Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (oz failed to provide Lender with any nitezial information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this security Instrument is on a leasehold, Borrower shall comply with all the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless Lender agrees to the merger in writing. 7. Protection of Landsr's Rights in the'Property. If Borrower fails to perform the covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as'a proceeding in bankruptcy, probate, for condemnation or forfeiture or to enforce laws or regulstions),;then Lender may do and pay for whatever is necessary to protect the value of the Property and Lender's rights in the Property. Lender's actions may include l paying any sups secured by a lien which has priority over this Security Instrument, appearing in court, paying reasonable attozneys' fees and entering on the Property to make repaira. Although Lender may take action under this paragraph 7, Lander does notlhave to do so. Any amounts disbursed by Lender under this paragraph 7 shall become additional debt of Borrower secured by this Security Instrument. Unless Borrower and Lender agree to other term of payment, these amounts shall beer interest from the date of disbursement at the Note rate and shall be payable, with interest, upon notice from Lender to Borrower requesting payment. 6. Mortgage Insuranoe. If Lender required mortgage insurance as a condition of making the loan secured by this Security Instrument, Borrower shall pay the premiums required to maintain the mortgage insurance in effect. If, for any reason the mortgage insurance coverage required by Lender lapses or ceases to be in effect, Borrower shall pay the premiums required to obtain coverage substantially equivalent to the mortgage insurance previously in effect, at a cost substantially equivalent to the cost to Borrower of the mortgage insurance previously in effect, from an alternate mortgage insurer approved by Lender. If substantially equivalent mortgage insurance coverage ra not available, Borrower shall pay to Lender each month a sum equal to one-twelfthlof the yearly mortgage insurance premium being paid by Borrower when the insurance coverage lapsed or ceased to be in affect. Lender will accept, use and retain these payments as a loan reserve in lieu of mortgage insurance. Loss reserve payments may no longer he required, at the option of Lender, if mortgage insurance coverage (in the amount and for the period that Lender requires) provided by an insurer approved by Lender again becomes available and is obtained. Borrower shall pay the premiums required to maintain mortgage insurance in effect, or to provide a loss reserve, until the requirement for mortgage insurance ends in accordance with any written agreement between Borrower and Lender or applicable law. 9. Inspeation. Lender or rta agent may make reasonable entries upon and inspections of the Property. Lender shall give Borrower notice 'at the time of or prior to an inspection specifying reasonable cause for the Inspection. 10. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in lieu of condemnation, are hereby assigned and shall k)e paid to Lender. In the event of a total taking of the Property, the proceeds shall be applied to the sums secured by this Security Instrument, whether or not then1due, with any excess paid to Borrower. In the event of a partial taking of the Property in which the fair market value of the Property immediately before the taking is equal to or greater than the amount of the sums secured by this Security instrument immediately before the taking, unless Borrower and Lender otherwise agree in writing, the sums secured by this security Instrument shall be reduced by the amount of the proceeds multi-plied by the following fraction: (a) the total amount of the sums secured immediately before the taking, divided by (b) the fair market value of the Property immediately before the taking. Any balance shall be paid to Borrower. In the event of a partial taking of the Property in wlich the fair market value of the Property immediately before the taking is less than the amount of the sums secured immediately before the taking, unless Borrower and Lender otherwise agree in writing or unless applicable law otherwise provides, the proceeds DWWJi ),08 FACE • 16 shall be applied to the sums secured by this, Security Instrument whether or not the sums are then due. If the Property is abandoned by Borrower, or if, after notice by Lander to Borrower that the condemnor offers to make an award or settle a claim for damages, Borrower fails to respond to Lender within 30 days after the date the notice is given, Lender is authorized to collect and apply the proceeds, at its option, either to 'restoration oz repair of the Property or to the sums secured by this Security instrument, whether or not then due. ` Unless Lender and Borrower otherwise agree in writing, any application of proceeds to principal 1 shall not extend or postpone the due date of the monthly payments referred to in paragraphs 1 and 2 or change the amount of such payments. 11. Borrower Not Released; Forbearance By Lander Not a Waiver. Extension of the time for payment or modification of amortization of the mums secured by this Security Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successors in interest. Lender dhall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sumo secured by this Security instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or xemedy. 12, eueeessors and Assigns Bound; Joint and several Liability; Co-signers. The covenants and agreements of this Security Instrument shaillbind and benefit the successors and assigns of Lender and Borrower, subject to the prOViaions of paragraph 17. Borrower's covenants and agreements shall be joint and several, Any Borrower who co-signs thislSecurity Instrument but does not execute the Note: (a) is co-signing thin Security Instrument only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument: (b) is not personally obligated to pay the sums secured by this security Instrument; and (c)l agrees that Lender and any other Borrower may agree to extend, modify, forbear or make any accommodations with regard to the terms of this Security Instrument or the Note without that Borrower's consent.' 13. Login Charges. If the loan aecured,by this Security instrument is subject to a law which sets maximum loan charges, and that law is finally interpreted so that the interest or other loan charges collected or to be collected in connection with the loan exceed the permitted limits, then: (a) any such loan charge shall be reduced by the amount necessary to reduce the charge to the permitted limit; and (b) any sums already collected from Borrower which exceeded permitted limits will be refunded to Borrower. Lender may choose to make this refund by reducing the principal owed under the Note or by making a direct payment to Borrower. If a refund reduces principal, the reduction will be treated as a partial prepayment without any prepayment charge under the Note.I la. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class Rail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice to Lender. Awry notice to Lender shall be given by first class mail to Lender's address stated herein or any other address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 15. poveraing Law; Beverability. This Security instrument shall be governed by federal law and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affectl other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision, To this end the provisions of this Security Instrument and the Note are declared to be severable. 16. Borrower's copy. Borrower shall belgiven one conformed copy of the note and of this Security Instrument. 17, sraAster of the property or a Beneficial Interest in Borrower. If all or any part of the Property or any interest in it is sold or transferred (or if a beneficial interest in Borrower In Sold or transferred and Borrower is not a natural person) without Lender's prior written consent, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. However, this option shall not be exercised by lender if exercise is prohibited by federal law as of the date of this Security Instrument. If Lender exercises this option, Lender -hall give Borrower notice of acceleration. The notice shall provide a period of not lase than 30 days from the date the notice is delivered or mailed within which Borrower must pay all sums secured by this, Security Instrument. If Borrower fails to pay these sum prior to the expiration of this period, Lender may invoke any remedies permitted by this security instrument without further notice or demand onlBorrower. 19. Borrower's Bight to Reinstate. If Borrower meta certain conditiona, Borrower shall have the I right to have enforcement of this Security instrument discontinued at any time prior to the earlier of; (a) 5 days (or such other period as applicable law may specify fox reinstatement) before sale of the Property pursuant to any power of sale contained in this Security Instrument; or (b) entry of a judgment enforcing this Security Instrument. Those conditions are that Borrower: (a) pays Lender all sums which then would be due under this Security Instrument and the Note as if not acceleration had occurred; (b) cures any default of any other covenants or agreements; (c) pays all expenses incuxxed in enforcing this Security Instrument, including, but not limited to, reasonable attorneys' fees; and (d) takes such action I Lender may reasonably require to assure thatlthe lien of this Security Instrument, Lender's rights in Property and Borrower's obligation to pay the sum secured by this security Instrument shall continue unchanged, Upon reinstatement by Borrower, this Security Instrument and the obligations secured hereby shall remain fully effective as if no acceleration had occurred. However, this right to reinstate shall not apply in the case of acceleration under paragraph 11. 19. Pale of Note; Change of Loan Pervioe=. The Note or a partial interest in the Note (together with this Security Instrument) may be sold one or more times without prior notice to Borrower. A sale may result in a change in the entity (known as the "Loan Servicer") that collects monthly payments due under the Note and this Security Instrument. There also may be one or more changes of the Loan Sarvicer unrelated to a sale of the note. If there is Is change of the loan Servicer, Borrower will be given written notice of the change in accordance with paragraph 14 above and applicable law. The notice will state the name and address of the new Loan Servicer and the address to which payments should be made. The notice will also contain any other information required by applicable law. 20. Hazardous aubstsncas. Borrower shall not cause or permit the presence, use, disposal, I storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone also to do, anything affecting the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any governmental or regulatory agency or private party involving the Property and any I Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substance affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in paragraph 20. "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flamnnble or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or I B?ON1?`T?BPAGE + f7 formaldehyde, and radioactive materials. As used in this paragraph 20, "Environmental Law" means federal laws and lama of the jurisdiction where the Property is located that relate to health, safety or environmental protection. i NON-UNIFORM COVENANTS. Borrower and tender further covenant and agree as follows: •21. Acceleration: Rsasdass. Lander shall gave notios to Borroret prior to acceleration following Borrower's breach of any covenant or agreement an this security Instrument (but not prior to aooalecatsen under paragraph 17 unless applicable law provide otherwise:. Lander shall notify Borrower of, -song other than: (a) the default: (b) the action required to cure the default: (a) wham the default must be cured: and (d) that failure to aura the default as spsoified May result so acoalarataon of the sums aecured by this Samwity Instrument, foxsclosnre by judicial proceeding and sale of the Property. I,emder shall further infom Borrower of the right tolrsinstate after aaoeleratiou and the right to assert an the foreclosure proceeding the non-exietenoe of a default or any other defense of Borrower to aaoeleration and foreclosure. If the default is not cured as specified, Lander at its option may require soediate payment an full of all suns sewed by this s6aarity Instrument wathout further demand and any foreclose this Security Instrument by 3udaeaal procood ng. Lander shall be entitled to eolleat all espenses, incurred an pursuwg the remedies provided an 'this paragraph 21, including, but not limited to, attorneys, fees and costs of title evsdenw to the extent permitted by applicable law. 22. Release. Upon payment of all sums secured by this security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costa. 23. Weavers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for Stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 24. Reanatatement Period. Borrower's time to reinstate provided in paragraph 18 shall extend to one hour prior to the commencement of bidding et a sheriff's sale or other sale pursuant to this Security Instrument. 25. Purchase mousy Nmrtgage. If any of the debt secured by this Security Instrument is lent to Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage. 26. Interest Rate After Judgment. Borrower agrees that the interest rate payable after a judgment is entered on the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note. 1 27. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security Instrument, the covenants and agreements of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)) ? Adjustable Rate Rider ? Adjustable Rate Rider ? Adjustable Rate Rider ? Graduated Payment Rider ? Planned Unit Development Rider? Biweekly Payment Rider ? Balloon Rader ? Rate Improvement Rider ? Second Nome Rider ? Other(s) [specify] BY SIGNING BELOW, Borrower acceptaland agrees to the terms and covenants contained in this Security instrument and in any rider(s) exi ed by Borrower and recorded with it. witnesses:v (Seel) (Seal) --------------------(Space Below This Line foi Acknowledgment) Certificate of Residence I __________________ I, Dwayne E. Pope, paralegal, do herebylcertify that the correct address of the within-named Mortgagee as 57 W. Timonium Rd., Suite 217, Timonium, MD 21093. Witness my hand this 9th day of December, 1999. i ZZ "d Agent of Mortgagee COMHONWEALTH OF PRNNSYLVANIA, YORK COUNTY On this, the 9th day of December, 1999, before me, the undersigned officer, personally appeared Jared E. Wallace and Kimberly T. Wallace, known to me (or satisfactorily proven) to be the person(s) whose name(s) ere/is subscribed to the within instrument and acknowledged that he/she/they executed the some for the purposes herein contained. I IN WITNESS WHEREOF, I hereunto not my an BOOK1588 FAK • 18 ALL T8AT t?rA N lot or vim of had taomtod is Em Peatabocv rowantip, C046ty , CaMmoaartaM of Yw•sylwudm, ad if a -, a and nobftd v Lot 17 uid , tan (10) "of Lac No. 1614 Plat Na. 1. CC BOWS Ad Uft to Et Db, said ras bias racoc+ded lti tits O"I t. for 90 PJDOUt ict of Daodc Ia And ltss Cm&iW Ct miberWd in Plod Boric 1. Pace 7. M d voce -Aa% >ady bgm dM trod dg=g*d U WDWX. ID WIC xw&aVpw at a *a in fife aard?eraWaedllr line o[Pa?oos ? lbet+ee noett?arard?jr . aioag do 192 of Wt." id. op *4 hour meaabtmd plan of lot+, am budc'td tl*W (1309 im to aodfc=lc so of a iwdm im W vft alley; *Aft 1pCiirvalft al" am ! soot< m no of wdvo (lz face why fibb 00 toot to a abkq am= sumo ra ft ooa b?eo ililcty (13% feet to a pout Laths Adct floe of PAM am*% *me accwao* long the . noc-1 ' No of FdRm Sout My (M feet to a podn6 de rb" of ttre BHGI WWO. AM W pa of rite. tams to, ' to %ftk X TWO= MiM Mw o of CoMy Qf od. by doot. &W 22 Ymm 1999 04 iraoadsd In do Iia wda of Dtxdt OM= In and ON CMItY C=d d U d 1m des SGWVS Deed Bo* =, Pap 167 Fmod and oooveyed, pma cac tQ a Coast O der dried 36 Mamb 1999. Data P=Wk L iaq. In fee *a*. PREMSES BEM. 345 WLTOP STREET EXHIBIT "C" a???? • or F Y's R03E.IT ; . L1ECLER RECORD:: OF DEEDS CUMBERLAND COUNTY-PA '99 DEC 20 Rol 11 30 LOAM ID # _ ASSIGNMENT OF SECURITY INSTRUMENT KNOW ALL MEN BY THESE PRESENTS THAT 1ST CENTRAL MORTGAGE ORGANIZED AHD EXISTING UNDER THE LAWS OF THE STATE OF MARYLAND parry of the first part, in consideration of the sum of ONE DOLLAR ($1.00) and other good and valuable consideration in lawful money of the United States to it in hand paid by FLAGSTAR BANX patty of the second part, at or before the ensealing and delivery of these presents, the receipt whereof is hereby acknowledged, has granted, bargained, sold, assigned, transferred and set over and by these presents does hereby grant, bargain, sell, assign, transfer and set over unto the said party of the second part that certain Security Instrument executed by JARED Z. WALLACE AND KIMBERLY T. WALLACE dated DECEMBER 9TH, 1999 and to be filed for record in the Clerk's office of the Circuit Court of the COUNTY of CUMBERLAND State of PENNSYLVANIA on the following describeeiRETroperty: SEE SCHEDULE 'A' ATTACHED HEO AND MADE A PART HEREOF. together with the Note or obligation described in said Security Instrument and the money due and to become due thereon, with interest accrued and owing thereon. TO HAVE AND TO HOLD the same unto the said party of the second part, its successors and assigns forever, the said parry of the first pan has caused these presents to be signed in its name by its officer, and its corporate sea] to be affixed, this 9TH day of DECXMER, 9,99 r?i' FiS ? §S: . 1 18Tita St ..MARfPC3AhE t a State of kot County of Cal (0 Kt AA&" By: Its: (SEAL) )SS.. 1, an Officer duly authorized to take acknowledgements of deeds according to the laws of E STATE OF MARYLAND duly qualified and acting, hereby certify that u d personally known to me, this day acknowledged before me that said person executed the foregoing Assignment of Security Instrument as such Officer of said organization and that said person affixed thereto the Official Seal of tie said organization and I further certify that 1 know the said person making said acknowledgement to be the individual described in and who executed said Assignment of Security Instrument. IN WITNESS WHEREOF, f hereunto set my hand and Official Sea] in said county d state this 9TH day. of ntecmmzR. logo (SEA#ft?,? -- - - - --? aA? ' cnrmCS110Q Notaryublic c n expires: Doc Prep Plus, Inc. Nok (23 £AE 1.038 EXHIBIT "D" r C, f R03'77 ZIEAER CMMC#? RECORGc . U DEEDS FB#: 9 98 309 3 DUMBERLAND COUNTY-PA FNMA P ol- 259 4 Inv#: 673 656 '00 AUG 28 P(1 1 12 TAX COD /Pi :9 40834112 ASSIGNMENT OF MORTGAGE FOR GOOD AND VALUABLE CONSIDERATION, the sufficiency of which is hereby acknowledged, the undersigned, FLAGSTAR BANK, FSB, a Federally Chartered Savings Bank, located at 30400 Telegraph Road, Bingham Farms, MI 48302, (assignor), by these presents does convey, grant, sell, assign, transfer and set over the described mortgage together with the certain note(s) described therein together with all interest secured thereby, all liens, and any rights due or to become due thereon to Fannie Mae, in care of CHASE MORTGAGE COMPANY an Ohio Corporation, whose address is 3415 Vision Drive, Columbus, OH 43219, its successor or assignee, (assignee). Said mortgage dated 12/09/99 in the amount of $96,800.00 made by JARED E. WALLACE & KIMBERLY T. WALLACE to 1ST CENTRAL MORTGAGE, INC. recorded on 12/20/99, in the Office of the Recorder of Deeds of CUMBERLAND County, Pennsylvania, in Book 1588 Page 15 (or Document No. ) Mortgage Premise:345 FULTON STREET EAST PENNSBORO TWP ENOLA,PA 17025 In witness whereof, the said Corporation has caused this instrument to be executed in its corporate name by KEVIN HOLT its VICE PRESIDENT and by ANTHONY CERVANTES the ASST. SECRETARY its authorized signer, this 24th day of July, 2000 FLAGSTAR BANK, FSB f/k/a FIRST SECURITY SAVINGS BANK, FSB BY:KC ATTEST: IN HBLT ANTHONY CEAit ES VICE PRESIDENT ASST. SECRETARY STATE OF CALIFORNIA COUNTY OF LOS ANGELES On 07/24/2000 before me, M. EASH the Undersigned, Notary Public, personally appeared KEVIN HOLT who acknowledged to be the VICE PRESIDENT and ANTHONY CERVANTES the ASST. SECRETARY of FLAGSTAR BANK, FSB f/k/a FIRST SECURITY SAVINGS BANK, FSB a corporation, and that s/he as such, being authorized so to do, executed the foregoing instrument for the purposes therein contained, by signing the name of the corporation by themselves as such corp- orate officers. IN WITNESS WHER OF, I hereunto set my hand and official seal. ` M. EASH M, SH Notary 0 CONIA 0 1213647 y Publ .? - NOTARY PUBLIGCAUFORNlAW My ommission expires:03/19/2003 LOS ANGELES COUNW 0 COMM. EXP. MARCH 19.2003 ? I do certify that the above address of the assignee is: Fannie Mae, in care of CHASE MORTGAGE COMPANY an Ohio Corporation, whose address is 3415 Vision Drive, Columbus, OH 43219, its successor or assignee, (assignee). Prepared by: D.Colon/NTC,101 N. Brand #1800, Glendale, CA 91203 (800)346-9152 Return to: Nationwide Title Clearing 101 N. Brand #1800 Glendale, CA 91203 ga0,K 653 PAGE 613 Loan Number Assignment of Mortgage from: FLAGSTAR BANK, FSB, a Federally Chartered Savings Bank, located at 30400 Telegraph Road, Bingham Farms, MI 48302, (assignor), to: Fannie Mae, in care of CHASE MORTGAGE COMPANY an Ohio Corporation, whose address is 3415 Vision Drive, Columbus, OH 43219, its successor or assignee, (assignee). Mortgagor:JARED E. WALLACE & KIMBERLY T. WALLACE when recorded return to: Nationwide Title Clearing 101 N. Brand #1800 Glendale, CA 91203 All that certain lot or piece of ground situated in Mortgage Premise: 345 FULTON STREET EAST PENNSBORO TWP ENOLA,PA 17025 • CUMBERLAND (Borough or Township, if stated), Commonwealth of Pennsylvania. Being more particularly described in said mortgage. I INI11 IIINI fl 111 NNI IIN Ilal 111 ills II111111 III IIII FLCM1 FG 3 9 FG VIC' State of Pennsylvania 1 County of Cumberland) Rccordod in tho office for the recording of Deeds eat in q for Cp[?oriand County, Pp. ol. ? Page 0-13 wi css my hand and seal of office of Ca isle, PA this day of , Record r i?r BOO{ 65 PAGE {3]_4 EXHIBIT "E" ASSIGNMENT OF MORTGAGE KNOW ALL MEN BY THESE PREShrNTS that "Federal National Mortgage Association" hereinafter "Assignor" the holder of the Mortgage hereinafter mentioned, for and in consideration of the sum of ONE DOLLAR ($1.00) lawful money unto it in hand paid by Chase Manhattan Mortgage Corporation, "Assignee" at the time of execution hereof, sell, assign, transfer and set over unto the said Assignee, the receipt whereof is hereby acknowledged, does hereby grant, bargain, its 10 successors and assigns. ALL THAT CERTAIN Indenture of Mortgage given and executed by Jared E. Wallace and Kimberly's'. Wallace to 1st Central Mortgage, Inc., bearing the date 1219/99, in the amount of $96,800,00, to der d' O 00 with the Note and indebtedness therein mentioned. said Mortgage being recorded on 12/20/99 in the County?f ?'o Q Cumberland, Commonwealth of Pennsylvania, in Mortgage Book 1588 Page 15, Which Mortgage was Assigned ? ?? 'a Federal National Mortgage Association, recorded on 8/28/00 in Book 653, Page 613. ? ?p 0 t" Being Known as Premises: 345 Fulton Street, Enola, PA 17025 9 0G Parcel No: 09-14-0834-1 12 ip Also the Bond or Obligation in the said Indenture of Mortgage recited, and all Moneys. Principal and Interest, due and to . grow due thereon, with the Warrant of Attorney to the said Obligation annexed. Together with all Rights, Remediesand ?y incidents thereunto belonging. And all its Right, Title, Interest, Property, Claim and Demand, in and to the same: TO HAVE. HOLD, RECEIVE AND TAKE, all and sin6rular the hcreditamcnts and premises hereby granted and assigned, or mentioned and intended so to be, with the appurtenances unto Assignee, its successors and assigns, to and for its only proper use, benefit and behoof forever. subject, nevertheless, to the equity of redemption of said Mortgagor in the said Indenture of Mortgage named. and his/her/their heirs and assigns therein. I N WITNESS WHEREOF, the said "Assignor as caused its Co rate Seal to be herein affixed and these presents to be duly executed by its proper officers this day of -2 0 -•ut'ti? `y * Federal Nat atA rtgageAssociation r•r t?`. Sealed .c` t{i\?? By- and Delivered VI CF? t in the resence ofus; ?^ 'A P Attest: go= L a ???a J State of °` SS. County of: On this day of , 20AJ(before me, the subscriber, personally appeared r..E MMMME who acknowledged him/herselfto be the Vice President of Federal National Mortgage Association, and that he/she, as such Vice President, being authorized to do so, executed the foregoing instrument for the purposes therein contained. IN WITNESS WHEREOF, i hereunto set my hand and Mcial seal. J%,4?lff I?L//,- A rdJ6 NotaryPub is ELIZABETH A. HIS D)MI WM PAft Sto of Ngr Commbalon Exp 0 *11-3 The precise address of the within named Assign is: 3415 i ' D i e Columbus, 9 By: \ (Fo nee) After recording return to: FEDERMAN & P1IELAN, L.LP One Penn Center 1617 J,F.K. Blvd., Ste, 1400 Philadelphia, PA 19103-1814 2/26/04-JHC Document Request 1963029039 * Chase Manhattan Mortgage Corporation, atty in fact for Box 70*7 I?ACE 546 r ALL THAT CE RMIN lot or pica, of bW 40-OW is hiss Peagsbm row=bip, COQ' Q=b=iand. Cmamommft of Bat "Y'h¦aia, aad lm M and nwhend, as Lot 17 Arid . tea (10) f a of Lot No. M Ifs via Na. Z. of Hom'A Addhi ns to Eaola. said Pb a belga tccordod bi des 0W W_ for the Reomaw of DOOM IR 04 fdr CMWW CaabeKtod in Play Boots 1. Page 7. and mote -muaf>ady bounded cod desch'bcd u Wows. to wit; MMOM0 at a pin in the aardtaa r line of PaKaa Stt4 "g The wCdCm ft.- of W m. 18. op tine bK"W soeaipaod plots of lops. au bundted j dthw (UM ka to saadtaa lice of a twelve XMMM 16ae of twelve (M >= rovldo ?Y: tfic+ace vadtiv? alorsg t>te ; XMri (130) tea to ¦ (12) f ft allC? MY OM f*K tip a ?C MM8 aoiathtiaa ft OM bnA" POW in the Wkthe:a llae of SAM Stems tbeoee =a*=gy tag do w8bm We of ttttt-a Sum 6dtY (SO feet to a pohlk tste Pbm of the BMWNWO. Maw pm of tie. acme Pra+ks which R. 700mas x1mc. S wx of Cotuay t Cftb&Utd. by deaf. datied 22hft IM add mWeded In Me Rmftft of-DoedA 0Mm In and for COURty Ctunbe Mel to do SOWS Deed Boots 202, Pap 167 pLowd ad mmyed, p<uwaot to a Caatt Oc tr dazed, 26 Marcb IM, um* Pamr1h L L&4. In fee sbaple. PRFMSES BEING: 345 FUTON STREET r,,,fi fv thi:s to be recorded ,and County PA ..BOOK 70'7 ..PALE .54 ti•?r l --?/: Recorder of Deeds VERIFICATION E ULO, Moyuc. , hereby states that he/she is N"- ANW;c1enk of JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Name: Elma HC1plc DATE: ice Presdent ?? apt Title: 3P "-C.6' M • i:) File #: 075-10095 Name: Wallace, Jared SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy 'JI. THE pROTHr,"N 2012 MAR -5 PM 2: 41 Richard W Stewart Solicitor r,UMBERLANU COUNTY PENNSYLVANIA JP Morgan Chase Bank, NA Case Number vs. Jared E. Wallace (et al.) 2012-1002 SHERIFF'S RETURN OF SERVICE 03/02/2012 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: Jared E. Wallace, 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 Jared E. Wallace. Request for service at 345 Fulton Street, Enola, Pennsylvania 17025 is vacant. Deputies were advised by Father in Law of Defendant, at 107 Pine Hill Road, Enola, Pennsylvani-, 17025 the Defendant has moved to Dillsburg, Pennsylvania. 03/02/2012 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: Kimberly T. Wallace, 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 Kimberly T. Wallace. Request for service at 345 Fulton Street, Enola, Pennsylvania 17025 is vacant. Deputies were advised by Father of Defendant at 107 Pine Hill Road, Enola, Pennsylvania 17025 the Defendant has moved to Dillsburg, Pennsylvania. SHERIFF COST: $84.00 March 02, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, CIVIL DIVISION NO.: 2012-1002 TYPE OF PLEADING Praecipe to Reinstate Civil Actiorr? Complaint in Mortgage Foreclosure Defendants. FILED ON BEHALF OF PLAINTIFF: JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 $11.15 Pao A`r'r'./ e'# 13'M331 P_,41amolo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE NO.: 2012-1002 CORPORATION, Plaintiff, VS. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. PRAECIPE TO EINSTATE CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE TO: PROTHONOTARY SIR: Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY: Kristine M. Anthou, Esquire Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor r4r 4,14 ti?19?J1t? r??i._ t PENNSYLVANIA JP Morgan Chase Bank, NA vs. Jared E. Wallace (et al.) Case Number 2012-1002 SHERIFF'S RETURN OF SERVICE 04/10/2012 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: Jared E. Wallace, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 04/10/2012 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: Kimberly T. Wallace, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of York County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure according to law. 04/16/2012 02:45 PM - York County Return: And now April 16, 2012 at 1445 hours I, Richard P. Keuerleber, Sheriff of York County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Jared E. Wallace by making known unto himself personally, at 134 Fairway Drive, Dillsburg, Pennsylvania 17019 its contents and at the same time handing to him personally the said true and correct copy of the same. 05/01/2012 York County Return: And now, May 1, 2012 I, Richard W. Keuereber, Sheriff of York County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Kimberly T. Wallace the defendant named in the within Complaint in Mortgage Foreclosure and that I am unable to find her in the County of York and therefore return same NOT FOUND. Request for service at 135 Fairway Drive, Dillsburg, Pennsylvania 17019 the Defendant was not found. Deputies were advised, Kimberly T. Wallace is not known at this address. SHERIFF COST: $53.00 May 17, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c) CountySuite Sheriff, Teleosoft. Inc. SHERIFF'S OFFICE OF YORK COUNTY Richard P Keuerleber Sheriff Reuben B Zeager Chief Deputy, Operations PETER J. MANGAN, ESQ. Solicitor Richard E Rice, II Chief Deputy, Administration JP MORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t CHASE HOME Case Number FINANCE 2012-1002 CIVIL vs. JARED E. WALLACE (et al.) SHERIFF'S RETURN OF SERVICE 04/16/2012 02:45 PM -DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, SERVED THE REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE (CIMF) BY "PERSONALLY" HANDING A TRUE COPY TO A PERSON REPRESENTING THEMSELVES TO BE THE DEFENDANT, TO WIT: JARED E. WALLACE AT 135 FAIRWAY DRIVE, DILLSBURG, PA 17019. MICHAEL NOVAN, DEPUTY 04/16/2012 02:45 PM - DEPUTY MICHAEL DONOVAN, BEING DULY SWORN ACCORDING TO LAW, ATTEMPTED SERVICE TO THE DEFENDANT, TO WIT: KIMBERLY T. WALLACE AT 135 FAIRWAY DRIVE, DILLSBURG, PA 17019. THE DEFENDANT WAS FOUND TO HAVE MOVED. 05/01/2012 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: KIMBERLY T. WALLACE, 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 135 FAIRWAY DRIVE, DILLSBURG, PA 17019. PER POST OFFICE CHECK, NOT KNOWN AT ADDRESS GIVEN. SHERIFF COST: $51.54 SO ANSWERS, May 04, 2012 RICHARD P U LE ER, SHERIFF --------------- -- NOTARY COMMbNV+gLT F PENNSYLVANIA Affirmed and subscribed to before me this C LISA ?? N q 4TH day of MAY 2012 MY COkft„ISSiON EXPIRES AU ,N2, 2013 p Countq Suite Sheriff, Ieleosoft . Inc z .? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE NO.: 2012-1002 CORPORATION, ; Plaintiff, , r vs. JARED E. WALLACE and KIMBERLY T. WALLACE, 1- _ Defendants. ORDER OF COURT AND NOW, to wit, this day of ' ri4 lt.7 , 2012, upon consideration of the within Motion for Service of the Complaint in Mortgage Foreclosure Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED that the Sheriff of Cumberland County is hereby directed to serve Defendant, Kimberly T. Wallace, with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure by posting the property at 345 Fulton Street, Enola, Pennsylvania 17025 and Plaintiff is permitted to serve Defendant by certified mail, return receipt requested and by First Class U.S. Mail, postage pre- paid at 135 Fairway Drive, Dillsburg, PA 17109. Service on the Defendant shall be deemed complete and valid upon posting by the Sheriff and mailing by the Plaintiff. BY THE COURT: i J. 1 ?rei,en 4 /3ir-S"c_/ P.e-- 6 CVp? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, VS. CIVIL DIVISION -' r j - NO.: 2012-1002 tea ' TYPE OF PLEADING _ na Praecipe to Reinstate Civil Action --`' - Complaint in Mortgage Foreclosure JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. FILED ON BEHALF OF PLAINTIFF: JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 3) V Cry I 3S(o ? a??o3? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE NO.: 2012-1002 CORPORATION, Plaintiff, VS. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. PRAECIPE TO REINSTATE CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE TO:PROTHONOTARY SIR: Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with respect to the above-referenced matter and mark the docket accordingly. GRENEN & BIRSIC, P.C. BY: , / J L C K Kristine M. Anthou, Esquire Attorneys for Plaintiff SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 2-fH2 JU -3 PM 1:22 JP Morgan Chase Bank, NA Case Number vs- 2012-1002 Jared E. Wallace (et al.) SHERIFF'S RETURN OF SERVICE 06/26/2012 09:00 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according tolaw, states that on June 26, 2012 at 2100 hours, he served a true copy of the within Complaint in Mort ge Foreclosure, upon the within named defendant, to wit: Kimberly T. Wallace, pursuant to order of cou by'posting the premises located at 345 Fulton Street, Enola, Cumberland County, F'ennsylvaniq 1 02 with`. a true and correct copy according to law. { SHERIFF COST: $55.00 June 28, 2012 WN HAT FMSON. DEPUTY SO ANSWERS, 4-1r4Y R ANDERSON SHERIFF t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. I hereby certify that the address of Plaintiff is: 3415 Vision Drive Columbus, OH 43219 the last known address of Defendants is: Jazed E. Wallace 135 Fairway Drive, Dillsburg, PA 17019 Kimberly T. Wallace 135 Fairway Drive, Dillsburg, PA 17019 and 345 Fulton Street, Enola, PA 17025 GRENEN &BIRSIC, P.C. Attorn ys for Plainti -~ CIVIL DIVISION ~ ~- ,~=,:' z ~ ` ' -~ ~' r`' r -C ° ~~ ,_ r NO.: 2012-1002 ~ ~ ~,~, p TYPE OF PLEADING PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF PLAINTIFF: JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN &BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412)281-7650 ,~ s~ V.~O~ Q~ ~ ~' C~ 13 9 9 ,~ fz ? °! ~ No ~ ~y~~I.~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION NO.: 2012-1002 Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR: Please enter a default judgment in the above-captioned case in favor of Plaintiff ai against Defendants, Jared E. Wallace and Kimberly T. Wallace, in the amount of $121,970.3 which is itemized as follows: Principal $ 92,035.01 Interest from 8/ 1 /09 through 8/ 13/ 12 $ 22,001.42 Late Charges to $ 342.81 Escrow Deficiency to $ 4,980.46 Corporate Advances $ 522.00 Suspense Balance $ - 58.89 Attorney's fees $ 1,170.00 Foreclosure Costs $ 977.25 TOTAL $1 21,970.36 together with interest, costs, fees, and charges collectible under the note and mortgage inclu~ but not limited to attorneys fees and costs, and for the foreclosure and sale of the mortgaged property. GRENEN & BIRSIC, P.C. _ ._. ~ ,L.L /~. BY: Kris ' ~te M. Anthou, Esquire Attorneys for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING_OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and authori representative of Plaintiff who, being duly sworn according to law, deposes and says that Defendants were not in the military service of the United States of America to the best of knowledge, information and belief and certifies that the Notices of Intent to take Def Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copi~ Sworn to and subscribed before me this _l~~ day of , 2012. Notary Pu 1c ~MP90NWEALTH OF PENNSYWANIA Patricia A. Townsend~Nlotary Public ~Y ~ PlUsburgh, Allegheny County MY Commi~Cn Expires June 2, 2015 MEMBER' PEIyNSyI,yA~ ASSOCIATION OF NOTARIES IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. TO: Jared E. Wallace 135 Fairway Drive Dillsburg, PA 17019 DATE OF NOTICE: May 10, 2012 CIVIL DNISION NO.: 2012-1002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRIT'] APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COI YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNL: YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. 1F YOU DO NOT HA A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE C, PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LE( SERVICES TO ELIGBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 FIRST CLASS MAIL, POSTAGE PREPAID GRENEN & BIRSIC, P.C. By. ~ ~ „~ Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 T ~' IN "fHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. TO: Kimberly T. Wallace l 35 Fairway Drive Dillsburg, PA 17019 DATE OF NOTICE: July 19, 2012 CIVIL DIVISION NO.: 2012-1002 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAII.ED TO ENTER A WRIT"] APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COt YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNL YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR. PROPERTY OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HA A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE C, PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LE( SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (71'n 249-3166 or Toll Free (800) 990-9108 FIRST CLASS MAIL, POSTAGE PREPAID GRENEN & BIRSIC, P.C. `~ .~~ , By: Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 E IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA J PMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, CIVIL DIVISION NO.: 2012-1002 Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. TO: Kimberly T. Wallace 345 Fulton Street Enola, PA 17025 DATE OF NOTICE: July 19, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITT APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COU YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLI YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT I A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEC SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 FIRST CLASS MAIL, POSTAGE PREPAID GRENEN 8t BIRSIC, P.C. `~ ~'~' ~ By: ~ Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE NO.: 2012-1002 CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Jared E. Wallace 135 Fairway Drive Dillsburg, PA 17019 ( ) Plaintiff (XX) Defendant ( )Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ~ ~~ a'1 . ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $121,970.36 together with interest, costs, fees, and charges collectible under the note and mortgage inclu~ but not limited to attorneys fees and costs, and for the foreclosure and sale of the mortgaged property. .~;~:./ • _ 1~ •~. _.~. r/ Deputy "~.r~ ~1~,' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE NO.: 2012-1002 CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. NOTICE OF ORDER DECREE OR JUDGMENT TO: Kimberly T. Wallace 135 Fairway Drive Dillsburg, PA 17019 ( )Plaintiff (XX) Defendant ( )Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ~ ~ low ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $121,970.36 together with interest, costs, fees, and charges collectible under the note and mortgage inclu~ but not limited to attorneys fees and costs, and for the foreclosure and sale of the mortgaged property. w Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVAN JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE NO.: 2012-1002 CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. NOTICE OF ORDER DECREE OR JUDGMENT TO: Kimberly T. Wallace 345 Fulton Street Enola, PA 17025 ( )Plaintiff (XX) Defendant ( )Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ~ ~ ~a. ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $121,970.36 together with interest, costs, fees, and chazges collectible under the note and mortgage inclu~ but not limited to attorneys fees and costs, and for the foreclosure and sale of the mortgaged property. ~,~ ~,~...r, A. J1 .F rel.. Deputy i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY P ENNSA ~~ ~I ~,-Ys ~ r ~ sv ~ ~o JPMORGAN CHASE BANK ' CIVIL DIVISION ~~' F--~-- ° ~~ ~-n NATIONAL ASSOCIATION, s/b/m/t ~~ '~ ~'~ CHASE HOME FINANCE LLC, s/b/m/t ~ ~ ~, ~~'- CHASE MANHATTAN MORTGAGE :2012-1002 N0 ~'' ~ v . CORPORATION, ..., ~; ~ Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, TYPE OF PLEADING Proof of Service as to Kimberly T. Wallace FILED ON BEHALF OF PLAINTIFF: Defendants. JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE NO.: 2012-1002 CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, Defendants. PROOF OF SERVICE AS TO KIMBERLY T. WALLACE Kristine M. Anthou, Esquire, Attorney for Plaintiff, JPMorgan Chase Bank, N Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage being duly sworn according to law deposes and makes the following Affidavit regarding of Plaintiffs Complaint in this matter on Defendant, Kimberly T. Wallace: Pursuant to Order of Court dated June 6, 2012, service of the Complaint Mortgage Foreclosure upon Defendant, Kimberly T. Wallace, was deemed complete and upon mailing by the Plaintiff by certified mail, return receipt requested, and by first class postage prepaid, addressed to 135 Fairway Drive, Dillsburg, Pennsylvania 17109, and by of a copy of the Complaint, by the Sheriff of Cumberland County, at the property located at 3'}5 Fulton Street, Enola, Pennsylvania 17025. A true and correct copy of said Order of Court marked Exhibit "A", attached hereto and made a part hereof. 2. On June 27, 2012, Plaintiff mailed the Complaint in Mortgage Foreclosure Defendant, Kimberly T. Wallace, at 135 Fairway Drive, Dillsburg, Pennsylvania 17109, certified mail, return receipt requested and by first class mail, postage prepaid. A true a~ correct copy of the U.S. Postal Service form 3800, Article Number 7011 3500 0000 5866 501 and the Certificate of Mailing, evidencing service by certified mail and first class mail on t: identified Defendant, are marked Exhibit "B", attached hereto and made a part hereof. 3. On or about June 26, 2012, the Sheriff of Cumberland County posted Complaint on the property located at 345 Fulton Street, Enola, Pennsylvania 17025. A true correct copy of the Sheriffs Return is marked Exhibit "C", attached hereto and made a hereof. I verify that the facts contained in this Affidavit are true and correct based upon ~y personal knowledge, information, and belief. GRENEN & BIRSIC, P.C. BY: V i ~~~L. s~ ~,~ ~ ti Kristine M. Ant ou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBSCRIBED BEFORE ME THIS J~~~~AY OF ~ , 2012. \~ ~ n o1'~~ 1~~L~~~~ Notary Public e9MM9N fii1 QF _,,,~ENNSYLVANIA Nolarlal Seas Patrida A. TO~msend; iVta~$ry Public City of PItt94uryh, ,41t~grrenv County My Commisslpn ExpF~r:r .rune 2, 2015 MEMBER, PENNSYLVANIA ASSOCL4TION OF NOTARIES EXHIBIT "A" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV. JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION, Plaintiff, vs. JARED E. WALLACE and KIMBERLY T. WALLACE, CIVIL DIVISION NO.: 2012-1002 Defendants. ~~_ ~; v , ~.. ~. ~.- ORDER OF COURT AND NOW, to wit, this (,E' day of ~ /c,/ , 2012, consideration of the within Motion for Service of the Complaint in Mortgage F Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED _. i ,.;-: the Sheriff of Cumberland County is hereby directed to serve Defendant, Kimberly T. Wall with a true and correct copy of Plaintiffs Complaint in Mortgage Foreclosure by posting property at 345 Fulton Street, Enola, Pennsylvania 17025 and Plaintiff is permitted to s~ Defendant by certified mail, return receipt requested and by First Class U.S. Mail, postage paid at 135 Fairway Drive, Dillsburg, PA 17109. Service on the Defendant shall be complete and valid upon posting by the Sheriff and mailing by the Plaintiff. BY THE COURT: ~~ _- J. EXHIBIT "B" U.S. POSTAL SERVICE CERTIFICATE Of MAILINt3 MAY BE USED FOR DOMESTIC AND INTERptAT L MAIL DOE r: PROVIDE FOR INSURANCE-POSTMASTER Received From: ~ ,ley Grenen 8~ Bi 'c P.C. ~ °~ ' ~~ One Gatevra Center 9~ Floor Eo FRO~n One piece of ordinary mail addressed to: _v PS Form 3817, January 2001 0 _n ~n 0 0 0 O O m 0 N Alfa fee herein stamps or meter postage and post mark. Irpuire of PITNEY BOWES '~~~.~ ~0 ,;u~U zr~~~~z ~.~ 1222 '~GiOd ~;,A ~~ ~~~ ~j EXHIBIT "C" SHERIFF'S~OFFICE OF CUMBERLAN~COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor vo~uty of ~utrtbrrya~~ C~. ,,.. r...~~4 .,.~ OFFICE OF THE SM£RIFF JP Morgan Chase Bank, NA vs. Case Numb r Jared E. Wallace (et al.) 2012-1002 SHERIFF'S RETURN OF SERVICE 06/26/2012 09:00 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according 26, 2012 at 2100 hours, he served a true copy of the within Complaint in Mor within named defendant, to wit: Kimberly T. Wallace, pursuant to order of coy located at 345 Fulton Street, Enola, Cumberland County, Pennsylvaniry`~1~7,A,2I according to law. t ~~ ~~ SHAWN SHERIFF COST: $55.00 June 28, 2012 ,states that on J ne ~g Foreclosure, upo the by osting the premis s vit a true and corre copy ON, DEPUTY SO ANSWERS, ~~ RON R ANDERSON, S Vic) CoimtySui~e SherdF. TeleosoR. Inc. CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Proof Service was mailed by U.S. First Class Mail, postage pre-paid, on the _~~Day of Augt 2012, to the following: Kimberly T. Wallace 135 Fairway Drive Dillsburg, PA 17019 and 345 Fulton Street Enola, PA 17025 GRENEN & BIRSIC, P.C. BY~ ~ -cx-~ ' G~~--L L_ Kristine M. An ou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412)281-7650