HomeMy WebLinkAbout12-1002IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYItXANIA
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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
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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.
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EXHIBIT "B"
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AFTER RECORDING MAIL TO:
1sT"=ZMIVAL NMMVaai, IM.
57 MST TDOMMU ROAD SUITZ 217
T111s1NICM DID-
LOAN NO. i
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%?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"
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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