HomeMy WebLinkAbout12-1120•
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO.
MICHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929
LESLIE RASE, ESQ., ATTORNEY I.D. NO. 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
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JPMorgan Chase Bank, National Association, COURT OF COMMON PLEAS
sucessor by merger to Chase Home Finance, CIVIL DIVISION
LLC s/b/m to Chase Manhattan Mortgage CUMBERLAND COUNTY
Corporation
PLAINTIFF NO: ?? ?- c7u C?v?(
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
5211 Pine Hill Road
Dover, PA 17315
DEFENDANT
COMPLAINT - CIVIL ACTION
MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE
FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND
NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU
ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE
ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE
COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY
OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
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.
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Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT YOU ARE ADVISED THAT THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE
DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,
USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA
DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA
ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA
ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU
PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA
MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O
NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA
PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O
OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
MICHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929
LESLIE RASE, ESQ., ATTORNEY I.D. NO. 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
sucessor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
5211 Pine Hill Road
Dover, PA 17315
DEFENDANT
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff, JPMorgan Chase Bank, National Association, sucessor by merger to Chase
Home Finance, LLC s/b/m to Chase Manhattan Mortgage Corporation, the address of which is,
3415 Vision Drive, Columbus, Ohio 43219, brings this action of mortgage foreclosure upon the
following cause of action:
1. (a) Parties to Mortgage:
Mortgagee: Citizens Mortgage Corporation
Mortgagor(s): Robert K. Danner
(b) Date of Mortgage: December 19, 2003
(c) Place and Date of Record of Mortgage:
Recorder of Deeds
Cumberland County
Mortgage Book 1849, Page 1754
Date: December 23, 2003
The Mortgage is a matter of public record and is incorporated herein as provided
by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached
hereto and marked as Exhibit "A" and incorporated herein by reference.
(d) Assignments:
Assignor: Citizens Mortgage Corporation
Assignee: Chase Manhattan Mortgage Corporation
Date of Assignment: January 27, 2006
Recording Date: October 12, 2006
Book: 731
Page: 532
2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal
successor in interest to the original Mortgagee, or is the present holder of the mortgage by
operation of law.
3. The real property which is subject to the Mortgage is generally known as 214 West Allen
Street, Mechanicsburg, PA 17055 and is more specifically described as attached as part
of Exhibit "A".
4. Each Mortgagor named in paragraph 1 executed a note as evidence of the debt secured by
the Mortgage (the "Note"). A true and correct copy of the Note is attached and marked as
Exhibit "B".
5. The name and mailing address of the Defendant is:
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased, 214 West
Allen Street, Mechanicsburg, PA 17055
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased, 5211 Pine
Hill Road, Dover, PA 17315
6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both. The said
Robert K. Danner died on or about May 21, 2010, and an estate was raised naming Darla
Maurer as Representative of the Estate.
7. The Mortgage is in default because the monthly installments of principal and interest and
other charges stated below, all as authorized by the Mortgage, are due as of May 1, 2010
and have not been paid, and upon failure to make such payments when due, the whole of
the principal, together with charges specifically itemized below are immediately due and
payable.
8. The following amounts are due as of September 30, 2011:
Principal Balance Due
Interest Currently Due and Owing at 5.875%
From April 1, 2010 through September 30, 2011
Late Charges
Escrow Advances
Appraisal Fees
Property Inspection
Property Preservation
$66,552.29
$5,864.94
$97.88
$2,957.07
$250.00
$42.00
$410.00
$76,174.18
9. Interest accrues at a per diem rate of $10.71 each day after September 30, 2011, that the
debt remains unpaid, and Plaintiff may incur other expenses, costs and charges collectible
under the Note and Mortgage.
10. In addition to the above amounts, reasonably incurred attorneys fees and costs as well as
proof of title in conformity with the mortgage documents and Pennsylvania law, shall be
sought by Plaintiff and included in any request for judgment.
11. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S.
§ 1680.402c, et SeMc ., was sent to each individual Mortgagor at their mailing address and/or
the mortgaged property address by first-class mail and certified mail. Copies of the material
part of the Notice are attached hereto as Exhibit "C" in accordance with Pa.R.C.P. 1019(i).
12. Pursuant Pa.R.C.P. 1019(d), the Notice sent to the Defendant(s) contains the information
required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. § 403 et seq., and separate
Notice of Intention to Foreclose is not required.
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in
favor of Plaintiff and against Defendant, in the amount set forth in paragraphs 8 and 9, together
with interest, attorneys' fees and for other expenses, costs, and charges collectible under the Note
and Mortgage and for the foreclosure and sale of the mortgaged premises.
Date: 120 ?
1
SHAPIRO & DeNARDO, LLC
BY: 6-1--l
Attorneys for Plaintiff
S & D File No. 10-038403
(DA X Mao
Afbw Recording Rctmu To:
C antis Mortgage Carpewkw
87S W swag 1T-
ROPBERT F. ZIEGLER
RE'OF.DER OF DEEDS
C-.'ktaEiRSLAND COUTY-F„
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[Spew Above This Line For Recordieg Datal
MORTGAGE
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N011CE• THIS LOAN IS NOT ASSUWABLE vATHOUTTHE APPROVAL OF THE
D13?ONS DEPARTMENT OF VETERANS AFFAIRS OR ITS
AUTHORS AGENT.
Words used in multiple sections of this dwament are defined below and other words ace defined in
Sections 3,11,13,18, 20 and 21. Certain rules regarding fimusage of words used in this document
are also pwvided in Section 16.
(A) aSeew ity hotmwent" means tWa document, which is dated aKwher iv
=3 . together with atl Riders to this docummt.
(B) "Borrower" is Rolu >L Cl HM Borrower is
the mortgagor under this Security Instrlnmemt.
(G) -Lauder" is LT tzm MOUGAGE COMIATION . Lender is a
mmo9, organized and existing under the laws of
The State of Rhc& Wand Lender's address is
to TQpas zat 1WERSIDFa1[„029 t r . Lender is the mattgegee under this Seomity Instmment.
(D) "Note means the promissory note signed by Borrower and dated nwau ,.. 19
mw . Tice Note atates that Borruwar owes Leader minus-d FnrU milord and aor100_
Dollars (U.S_ 11 73.40040 ) plus intcrcat. Bottom has promised to pay Na debt in
regular Periodic Payments sod to pay the debt in fall not later than Imax t s4 .
M) "Property" means the property that is described below under the heading "rrander of RigbU
in the Property."
M "Loan" means the debt evidenced by the Note, plus inowest, any prepayment dmgea and late
charges due under the Note, and all sums due under Wg Security Instrument, phis interest.
(G) "Liidera" means all Riders to this Security Instrument that ace executed by Borrower. The
following Riders are to be executed by Borrower [check box as applicable):
? A4netaMe Rate Rider O Cmdomkdmms Rider ? SecmdHome Rider
D Ballow Rider 11 Planned Wit Development Rider 0 Odtit( ppmIlyl
? 1-4 Family Rider ? Biweekly Payrnrad Ricks
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(H) "Applicable Law" means all corrhrolhng applicabie federal, state and local S. regulations,
ordinances and administrative rules and orders (that have the effect of law) as well as all applicable
final, acn- pealabte judicial opiaiona.
(1) "Community Association Dues, Fees, and Amessmeak" means all dues, fees, assessmants
and other charges that are imposed on Borrower or the Property by a ooridomimum 2880e101tiM,
horneownem association or sknffar organintiom
(J) "Mactroak Duds Transfer" means any Uansfer of fends, other than a transaction originated
by check, drag or similar paper instrument, which is initiated through an electronic terminal,
telephonic instrument, computer, or magnetic tape so as to order, instract, or authorize a financial
institrhtion to debit or credit an accmma. Such term includes, but is not limited to, point-of-sale
transfers, automated teller machine transactions, transfers initiated by telephone, wire transfers, and
automated clearinghouse trughm.
(K) "Escrow Items" noeans those items that are deambed in Section 3.
(L) "Miacelaneous Proceeds" means any compensation, settlement, award of damage*, or
proceeds paid by any third party (other than insurance proceeds paid under the coverages described
in Section 5) fa: (i) damage to, or destruction of, the Property; (a) condemnation or other fairing of
all or any part of the Property; (iii) conveyance in lien of c o ndem nsdon, or (iv) misrepresentations
of, or omissions as to, the value and/or condition of the Property.
(M) "Mortgage Insurance" mesas insurance protecting Loader against the nonpayment oft or
default on, the Loan.
(N) "Periodic Payment" means the regularly scheduled amoment doe for (i) principal and interest
under the Note, plus (it) any amounts under Section 3 of this Security Instrument.
(O) "RESPA" means the Real Estate Settlement Proaedhhres Act (12 U.S.C §2501 et sec}.) and its
implementing regulation, Regulation X (24 C.F.R. Part 3500}, as they might be amended ftom time
to time, or any additional or successor legislation or regulation that governs the same subject matter.
As used in this Security Instrument, 'TMPA" refers to all roquirwnft and restrictions that are
imposed in regard to a "federally related mortgage loan" even if the Loan does not qualify as a
"federally related mortgage loan" under RESPA.
(P) "Snewwr in Interest of Borrower" maims nay party that has taken title to the Property,
whether or not that party has assumed Borrower's obligations under the Note and/or this Security
insh went.
TRANSFFR OF RIGHTS IN THE PROPERTY
This Security InaUumord secures to Lender (I) the =payment of the Loan, and all nmewals,
=t= k= and modifications of the Note; and (ii) the performance of Borrower's covenants and
agreements under this Security instrument and the Note. For this purpose, Borrower does hereby
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ge, grM t and convey to Lender the following described property located in the
O j Q 'TY Of CUMA RLAN D
[Type of Recording .Jurisdiction] [Nauhe of Recording Jurisdiction]
which currently has the address of
214 WEST AU AN S1REEr
[S?]
MECHANKSeuae Pennsylvania r Toss ("Property Address'?
[may] [Zip Code]
TOGETHER WITH all the improvements now or hereafter ermted on the property, and all
easerneuts, mss. and fixhum now or hereafler a part oft}he property. All replacements and
additions shall also be covered by this Security Instrument. All of the foregoing is reftrred to in this
Security Instrument as the "Property."
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby omn eyed
and has she right to mortgage, grant and convey the Property and that the Properly is to mbered,
except for encumbrances of record. Borrower warrarb and will defend generally the title to the
Property against att claims and demands, enbjeet to arty encumbrsaces of record.
THIS SECURITY INSTRU MU combines uniform covenants for national use and non-
unifocm covenants wish limited vanah ms by jurisdiction to consulate a unifomh security instrument
covering reel property.
UNWORM COVENANTS. Borrower and Lender covenant and agree as follows:
L Payment of Prjudpsl, Interest, Fscrow Items, Prepayment Charges, and Late
Charges. Borrower shall pay when due the principal o& and interest on, the debt evidenced by the
Note and any prepayment charges and late charges due under The Note. Borrower shall also pay
fiords for Escrow items pursuant to Section 3. Payments due under the Note and this Security
Instrument shall-be made in U.S. can wcy. However, if say chwi or other im&wneat received by
Lender as payment under the Note or this Security Instrument is returned to Leader unpaid, Lender
may require that any or all subsequent payments dae under the Note and this Security Instrument be
grade in one or more of The following forms, as selected by Lender. (a) cash; (b) money order,
(c) certified check, bank check, treasarce B check or cashier's check, provided any such check is
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drawn upon an institution wbose deposits are insured by a federal agency, instrumentality, or entity;
or (d) Electronic Funds Transfer.
Payments are deemed received by Lowder when received at the location designated is the
Note or at such other location as may be designated by Lender in accordance with tiro notice
provisions in Section 15. Lender may return any payment or partial payment if the payment or
partial payments are mauffrcicrd to bring the Loan current. Lender may accept any Payment or
partial payment inatfficient to bring the Loan current, without waiver of any rights hereunder or
prejudice to its rights to refuse such payment or partial payments in the future, but Leader is not
obEigated to apply such payments at the time such payments are accepted.. If each Periodic Payment
is applied as of its scheduled due date, then Lender need not pay interest on unapplied funds. Lender
may hold such unapplied fonds until Borrower makes payment to bring the Loan current. If
Borrower does not do so within a reasonable period of time, Lender shall either apply such funds or
return them to Borrower. If not applied earlier, such funds will be applied to the outstanding
principal balance under the Note immediately prior to foreclosure. No offset or claim which
Borrower might have now or in the future against Leader shall relieve Borrower from staking
payments due under the Note and this Security Instrument or perforating the covenants and
agreements secured by this Security Instrument
2. Applicadou of Payments or Proceeds. Except as otherwise described in this Section 2,
all payments accepted and applied by Lender shall be applied in the following order of priority:
(a) interest due under the Note; (b) principal due under the Note; (c) amounts due under Section 3.
Such payments shall be applied to each Periodic Payment in the order in which it became due. Any
remaining amounts shall be applied first to late charges, second to any other amounts due under this
Security Inwur ant, and then to reduce the principal balance ofthe Note.
If Lender receives a payment from Borrower for a delinquent Periodic Payment which
includes a sufficient amount to pay any late charge due, the payment may be applied to the
delinquentpayment and the late charge. If more than one Periodic Payment is outstanding, Lender
may apply any payment received fmmBorrmwer to the repayment ofthe Periodic Payments if, and
to the extent that, each payment can be paid in f tlL To the extent that any excess exists after the
payment is applied to the full payment of one or more Periodic Payments, such excess may be
applied to any late charges due. Voluntary prepayments shall be applied first to any prepayment
charges and then as described in the Note.
Any application of payments, insun u= proceeds, or Miscellaneous Proceeds to principal
due under the Note shall not extend or postpone the due date, or change the amount, of the Periodic
Payments.
3. Funds for Escrow Items. Borrower shall pay to Lender on the day Periodic Payments
are due under the Note, until the Note is paid is full, a sum (the "Funds'l to provide for payment. of
amounts dire for. (a) taxes and asessmmts and other items which can attain priority over this
Security Instrument as a lien or encumbrance on the Property; (b) leasehold payments or ground rents
on the Property, if aW, (c) premiums for any and all insurance r xpiired by Lender under Sectioa 5;
and (d) Mortgage Insurance premiums, if any. or any sums payable by Borrower to Lender in lien
of the payment of Mortgage insurearx premiums in accordance with the provisions of Section 10.
These items are catled "Ewww Items." At origination or at any time during the term of the Loan,
L,satder may require that Como mrnity Association Dues, Fees, and Assessments, if any,
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be esmwnd by Borrower, and such. dues, fees and assessments dzU be an Escrow Items. Borrower
shall promptly famish to Lender all rwti es of amounts to be paid under this Section. Borrower et a[l
pay Lender The Fonda for Escrow Items unleae Lender waives Borrower's obligation to pay the Finds
for any or all Esmvw Items. Leader may waive Borrower's obligation to pay to Lender Funds for
any or all Escrow Items at any time. Any such waiver may only be in writing. In the event of such
waiver, Boavwar shall pay directly, when and where pa*1c. the ammints due for any Escrow Items
for which payment of Funds has bra waived by Lender and, if Lender requires, gall fimmis h to
Lender receipts endencing such payment within such time period as Leader may require.
Borrower's obligation to malm such payments and to provide recelptu shall for all purposes be
deemed to be a covenant and agreement contained in this Security Instramart, as the phrase
"covenant and agreement" is used in Section 9. If Borrower is obligated to pay Escrow Items
directly, pursuant to a waiver, and Borrower fails to pay the amount due fear an Emow Item, Lender
may exercise its rights under Section 9 and pay such amount and Borrower shall then be obligated
under Section 9 to repay to Lender any sercb amount. Lender may revoke the waiver as to any or all
Escrow Items at say time by a notice given in accordance with Section 15 and, upon such revocation,
Borrower shall pay to Lender alt Funds, and in such amounts, that are then required under this
Section 3.
Lender may, at any time, collect and hold Funds in an among (a) sufficient to permit Lender
to apply the Funds at the time specified under RESPA, and (b) not to mweed the maximum. amount
a lender can require under RESPA. Lender shall estimate the amount of Funds due en the basis of
current data and reasonable estimates of expenditures of future Escrow Items or aftherwise in
accordance withApplicable law.
The Funds shall be held in an instiihuYion where deposits are insured by a federal agency,
instrumentality, or entity (including Lenda, sf Lendier is an institution whose deposits are so insured)
or in any Federal Home Loan Bank. I.emder shall apply the Funds to pay the Escrow Items no later
tban the time epeffiod under RESPA. Lender shall not charge Borrower for holding and applying
tie Funds, annually ana4-Zmg the escrow account, orverifying the Escrow Treats, unless Lender pays
Borrower interest on the Funds and Applicable Law parmits Lender to make such a charge. Unless
an agra meat is made in writing or Applicable law requires interest to be paid on the Funds, Lender
shall not be required to pay Borrower any interest or earnings on the Funds. Borrower and Lender
can agree w writing, however, flat interest shell be paid on the Funds. Lender shall give to
Borrower, wt(hout charge, an annual accounting of the Funds as required by RESPA.
If there is a surplus of Funds held in ewmw, as defined under RESPA, Lender shall account
to Borrower for the excess fiords in accordance with RESPA. Ifdwre is a shortage of Funds held
in escrow, as dcfined under RESPA, Lender shall notify Borrower as required by RESPA, and
Borrower shall pay to Lender the amount necessary to make up the shortage in accordance with
RESPA, bat in no more than, 12 monthly payments. If there is a doftie:ncy of Funds bold in escrow,
as deftteed under RESPA, Lender shall notify Borrower as required by RESPA, and Borrower shalt
pay to Lender the amount necessary to tralm up the deficiency is eccordanoe with RESPA, but in
no more bran 12 monthly payments.
Upon paym ent in full of all sums secured by this Security Instrument, Leader shall promptly
refund to Borrower any Funds held by Leader.
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4. Charges; Liens. Borrower shall pay all t$xes, assessments, charges, finea, and
impositions attributable to the Property which can attain priority over this Security bgr meut
leasehold payments or ground rents on the Property, if any. and Community Association Dues, Fees,
aid Assessments, if any. To the extent that these items art Escrow Items, Borrower shall pay them
in the manner provided in Section 3.
Borrower shall promptly discharge any lien which has priority over this Security Instrument
unless Borrower: (a) agrees in writing to the payment of ills obflgation secured by the lien in a
manner acceptable to lender, but only so long as Borrower is performing such agreement;
(b) contests the lien in good faith by, or defends against enforcement of the lien in, legal proceedings
which in Lender's opinion operate to prevent the enforcement of the lien while those proceedings
are pending, but only until such proceedings are conchhded; or (c) secures 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 can attain priority over this
Seeurity Instrumerrt, Lender may give Borrower a notice identifying the I= Within 10 days of the
date on which that notice is given, Borrower shall satisfy the lien or take one or more of the actions
set forth above in this Section 4,
Lauder may require Borrower to pay a one-time charge for area! estate tax verification and/or
reporting service used by Lender in connection with this Loan.
5. Property Insuraace. Borrower shall keep the improvements now existing or hereafter
erected on the Property insured against Ions by fire, hazards included within the term "extended
coverage," and any other hazards including, but not limited to, earthquakes and floods, for which
Lender requires insurance. This insurance shall be maintained in the amounts (including doductible
levels) and for the perms that Lender requires. What Lender requires pursuant to the preceding
sentences can change during the term of the Loan, The insurance carrier providing the insurance
shall be chosen by Borrower subject to Lender's fight-in disapprove Borrower's choice, which right
shall not be exercised unreasonably. Lender may require Borrower to pay, in connection with this
Loan, eifher. DO a one-time charge for flood zone determination, oertifieation and tracking services;
or (b) a one-time charge for flood zone determination and certification services and subsequent
charges each time remappings or si ndar changes ocmr which reasonably might affect such
determination or certification. Borrower shall also be rmponsr'bie for the payment of any fees
imposed by the Federal Emergency Management Agency in connection with the review of any flood
zone determination resulting from an objection by Borrower.
If Borrower fails to maintain any of the coverages described above, Lender may obtain
insurance coverage, at Lender' a option and Borrower's expense. Lender is under no obligation to
Purchase any particular type or amount ofooverage. Therefore, such coverage shall cover Lender,
but fright or might not protect Borrower, Borrower's equity in the Property, or the contents of the
Property, against any risk, hazard or liability and might provide greater or lesser coverage than was
previously in effect. Borrower acknowledges that the cost of the insurance coverage so obtained
might significantly exceed the cost of insurance that Borrower could have obtained Any amounts
disbursed by Lender under this Section 5 shall become additional debt of Borrower secured by this
Security Instrument. These amounts shall bear interest at the Note late fiom the date of disbursement
and shall be payable, with such interest, upon notice from Leader to Borrower requesting payment,
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All insurance policies repired by Lender and renewals of such policies shall be anbimt to
Lender's right to anwove surb policies, shall include a standard mortgage clause, and shall same
Lender as mortgagee andlor as an additional lose payee. Leader shall have the right to hold the
policies and renewal certif rotes. If Lander requires, Borrower shall pmrnptly give to Lender all
ra=ipft ofpaid prnmsiM and rMIVWW notices. IfBorrower obtains any form of insurance coverage,
not otherwise required by Lender, for damage to, or destruction of, the Property, sash policy shall
iachute a standard mortgage oleum and shall us= Lender as mortgagee and/or as an additional loss
payee. In the event of loss, Bonvwer shall give prompt notice to *a insurance carrier and Lender.
Lender may make proof of low if not made prommpdy by Borrower. Unless Lender and Borrower
otherwise agree in writing, any insurance proceeds, whether or not the underlying insurance was
required by Lender, shall be applied to restoration or repair of the Property, if the to Wration or repair
is economically f s ble and Leader's security is not lessened. Daring such repair and restoration
period, Lender shalt have the right to bold such inuatmee proceeds until. Lender has had an
opportunity to inspect such Property to ensure the work has been cmipleted to Lender`s satisfact on,
provided that such inspection shall be imdcrtalcm promptly. Lender may disburse proceeds for the
repairs and restoration in a single payment or in it series of progress payments as the work is
completed. Unless an agreement is made in writisag or Applicable Law requires interest to be paid
sm such insurance proceeds, Lander shall not be required to pay Borrower any interest or earnings
on such proceeds. Fees for public adjusters, or other third parties, retained by Borrower shall rat be
paid out of the insurance proceeds and shall be the sole obligation of Harrower. ff tine restoration
or repair is not wouornically feasible or Lender's security would be lessened, the insraamce proceeds
shall be applied i o the snorts secreted by this Security Instrument, whether or not then due, with the
excess, if any, paid to Borrower. Such insurance proceeds shall be applied in the order provided for
in Section 2.
If Borrower abandons the Property, Lender may file, nagotiaie and settle awry available
insurance claim and related matters. If Borrower does not respond within 30 days to a notice from
Leader that the insurance carrier has offered to settle a claim, than Lauder may negotiate and settle
the claim, The 304sy period will begin when the notice is given. In either event, or if Lauder
acquires the Property under Section 22 or otherwise, Borrower hereby assigns to Lender
(a) Borrower's rights to any insurance proceeds in an amount not to w=ed the amounts unpaid
under the Note or this Security Instrument, and (b) any other of Borrower's rights (other than the
right to any r:eftind of unearned premix ms paid by Borrower) corder all insurance policies covering
the Properly, insofar as sack rights are applicable to the coverage of the Property. Lender may use
the insurance proceeds either to repair or restore the Property or to pay amounts unpaid under the
Note or this Security Instrumcrit, whether or not then due.
6. Uccapaney. Borrower sbdl oecarpy, establish, and use the Property as Borrower's
principal residence within 60 days aft the execution of this Serenity Instrument and shall continue
to occupy the Property as Borrower' a principal residence for at least one year after the date
of occupancy, mtless Leader otherwise agrees in writing, which consent aball not be unreasonably
withheld, or unless extenuating circumstances exist which are beyond Bormwar's control,
7. Preservation, Mabdessanee and Protection of the Property; Impections. Harrower
shaIl not destroy, damage or impair the Property, allow the Property to deteriorate or commit waste
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on the Properly. Whether or not Borrower is residing in the Property, Borrower aball maintain the
Property in order to prevesd the Property from detoriorsting or decreasing in value due to its
condition Unless it is determbied pursuant to Section S that repair or restoration is not economically
feasible, Borrower shall promptly repair the Property if damaged to avoid hirther deterioration or
damage. If insurance or condmnnation proceeds are paid in connection with damage to, or the tarring
oC the Property, Borrower shall be responsible for repairing or restoring the Property only if Lender
bas released proceeds for such purposes. Lender may disburse proceeds for the repairs and
restoration in a single payment or is a series ofprogisss payments as the work is completed. If the
insurance or condemnation proceeds are not safficient to repair or restore $m Property, Borrower is
not relieved of Borrower's obligation for the completion of sock repair or restoration.
Lender or its agent may make reasonable ernes upon and inspections of the Property. If
it has reasonable cause, Lender may inspect the interior of the briprovemeats on the Property.
Lender shaU give Borrower notice at the time of or prior to such an interior inspecliou specifying
snob reasonable cause.
& Barrowees Loan .Application, Borrower shall be in default ii; during the Loan
application process, Borrower or any persons or entities acting at the direction of Bon-Dwer or with
Borrower's knowledge or consent gave materially false, misreading, or inaccurate iaformsfion or
statements to Lender (or failed to provide Lender wifli material information) in connection with the
Lean. Material representations include, but are not limited to, representations concerning Borrower's
occupancy of the Property as Borrower's principal residence.
9. Protection of Lender's Interest In the Property and Rlgbts Under this Secerlty
bestrament. If (a) Borrower fails to perform the covenants and agreements contained in this
Security Inskurnent, (b)1 hem is a legal proceeding that might slgntficandy affect Leader's interest
in the Property andlor rights under this Security Instrument (such as a proeeeding in bankruptcy,
probate, for condeumaat iiotr or forfeiture, for onfowmao t of a lien which may attain priority over this
Security Instrument or to enforce laws or regalationsl or (c) Borrower has abandoned the Property,
then Leader may do and pay for whatever is reasonable or appropriate to protect Lender's interest
in the Property and rights under this Security Instrument, including protecting and/or assessing the
value of the Property, and securing and/or repairing the Property. Lender's actim can include, but
are not limited to: (a) paying any sums secured by a fi® which has priority over this Security
Instrument; (b) appearing in court; and (c) paying reasonable att oneeya' fees 10 protect its interest
in the Property and/or rights under this Security InstrUment, incluuHng its accured position in a
bankruptcy proceeding. Securing the Property includes, but is not limited to, eateing ere Property
no drake repairs, change locks, replace or board up doors and windows, drain water from pipes,
eliminate building or other code violations or dangerous conditions, and have utilities tanned on or
off. Althoug)n Lender may farce actimh under this Section 9, Leader does not bane to do so and is not
under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any
or all actions authorized under this Section 9.
Any amounts disbursed by Lender under this Section 9 shall become additional debt of
Borrower secured by this Security Instnanent. Thew amowue shall bear imam at the Note rate
from the date of dltabursement and shall be payable, with suede interest, upon notice from Lender to
Borrower requesting payment.
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If this Scmn* Instrumad is an a leasehold, Borrower shalt 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.
10. Mortgage Ins wand e. If Lender required Mortgage Insarance as a condition of making
the Loan, Borrower shall pay the premiums regWred to maiutsin the Mortgage Insurance in effete
If, for any reason, the Mortgage Insurance coverage requited by Leader ceases to be availabie from
the mortgage insurer that previously provided such imsrmome and Borrower was required to make
separately designates{ payments toward the premiums for Mortgage Insurance, Borrower shall pay
the premiums required to obtain coverage snbstanbalty 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 aeleated by Leader. If
substantially agghivaleat Mortgage Insurance coverage is act avaiilable, Borrower shall continue to
pay to Leader the amount of the separately designated payments that were due when the insurance
coverage ceased to be in effect. Larder will accept, use and retain these payments as a non
refundable loss reserve in lieu of Mortgage lnsarauce. Such loss reserve shall be non-refundable,
notwithstanding the fact that the Loan is ultimately paid in full, and Leander shall not be required to
pay Bomawer any f oterest or earnings on ahch loss reserve. Lender can no longer require kiss reserve
payments if Mortgage Insurance coverage (in the amount and for the period that Lender requites)
provided by an insaunr selected by Leader again becomes availeble, is obtained, and Lender requires
separately designated payromm toward the promhmns for Mortgage Insurance. If Lander required
Mortgage Insurance as a condition of making the Loan and Borrower was required to make
separatelly designated payments toward due premiums for Mortgage Inmumca, Borrower sball pay
the premiums requited to maintain Mortgage Insurance in effect, or to provide a non-mftmdable lass
reserve, until Leader's requirement for Mortgage Insurance ends m accordance with any written
agreement between Borrower and Lender providing for such termination or until termination is
required by ApplicaMe Law. Nothing in this Section 10 affects Borrower's obligation to pay interest
at the rate provided in the Note.
Mortgage Insurance reimburses Lender (or any entity that purchases the Note) for certain
losses it may in= if Borrower does not repay the Doan as agreed. Borrower is not a patty to the
Mortgage Insurance.
Mortgage insurers evaluate their total risk on all such insarsuae in force from time to tithe,
and may enter into agreements with other parties that aharc or modify their risk, or reduce losses.
Theae agreements are on temps and conditions that are satisfactory to the mortgage imuser and the
other party (or parties) to these agreements. That agreements may requite the mortgage insurer to
make payments using any source of funds that the mortgage insurer may have available (which may
include fi rods obWued from Mortgage Insurance premiums).
As a remit of these agree, Lender, any purchaser of the Note, another insurer, any
minearer, any other entity, or any affiliate of any of tyre foregoing, may receive (directly or indirectly)
amounts that derive from (or might be characterized as) a portion of Bonowet's payer for
Mortgage Insurance, m exchange for sharing or modifying the mortgage insurer's risk, or reducing
losses. If such agreement provides that an affiliate of Leader takes a share of the insurer's risk in
exchange for a share of the premiums paid to *c insurer, the a m mgeoneat is oftenn, termed "captive
reinsurance." Further:
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(a) Any such agreements will not affed the amomats that Borrower has agreed to pay
for Mortgage Insurance, or any other term of the Loan. Such agreements will not increase
the amount Borrower will owe for Mortgage Iasarance, and they will not w6de Borrower to
any refund.
(b) Any such agreements will not affect the rights Borrower has - 4f any - with respect
to the Mortgage Insurance under the Homeowners PnAectloo Act of 1998 or may ether law.
These rights may Include the night to receive cartida disclosures, to request and obtain
cancellation of the Mortgage Insurance, to have the Mortgage Insurance terminated
automatically, and/or to receive a refunnd of any Mortgage Insurance pressimas that Pere
unearned at the dw of such cancellation or termh[atlam
11-Assignment of Miscellaneous Proceeds; Fezfatfare. All Wascellaneans Proceeds are
hereby assigned to and shall be paid to Lender.
If the Property is damaged, such Idiscellaneovs Proceeds shaft be applied to restoration or
repair of the Property, if the restoration or repair is economically feasible and Lender's security is
not lessened. During such repair and restoration period, Lender shall have the right to hold such
Miscellaneous Proceeds until Lender has had an opportunity to inspect such Property to ensure the
work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken
promptly. Leader may pay for the repairs and restoration in a single disbursement or in a series of
progress payments as the work is completed. Unless an agreement is made in writing or Applicable
Law requires interest to be paid on such Miscellaneous; Proceeds, Lender shall not be required to pay
Borrower any interest or earnings on such Miscellaneous Proceeds. If the restoration or repair is not
economically feasible or bender's security would be lessened, the Miscellaneons Proceeds shall be
applied to the sums secured by this Security Instrument, whether or not then due, with dr excess,
if any, paid to Borrower. Such Kiseellaneous Proceeds shall be supplied in the order provided for
in Section 2.
In the event of & total taking, destruction, or loo in value of the Properly, the Miscellaneous
Proceeds shall be applied to the suers secured by this Swadty Instrument, whether or not then due,
with the excess, if any, paid to Borrower,
In the event of a partial taking, destruction, or loss in valve of the Property in which the fair
market value of the Property immediately before the partial taking, destruction, or loss in value is
equal to or greater than the amount of the sums secured by this Security Instrumeat immediately
before the partial taking, destruction, or loss in. valve, unless Borrower and Lender otherwise agree
in writing, the sutras secured by this Security Instrument shall be reduced by the amount of the
Miscellaneous Proceeds multiplied by the following fraction: (a) the total amount of the sums
secured immediately before the partial talcing, destruction, or loss in value divided by (b) the fair
market value of the Property immediately before the partial taking, destruction, or loss in value. Any
balance shall be paid to Borrower.
In the event of a partial taking, destruction, or lots in value of the Property in which the fair
market value of the Property imrnediatety before the partial taking, destruction, or loss in value is
less than the amount of the sums secured immediately before the partial talaug, diestructiort, or bss
in value, unless Borrower and Lender otherwise agree in writing, the Wfiscellaneous Proceeds shaft
be applied to the sums secured by this Secau'ity Instrument whether or not the sums are then due.
If the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the
Opposing Party (as defined in the next sentmce) offers to make an award to settle a claim for
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damages, Borrower fails to respond to Lender wMa 30 days after the date the notice is given,
Lender is authorized to collect and apply the hfiseeltaneons Proceeds either to restoration or repair
of the Property or to the sums secured by this Security Instrument, whether or not then due.
"Opposing party" means do third party that owes Borrower Miscellaneous Proceeds or the party
against whom Borrower has a right of action in regard to Miact laoeous Proceeds.
Harrower shall. be in default if any action or proceeding, whether civil or criminal, is begin
that, in Lender's judgment, could result in forfeiture of the Property or other material impairment
of Lender's interest m the Property or *his radar this Security Instrument. Borrower can cute such
a default and, if ac calerstiou has occu:rred, reinstate as provided in Section 19, by caning the action
or proceeding to be dismissed with a raping that, in Lender's judgment, precludes forfeiture of the
Property or other material impairment of Leader's interest in the property or 4bts under this
Security Instrunent The proceeds of any award or claim for damages that are etlributable to the
impairment of Lender's interest in the Property are hereby assigned and shall be paid to Lexmder.
All MmAsneoas Proceeds that are not applied to restoration or repair of the Property shall
be applied in the order provided for in Section 2.
12. Borrower Not Released; Forbearsace By Lender Not a Waiver. Extension of the
time for payment or modification of amortization of the sums secured by this Security Instrument
granted by Lender to Borrower or any Successor in Interest of Borrower shall not operate to rd um
the liability of Borrower or any Successors in Interest ofBorrower. Lender shall not be required to
commence proceedings against any Successor in Intrust of Borrower or to refine to extend tiara for
payment or otherwise modify amortization of the sums secured by this Security Instrument by reason
of any demand made by the original Borrower or any Successors in Interest of Borrower. Any
forbearance by Lender in exercising any right or remedy including, without limitation, Larder's
acceptance of payments from third persons, entities or S=cssors inlateest of Borrower or in
amounts less than the amount then due, shall not be a waiver of or prmludc the exercise of any right
or remedy.
13. Joint and Sevaid Liability; Co-sigaen; Successors and Assigns Bowul. Bon w w
covenants and agrees that Borrower's obligations and Habiility shall be joint and szveral. However,
any Borrowerwho co-signs this Security Instrument but does not execute the Note (a "cc-sigacr'")
(a) is co-signing this Secarity Instrument only to mortgage, grant and convey the co-signer's interest
m the Property under the terms of this Secrn* Instrument; (b) is not personally obligated to pay the
sums secured by this Security Instruments and (c) agrees that Lender and any other Borrower can
agree to extend, modify, forbear or make any accommodations with regard to the terms of this
Security Instrument or the Note without the co-signer's consent
Subject to the provisions of Section 18, any Successor in Interest of Borrower who assumes
Borrower's obligations under this Security Instrument in writing and is approved by Leader, shall
obtain all of Borrower's rights and benefits under this Security Instrument. Borrower shall not be
released from Borrower's obligations and liability under this Security Instrument unless Lender
agrees to such release in writing. The covenants and agreeaneats of this Security Instrument shall
bind (except as provided in Section 20) and benefit the successors and assigns of Leader.
14. Loan Charges. Lender may cbKp Borrower fees for sat-vices performed hs connection
with Borower's default, for the purpose of protecting Lender's interest in the Property, and rights
under this Security Instrument, including, but not fronted to, attorneys' fees, property inspection and
valuation ferns. In regard to any other fees, the absence of express authority in this Security
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Instrument to charge a specific fee to Borrower shall not be construed as a prohibition on the
charging of such fee. Lender may not charge fees that are expressly prohibited by this Security
lnsmauent or by Applicable Law.
If the Loan is subject to a law which sets maximum loan charges, and that law is finally
intmpprWA so that the irftrest or other loan charges collected or to be collected in connection. with
the Loan exceed the permitted limits, tlrea: (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 fuvm
Borrower which exceeded permitted limits will be rdbMed 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 redu ctim will be treed as a partial prepayment without
any prepayment charge (whether or not a prepayment charge is provided for under the Note).
Borrower's acceptance of any such refund made by direct payment to Borrower will constitute a
waiver of any right of action Borrower might have arising out of such overcharge,
15. Notices. All notices given by Borrower or Lender in counec6on with this Security
Instrument mua be in writing. Any notice to Borrower in connection with dais Security Instrument
shall be deemed to have been given to Borrower when mailed by first class mail or when actually
delivered to Borrower's notice address if sent by other means. Notice to any one Borrower shall
constitute notice to all Borrowers unless Applicable Law expressly requires otherwise. The notice
address shall be the Property Address unless Borrower has designated a substitute notice address by
notice to Lender. Borrower shall promptly notify Lender of Barrowet's change of address. If Lender
specifies a procedure for reporting Borrower's change of address, then Borrower shall only report
a change of address through that specified procedure. There may be only one designated notice
address under this Security Instrumeat at any one time. Any notice to Lender shall be given
by delivering it or by mailing it by first class mail to Lender's address stated herein unless Lender
has designated another address by notice to Borrower. Any notice in connection with this Security
Instrument shall not be deeemled tD have been giver to Lender until actually received by Lender, If
any notice required by this Security Inefinent is also required under Applicable Law, the
Applicable Law requirement will satisfy the corresponding requirement under this Security
instrument.
16. Governing Law; Severabilty; Rules of Construction. This Security ]aatrument shall
be governed by federal law and the law of the juriadictioa in which the Property is located. All rights
and obligations contained in this Security Instrument are subject to any requirements and limitations
of Applicable Law. Applicable Law might explicitly or implicitly allow the parties to agree by
contract or it might be sila rk but such silence shall not be construed as a prolubition against
agreement by contract. In the event diet any provision or clause of this Security Instrument or the
Note conflicts with Applicable Law, such conflict shall not affect other provisions ofthia Security
Instrument or the Note which can be given effect without the conflicting provision.
As used in this Security Instrument: (a) words of the masculine gender shall mean and
include corresponding neuter words or words ofthe feminine gender; (b) words in the singular shall
mean and inchrde the plural and vice vcrsa; and (c) the word'Imay^ gives sole discretion without any
obligation to take any action.
17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security
instrument
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18. Tnaeder of the Property or a Beneficial Interest la Borrower. As used in this
Section 18, "I.nti adja the Property" means any legal or beneficial interest in the Property,
including, but not limited to, those beneficial interests transferred in a bond for deed, contract for
deed, insta mat sales contract or escrow agreement, the intent of which is the transfer of title by
Born war at a fuhrre date to a purchaser.
if all or any part of the Property or any Interest in the Property is sold or transferred (or if
Bonvwer is not a natural person and a beneficial interest is Borrower is sold or transf nod) without
Lender's priorwritten consent, Lender may require immediate payment a full of all sums secured
by this Security lnehament. However, this option shall not be exercised by Lender if such exercise
is prohibited by Applicable Law.
IfLender exercises (his option, Lender shall give Borrower notice of seoderetion. The notice
shall provide a period of not less than 30 days from the data the notice is given in accordance with
Section 15 within which Borrower must pay all stuns secured by this Security Instrument, If
Borrower fails to pay these sums prior to the expiration of this period, Lender nay invoke any
mmedias percaitted by this Security Instrument without further notice or demand on Borrower.
19. Borruwer's Right to Reinstate After Accelmation. If Borrower meets certain
conditions, Borrower shall have the right to have enforcement of this Security Instrument
discos at any time prior to the earliest of (a) five days before sale of the Property pursuant to
any power of sale oontamed m this Security Instrument; (b) sack other period as Applicable Law
migid specify for the termination of Borrower's right to reinstate; or (c) entry of a judgment
enforcing fibs Security Instrument. Those conditions are that Borrower. (a) pays Lender all sums
which then would be due under this Security Instrurnent and the Note as if no accaleration had
occurred; (b) cures any default of any other covenants or agnearnents; (c) pays all expenses ft a wd
in enforcing this Scmxity Instrument, including, but not limited to, reasonable sdorveys' fees,
property inspection and valuation furs, and other fees inured for the purpose of protecting LAmder's
interest in the Property and rights under this Security Instrumwm ; and (d) fakes suck adhere as Lender
may reasonably require to assure that Lender's interest in the Property and rights under this Semoty
Instm n ant, and Borrowe es obligation to pay the sums secured by Phis Security Instrument, shall
coubme unchanged. Lander may require that Bomnwer pay such reinstatement some and expenses
in one or more of the fallowing forms, as selected by Lender: (a) cash; (b) money order (c) =tified
check, bank cheat, treasurer's check or cashier's check, provided any such check is drawn upon an
i vzt r on whose deposits are Insured by a federal agency, instrumentality or entity; or (d) Electronic
Funds Transfer. Upon reinstatement by Borrower, Ws Security Instrument and 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 Section 18.
20. Sale of Nom; Change of Loan Servicer ; Notice of Grievance. The Note or a partial
interest in the Note (together with this Seca&y Instrument) can be sold one or more times without
prior notice to Borrower, A sale might result in a change in the entity (known as the "Loan
Servioer") that toilette Periodic Payments due under the Note and this Security Instrument and
performs other mortgage loan servicing obligotiow under the Note, Ws Setnrity Instrument, and
Applicable Law, Them also alight be one or more changes of the Loan Sexvicer trrnelated to a ale
of the Note. If tb = is a Change of the Loan Servic cr, Borrower will be given written notice of the
dsange which will state the name and address of the new Loan Servieer, the address to which
payments should be made and any other information RESPA requires in connection with a notice
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of transfer of servicing. If the Note is sold and thereafter the Loan is serviced by a Loan Servicer
other than the purchaser of the Note, the mortgage loan servicing obligations tQ Borrower will
rcoaain with the Loan Servioer or be trandferred to a successor Loan Servicer and are not assumed
by the Now purchaser unless otherwise provided by the Note purchaser.
Neither Borrower nor Lender may commence, join, or be joined to any ju&cial action (as
either an individual litigant or the member of a ohm) that arises from the other party's actions
pursuant to this Security Insmxnrant or that alleges that the other party has breached any provision
of, or any duty owed by reason oi, this Secarity Insttutneat, until such Borrower or Leader has
notified the other party (with such notice given m compliance with the requirements of Section 15)
of such alleged breach and afforded the other party hereto a reasonable period afk r the giving of such
notice to tube corrective action. FfApplicable Law provides a time period which must elapse beibre
certain action can be taken, that time period will be deemed to be reasonable fbr purposes of this
paragraph. The notice of acceleration and opportunity to come given to Borrower pursuant to Section
22 and the notice of acceleration given to Borrower pun mut to Section 18 shall be deemed to satisfy
the notice and opportunity to take corrective action provisions of this Section 20.
21. Hazardous Substanees. As used in this Section, 21: (a) "Hazardous Substances" are
those substances defined as toxic or hazardous substances, pollutants, or wastes by Environmental
Law and the U lowing substances: gasoline, kerosene, other flammable or toxic petroleuru product,
toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and
radioactive materials; (b) "Environmental Law" means fedessl laws and laws of the jurisdiction
where the Property is located that relate to haaltt, safety or eavironmental protection;
(c) 'Environmental Cleanup" includes any response action, remedial action, or removal action, as
defined in Environmental Law; and (d) an "Environmental Condition" means a condition that can
cause, contribute to, or otherwise triggor an Environmental Cleararp.
Borrower shall not cause or permit the presence, use, disposal, storage, or release of any
Hazardous Substances, or threaten to release any Hazardous Substances, on or in the Property,
Borrower shall not do. nor allow anyone else to do, anything affecting the Property (a) that is in
violation of any Environmental Law, (b) which creates an Environmental Condition, or (c) which,
due to the presence, use, or release of a Hazardous Substance, creaft a condition that adversely
affects the value of the Property. The preceding two seatemoxs shall not apply to the presence, use,
or storage on the Property of small quantities ofHaz wdom Substances that are generally recognized
to be appropriate to normal residential uses and to maintenance of the Property (including, but not
limited to, hazardous substances in consumer products).
Borrower shall pion Ay give Lender written notice of (a) any investigatiorr, claim, demand,
lawsuit or other action by any governmental or regulatory agency or private party irrvoh* the
Property and any Hazardous Substance or Emvitmmerdal Law of which Borrower has actual
knowledge, (b) any Envirownental Condition, including but not limited to, any spilling, leaking,
discharge, release or threat of release of any Hazm*w Substance, and (c) any condition caused by
the presence, use or release of a Hazardous Substa m which adversely affects the value of the
Property, If Borrower learns, or is notified by any governmeaW or regulatory authority, or any
private party, that any removal or other mediation of any Hazardous Substance affecting the
Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance
with Environmental Law. Nothing herein shall create any obligation on Lender for an
Environmental Cleamgh.
PUMYLVAMA-SkmisFwWb-Fader wMkeddreMwINWOYMVaTRUil M Farm3W Lot OMW!t, tdpaged
P11 May-RM "M
BX 184gP 1767
NODE UNIFORM COVENANTS. Baaower and Lander farther covanant and agree as
foilows.
22. Acceleration; Remedles. Leader shall give notice to Borrower prior to acceleration
following Borrower's breach of any eavenaat at agreement in this Semity In sfimment (bat
not prior to acceleration undwr Section 18 unless Applicable Latin provides otherwise). Leader
skaS notify Borrower 4 among other things: (a) the default, (b) the action required to care
the default; (c) when the default must be cared; and (d) Ong failure to care the default as
specified may reedit In acceleration of the sans secured by this Security Instrument,
foreclosure by judicial proceeding and ask of the Property. Leader shall furtlier inform
Borrower of the right to relastate after acceleration and the right to assert is the foreclosure
proceeding the am-existence of a default or any other defense of Borrower to acceleration and
foreclosure. If the defaalt h not cured as specified, Lender at its option may require
immediate payment in full of aU sums secured by this Security Instrument witkoat farther
demand and may foreclose this Security Instrument by judicial proceeding. Leader shall be
entitled to collect an ezpe un incurred in parsaisg the reaaedles provided in this Section 22,
including, but not Bruited * attorneys' few and dots of title evidence to the extent perasfed
by Applkable Law.
23. Relerste. Upon payment of all sums secured by this Security lnstrament, this Security
Instrument and the estate conveyed shalt tam mate and became void After such owwreace, Lender
shall discharge and satisfy this Security Instrurnent. Borrower shell pay any recordation costs.
Lender may charge Borrower a fee for releasing this Secuity Instrument, but only if the fee is paid
to a third party for services rendered and the clanging of the fee is permitted under Applicable Law.
?A Waivers. Bonvwer, to the extent permitted by Applicable Law, waives and rem any
error or defects in proaxdinga to enforce this Security Instrument, and hereby waives the benefit of
day present or future laws provi#g for stay of execution, extension of time, exemption from
attachment, levy and sale, and homwtead exemption.
25. Reinstatement Period. Borrower's time to reinstate provided in Section 19 shell extend
to mm hour prior to the commencement ofbidding at a sheriffs We or other sale pursuant to this
Security bnstrnmont.
26. Purchase Money Mortgage. If any of tine debt scmvd by this Security Instrument is
lent to Borrower to acquire title to the, Property, this Security bxsi mment shall be a purchase money
mortgage.
27. 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 NOW
PLl tMLVANtA-S1qeFUTOY--FAdkNiw& "kU"UWOBASWSIZVOWT Fa =3W W1 6mvIS f)6pVq;
PA04ll.PRM MAi
BKI 84-9PV 1768
BY SIGNING BELOW, Bummer accepts and agrees to the terms and coveoettts coaWaad
in this Sem rhy lasttvmeat and in say Rider eaearted by Hmm7wer and morded wilh it.
Signed, sealed and dalivqed the preaeoce of.
k?4h4?-_
pe & 17dA"G`_ (Sea)
Soaal Semutty Numbers si-4405-Barra
Pet)
-Bomwer
Social Secarity Number
- tseal?
Bmmwcr
Social Security Number
(Seal)
-Borrower
Social Security Number
[Space Below This Unc far Admowledpaent]
Certirmte of Reddmm
the ?r xt address of tha within. aaua d Mortgagee is 10 UJPPS LANE
R1VMWE, Rl 0271S -?
,do hereby cartify that
Wham my hand this t4th day of D 2001
fct•
Agek of Mm%ngw
COMWNWBALTH OF PEMgYLVANLt, tic Cl-A_Wl Dis4-Aro k) county we
On this, the 19* day of December 2007 ,befum me, the
uudem4ped officer, personally appeared,
ROHEBT K. DANNFB
known to me (of satlafactadly proem) to be dw Pesaoa(s) whose Inter(s) is/are submibed to the wkbin
inatrvmwA and acitnowiedged that halshe:ldwy owcuted the same far the parposea bcreki contained.
IN WrMM WHEREOF, I heraunw set my hand and official seal,
h'fY Canvmisaiaa Buplres:
?o?t? me of O€fi
tas.e.,uaaorunh
aaaa
PAa23FaM SeMl?c iL,a lQb 114 tow la r2sp sl
PAOiLCP?1,t M@
BK 1849PG 1769
}w, 7UT CZLTAZH piece or p¦rcal of land eituits in the Baroup of ebt kmi'asbuta, ,
Otimbeclaud County, Paanayl'ania, bounded and described so follows, to wit:
Ei at a point an the !Earth aids of Welt Allen Streat, at acme; of lands ?
now or fonorly of belly Mattis 11"art thenoa along Al.le-u West, westward ¦u- {
-tats and three hondradthe 116.03) fiat to i point at career of Unds nov or
lo"oplr of Jolla 3. Ockrri Fhexice by slit line of said Los, uorthVwrd and through ,
the center of a frme partition vall and bayond, ninety (90,00) feet, mate at Fees,,
to a point at Qc'mar of leads now or formally of AwLe Pauby; thenoe glong line
of said Lot, a9mow"A Oxteou and f-kyo-tetsubo (16.5) feet, part at Lass, to a
point: ttc cumv of Lot nos or towarly of Dolly 14artiq Wsbar aforsaaidi theaae '
alnad t6a ],ins of said Let, Oowtluakd end throag(t the auobcr of a franc gxzts rfm
Mall, eighty-eight (86.00) Faet, mote of laas,-•te a pubit, the plane of 81DOt11NVIr. l
K 18 4 9-M 17,70
VJL ASSUMPTION POLICY RWER
NOTICE: TM LOAN IS NOT ASSUMABLE WITHOUT THE APPROVAL. OF
THE DEPARTMENT OF VETERANS AFFAIRS OR ITS AUT14ORTZED AGENT.
THW ABe WDQN P0L CYA0M 4 rude tftla 19111 day el Ome"dw 2093 ,
armdi Neotperahd imde eaddaiMetwaad b mrwnd aedstmpdmrrddw abrO.We. CMd dTrw6 mrr Oedb BaanetHM -
t7nsf.ewit'}dfrwea4ahrewm.YMwrhYia*dmlp?odCNegpr?}mraeuada?IonPOa's Net. S'?a9dlraame
dote m
CITIZENS MORTGAGE CORPORATION , a Rhode Im*W CarpormMon,
h mamwaar! ad *ubam CVA4pmaw') wdmovwitmptbm pddpwtydwwed bat artnammaawdbmdad &
214 WET ALLEN FMINT
MECHANIOMURG, PA 17055
Nob4+ebmdmV W4* l* aw Cal*wy.r era, In ama kmmamrawn, MmrWgW rod umty.pm rmaatmy adwvMWpm and now tear
falkx ma
GUARANTY: swum the Dapammrmd dvdwwm Mika fa or mtun b qua ra prmaaykblammrmt aKMmrmadmgr hear or
dwarfd&erramidmmommdybamaraslooprwamhprongmatmr" up=by0wDmpmrtwldVakrawAftWwdw
ar prwWm orTrra 36 d the U.L Code'Vdmm Bwmdh; 16e Modpapw"dads drbdsMowm kvoby aamadd dmmmwa
dae amd paydaa amd many brmmtmaa bamndtateq' a mmmq aaewba aryl aammrmfphb mrmaadw a kits mnyaawrpn?mw amiamm u M
law pmwA"
TRANSFER OFTHE- PROPERT &d way put d tw Pampady or aq blrwtb ak add ma taoreuwr tlrabrt troy b
tr.d.rrdr.rm.totrdnerrdP •ww+baairC.,a.,,rpm,rrda¦pdr.r4 .mr.1 moo* term.ayaat.r.moC..wrdat
wlwatwacampaauydrrumxppkawr<wardartatamimvbbft hVdoaapefWWWv*mmANwQe
wtotada" pwawMta sadt= s?ud eawirsr, TED Sk tk*WSM" Cmi .
Madmwimed iMfrw('tlwlalpmmi') dai pemmpmmty abY raao 3N amr)mdb addammal ravwmab and mpaaweaa n met twat blare
(e)ASWMPTIONFLINOMFEE%ramegudbmom.hddtpwndtWdtlrwwdddpr' tm9wwdImk
can w dar mYb dlrmmdwd aw pmpwlydmd pmpaymblad amtimr dtanmirb Ism amnmpepae mrla amfmddnd myear. w rtwie
bwruo.p.aeiddvd.mwAtldm. xnea.wn.rerrbpgwar..aaarmraearwr,d,.Maaaraauhaa.n.ereaw
dbbticartdmimyaaaradbyamkbamwmmwmt,daKbw.fundstew maalook, pwAdmaand,atttwWftdkam erwmat
ml - mtmartmarandy aaaaadoreq aardieve2 weal, ah d he turrdwiby dwa W papVt. Ible fee it admuwm¦l y er-do
K au.wanwimwmgawdmraa prwkkro daU.s C.3a roL
(b)ASSUMPTIONPROCESSINGOHARGg4 mmmppleatemtlarappmavdbdayunugKwmdtrwhrottth
bamm, a paaneivf@a rwy Gedurgad by lM o-ion orb mdiw od mmpal tmrdrimmo Kt a mmrmhmwambmw d on sa mr
ada s*wpnmiienishtdam' wAmm WpmwdmwhmaaAppwmdttwatwimrr0mA11maomeafft min Mel
rot nod Kr w"Ordba armramaa mWbPshd by tlr Dmpwtrdr4 olVdwww A41o Iwatmwm a wtdmb $oWbn VUd prow
77. Tft 3e, W" ftba Cade applaawaW mredrna prwwbmd by eppo=W ftb w.
(a) ASSUMPTION INOEMNITYLIABMJTY3rtrdaawk0llmneanenKrhanam¦wwawbm*vor mtaammwee
aKd*WcHoommodvdamnwwwarramsdmbrbwwdmwmm ftwwnotrrgttabatbmbmdrytlmammtilKm- dtre
vdaaeblydwm*dwDepwtmtdVdawmAihdatadoeortwtday*Wpararadaditia adftivathe goes* or' of
aw im MM mma op=ted by tale lawrmea
IN W HESS WHEREOF, kwtpeamr*) has amamtMdamk Anwmdmn Palo/ Mdma.
,mmit-
R013ERT BERT IL DANNER mm..,.ar, WNW
-;sdall -000
amore mmmrot°r
I Certify this to be =rded
in Cumberland County PA
mw. ??? a,mr~w.?oa-m?ratr
.L
Recorder ofDee* ?. 9 PG 177 f
2274080
r
40NOTE
NOTICE: THIS LOAN IS NOT ASSUMABLE WITHOUT THE
APPROVAL OF THE DEPARTMENT OF VETERANS AFFAIRS
OR ITS AUTHORIZED AGENT.
[OmI [city] 1kft]
December 19 2003 MECHANICSBURG PENNSYLVANIA
[Pmpetty ]
214 WEST ALLEN STREET MECHANICSBURG, PA 17055
1. BORROWER'S PROMISE TO PAY
In return for a loan that 1 have received, I promise to pay U.S. $ 73,400.00 (this amount
is called "Principar), plus interest, to the order of the Lender. The Lender is CITIZENS MORTGAGE CORPORATION
a Rhode ldand Corporation
I will make all payments under this Note in the form of cash, check or money order.
1 understand that the Lender may transfer this Note. The Lender or anyone who takes this Note by transfer and
who is entitled to receive payments under this Note is called the "Note Holder."
2. INTEREST
Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay interest at a
yearly rate of 5.875 W
The interest rate required by this Section 2 is the rate I will pay both before and after any default described in
Section 6(B) of this Note.
3. PAYMENTS
(A) Time and Puce of Payments
I will pay principal and interest by [Waking a payment every month.
I will make my monthly payment on the First day of each month beginning on February 1 2004
l will make these payments every month until I have paid all of the principal and interest and any other charges
described below that I may owe under this Note. Each monthly payment will be applied as of its scheduled due date
and will be applied to interest before Principal. If, on January 1 2034 .I still owe amounts
under this Note, I will pay those amounts in full on that date, which is called the "Maturity Date." I will make my
monthly payments at
PO BOX 4512 WOSURN, MA 01888-4512
or at a different place if required by the Note Holder
(8) Amewt of Monthly Payments
My monthly payment will be in the amount of U.S. $ 434.18
MULTISTATE FIXED RATE NOTE-Nn& Famay-F=1k MAdF1rWdir Mac UNIFORM INSTRUMEW (with VA madMeadent)
ZAa9. 09/00 (Pale 1 of 4) Form 32001101
SMOVA.FR1r1 41 Vet)
4. BORROWER'S RIGHT TO PREPAY - i- t
I have the right to make payments of Principal at any time before they are due: A payment of Principal only is
known as a "Prepayment." When I make a Prepayment, I will tell the Note Holder in writing that I am doing so. I
may not designate a payment as a Prepayment if I have not made all the monthly payments due under the Note.
I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder
will use my Prepaymems to reduce the amount of Principal that I owe under this Note. However, the Note Holder
may apply my Prepayment to the seemed and unpaid interest on the Prepayment amount, before applying my
Prepayment to reduce the Principal amount of the Note, If I make a partial Prepayment, there will be no changes in
the due date or in the amount of my monthly payment unless the Note Holder agrees in writing to those changes.
5. LOAN CHARGES
if a law, which applies to this loan and which sets maximum loan charges, is finally interpreted so that the
interest or other loan charges collected or to be collected in connection with this 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 me which exceeded permitted limits will be refunded to me, The Note
Holder may choose to make this refund by reducing the Principal I owe under this Note or by making a direct
payment to me. Ifa refund reduces Principal, the reduction will be treated as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Cbarge for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the end of 15
calendar days after the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be
4.000 %of my overdue payment of principal, interest and escrow for taxes and insurance. 1 will
pay ibis late charge promptly but only once on each late payment.
(B) Default
If I do not pay the full amount of each monthly payment of the date it is due,1 will be in default.
(C) Notice of Default
If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue
amount by a certain date, the Note Holder may require me to pay immediately the full amount of Principal which
has not been paid and all the interest that I owe on that amount. That date must be at least 30 days after the date on
which the notice is mailed to me or delivered by other means.
(D) No Waiver By Note Holder
Even if, at a time when I am in default, the Note Holder does not require me to pay immediately in full as
described above, the Note Holder will still have the right to do so if I am in default at a inter time.
(E) Payment of Note Holder's Costs and Expenses
If the Note Holder has required me to pay immediately in full as described above, the Note Holder will have the
right to be paid bade by me for all of its costs and expenses in enforcing this Note to the extent not prohibited by -
applicable law. Those expenses include, for example, reasonable attorneys' fees.
7. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will be
given by delivering it or by mailing it by first class mail to me at the Property Address or at a different address if I
give the Note Holder a notice of my different address.
Any notice that must be given to the Note Holder under this Note will be given by delivering it or by mailing it
by first class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am
given a notice of that different address.
8. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person is fully and personally obligated to keep all of the
promises made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor,
surety or endorser of this Note is also obligated to do these things. Any person who takes over these obligations,
including
ZA90: 09lC0 (Page 2 of 4)
32001VARIM n1rot)
3a001VA M4MM
a '
t
c
i i
the obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises made in
this Note. The Note Holder may enforce its rights under this Note against each person individually or against all of
us together. This means that any one of us may be required to pay all of the amounts owed under this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the rights of Presentment and Notice of
Dishonor. "Preseatmere means the right to require the Note Holder to demand payment of amounts due. "Notice of
Dishonor" means the right to require the Note Holder to give notice to other persons that amounts due have not been
paid.
10. UMFORM SECURED NOTE
This Note is a uniform instrument with limited variations in same jurisdictions. In addition to the protections
given to the Note Holder under this Note, a Mortgage, Deed of Trust or Security Deed (the "Security Instrument"),
dated the same date as this Note, protects the Note Holder from possible losses which might result if I do not keep
the promises which I make in this Note. That Security Instrument describes how and under what conditions I may be
required to make tmRtediate payment in fill of all amounts lowe under this Note. Some of those conditions are
described as follows:
Regulations (38 C.F.R. Part 36) issued under the Department of Veterans Affairs ("V.A.") Guaranteed
Loan Authority (38 U.S.C. Chapter 37) and in effect on the date of lost closing shall govem the rights, ditties
and liabilities of the parties to this loan and any provisions of this Note which are inconsistent with such
regulations are hereby amended and supplemented to conform thereto.
WITNESS THE HAND(S) AND SEAL(S) OF THE UNDERSIGNED
(seat)
ROBERT K. DANNER -Borrower
(Scal)
-Borrower
-Borrower
7A91 '09/00
32002VA.FRU,1 ,,I,
Past to the ft0r d (ftp 3 of4)
Without Recourse
Cheselmanhattan Mortgage Corporrl&M
PAY TOmowftecoutsETHE ORDER OF
CUK AMAMMAWWAM &&.
tiA?E cupwl8il
ax
PUNW_
CM'?S MORTGACM CORPORA DON
BY_.ji???? urn
REBECCA BROW WASST. SECRETARY
.• (Seal)
•. ? - '-BOteOWQ
(Seal)
-BO[19wer
[Sign Original Only]
ZA92 oww (Page 4 of 4)
3WWA,"W o!mo?
ALL THAT MUZL= { piece or parcel of land .ituits in the Borough of HsehsnVcsbuig,
Cumberland County, Pennsylvania, bounded and desctribad as folloxas to wit;
8x0Ijr1iM at a paint on the IVacth aide of Viest Allen Street, at aorue; of lards
nD0 at forMatly of Dolly Hattin Yeber; thence along Allen Street, weatteard six-
-teen and three hundredcha 0.6.03) feet to a point ar corner of lands nos or I
formerly of John $. Oeker; ;henct by the line of said Lot, northward end through
the center of a frame partition wall and beyond, ninety (90,DO) feet, recto or leveli
to s point at torntr of laude now or formerly of Mnia Innubyi thence along line
of said Lot, eaetvard sixteen and five-tenths (16.5) feet, more or lass, to a j
point at corner of Lot nosr or formerly of Dolly Martiq Weber aforesai8I thence
along the line of said Lob, vovthwerd and through the eagter of a frame partition
wall, eighty-eight (88.00) felt, moue at lese,•'to a poi'ht r the place of BBGINRING..
NAME AFFIDAVIT
THE STATE OF:
COUNTY OF:
BEFORE ME, the undersigned authority, a Notary Public In and for said County and State, on this day
personally appeared ROBERT K DANNER
, who after being by me first duly sworn,
upon his/her oath does depose and say:
THAT
as the name is signed on the Note and Deed of Trust in connection with the purchase of property known as
Lot . Block _
is one and the same person as
as the name appears on the FHANA Commitment or Contract of Sale.
SUBSCRIBED AND SWORN TO before me this thel h day of December 2003
?tcrreaem o lic in and for
Mir Crtd?t rtarq Aeb
MAdwile?Eiry emo. CuaOrYM Oau+y
eMOalrNrloneopw.epwsllr.ft,aaoe a.. ? County, p?
aSNA P1101)
Name AIWM
Date: 7009 2820 D003 8346 4291
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
5211 Pine Hill Road
Dover, PA 17315
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
This is an official notice that the mortgage on Your home Is in default and the lender
intends to foreclose. Specific information about the nature of the default is Provided in the
attached pages.
The HOMEOWNER'S MORTGAGE ASSISTANCE PROGRAM (HEMAP) may be able
to help save Your home. This notice explains how the pro tram woT To see if HEMAP
can help. von must MEET WITH A CONSUMIMR CREDIT COUNSELING AGENCY
WITHIN 33 DAYS OF THE DATE OF THIS NOTICE Take this Notice with You when
on meet with the Conn-— Agency
The name, address and phone number of Consumer Credit Counseling Agendes serving
your County are listed at the end of this Notice If You have any questions. you may can the
Pennsyivanin Housing Finance Agency toil free at 1,800-342-2397 (persons with impsired
hearing can call (717) 780-1869).
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain it.
You may also want to contact an attorney in your area. The local bar association may be
able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA SU
DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDITAMENTE LLAMANDO ESTA AGENCIA (PENNSYLVANIA HOUSING
FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO ARRIBA. PUEDES
SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA LLAMADO
"HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE PROGRAM" EL CUAL
PUEDE SALVAR SU CASA DE LA PERDIDA DEL DERECHO A REDIMIR SU
HIPOTECA.
ExhIh?T ??C??
HOMEOWNER'S NAME(S):
Danner, deceased
PROPERTY ADDRESS:
LOAN ACCT. NO.:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER
LAW FIRM FILE NO.:
Darla Maurer, Representative for the Estate of Robert K.
214 West Allen Street, Mechanicsburg, PA 17055
Citizens Mortgage Corporation
Chase Home Finance, LLC
10-038403
HOMEOWNER'S EMERGENCY MORTGAGE ASSISTANCE; PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
IF YOU COMPLY WITH THE PROVISION OF THE HOMEOWNER'S EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE
FOR EMERGENCY MORTGAGE ASSISTANCE:
IF YOU DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND
YOUR CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY
THE PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE- Under the Act, you are entitled to a temporary
stay of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three
(3) days for mailing). During that time you must arrange and attend a "face-to-face" meeting
with one of the consumer credit counseling agencies listed at the end of this Notice. THIS
MEETING MUST OCCUR WITHIN THE NEXT THIRTY-THREE (33) DAYS. IF YOU
DO NOT APPLY FOR EMERGENCY MORTGAGE ASSISTANCE. YOU MUST BRING
YOUR MORTGAGE UP TO DATE THE PART OF THIS NOTICE CALLED "HOW TO
CURE YOUR MORTGAGE DEFAULT" EXPLAINS HOW TO BRING YOUR MORTGAGE
UP TQ DATE.
CONSUMER CREDIT COUNSELING AGENCIES- If you meet with one of the consumer
credit counseling agencies listed at the end of this notice, the lender may NOT take action
against you for thirty (30) days after the date of this meeting. The names, addresses and
telephone numbers of designated consumer credit counseling agencies for the county in which
the property is located are set forth at the end of is Notice It is only necessary to schedule one
face-to-face meeting. Advise your lender immediately of your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE- Your mortgage is in default for the
reasons set forth later in this Notice (see following pages for specific information about the
nature of your default). You have the right to apply for financial assistance from the
Homeowner's Emergency Mortgage Assistance Program. To do so, you must fill out, sign and
file a completed Homeowner's Emergency Assistance Program Application with one of the
designated consumer credit counseling agencies listed at the end of this Notice. Only consumer
credit counseling agencies have applications have for the program and they will assist you in
submitting a complete application to the Pennsylvania Housing Finance Agency. To temporarily
stop the lender from filing a foreclosure action, your application MUST be forwarded to PHFA
and received within thirty (30) days of your face-to-face meeting with the counsel ing agency.
YOU SHOULD FILE A REMAP APPLICATION AS SOON AS POSSIBLE IF YOU HAVE A MEETING
JFrM A COUNSELING AGENCY WITHIN 33 DAYS OF THE POST MAR$ DATE OF THIS NOTICE M
FILE AN APPLICATION WITH PHFA if77HIN 30 DAYS OF THAT MEETING, THEN THE LENDER
WILL BE TEMPORARILY PREVENTED FROM STARTING A FORECLOSURE AGAINST YOUR
PROPERTY, AS EXPLAINED ABOV& IN THE SECTION CALLED "TEMPORARY STAY OF
FORECLOSURE'.
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND n =f TIME PERIOAs A
LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A FORECLOSURE
ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY TIME BEFORE A
SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION -- Available funds for emergency mortgage assistance are very limited. They will
be disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania
Housing Finance Agency has sixty (60) days to make a decision after it receives your application. During
that time, no foreclosure proceedings will be pursued against you if you have met the time requirements
set forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision
on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy, you can still analy for Emereenev MortvaQe Assistance-1
HOW TO CURE YOUR MORTGAGE DEFAULT Bring it up to date)
NATURE OF THE DEFAULT-The MORTGAGE debt held by the above tender on your
property located at: 214 West Allen Street, Mechanicsburg, PA 17055
IS SERIOUSLY IN DEFAULT because:
A. YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS for the following months
and the following amounts are now past due:
May 1, 2010 to September 1, 2010 @ 611.77 = 058.85
Other charges (explainlitemize):
Late Charges: May 16, 2010 to September 16, 2010 @ 24,47 = S122.35
Inspection Fees: _ $14.00
TOTAL AMOUNT PAST DUE: = 53 195.20
B. YOU HAVE FAILED TO TAKE THE FOLLOWING ACTION (Do not use if not
applicable):
HOW TO CURE THE DEFAULT - You may cure the default within THIRTY (30) DAYS of
the date of this notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE
LENDER, WHICH IS $3.195.20• PLUS ANY MORTGAGE PAYMENTS AND LATE
CHARGES WHICH BECOME DUE DURING THE THIRTY (30) DAY PERIOD. Payments
must be made either by cash, cashier's check. certified check or money order made,2avable and
sent to:
Chase Home Finance, LLC
c/o Shapiro & DeNardo, LLC
3600 Horizon Drive, Suite 150
King of Prussia, PA 19406
You can cure any other default by taking the following action within THIRTY (30) DAYS of the
date of this letter. (Do not use if not applicable.)
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30)
DAYS of the date of this Notice, the lender intends to exerdu its rights to accelerate the morttat*_e
M. This means that the entire outstanding balance of this debt will be considered due immediately and
you may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount
past due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start
legal action to foreclose upon your marMtated property.
IF THE MQRTGAGE IS FORECLOSED UPON -- The mortgaged property will be sold by the
Sheriff to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the
delinquency before the lender begins legal proceedings against you, you will still be required to pay the
reasonable attorney's fees that were actually incurred, up to $50.00. However, if legal proceedings are
started against you, you will have to pay all reasonable attorney's fees actually incurred by the lender even
if they exceed $50.00. Any attorney's fees will be added to the amount you owe the Icnder, which may
also include other reasonable costs. If you cure the default within the THIRTY (30) DAY period- you
will not be required to nay attorney's tees.
OTHER LENDER REMEDIES - The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SH&RIFF'S SALE -- If you have not cured the
default within the THIRTY (30) DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time up to one hour before the Sheriffs Sale. You
may do so by Peeing the total amount then past due plus any late or other charges then due, reasonable
attorneVs fees and costs connected with the foreclosure sale and any other costs cop. ected with the
Sheriffs Sale as specified in writing by the lender and by performing any other rec uircments under the
mo a e. Curing your default in the manner set forth in this notice will restore your mortgage to
the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE ATE -- It is estimated that the earliest date that such a
Sheriffs Sale of the mortgaged property could be held would be approximately 3 months from the date
of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale. Of
course, the amount needed to cute the default will increase the longer you wait. You may fund out at any
time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER:
Name of Lender: CIO The Law Firm of Shapiro & DeNardo. LLC
Address: 3600 Horizon Drive. Suite 150. King of Prussia. PA 19406
Phone number: (6101278-6800
Fax number: (610)278-9980
Contact person: Christopher A. DeNardo. Esaulre
EFFECT OF SHERIFF'S SALE- You should realize that a Sheriffs Salc will end your
ownership of the mortgaged property and your right to occupy it. If you continue to live in the
property after the Sheriffs Sale, a lawsuit to remove you and your furnishings and other
belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE-You X may or , may not (CHECK ONE) sell or
transfer your home to a buyer or transferee who will assume the mortgage debt, provided that all
the outstanding payments, charges and attorney's fees and costs are paid prior to or at the sale
and that the other requirements of the mortgage are satisfied.
i
YOU ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE
DEBT OR TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO
PAY OFF THIS DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR
BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO
DEFAULT HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU
DO NOT HAVE THIS RIGHT TO CURE YOUR DEFAULT MORE THAN THREE
TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE
PROCEEDING OR ANY OTHER LAWSUIT INSTITUTED UNDER THE
MORTGAGE DOCUMENTS,
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH
ACTION BY THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
CONSUMER CREDIT COUNSELING AGENCIES SERVING YOUR COUNTY
(Fill in a list of all Counseling Agencies listed In Appendix C, FOR THE COUNTY in
which the property is located, using additional pages if necessary).
HEMAP Consumer Credit Counseling Agencies
CUMBERLAND County
Adams County Interfaith Housing Authority
40 E High Street
Gettysburg, PA 17325
717.334.1518
CCCS of Western PA
2000 Linglestown Road
Harrisburg, PA 17102
888.511.2227
888.511.2227
Community Action Commission of Captial Region
1514 Deny Street
Harrisburg, PA 17104
717.232.9757
Loveship, Inc,
2320 North 5th Street
Harrisburg, PA 17110
717.232.2207
Maranatha
43 Philadelphia Avenue
Waynesboro, PA 17268
717.762.3285
PHFA
211 North Front Street
Harrisburg, PA 17110
717.780.3940
800.342.2397
r
VERIFICATION
5e I v4f ??k?n? hereby states that he/she is 0 'cc Gres lde.-, A
of JPMorgan Chase Bank, National Association, 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 his/her 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.
DATE: 2 (?'L Name:
el?? ?k r
Title: V,t-e p, e-6,, t e-
-11) R46) W4,
Company: JPMorgan Chase Bank,National Association
S&D FILE NO: 10-038403
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
JP Morgan Chase Bank, NA
vs.
Darla Maurer
11 N n
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l., F t 4L P`? it
LD
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q E h 3 r• f r
E st ":a l L??,->.NI
Case Number
2012-1120
SHERIFF'S RETURN OF SERVICE
02/23/2012 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: Darla Maurer, Representative for The Estate of Robert
K. Danner, Deceased, 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
03/07/2012 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: Occupant of 214 W. Allen Street, Mechanicsburg,
Pennsylvania 17055, but was unable to locate them in his bailiwick. He therefore returns the within
Complaint in Mortgage Foreclosure as not found as to the defendant Occupant. Request for service at
214 W. Allen Street, Mechanicsburg, Pennsylvania 17055 is vacant.
03/07/2012 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: Darla Maurer, 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 Darla Maurer. Request for service at 214 W. Allen Street, Mechanicsburg, Pennsylvania 17055
is vacant. The Mechanicsburg Postmaster has confirmed, Darla Maurer is not known at this address.
03/09/2012 York County Return: And now, March 9, 2012 I, Richard P. Keuerleber, Sheriff of York County,
Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Darla Maurer 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 5211 Pine Hill Road,
Dover, Pennsylvania 17315 the Defendant was not found. Deputies were advised, Darla Maurer is
currently in Mechanicsburg Hospital Life Care Long Term Facility, and Attorney Mark Thomas is
representating the Defendant.
03/21/2012 01:52 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on March
21, 2012 at 1352 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Darla Maurer, by making known unto Mark Thomas, Attorney for Darla
Maurer at 101 S. Market Street, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents
and at the same time handing to him personally the said true and correct copy of the same.
GUTS , DEPUTY
SHERIFF COST: $115.00
April 03, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
Acceptance of Service
I accept the service of the , C47-;It?
(on behalf of
and
certify that I am authorized to do so.)
3 a/ ??2
Date
Authorized Agent
Mailing Address
r
SHERIFF'S OFFICE OF YORK COUNTY
Richard P Keuerleber
Sheriff
Reuben B Zeager
Chief Deputy, Operations
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION
vs.
DARLA MAURER
PETER J. MANGAN, ESQ.
Solicitor
Richard E Rice, II
Chief Deputy, Administration
Case Number
2012-1120 CIVIL
SHERIFF'S RETURN OF SERVICE
03/09/2012 SHERIFF RICHARD P KEUERLEBER, BEING DULY SWORN ACCORDING TO LAW, STATES HE
MADE DILIGENT SEARCH AND INQUIRY FOR THE WITHIN NAMED DEFENDANT TO WIT: DARLA
MAURER, BUT WAS UNABLE TO LOCATE THE DEFENDANT IN HIS BAILIWICK. THE SHERIFF
THEREFORE RETURNS THE WITHIN REQUESTED COMPLAINT IN MORTGAGE FORECLOSURE
(CIMF) AS "NOT SERVED" AT 5211 PINE HILL ROAD, DOVER, PA 17315.
DEFT IS IN MECHANICSBURG HOSPITAL LIFE CARE LONG TERM. THE ATTORNEY
REPRESENTING THIS CASE IS MARK THOMAS AT MARKET STREET IN MECHANICSBURG.
DARLA'S CELL IS 514-6802.
SHERIFF COST: $74.52 SO ANSWERS,
March 09, 2012 CHARD P KEUERLEBER, SHERIFF
NOTARY
Affirmed and subscribed to before me this C o I NNSYivAN
9TH day of MARCH 2012
a
4v?--b 77
LLISA L THici County SureSnriff. Teieoson Hnc CITY OF YORK. YORK OMMISSION EXPIRES AUO` 12, 2013
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
yl??r?i? _ 1?
H0?171A?
t'ii 'E?11
,31 NUC. -2 Pl 2? 41
;UiPC t3NSYLVANI TY
A
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 2012-1120
AMENDMENT TO MOTION FILED
Pursuant to Cumberland County Local Rule 208.3(a)(2); No other judge has ruled
upon any other issue in the same or related matter.
2. Pursuant to Cumberland County Local Rule 208.3(a)(9); On July 20, 2012,
Plaintiff sought the concurrence of any opposing counsel of record and no response was
submitted within 10 days of concurrence requested.
SHAPIRO & DeNARDO, LLC
BY:
Christopher A. DeNardo, Esquire
Attorney for Plaintiff
S&D: 10-038403
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I. D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 2012-1120
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
CERTIFICATE REGARDING NON-CONCURRENCE
And now this at day of ?()? 2012, the undersigned hereby certifies that she has
sought the concurrence in the motion that concurrence was not given.
SHAPIRO & DeNARDO, LLC
BY:
Christopher A DeNardo, Esquire
PA Bar I.U. No. 78447
3600 Horizon Drive, Suite 150
King of Prussia, PA 19406
Pabk(Oo s
Phone: (610)278-6800
Fax: (610)278-9980
Attorney for Plaintiff
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SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance, ;
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 2012-1120
ORDER
Plaintiffs Memor
andum of Law is support thereof, and any response thereto, it is hereby
document or pleading requiring original
Estate of Robert
simultaneous ,
Dover,
located at 214 West
adult.
I
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r
<>
r" t>
.w
,
AND NOW, this day of a& , 20_ , upon consideration of
Motion for Service Pursuant to Court Order, Affidavit of Good Faith Investigation and
ORDERED AND DECREED that Plaintiff may serve the Complaint and any other
process on Defendant, Darla Maurer;. Representative for
K. Danner, deceased, by (1) sending true and correct copies thereof by
certified and regular mail to the last known address located at 5211 Pine Hill Road
PA 17315; and (2) posting a true and correct copy thereof on the mortgaged property
Allen Street; Mechanicsburg, PA 17055 by the Sheriff or any competent
Service of the aforementioned mailings is effective upon the date of mailing and is to be
effectuated by Plaintiff s attorney, who will file with the Prothonotary's Office a Certificate of
Service as to such mailings
ar;ro 4- yr El SA w
BY THE COURT:
-s i
~•
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Baz # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association, ;
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
VS.
Dazla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 2012-1120
PRAECIPE FOR REINSTATEMENT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above-captioned matter.
SHAPIRO & DeNARDO, LLC
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BY:
Christopher A. DeNazdo, Esquire
Attorney for Plaintiff
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SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIlZE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
AFFIDAVIT OF SERVICE
.~,
I, Tiffany Donnellrt1he undersigned, being duly sworn according to law, hereby depose
and say that on the ~V~ day of , 2012, pursuant to the attach
Order of Court, attached as Exhibit "A", I served a true and correct copy of the Complaint in
Mortgage Foreclosure in the above captioned matter to the Defendant by certifiediand regular
mail, to their last known address of:
. ;c
Darla Maurer, Representative for the Estate of Robert K: Danner, deceased, 5211, Pine Hill
Dover, PA 17315 ~~~
SWORN AND SUBSCRIB D
Before me this ~ day of
~2Ai2 . ~
Notary Public
S & D FILE NO. 10-038403
CQMMQNWEALTH OF PENNSYLVANIA
Notarlai Seai
Denise L. Semetti, Notary Public
Upper Merlon Twp., Montgomery County
My Commission Expires July 22, 2018
SHAPIRO & DeNARDO, LLC
BY: _
Tiffany Donnell
Legal Assistant to Attorney for Plaintiff
~.~,~ ~ ~~~ F~`~~'H~N~~As'
~..
2~;r2 AUG 24 Pl~'~: (-2
~l~Mc~ERLAND COUNT'l
°Et~NSYLVANlA
COURT OF COMMON PLEAS
CIVIL DNISION
CUMBERLAND COUNTY
NO: 2012-1120
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SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association.
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
N0:2012-1120
PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER
AND ASSESSMENT OF DAMAGES
Enter.Iudgment IN REM in the amount of $87,745.35 in favor of the Plaintiff and against
the Defendant, for failure to file an answer to Plaintiff's Complaint in Mortgage Foreclosure
within 20 days from service thereof and assess Plaintiffs damages as follows and calculated as
stated in the Complaint:
Principal of Mortgage Debt Due and Unpaid $66,552.29
Interest to October 15, 2012 $9,935.58
Late Charges $97.88
Escrow Advances $7,977.10
Appraisal Fees $250.00
Property Inspection $168.00
Property Preservation $1,010.00
Attorney Fees & Costs of Foreclosure $1.754.50
TOTAL $87,745.35
BY.
Christopher A. DeNardo, Esquire
44torn Plaintiff
AND NOW, judgment is entered in favor of the Plaintiff and a inst t of nt and
damages are assessed as above in the sum of $87,745.35.
Pro.
10-038403
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SHAPIRO & DeNARDO, LLC
BY: MICHAEL J. CLARK, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 202929
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
3415 Vision Drive
Columbus, OH 43219
PLAINTIFF
VS.
Darla /laurcr, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT(S)
STATE OF:-PENN SYLVANIA
COUNTY OF: MONTGOMERY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
201.2-1120
AFFIDAVIT OF NON-MILITARY SERVICE
THE UNDERSIGNED being duly sworn, states that he/she is over the age of eighteen
years and competent to make this affidavit and the following averments are based upon
information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that
the above captioned Defendants last known address is as set forth in the caption and they are not
to the best of our knowledge, information or belief, in the Military or Naval Service of the
United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940, as amended.
SHAPIRO & DENARDr, LL
By:
Michael J. Clark, 14squire
Sworn to and subscribed
before me this day
?,2012.
Not y Public
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 2012-1120
CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1
The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for
the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of
record, if any, after the default occurred and at least (10) days prior to the date of the filing of the
Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto,
September 14, 2012 to the following Defendants:
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased, 5211 Pine Hill Road,
Dover, PA 17315
R. Mark Thomas, 101 South Market Street, Mechanicsburg, PA 17055
Tiffany Donnell, Legal Assistant
to Christopher A. DeNardo, Esquire for
Shapiro & DeNardo, LLC
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNAR.DO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE ISO
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 2012-1120
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
NOTICE OF INTENTION TO TAKE DEFAULT
IMER PA.R.C.P. 237.1
IMPORTANT NOTICE
TO: Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
DATE OF NOTICE: September 14, 2012
You are in default because you have failed to enter a written appearance personally or by attorney
and file in writing with the court your defenses or objections to the claims set forth against you. Unless you
act within ten (10) days from the date of this notice, a Judgment may be entered against you without a
hearing and you may lose your property or other important rights. You should take this notice to a lawyer at
once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out
where you can get legal help:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
NOTIFICACION IMPORTANTE
Usted se encuentra en estado de rebeldia por no haber tornado la accion requirida de su parte en
este caso. Al rro tomar la accion debida dentro de un terrnino de diet (10) Bias de la fecha de esta
notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba
alguna, dictar sentencia en su contra. Usted puede perder bienes y otros derechos iniportantes.
I)ebe Ilevar esta notilicacion a un abogado immediatamente. Si usted no tiene abogado o si no
tiene dinero suficiente para tal servicio, vaya en persona o flame por telefono a la oficina cuya
direccion se encuentra escrita ubajo Para averiguar donde se puede conseguir assitcncia legal:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIL. DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT, ANY INFORMATION OBTAINED WILL, BE
USED FOR THAT PURPOSE.
PERSONS TO W140M RILE 237.1 NOTICE SENT TO:
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased, 5211 Pine Eiill Road,
Dover, PA 17315
1Z. Mark Thomas, 101 South Market Street, Mechanicsburg, PA 17055
Christopher A. DeNardo, Esquire
Shapiro & DeNardo, LLC
Attorney for Plaintiff
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 2012-1120
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER P*.ILC.P. 237.1
IMPORTANT NOTICE
TO: R. Mark Thomas
DATE OF NOTICE: September 14, 2012
You are in default because you have failed to enter a written appearance personally or by attorney
and file in writing with the court your defenses or objections to the claims set forth against you. Unless you
act within ten (10) days from the date of this notice, a Judgment may be entered against you without a
hearing and you may lose your property or other important rights. You should take this notice to a lawyer at
once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out
where you can get legal help:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
NOTIFICACION IMPORTANTE
Usted se encuentra en estado de rebeldia por no haber tomado la accion requirida de su parte en
este caso. Al no tomar la accion dcbida dentro de un tcrmino de diet (10) dias de la f'echa de esta
notificacion, el tribuna podra, sin necesidad de compararecer usted in corte o escuchar preuba
alguna, dictar scrttencia en su contra. Usted puede perder bienes y otros derechos importantes.
Debe llevar esta notifcaeion a un abogado immediatamente. Si Listed no tiene abogado o si no
tiene dinero suficiente pars tal servicio, vaya en persona o flame por telelfono a la oficina cuya
direccion se cncuentra escrita abajo para averiguar donde se puede conseguir assitencia legal:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 1.7013
717-249-31.66
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE,
PERSONS TO WHOM RULE 237.1 NOTICE SENT TO:
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased, 5211 Pine flill Road,
Dover, PA 17315
R. Mark Thomas, 10 South Market Street, Mechanicsburg, PA 17053
?<7-
Christopher A. DeNardo, Esquire
Shapiro & DeNardo, LLC
Attorney for Plaintiff
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC slblm to Chase Manhattan Mortgage
Corporation
PLAINTIFF
vs.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:2012-1 120
CERTIFICATE OF SERVICE
I, Christopher A. DeNardo, Esquire, Attorney for the Plaintiff, hereby certify that I have
served by first class mail, postage prepaid, true and correct copies of the attached papers upon
the following person(s) or their attorney of record:
Darla Maurer. Representative for the Estate of Robert K. Danner, deceased
5211 Pine Hill Road
Dover. PA 17315
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
214 West Allen Street
Mechanicsburg, PA 17055
Date Mailed: J
SHAPIRO & DeNARDO, LLC
_
BY: - ?::?
Christopher A. DeNardo, Esquire
Attorney for Plaintiff
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA. PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
vs.
Darla Maurer. Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO:2012-1120
CERTIFICATION OF ADDRESS
I hereby certify that the correct address of the judgment creditor (Plaintiff) is:
JPMorgan Chase Bank, National Association, successor by merger to Chase Home Finance, LLC
s/b/m to Chase Manhattan Mortgage Corporation
3415 Vision Drive
Columbus, OH 43219
and that the last known address of the judgment debtor (Defendant) is:
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
5211 Pine Hill Road
Dover. PA 17315
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
214 West Allen Street
Mechanicsburg. PA 17055
SHAPIRO & DeNARDO, LL(--'
BY:
Christopher A. DeNardo, Esquire
Attorney for Plaintiff
10-038403
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
David D. Buell
Prothonotary
TO: Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
5211 Pine Hill Road
Dover, PA 17315
JPMorgan Chase Bank, National Association, COURT OF COMMON PLEAS
successor by merger to Chase Home Finance, CIVIL DIVISION
LLC s/b/m to Chase Manhattan Mortgage CUMBERLAND COUNTY
Corporation
PLAINTIFF NO: 2012-1120
VS.
Darla Maurer, Representative for the Estate of
Robert K. Danner, deceased
F
DEFENDANT
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
.Judgment has been entered against you in the above proceeding as indicated below.
David D. Buell
Prothonotary
[XX] Judgment by Default
[ ] Judgment for Possession
Judgg ment on Award of Arbitration
[]
[ ] Judgment on Verdict
[ ] Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY CHRISTOPHER A. DENARDO. ESQUIRE AT (610)278-6800.
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?: §.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
Vs.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT(S)
TO THE PROTHONOTARY OF THE SAID COURT:
O Confessed Judgment
OOther
FileNo? ? _ kk DD
.
Amount Due $87,745.35
Interest October 16, 2012 to March 6, 2013 .
is $2,005.47
Atty's Comm --_?-
Costs r-
C-
The undersigned hereby certifies that the below does not arise out of a retail installment safe, contract, or
account based on a confession of judgment, but if it does, it is based on the appropriate original proceeding filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amended.
Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon
the following described property of the defendant(s)
See attached Legal Description
PRAECIPE FOR ATTACHEMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland County, for debt, interest and costs, as above,
directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Index this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date:_ Il &1
.a>?>a
?( 11
lob I,z -1
f2
Signature:
Print Name: Christopher A. DeNardo, Esguire
Address: 3600 Horizon Drive, Suite 150
King of Prussia. PA 19406
Attorney for: Plaintiff
Supreme Court ID # PA Bar # 78447
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ALL THAT CERTAIN lot, piece or parcel of land situate in the Borough of Mechanicsburg,
Cumberland County, Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on this North side of West Allen Street, at corner of lands now or
formerly of Dolly Martin Weber; thence along Allen Street, westward sixteen and three
hundredths (16.03) feet to a point at corner of lands now or formerly of John B. Ocker; thence by
this line of said Lot, northward and through the center of a frame partition well and beyond,
ninety (90.00) feet, more or less, to a point at corner of lands now or formerly of Annie Knauby;
thence along line of said Lot, eastward sixteen and five tenths (16.5) East, more or less, to a
point at corner of Lot now or formerly of Dolly Martin Weber aforesaid; thence along the line of
said Lot, southward and through the center of a frame partition wall, eighty-eight (88.00) feet,
more or less. to a point the place of BEGINNING.
Parcel No. 19-23-0567-127
BEING the same premises which Jean Lois Lyter and Richard E. Lyter, her husband, Joan
Louise Costello and Bruce P. Costello, her husband, as Joint Tenants With the Rights of
Survivorship and not as Tenants in Common, by Deed dated December 16. 2003 and recorded in
the Cumberland County Recorder of Deeds Office on December 23, 2003 in Deed Book 260,
page 4881. granted and conveyed unto Robert K. Danner, a single person.
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO,
ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m_ to Chase Manhattan Mortgage
Corporation
PLAINTIFF
VS. '
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
R
` 3f
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 2012-1120
AFFIDAVIT PURSUANT TO RULE 3129.1
JPMorgan Chase Bank, National Association, successor by merger to Chase Home
Finance, LLC s/b/m to Chase Manhattan Mortgage Corporation, Plaintiff in the above action,
sets forth, as of the date the praecipe for the writ of execution was filed, the following
information concerning the real property located at 214 West Allen Street, Mechanicsburg, PA
17055.
Name and address of Owner(s) or Reputed Owner(s)
Darla Maurer. Representative for the Estate of Robert K. Danner, deceased
5211 Pine Hill Road
Dover, PA 17315
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
214 West Allen Street
Mechanicsburg, PA 17055
2. Name and address of Defendant in the judgment:
Darla. Maurer. Representative for the Estate of Robert K. Danner, deceased
5211 Pine Hill Road
Dover, PA 17315
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
214 West Allen Street
Mechanicsburg, PA 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
JPMorgan Chase Bank, National Association, successor by merger to Chase Home
Finance, LLC s/b/m to Chase Manhattan Mortgage Corporation
3415 Vision Drive
Columbus, OH 43219
4. Name and address of the last recorded holder of every mortgage of record:
JPMorgan Chase Bank, National Association, successor by merger to Chase Home
Finance, LLC s/b/m to Chase Manhattan Mortgage Corporation, Plaintiff
3415 Vision Drive
Columbus, OH 43219
5. Name and address of every other person who has any record lien on the property:
Internal Revenue Service
WM S. Moorehead Federal Bldg. Advisory
1000 Liberty Avenue, Room 704
Pittsburgh, PA 15222
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle. PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
214 West Allen Street
Mechanicsburg. PA 17055
Commonwealth of Pennsylvania
Department of Revenue Inheritance Tax Divsion
1 131 Strawberry Square, 6th Floor
Harrisburg, PA 17128
Department of Public Welfare
Estate Recovery Program
P.O. Box 8486, Willow Oak Bldg
Harrisburg, PA 17105
Commonwealth of Pennsylvania, Department of Revenue
Inheritance Tax Division, Bureau of Compliance
Dept. 280946
Harrisburg, PA 17128-0946
Department of Treasury
Internal Revenue service Center
Cincinnati, OH 45999
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
S? eNARDO, LLC
BY:
Christopher A. DeNardo, Esquire
10-038403
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA. PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/m to Chase Manhattan Mortgage
Corporation
PLAINTIFF
VS.
Darla Maurer. Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
,urf
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 2012-1120
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
214 West Allen Street
Mechanicsburg, PA 17055
Your house (real estate) at:
214 West Allen Street, Mechanicsburg, PA 17055
19-23-0567-127
is scheduled to be sold at Sheriffs Sale on March 6, 2013 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle. PA 17013
at I0:OOAM to enforce the court judgment of 587,745.35 obtained by JPMorgan Chase Bank,
National Association, successor by merger to Chase Home Finance, LLC s/b/m to Chase
Manhattan Mortgage Corporation against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
The sale will be cancelled if you pay back to JPMorgan Chase Bank, National
Association, successor by merger to Chase Home Finance, LLC s/b/m to Chase
Manhattan Mortgage Corporation the amount of the judgment plus costs or the back
payments, late charges, costs, and reasonable attorneys fees due. To find out how much
you must pay, you may call: (610)278-6800.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two of how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (610)278-6800.
6. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call 717-240-6390.
8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
9. You have a right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
10. You may be entitled to a share of the money, which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff no later than
thirty days after the Sheriff Sale. This schedule will state who will be receiving the
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10)
days after the date of filing of said schedule.
11. You may also have other rights and defenses or ways of getting your house back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR.
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
10-03 8403
ALL THAT CERTAIN lot, piece or parcel of land situate in the Borough of Mechanicsburg,
Cumberland County, Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on this North side of West Allen Street, at comer of lands now or
formerly of Dolly Martin Weber; thence along Allen Street, westward sixteen and three
hundredths (16.03) feet to a point at corner of lands now or formerly of John B. Ocker; thence by
this line of said Lot, northward and through the center of a frame partition well and beyond,
ninety (90.00) feet, more or less, to a point at corner of lands now or formerly of Annie Knauby;
thence along line of said Lot, eastward sixteen and five tenths (16.5) East, more or less, to a
point at corner of Lot now or formerly of Dolly Martin Weber aforesaid; thence along the line of
said Lot, southward and through the center of a frame partition wall, eighty-eight (88.00) feet,
more or less. to a point the place of BEGINNING.
Parcel No. 19-23-0567-127
BEING the same premises which Jean Lois Lyter and Richard E. Lyter, her husband. Joan
Louise Costello and Bruce P. Costello, her husband, as Joint Tenants With the Rights of
Survivorship and not as Tenants in Common, by Deed dated December 16. 2003 and recorded in
the Cumberland County Recorder of Deeds Office on December 23, 2003 in Deed Book 260,
page 4881, granted and conveyed unto Robert K. Danner, a single person.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-1120 Civil
CIVIL ACTION -- LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION, SUCCESSOR BY MERGER TO CHASE HOME FINANCE, LLC S/B/M TO
CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff (s)
From DARLA MAURER, REPRESENTATIVE FOR THE ESTATE OF ROBERT K. DANNER,
DECEASED
(1) You are directed to levy upon the property of the defendant (s)and to sell SEE LEGAL
DESCRIPTION.
(3) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $87,745.35 L.L.:.50
Interest FROM OCTOBER 16, 2012 TO MARCH 6, 2013 IS $2,005.47
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $322.00 Other Costs:
Plaintiff Paid:
Date: 1.0/22/12
David D. Buell, Prothonota
(Seal)
Deputy
REQUESTING PARTY:
Name: CHRISTOPHER A. DENARDO, ESQUIRE
Address: SHAPIRO & DENARDO, LLC
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Telephone: 610-278-6800
Supreme Court ID No. 78447
1
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO,
ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-03 8403
JPMorgan Chase Bank, National Association,
successor by merger to Chase Home Finance,
LLC s/b/rn to Chase Manhattan Mortgage
Corporation
PLAINTIFF
VS. '
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
i !_ i .
ii - '.
t~? t-E~sF, ~ ? Pfd ,~~ f ~:
",~r11~SYl-~~'~F~1
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 2012-1120
AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1
JPMorgan Chase Bank, National Association, successor by merger to Chase Home
Finance, LLC s/b/m to Chase Manhattan Mortgage Corporation, Plaintiff in the above action,
sets forth, as of the date the praecipe for the writ of execution was filed, the following
information concerning the real property located at 214 West Allen Street, Mechanicsburg, PA
17055.
1. Name and address of Owner(s) or Reputed Owner(s)
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
5211 Pine Hill Road
Dover, PA 17315
2. Name and address of Defendant in the judgment:
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
5211 Pine Hill Road
Dover, PA 17315
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
JPMorgan Chase Bank, National Association, successor by merger to Chase Home
Finance, LLC s/b/m to Chase Manhattan Mortgage Corporation
3415 Vision Drive
Columbus, OH 43219
4. Name and address of the last recorded holder of every mortgage of record:
JPMorgan Chase Bank, National Association, successor by merger to Chase Home
Finance, LLC s/b/m to Chase Manhattan Mortgage Corporation
3415 Vision Drive
Columbus, OH 43219
5. Name and address of every other person who has any record lien on the property:
Internal Revenue Service
WM S. Moorehead Federal Bldg. Advisory
1000 Liberty Avenue, Room 704
Pittsburgh, PA 15222
Borough of Mechanicsburg
c!o David J. Spotts
36 West Allen Street
Mechanicsburg, PA 17055
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 1712$-1230
6. Name and address of every other person who has any record interest in the property and
whose interest maybe affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which maybe affected by the sale:
TENANT OR OCCUPANT
214 West Allen Street
Mechanicsburg, PA 17055
Commonwealth of Pennsylvania
Department of Revenue Inheritance Tax Division
1131 Strawberry Square, 6th Floor
Harrisburg, PA 17128
Department of Public Welfare
Estate Recovery Program
P.O. Box 84$6, Willow Oak Bldg
Harrisburg, PA 17105
a
Commonwealth of Pennsylvania, Department of Revenue
Inheritance Tax Division, Bureau of Compliance
Dept. 280946
Harrisburg, PA 17128-0946
Department of Treasury
Internal Revenue service Center
Cincinnati, OH 45999
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
SHAPIRO~& DeNARDO, LLC
BY: C~~Y~~
Christopher A. DeNardo, Esquire
10-038403
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith ,° 11 < ;x
Chief Deputy r !t, I _ F. ,
e i f
Richard W Stewart { t
Solicitor t e , cu c 1 `�C I i L�? i'1 iy' :� i' Y
JP Morgan Chase Bank, NA
Case Number
vs.
Darla Maurer 2012-1120
SHERIFF'S RETURN OF SERVICE
01/04/2013 03:00 PM -Deputy Noah Cline, being duly sworn according to law, states service was performed by
posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the
above titled action, upon the property located at 214 West Allen Street, Mechanicsburg, PA 17055,
Cumberland County.
01/28/2013 08:09 PM - Deputy Shawn Harrison, being duly sworn according to law, served the requested Real Estate
Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Darla
Maurer, pursuant to Order of Court by"Posting"the premises located at 214 W. Allen Street,
Mechanicsburg Borough, Mechanicsburg, PA 17055, Cumberland County with a true and correct copy
according to law.
03/06/2013 Ronny R. Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to law, he exposed the within described premises at public venue or outcry at the
Cumberland County Courthouse, 1 Courthouse Square, Cumberland County, PA on March 6, 2013 at
10:00 a.m. He sold the same for the sum of$5,000.00 to Attorney Nathan Wolf, on behalf of Department
of Veterans Affairs, being the buyer in this execution, paid to the Sheriff the sum of$
SHERIFF COST: $1,435.81 SO ANSWERS,
April 26, 2013 RONN R ANDERSON, SHERIFF
PROPOSED SCHEDULE OF DISTRIBUTION
Date Filed: Apri14, 2013
Writ No. 2012-1120 Civil Term
JPMorgan Chase Bank, National Association, successor by merger to Chase Home Finance, LLC
s/b/m to Chase Manhattan Mortgage Corporation
vs
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
214 West Allen Street
Mechanicsburg, PA 17055
Sale Date: March 6, 2013
Buyer: JPMorgan Chase Bank, National Association, successor by merger to Chase
Home Finance, LLC
s/b/m to Chase Manhattan Mortgage Corporation
Bid Price: $ 5,000.00
Real Debt: $ 87,745.35
Interest: 2,005.47
Atty Paid: 322.00
Total: $ 90,072.82
DISTRIBUTION:
Receipts:
Cash on Account (10/26/2012): $ 1,500.00
Cash on Account (04/12/2013): 3,066.85
Total Receipts: $ 4,566.85
Disbursements:
Sheriffs Costs $ 1,135.81
Legal Search 300.00
Barry L. Heckard, Mechanicsburg Borough 554.65
Tax Collector
(Spring 2013 Taxes)
Borough of Mechanicsburg(Sewer/Refuse) 2,576.39
Credit Writ No. 2012-1120 Civil Term 433.15
Total Disbursements: ($4,566.85)
Balance for distribution: 00.00
So Answers:
onny R:Anderson ,
Sheriff
e
SNELBAKER& BRENNEMAN, P. C.
ATTORNEY AT LAW
44 W. Main Street
Mechanicsburg, PA 17055
TITLE REPORT
TO: Sheriff of Cumberland County
RE: Sheriffs Sale, Writ No. 2012-1120
Held: March 6, 2013
EFFECTIVE DATE: March 6, 2013
PREMISES: 214 West Allen Street, Borough of Mechanicsburg, Cumberland County,
Pennsylvania, Tax Parcel No. 19-23-0567-127 (the "Premises")
RECITAL: Being the same Premises which Jean Lois Lyter and Richard E. Lyter, her
husband, and Joan Louise Costello and Bruce P. Costello,her husband, by their
Deed dated December 16, 2003 and recorded December 23, 2003 in the Office of
the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed
Book 250, Page 4881 granted and conveyed unto Robert K. Danner, single
person. The said Robert K. Danner died May 21, 2010, Estate probated in the
Office of the Register of Wills in and for Cumberland County to File No. 2010-
00599, whereby Letters of Administration were granted June 10, 2010 to Darla
Maurer, Administrator.
The Premises identified above and as more fully described in the legal description
attached hereto and incorporated by reference herein as "Exhibit A" is subject to the below items
and exceptions. All recording and docket locations identified are in the Office of the Recorder of
Deeds of Cumberland County and/or the Court of Common Pleas of Cumberland County.
EXCEPTIONS:
1. Claims and charges for improvements and repairs to the Premises or delivery of materials
thereto for which payment has not been made.
2. Possible unfiled Mechanics Liens and municipal claims, charges and assessments.
3. The rights or claims of any tenants or other parties in possession.
4. Support arrearages of any owner or previous owner of the Premises pursuant to Act 58 of
1 997, as amended.
5. Any environmental liens or claims filed or on record in the Federal District Court.
6. Payment of state and local real estate transfer tax, if applicable.
7. Any secured transactions with respect to the Premises.
8. The area of the Premises is not certified.
9. Those matters which a view or inspection of the Premises would reveal.
10. The accuracy of the measurements and dimensions of the Premises or the rights or title of
or through any person or persons in possession of same,conflicts with adjoining
property, encroachments,projections or any other matter disclosed by an accurate survey
of the Premises.
11. The right of use as may be determined by any applicable municipal zoning ordinance or
regulation.
12. Any matter not of record at the Court House as of the effective date of this Title Report
and subsequent to the date hereof.
13. Any tax increase based on additional assessment made by reason of new construction or
major improvements.
14. The absence or failure of proper and required notice being given to all owners and
holders of liens and encumbrances intended to be divested by the Sheriffs sale and
procedural defects by any judgment creditor or lienholder executing on the Premises
giving rise to the Sheriffs sale noted above.
15. Identity and legal competency of all parties at any closing or conveyance of the Premises
should be established.
16. Access to the Premises by public road or street is not certified.
17. Suitability or existence of sewer and water facilities on or available to the Premises is not
certified.
18. Real Estate taxes on the Premises due and payable but not turned over for collection to
the Tax Claim Bureau.
-2-
19. All Real Estate taxes on the Premises assessed but not billed as well as those Real Estate
taxes accruing on and after January 1, 2013.
20. Mortgage in the amount of $73,400.00 from Robert K. Danner to Citizens Mortgage
Corp., dated December 19, 2003 and recorded December 23, 2003 in Mortgage Book
1849, Page 1754. Assigned October 12, 2006 in Misc. Book 731, Page 532 to JP Morgan
Chase Bank,N.A.
22. Judgment in mortgage foreclosure against the Estate of Robert K. Danner and Darla
Maurer as representative of the Estate of Robert K. Danner in favor of JP Morgan Chase
Bank,N.A. in the amount of$87,745.35 entered October 22,2012 to No. 2012-1120.
23. Municipal Lien entered December 14,2010 against the Estate of Robert K. Danner in
the amount of$860.94 in favor of the Borough of Mechanicsburg to No. 2010-7668.
24. Municipal Lien entered November 22, 2011 against the Estate of Robert K. Danner in the
amount of$520.60 in favor of the Borough of Mechanicsburg to No. 2011-8805.
25. Subject to any amounts due the Pennsylvania Department of Public Welfare,Estate
Recovery Program, if any, due to the provision of benefits to Robert K. Danner during
his lifetime.
26. Subject to the right-of-way noted in Deed Book "Y", Volume 17, Page 505.
27. Subject to the easement of any partition wall or walls.
28. Subject to the rights of others in and to any portion of the Premises lying within or
adjoining Allen Street and/or West Allen Street.
The undersigned shall not be bound by this Title Report to any person, firm or entity
other than the Sheriff of Cumberland County.
Snelbaker &Brenneman, P. C.
By: I
Keith O. Brenneman
-3-
Writ No. 20312-1120 Civil
JP Morgan Chase Bank,NA
VS.
Darla Maurer,Representative
for the Estate of
Robert K.Danner,Deceased
Atty.:Christopher DeNardo
ALL THAT CERTAIN lot, piece or
parcel of land situate in the Borough
of Mechanicsburg, Cumberland
County,Pennsylvania,bounded and
described as follows,to wit:
BEGINNING at a point on this
North side of West Allen Street, at
corner of lands now or formerly of
Dolly Martin Weber; thence along
Allen Street, westward sixteen and
three hundredths (16,03) feet to a
point at comer of lands now or for-
merly of John B. Ocker; thence by
this line of said Lot,northward and
through the center of a frame parti-
tion well and beyond,ninety(90.00)
feet,more or less,to a point at comer
of lands now or formerly of Annie
Knauby; thence along line of said
Lot,eastward sixteen and five tenths
(16.5)East,more or less,to a point at
comer of Lot now or formerly of Dolly
Martin Weber aforesaid;thence along
the line of said Lot, southward and
through the center of a frame parti-
tion wall, eighty-eight (88.00) feet,
more or less, to a point the place of
BEGINNING.
Parcel No. 19-23-0567-127.
BEING the same premises which
Jean Lois Lyter and Richard E.Lyter,
her husband, Joan Louise Costello
and Bruce P.Costello,her husband,
as Joint Tenants With the Rights of
Survivorship and not as Tenants in
Common, by Deed dated December
16, 2003 and recorded in the Cum-
berland County Recorder of Deeds
Office on December 23,2003 in Deed
Book 260, page 4881, granted and
conveyed unto Robert K. Danner, a
single person.
EXHIBIT A
t
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO,
ESQUIRE
ATTORNEY I.D. NO: PA Bar 9 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association, COURT OF COMMON PLEAS
successor by merger to Chase Home Finance, CIVIL DIVISION
LLC s/b/m to Chase Manhattan Mortgage CUMBERLAND COUNTY
Corporation
PLAINTIFF NO: 2012-1120
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT
AFFIDAVIT PURSUANT TO RULE 3129.1
JPMorgan Chase Bank, National Association, successor by merger to Chase Home
Finance, LLC s/b/m to Chase Manhattan Mortgage Corporation, Plaintiff in the above action,
sets forth, as of the date the praecipe for the writ of execution was filed, the following
information concerning the real property located at 214 West Allen Street, Mechanicsburg, PA
17055.
1. Name and address of Owner(s) or Reputed Owner(s)
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
5211 Pine Hill Road
Dover, PA 17315
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
214 West Allen Street
Mechanicsburg, PA 17055
2. Name and address of Defendant in the judgment:
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
5211 Pine Hill Road
Dover, PA 17315
Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
214 West Allen Street
Mechanicsburg, PA 17055
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
JPMorgan Chase Bank,National Association, successor by merger to Chase Home
Finance, LLC s/b/m to Chase Manhattan Mortgage Corporation
3415 Vision Drive
Columbus, OH 43219
4. Name and address of the last recorded holder of every mortgage of record:
JPMorgan Chase Bank, National Association, successor by merger to Chase Home
Finance, LLC s/b/m to Chase Manhattan Mortgage Corporation, Plaintiff
3415 Vision Drive
Columbus, OH 43219
5. Name and address of every other person who has any record lien on the property:
Internal Revenue Service
WM S. Moorehead Federal Bldg. Advisory
1000 Liberty Avenue, Room 704
Pittsburgh, PA 15222
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
214 West Allen Street
Mechanicsburg, PA 17055
Commonwealth of Pennsylvania
Department of Revenue Inheritance Tax Divsion
1131 Strawberry Square, 6th Floor
Harrisburg, PA 17128
Department of Public Welfare
Estate Recovery Program
P.O. Box 8486, Willow Oak Bldg
Harrisburg, PA 17105
Commonwealth of Pennsylvania, Department of Revenue
Inheritance Tax Division, Bureau of Compliance
Dept. 280946
Harrisburg, PA 17128-0946
Department of Treasury
Internal Revenue service Center
Cincinnati, OH 45999
1 verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
SH i DeNARDO, LLC
BY:
Christopher A. DeNardo, Esquire
10-038403
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar# 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 10-038403
JPMorgan Chase Bank, National Association, COURT OF COMMON PLEAS
successor by merger to Chase Home Finance, CIVIL DIVISION
LLC s/b/m to Chase Manhattan Mortgage CUMBERLAND COUNTY
Corporation
PLAINTIFF NO: 2012-1120
VS.
Darla Maurer, Representative for the Estate
of Robert K. Danner, deceased
DEFENDANT ;
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Darla Maurer, Representative for the Estate of Robert K. Danner, deceased
214 West Allen Street
Mechanicsburg, PA 17055
Your house (real estate) at:
214 West Allen Street, Mechanicsburg, PA 17055
19-23-0567-127
is scheduled to be sold at Sheriffs Sale on March 6, 2013 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
at 10:00AM to enforce the court judgment of$87,745.35 obtained by JPMorgan Chase Bank,
National Association, successor by merger to Chase Home Finance, LLC s/b/m to Chase
Manhattan Mortgage Corporation against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay back to JPMorgan Chase Bank,National
Association, successor by merger to Chase Home Finance, LLC s/b/m to Chase
Manhattan Mortgage Corporation the amount of the judgment plus costs or the back
payments, late charges, costs, and reasonable attorneys fees due. To find out how much
you must pay, you may call:(610)278-6800.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two of how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (610)278-6800.
6. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call 717-240-6390.
8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
9. You have a right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
10. You may be entitled to a share of the money, which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff no later than
thirty days after the Sheriff Sale. This schedule will state who will be receiving the
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10)
days after the date of filing of said schedule.
11. You may also have other rights and defenses or ways of getting your house back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
10-038403
ALL THAT CERTAIN lot, piece or parcel of land situate in the Borough of Mechanicsburg,
Cumberland County, Pennsylvania, bounded and described as follows, to wit:
BEGINNING at a point on this North side of West Allen Street, at corner of lands now or
formerly of Dolly Martin Weber; thence along Allen Street, westward sixteen and three
hundredths (16.03) feet to a point at corner of lands now or formerly of John B. Ocker; thence by
this line of said Lot, northward and through the center of a frame partition well and beyond,
ninety (90.00) feet, more or less, to a point at corner of lands now or formerly of Annie Knauby;
thence along line of said Lot, eastward sixteen and five tenths (16.5) East, more or less, to a
point at corner of Lot now or formerly of Dolly Martin Weber aforesaid; thence along the line of
said Lot, southward and through the center of a frame partition wall, eighty-eight (88.00) feet,
more or less, to a point the place of BEGINNING.
Parcel No. 19-23-0567-127
BEING the same premises which Jean Lois Lyter and Richard E. Lyter, her husband, Joan
Louise Costello and Bruce P. Costello, her husband, as Joint Tenants With the Rights of
Survivorship and not as Tenants in Common, by Deed dated December 16, 2003 and recorded in
the Cumberland County Recorder of Deeds Office on December 23, 2003 in Deed Book 260,
page 4881, granted and conveyed unto Robert K. Danner, a single person.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-1120 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION,SUCCESSOR BY MERGER TO CHASE HOME FINANCE,LLC S/B/M TO
CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff(s)
From DARLA MAURER,REPRESENTATIVE FOR THE ESTATE OF ROBERT K.DANNER,
DECEASED
(1) You are directed to levy upon the property of the defendant(s)and to sell SEE LEGAL
DESCRIPTION.
(2) You are also directed to attach the property of the defendant(s)not levied upon in the possession
of
GARNISHEE(S)as follows:
and to notify the garnishee(s)that:(a)an attachment has been issued;(b)the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s)and from delivering any property of the defendant
(s)or otherwise disposing thereof,
(3) If property of the defendant(s)not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due: $87,745.35 L.L.: .50
Interest FROM OCTOBER 16,2012 TO MARCH 6,2013 IS$2,005.47
Atty's Comm: % Due Prothy:$2.25
Atty Paid: $322.00 Other Costs:
Plaintiff Paid:
Date: 10/22/12
David D. Buell,Prothonotary
(Seal) v; d D
REQUESTING PARTY:
Name: CHRISTOPHER A.DENARDO,ESQUIRE
Address:SHAPIRO& DENARDO,LLC
3600 HORIZON DRIVE,SUITE 150
KING OF PRUSSIA,PA 19406
Attorney for:PLAINTIFF
Telephone: 610-278-6800 TRUE COPY FROM RECORD}
Supreme Court ID No. 78447 In"Testimony whereof,i here unto set my hand
and the seal of said Court at arlisla Pa.
This._22:day of G ,20 f°1-
Prothonotary
4y�vb CA, b
On October 26, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
Mechanicsburg Borough, Cumberland County, PA,
Known and numbered as, 214 West Allen Street,
Mechanicsburg, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: October 26, 2012
By.
R eal state Coordinator
Z 10 t10t
ci
CUMBERLAND LAW JOURNAL
Writ No. 2012-1120 Civil
JP Morgan Chase Bank,NA
VS.
Darla Maurer,Representative
for the Estate of
Robert K. Danner,Deceased
Atty.: Christopher DeNardo
ALL THAT CERTAIN lot, piece or
parcel of land situate in the Borough
of Mechanicsburg, Cumberland
County,Pennsylvania,bounded and
described as follows,to wit:
BEGINNING at a point on this
North side of West Allen Street, at
corner of lands now or formerly of
Dolly Martin Weber; thence along
Allen Street, westward sixteen and
three hundredths (16.03) feet to a
point at comer of lands now or for-
merly of John B. Ocker; thence by
this line of said Lot, northward and
through the center of a frame parti-
tion well and beyond,ninety(90.00)
feet,more or less,to a point at comer
of lands now or formerly of Annie
Knauby; thence along line of said
Lot,eastward sixteen and five tenths
(16.5)East,more or less,to a point at
comer of Lot now or formerly of Dolly
Martin Weber aforesaid;thence along
the line of said Lot, southward and
through the center of a frame parti-
tion wall, eighty-eight (88.00) feet,
more or less, to a point the place of
BEGINNING.
Parcel No. 19-23-0567-127.
BEING the same premises which
Jean Lois Lyter and Richard E.Lyter,
her husband, Joan Louise Costello
and Bruce P. Costello,her husband,
as Joint Tenants With the Rights of
Survivorship and not as Tenants in
Common, by Deed dated December
16, 2003 and recorded in the Cum-
berland County Recorder of Deeds
Office on December 23,2003 in Deed
Book 260, page 4881, granted and
conveyed unto Robert K. Danner, a
single person.
82
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid,being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 25, February 1, and February 8, 2013
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time,place and character of publication are true.
isa Marie Coyne/Editor
SWORN TO AND SUBSCRIBED before me this
8 day of Febru@a, 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
i
The Patriot-News Co.
2020 Technology Pkwy
t4e atr1*otjwXtw5
Suite 300
Mechanicsburg, PA 17050
Now You know
Inquiries - 71 7-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
2012.1120 Chr11
JP Morgan Chase Ban This ad ran on the date(s)shown below:
Vs
Masar;Fepr�erte or 01/22113
--the Estate of Robert K 111annsr, 0
Deceased 01/29/13
Aft ChftWphw Denardib C"1 02/05113
ALL THAT CERTAIN- lot, piece,�or
Parcel of land situate in the Borough of
Mechanicsburg, Cumberland County, . . . . . . . . . . . . . . . . . .
Pennsylvania, bounded and described as
follows tING Sworn to and s b ribed before me this day of February, 2013 A.D.
BEGINNING at a point�this North side y ry,
of West Allen street,at corner of hails now
or formerly of Dopy Martin Weber,thence
along Allen street,westward sixteen and iA
three hundredths (16.03)feet to a point Not Ic
at comer of lands now or formerly of John
R Ocker,thence by this line of said Lot,
northward and through the center of a
frame partition wen and beyond, ninety
(90.00)k et,more or less,to a point at comer
of lands now or formerly of Annie Knauby; COMMONWEALTH OF PENNSYLVANIA
thence along line of said Lot, eastward Notarial Seal
sixteen and five t�ths( East,more Holly Lynn Warfel,Notary Public
or less,to a point at cxmter Lc4nw or
formerly of Dolly Martin Weber aforesaid; Washington Twp.,Dauphin County
thence along the line of said Lot,soutliward My Commission Expires Dec.12,2016
and through the center of a frame partition MEMBER.PENNSYLVANIA ASSOCIATION OF NOTARIES
wall,eighty-eight(88.00)feet,more or less,
to a point the price ofB)GINNING.
Parcel No.19-23.0567127
BEING the same tv Jeanfipis
9rrrvlvat�ip ate' as is
in Common, by Deed dated,December
16,2003 and recorded in the Cumberland
County Recorder of Deeds Office on
December 23,2003 in Deed Book 260,page
4881,granted and conveyed unto Robert K
Danner,a single person.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which Secretary of Veterans Affairs is the grantee the same having been sold to
said grantee on the 6th day of March A.D., 2013, under and by virtue of a writ Execution issued on the
22nd day of October, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term,
2012 Number 1120, at the suit of JP Morgan Chase Bank, National Association s/b/m to Chase Home
Finance LLC s/b/m to Chase Manhattan Mortgage Corporation against Darla Maurer, Representative for
the Estate of Robert K. Danner, deceased is duly recorded as Instrument Number 201318607.
IN TESTIMONY WHEREOF, I have hereunto set my hand
and seal of said office this day of
A.D. 2
0/14/ )k *�
i
ecorder of Deeds
ertand Co",Caftle,PA
My Commission Tres �e Fret Monday of Jan.2014