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Home My WebLink About12-1205r ,1 7?' 23 2 FE 27 AJAI 9 c CUMBERLAND COUtw9 PE MSYLVANIA PHELAN HALLINAN & SCHMIEG, LLP Joseph P. Schalk, Esq., Id. No.91656 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, N.A. 3415 VISION DRIVE COLUMBUS, OH 43219 Plaintiff V. STEVEN J. PEERY SHANA L. PEERY 15 ORION ROAD BOILING SPRINGS, PA 17007-9792 Defendants 282203 ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. dO CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 282203 (? ?:S) uak -%IbS.7SF)d 0k#1/(W/7b 4?-l g`7/ Sad NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 282203 Plaintiff is JPMORGAN CHASE BANK, N.A. 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name(s) and last known address(es) of the Defendant(s) are: STEVEN J. PEERY SHANA L. PEERY 15 ORION ROAD BOILING SPRINGS, PA 17007-9792 who is/are the mortgagor(s) and/or real owner(s) of the property hereinafter described. 3. On 07/29/2005 STEVEN J. PEERY and SHANA L. PEERY made, executed and delivered a mortgage upon the premises hereinafter described to BROADVIEW MORTGAGE COMPANY which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book 1917, Page 1485. By Assignment of Mortgage recorded 08/03/2005 the mortgage was assigned to PLAINTIFF which assignment is recorded in Assignment of Mortgage Book 719, Page 3219. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 06/01/2011 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 282203 6 The following amounts are due on the mortgage as of 09/30/2011: Principal Balance $217,667.93 Interest $5,328.35 05/01/2011 through 09/30/2011 Property Inspections 14.00 Subtotal $223,010.28 Suspense Credit 173.34 TOTAL $222,836.94 7 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon. File #: 282203 9. The action does not come under Act 6 of 1974 because the original mortgage amount exceeds the dollar amount provided in the statute. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $222,836.94, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLIN N & SCHMIEG, UP By: chalk, Esquire ?se+ to ey for Plaintiff File #: 282203 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described in accordance with the Final Subdivision Plan for Forge Hills prepared by C. W. Junkins Associates, Inc., Professional Land Surveyor, dated January 22, 1987, and revised April 6, 1987, a copy of which is recorded in the Recorder's Office for Cumberland County in Plan Book 53, Page 13, as follows, to wit: BEGINNING at a point located on the southern right-of-way line of Orion Road, a fifty-foot wide road, said point also being on the dividing line of Lot Nos. 13 and 14; thence along said dividing line South 3 degrees 20 minutes 44 seconds West, a distance of 125.00 feet to a point located along lands now or formerly owned by Country Side Acres; thence along said lands North 86 degrees 39 minutes 16 seconds West, a distance of 160.00 feet to a point located at the dividing line of Lot Nos. 13 and 12, said point being the southwesternmost point of Lot No. 13; thence along said dividing line of Lot Nos. 13 and 12, North 3 degrees 20 minutes 44 seconds East, a distance of 125.00 feet to a point located along the southern right-of-way line of Orion Road, a fifty-foot wide road; thence along said right-of-way South 86 degrees 39 minutes 16 seconds East, a distance of o 160.00 feet to the Point and Place of BEGINNING. CONTAINING 20,000 square feet more or less, and being Lot No. 13 as shown on a Final Subdivision Plan for Forge Hills, recorded as aforesaid. PROPERTY ADDRESS: 15 ORION ROAD, BOILING SPRINGS, PA 17007-9792 PARCEL # 40-27-1921-050. File #: 282203 VERIFICATION J c. ?a of JPMORGAN I ?l.C?' hereby states that he/she ALI 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 my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: 1 i Name: uV Title: ? Cil?..r f 1 as_I JPMORGAN CHASE BANK, NATIONAL ASSOCIATION File#: 282203 Name:PEERY File #' 282203 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson Sheriff ?- T?' ?.;i?OT#ICPbl?r`' . okt?tt?, of Jody S Smith 2212 MAY -8 Alf 9:54 Chief Deputy CUMBERLAND COUNTY Richard W Stewart Solicitor PENNSYLVANIA citor JP Morgan Chase Bank, NA Case Number vs. Steven J. Peery (et al.) 2012-1205 SHERIFF'S RETURN OF SERVICE 03/01/2012 07:50 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on March 1, 2012 at 1950 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Shana L. Peery, by making known unto herself personally, at 126 Sable Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. ROB RT BITNER, DEPUTY 03/27/2012 08:55 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 27, 2012 at 2088 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Steven J. Peery, by making known unto himself personally, at 900 Spring Circle, 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. RYAN BURGETT, D 03/28/2012 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: Shana L. Peery, 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 Shana L. Peery. Request for service at 15 Orion Road, Boiling Springs, Pennsylvania 17007 is vacant. 03/28/2012 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: Steven J. Peery, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Steven J. Peery. Request for service at 15 Orion Road, Boiling Springs, Pennsylvania 17007 is vacant. Steven J. Peery currently resides at 900 Spring Circle, Mechanicsburg, Pennsylvania 17055. SHERIFF COST: $100.00 May 03, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF FILED-OFFICE ' THE PROTHONOTARY PHELAN HALLINAN & SCHMIEG, LL Attorney for Plaintiff Matthew Brushwood, Esq., Id. No.310592 2012 JUL -3 AM 1Q' GS 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza CUMBERLAND COUNTY Philadelphia, PA 19103 PENNSYLVANIA 215-563-7000 JPMORGAN CHASE BANK, N.A. CUMBERLAND COUNTY VS. COURT OF COMMON PLEAS STEVEN J. PEERY CIVIL DIVISION SHANA L. PEERY No. 2012-1205 CIVIL PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against STEVEN J. PEERY, and SHANA L. PEERY, Defendant(s) for failure to file an Answer to Plaintiff s Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiffs damages as follows: As set forth in Complaint TOTAL $222,836.94 $222,836.94 I hereby certify that (1) the Defendants' last known addresses are 15 ORION ROAD, BOILING SPRINGS, PA 17007-9792,900 SPRING CIRCLE, MECHANIC SBURG, PA 17055, and 126 SABLE DRIVE, CARLISLE, PA 17013, and (2) that notice as been given in a? ,ts accordance . ith ule Pa.R.C.P 237.1. C a?,7q,)y Date Matthe ; Esquire Attor y Plai r.Lti ff V _ DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PHS a 282203 PROTHONOTARY 282203 PHELAN HALLINAN & SCHMIEG, LLP Matthew Brushwood, Esq., Id. No.310592 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, N.A. VS. STEVEN J. PEERY SHANA L. PEERY Attorney for Plaintiff : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 2012-1205 CIVIL AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter, and that on information and belief, he/she has knowledge of the following facts. to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act of Congress of 1940, as amended. (b) that defendant STEVEN J. PEERY is over 18 years of age and the Defendants last known addresses are 15 ORION ROAD, BOILING SPRINGS, PA 17007-9792 and 900 SPRING CIRCLE, MECHANICSBURG, PA 17055. (c) that defendant SHANA L. PEERY is over 18 years of age and the Defendant's last known addresses are 126 SABLE DRIVE, CARLISLE, PA 17013 and 15 ORION ROAD, BOILING SPRINGS, PA 17007-9792. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date at e shwood. Esquire Attorn for Plaintiff 282203 (Rule of Civil Procedure No. 236) - Revised JPMORGAN CHASE BANK, N.A. CUMBERLAND COUNTY VS. COURT OF COMMON PLEAS STEVEN J. PEERY SHANA L. PEERY CIVIL DIVISION No. 2012-1205 CIVIL Notice is given that a Judgment in the above captioned matter has been entered against you on . If you have any questions concerning this matter please contact: Phelan Hallinan & Schmieg, LLP Matthew Brushwood, Esquire Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza. Philadelphia, PA 19103 215-563-7000 ** THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HA VE PREVIOUSL Y RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLY ENFORCEMENT OFA LIENAGAINST PROPERTY,** 282203 JPMORGAN CHASE BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff V. NO. 2012-1205 CIVIL STEVEN J. PEERY CUMBERLAND COUNTY SHANA L. PEERY Defendant(s) TO: STEVEN J. PEERY 15 ORION ROAD BOILING SPRINGS, PA 17007-9792 DATE OF NOTICE: TFIIS F1RM IS 7AD .BT C OI LECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT "TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND S1401JLD NOT BE CONSTRUED 'TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 By: il ri .lVlu'ley,Lsdrrfi?: ? - t rney for Plaintiff Phelan Hallman & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 292203 JPMORGAN CHASE BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff v- NO. 2012-1205 CIVIL STEVEN J. PEERY CUMBERLAND COUNTY SHANA L. PEERY Defendant(s) TO: STEVEN J. PEERY 900 SPRING CIRCLE MECHANICSBURG, PA 17 55 DATE OF NOTICE: THIS FIRM IS A EB7; COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU N AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE: DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR :LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195 BY: °AlldrOw.T, ailey> `.quife Attorney for Plaintiff ' Phelan Hallinan & Schmieg, LLB? °' 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 11617)249-31k,61, PHS # 282203 JPIVIORGAN CHASE BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff V. NO. 2012-1205 CIVIL STEVEN J. PEERY CUMBERLAND COUNTY SHANA L. PEERY Defendant(s) TO: SHANA L. PEERY 126 SABLE DRIVE CARLISLE, PA 17013 DATE OF NOTICE: THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDE13TEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE EN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA. 17013 ( 17) 249-3 ]?i)6 B y. f dr w .I. Marley, ? l s /F,?f Attorney for Plaintiff f°Phelan Hallinan & Schmieg, 11 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 282203 JPMORGAN CHASE BANK, N.A. COURT OF COMMON PLEAS CIVIL DIVISION Plaintiff V. NO. 2012-1205 CIVIL STEVEN J. PEERY CUMBERLAND COUNTY SHANA L. PEERY Defendant(s) TO: SHANA L. PEERY 15 ORION ROAD BOILING SPRINGS, PA 17007-9792 DATE. OF NOTICE: 4._....__ THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE.;. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 17)249-31 tom/ By: _ nOKew J. Marley, 1,' 1 c homey for Plaintiff ? Phelan Hallinan & Schmieg, 1-4f, 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 282203 FILEB-FFI E OF THE PRO Phelan Hallinan & Schmieg, LLP Attorney For Plaintiff 1617 JFK Boulevard, Suite 1400 2112 JUL 27 AM 10: 19 One Penn Center Plaza CU GiTY PbUadel &* PA 19103 fl?LAND ?? ? 215-563-7000 JPMORGAN CHASE BANK, N.A. Plaintiff vs STEVEN J. PEERY SHANA L. PEERY Defendant .:Court of Common Pleas Civil Division CUMBERLAND County No. 2012-1205 CIVIL PRAECIPE TO THE PROTHONOTARY: ? Please withdraw the complaint and mark the action Discontinued and Ended without prejudice. I ? Please mark the above referenced case Settled, Discontinued and Ended. ® Please Vacate the judgment entered and mark the action Discontinued and Ended) without prejudice. ? Please mark the in rem judgment Satisfied and the action Discontinued and Ended. Date. _ Z PHELAN HALL 7 SCHMIE4, LLP j By: Dana Os ,Esq., Id. No.83921 A rn or Plaintiff PHS # 282203 auk ?? 0' ?*O10VV r VVY A R Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza PhRa1*la, PA 19103 215-563-7000 JPMORGAN CHASE BANK, N.A. Plaintiff vs STEVEN J. PEERY SHANA L. PEERY Defendant Attorney For Plaintiff Court of Common Pleas Civil Division CUMBERLAND County No. 2012-1205 CIVIL CERTIFICATION OF SERVICE I hereby certify true and correct copies of the foregoing Plaintiffs Praecipe was served regular mail to the person(s) on the date listed below: STEVEN J. PEERY 900 SPRING CIRCLE MECHANICSBURG, PA 17055 SHANA L. PEERY 15 ORION ROAD BOILING SPRINGS, PA 17007-9792 Date: ?n 2L t - By: Dana Ostro , Esq., Id. No.83921 Aft for Plaintiff PHS # 282203