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HomeMy WebLinkAbout12-2737F f_ 3 n w tt =m ?C o? ETA to ? ? .< t-- a CD -n y' C-? z CDC) rTr PHELAN HALLINAN & SC"EG, LLP Joseph P. Schalk, Esq., Id. No.91 56 1617 JFK Boulevard, Suite 1400 ATTORNEY FOR PLAINTIFF One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 279096 JPMORGAN CHASE BAN, NATIONAL ASSOCIATION SB/M TOICHASE HOME FINANCE COURT OF COMMON PLEAS LLC, SB/M TO CHASE NHATTAN MORTGAGE CORPORAT ON SB/M TO CHASE, CIVIL DIVISION HOME MORTGAGE CO ORATION 3415 VISION DRIVE TERM COLUMBUS, OH 43219 NO, k9-,,2j37 UJVi tTem Plaintiff V. CUMBERLAND COUNTY JEFFREY L. FRYMOYER 312 PINEWOOD DRIVE SHIREMANSTOWN, PA 11011-6527 Defendant CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File 9: 279096 0 96- Pp A7T f P# a ?y583 NOTICE You have been sued i? Court. If you wish to defend against the claims set forth in the following pages, you must ta? e action within twenty (20) days after this Complaint and Notice are served by entering a writien appearance personally or by attorney and filing in writing with the Court your defenses or o$jections 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, 00 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 #; 279096 Plaintiff is JPMORGAN CHAS BANK, NATIONAL ASSOCIATION S/B/ TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION S/ /M TO CHASE HOME, MORTGAG CORPORATION 3415 VISION DRIV4 COLUMBUS, OH 43219 The name and last known address of the Defendant are: JEFFREY L. FRYMOIYER 312 PINEWOOD DRIVE SHIREMANSTOWN PA 17011-6527 who is the mortgagor land/or real owner of the property hereinafter described. 3. On 05/22/1986 JEFFREY L. FRYMOYER made, executed and delivered a mortgage upon the premises hereinafter described to CITY FEDERAL SAVINGS AND LOAN ASSOCIATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND Co4nty, in Mortgage Book 814, Page 1093. By Assignment of Mortgage recorded 0/07/1991 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book: 393, Page: 599. 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. The premises subject to said mortgage is described as attached. File it 279096 The mortgage is in default because monthly payments of principal and interest upon said mortgage due 05/01/2011 and each month thereafter are due and unpaid, and by the terms of said mortgage, updn failure of mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. 6. The following amounts are due on the mortgage as of 08/18/2011: Principal Bal? nce $19,409.75 Interest $733.44 04/01/2011 through 08/18/2011 Late Charges) $62.21 Property Inspections $28.00 Escrow Deficit $676.48 TOTAL $20,909.88 T Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has 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.' The mortgage premises are vacant and abandoned. File ##: 279096 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant in the sum of $20,909.88, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to a?ttorney fees and costs, and for the foreclosure and sale of the mortgaged property. Filek 279096 PHELAN HALLINAN & SCHMIEU, LLP T- LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern side of Queen Avenue (50 feet wide) at the southeastern corner of Lot No. 13 on the hereinafter mentioned Plan of Lots; thence along Lot No. 13 North 09 degrees 22 minutes 30 seconds West a distance of 140 feet to a point; thence North 80 degrees 37 minutes 30 seconds East a distance of 20 feet to a point; thence by Lot No. 15 on said Plan South 09 degrees 22 mi? utes 30 seconds East a distance of 140 feet to a point on Queen Avenue; thence by Queen A?enue South 80 degrees 37 minutes 30 seconds West a distance of 20 feet to a point, the place ol7 BEGINNING. HAVING THEREON ERECTED a townhouse known and numbered as 97 Queen Avenue. BEING Lot No. 14 on a Final Subdivision Plan No. 2 for Robert D. and Donna R. Leisenring, his wife, made January 17, 180 and February 13, 1980 by D. P. Raffensperger Associates and recorded in the Cumberland County Recorder's Office in Plan Book 37, Page 98. BEING the same premises which Michael J. Rock and Barbara H. Rock, his wife, by their deed dated February 26, 1983 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book C-30, page 94, granted and conveyed unto Barbara J. Nelson, Grantor UNDER AND SUBJECT, record pertaining to said PROPERTY ADDRESS: PARCEL # 09-13-1002.325 THELESS, to restrictions and conditions, easements of prior ses. QUEEN AVENUE, ENOLA, PA 17025-2338 File k: 279096 VERIFICATION i ?ereby states that he/she is f 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 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 aufthoriti DATE: File#: 279096 Name: FRYMOYER Name: Jenni r Jordan Title: Vice President JPMORGAN CHASE BANK, NATIONAL ASSOCIATION File #: 279096 JPMORGAN CHASE BANK, NATIONAL IN THE COURT OF COMMON PLEAS ASSOCIATION SB/M TO CHASE HOME FINANCE OF CUMBERLAND COUNTY, LLC, SB/M TO CHASE MANHATTAN MORTGAGE PENNSTLVANIA CORPORATION SB/M TO CHASE Plaintiff(s) vs. 040 JEFFREY L. FRYMOYER 0 - o tB? W4 Defendant(s) -Civil NOTICE OF RESID NTIAL MORTGAGE FORECLOSURE DI ERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the reside tial property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliat on conference in an effort to resolve this matter with your lender. If you do not have an attorney conference. First, within twenty (20) da, (717) 243-9400 extension 2510 or (800)1 charge to you. Once you have been appoi within twenty (20) days of the appointme the requested financial information so tha representative complete a financial work; Request for Conciliation Conference witl service upon you of the foreclosure comp opportunity to meet with a representative before the mortgage foreclosure suit proc you must take the following steps to be eligible for a conciliation s of your receipt of this notice, you must contact MidPenn Legal Services at 22-5288 extension 2510 and request appointment of a legal representative at not ited a legal representative, you must promptly meet with the legal representative it date. During that meeting, you must provide the legal representative with all a loan resolution proposal can be prepared on your behalf. If you and your legal feet in the format attached hereto, the legal representative will prepare and file a the Court, which must be filed with the Court within sixty (60) days of the aint. If you do so and a conciliation conference is scheduled, you will have an A your lender in attempt to work out a reasonable arrangements with your lender ;eds forward. If you are represented by a law yer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessa ry for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all the requested financial information so that a loan resolution proposal can be prepared on yo ur behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) day of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work our reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward, IF YOU WISH TO SAVE YO R HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THI$ PROGRAM IS FREE. 5 Date Respectfully submitted: 3 C z ca --t 1 CD z -n 3 mac: o ? r?, Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Co on Please Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): _ Property Address: City: _ Is the property for sale? Y Realtor Name: _ Borrower Occupied? Y Mailing Address (if different):_ City: _ Phone Numbers: H Email: # of people in household: Mailing Address: City: Phone Numbers: Email: # of people in household: First Mortgage Lender:_ Loan: Loan Number: Second Mortgage Lender: of Loan: _ Loan Number: No ? Listing date: No State: Zip: Price: $_ Realtor Phone: How long? State: Zip: How long? Date you Closed Your Loan: Type of State:_ Zip: Office: Other: Office: Other: Type Total Mortgage Payments Amou?t: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes No ? If yes, provide names, location o court, case number & attorney: Assets Home: Other Real Estate: Retirement Funds: Investments: Checking: Savings: Other: Automobile #1: Model: Amount owed: Automobile #2: Model: Amount owed: Year: Amount owed: Value: Year: Value: Year: ;? Model: Value Monthly Income Name of Employers: 1. 2. 3. Additional Income Description 1. monthly am 2. monthly am Borrower Pay Days:_ Value: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUN T EXPENSE AMOUNT Mortgage Food 2° Mortgage Utilities Car Pa ment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Money Day/Child Care/Tuit. Other Expenses Amount Available for Monthly Mo?tgage Payments Based on Income & Expenses: wages): Have you been working with a Housing Counseling Agency? Yes ? No ? If yes, please provide the followi4 information: Counseling Agency: Counselor: _ Phone (Office): Email: Fax: Have you made application for H meowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status Of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? If yes, please indicate the status o f those negotiations: Please provide the following information, if you know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I/We, authorize the above named to use/refer (this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this page along with the following information to lender: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility] bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) C1 r-41 --? SHERIFF'S OFFICE OF CUMBERLAND COUNTII-:T- , rri ,-- Ronny R Anderson rte. Sheriff .O" `.. ti tt(tIt or O .-{CD Jody S Smith 9?ttl Mfr w ?? - Chief Deputy Richard W Stewart - Solicitor _ r JP Morgan Chase Bank, NA Case Number vs. Jeffrey L. Frymoyer 2012-2737 SHERIFF'S RETURN OF SERVICE 05/04/2012 07:09 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on May 4, 2012 at 1909 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: Jeffrey L. Frymoyer, by making known unto himself personally, at 312 Pinewood Drive, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. RYAN BURGETT, DEPUTY' 05/08/2012 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: Jeffrey L. Frymoyer, but was unable to locate him in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program as not found as to the defendant Jeffrey L. Frymoyer. Request for service at 97 Queen Avenue, Enola, Pennsylvania 17025 is vacant. SHERIFF COST: $79.00 May 09, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF iC Courty5ui Le ?Zhentt, Ie'?eua )tI. In;. JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSTLVANIA Plaintiff(s) VS. JEFFREY L. FRYMOYER l1- a031 01villm Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have an attorney, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at not charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all the requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in attempt to work out a reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all the requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work our reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward, IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. b Date %EM v C, Y" r..? C.::'S N -c i w m 3 C7 rV r_• r r?- c o - C, z -ra C.3 ?7 m...? f Y'F -C. Respectfully submitted: Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Please Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: State: Zip: Is the property for sale? Yes F_1 No ? Listing date: Price: $_ Realtor Name: Realtor Phone:_ Borrower Occupied? Yes ? No ? Mailing Address (if different): City: Phone Numbers: Home: Cell: Email: # of people in household: How long? Mailing Address: City: Phone Numbers: Email: # of people in household: First Mortgage Lender: Loan: Loan Number: Second Mortgage Lender: of Loan: Loan Number: State: Zip: Home: Cell: State: Zip: Office: Other: Office: Other: How long? Date you Closed Your Loan: Type of Type Total Mortgage Payments Amount: $ Included Taxes & Insurance: Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ? No ? If yes, provide names, location of court, case number & attorney: Assets Amount Owed: Value: Home: $ $ Other Real Estate: $ $ Retirement Funds: $ $ Investments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Model: Amount owed: _ Value: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles, boats, motorcycles): Model: Year: Amount owed: Value Monthly Income Name of Employers: I. Year: Year: 2. 3. Additional Income Description (not wages): 1. monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food 2" Mortgage Utilities Car Payment(s) Condo/Nei . Fees Auto Insurance Med. (not covered) Auto f iel/repairs Other prop. payment Install. Loan Payment Cable TV Child Su ort/Alim. Spending Money Day/Child Care/Tuit. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Have you been working with a Housing Counseling Agency? Yes ? No ? If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Email: Fax: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ? No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? If yes, please indicate the status of those negotiations: Please provide the following information, if you know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: I/We, authorize the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/We understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this page along with the following information to lender: 1. Proof of income 2. Past 2 bank statements 3. Proof of any expected income for the last 45 days 4. Copy of a current utility bill 5. Letter explaining reason for delinquency and any supporting documentation (hardship letter) 6. Listing agreement (if property is currently on the market) r-- C-) N I^? ry rri x o zJ: C-- ?r PBELAN HALLINAN & SCIMEG, LLP Joseph P. Schalk, Esq., Id. No.91656 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 279096 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 V. Plaintiff JEFFREY L. FRYMOYER 312 PINEWOOD DRIVE SHIREMANSTOWN, PA 17011-6527 Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM NO. /a- 01737 0?vil 7em CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE jt4 File #: 279096 TRUE COPY FROM RECORD In Testimony wtwoof, l.hen 1N1b eat ny hand and the of of said at cove* Pr. This rdd Z0a- ?u u- 10P00oww y T`a,JtisCtAr13t71` i ?...o. . 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 9- 279096 1. Plaintiff is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION S/B/M TO CHASE HOME MORTGAGE CORPORATION 3415 VISION DRIVE COLUMBUS, OH 43219 2. The name and last known address of the Defendant are: JEFFREY L. FRYMOYER 312 PINEWOOD DRIVE SHIREMANSTOWN, PA 17011-6527 who is the mortgagor and /or real owner of the property hereinafter described. 3. On 05/22/1986 JEFFREY L. FRYMOYER made, executed and delivered a mortgage upon the premises hereinafter described to CITY FEDERAL SAVINGS AND LOAN ASSOCIATION which mortgage is recorded in the Office of the Recorder of CUMBERLAND County, in Mortgage Book 814, Page 1093. By Assignment of Mortgage recorded 02/07/1991 the mortgage was assigned to PLAINTIFF which Assignment is recorded in Assignment of Mortgage Book: 393, Page: 599. The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. File #: 279096 _5 6. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 05/01/2011 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. The following amounts are due on the mortgage as of 08/18/2011: Principal Balance $19,409.75 Interest $733.44 04/01/2011 through 08/18/2011 Late Charges $62.21 Property Inspections $28.00 Escrow Deficit 676.48 TOTAL $20,909.88 7 8. Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant has 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. The mortgage premises are vacant and abandoned. File #: 279096 WHEREFORE, Plaintiff demands an in rem judgment against the Defendant in the sum of $20,909.88, 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. File C 279096 PHELAN HALLINAN & SCHMIEG, LLP LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern side of Queen Avenue (50 feet wide) at the southeastern corner of Lot No. 13 on the hereinafter mentioned Plan of Lots; thence along Lot No. 13 North 09 degrees 22 minutes 30 seconds West a distance of 140 feet to a point; thence North 80 degrees 37 minutes 30 seconds East a distance of 20 feet to a point; thence by Lot No. 15 on said Plan South 09 degrees 22 minutes 30 seconds East a distance of 140 feet to a point on Queen Avenue; thence by Queen Avenue South 80 degrees 37 minutes 30 seconds West a distance of 20 feet to a point, the place of BEGINNING. HAVING THEREON ERECTED a townhouse known and numbered as 97 Queen Avenue. BEING Lot No. 14 on a Final Subdivision Plan No. 2 for Robert D. and Donna R. Leisenring, his wife, made January 17, 1980 and February 13, 1980 by D. P. Raffensperger Associates and recorded in the Cumberland County Recorder's Office in Plan Book 37, Page 98. BEING the same premises which Michael J. Rock and Barbara H. Rock, his wife, by their deed dated February 26, 1983 and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in Deed Book C-30, page 94, granted and conveyed unto Barbara J. Nelson, Grantor herein. UNDER AND SUBJECT, NEVERTHELESS, to restrictions and conditions, easements of prior record pertaining to said premises. PROPERTY ADDRESS: 97 QUEEN AVENUE, ENOLA, PA 17025-2338 PARCEL # 09-13-1002.325 File 4 279096 VERIFICATION hereby states that he/she is Ce ?f 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 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: `-? File#: 279096 Name: FRYMOYER Name: Jenn r Jordan Title: Vice President JPMORGAN CHASE BANK, NATIONAL ASSOCIATION File k 279096 IF PHELAN HALLINAN & SCHMIEG, LLP Christy Donati, Esq., Id. No.306628 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SBIM TO CHASE HOME FINANCE LLC, S/BIM TO CHASE MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION VS. JEFFREY L. FRYMOYER Attorney for Plaintiff CUMBERLAND COUNTY COURT OF COMMON PLEAS CIVIL DIVISION No. 12-2737-CIVIL-TERM C'? M z cnr" >? y ?c "-i z?• 0 -r •-•y r44 M f 1 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 JEFFREY L. FRYMOYE: Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages follows: As set forth in Complaint TOTAL $20,909.88 $20,909.88 I hereby certify that (1) the Defendant's last known addresses are 312 PINEWOOD DRIVE, SHIREMANSTOWN, PA 17011-6527 and 97 QUEEN AVENUE, ENOLA, PA 17025- 2338, and (2) that notice has been given in accordance w' Rule Pa.R.C.P 237.1. Date ?d ?7- Christy ti, Esquire Attorne for Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: 7 a ?llo,b pp ATN PHS a 279096 PROTHONOTARY C-#1.9o &64 e .77 rs ow kl4ie llla i lec? 2 PHELAN HALLINAN & SCHMIEG, LLP Christy Donati, Esq., Id. No.306628 1617 JFK Boulevard, Suite 1400 Attorney for Plaintiff One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION : CUMBERLAND COUNTY : COURT OF COMMON PLEAS : CIVIL DIVISION : No. 12-2737-CIVIL-TERM VS. JEFFREY L. FRYMOYER 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 knowl of the following facts, to wit: (a) that the defendant(s) is/are not in the Military or Naval Service of the Unite States or its Allies, or otherwise within the provisions of the Servicemembers Civil Relief Act Congress of 1940, as amended. (b) that defendant JEFFREY L. FRYMOYER is over 18 years of age and the Defendant's last known addresses are 312 PINEWOOD DRIVE, SHIREMANSTOWN, PA 17011-6527 and 97 QUEEN AVENUE, ENOLA, PA 17025-2338. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date v A \I- 'J y Christy Dona 1, squire Attorney for Plaintiff 2 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION Plaintiff V. JEFFREY L. FRYMOYER Defendant(s) TO: JEFFREY L. FRYMOYER 312 PINEWOOD DRIVE SH[REMANS'I'O N PA 17..] 1-6527 DATE OF NOTICE: 2!-, COURT OF COMMON PLEAS CIVIL. DIVISION NO. 12-2737-CIVIL-TERM CUMBERLAND COUNTY 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 1.7013 (717) 240-6195 CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE -ARL,ISLE. PA 17013 (717) 249-3166 By Matthew w s ooc1, Esquire Attorne f laintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza PHS # 279096 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION S/B/M TO CHASE HOME MORTGAGE CORPORATION Plaintiff v. JEFFREY L. FRYMOYER Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION NO. 12-2737-CIVIL-TERM CUMBERLAND COUNTY TO: JEFFREY L. FRYMOYER 97 QUEEN AVENUE ENOLA, PA 17022.38 DATE OF NOTICE: THIS FIRM IS A DE T 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 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: atthe rus ocxi, Esquire Attc?txte laintiff Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 PHS # 279096 (Rule of Civil Procedure No. 236) - Revised JPMORGAN CHASE BANK, NATIONAL : CUMBERLAND COUNTY ASSOCIATION SB/M TO CHASE HOME : FINANCE LLC, SB/M TO CHASE : COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION CIVIL DIVISION VS. : No. 12-2737-CIVIL-TERM JEFFREY L. FRYMOYER Notice is given that a Judgment in the above captioned matter has been entered against you on /1 0- If you have any questions concerning this matter please contact: Phelan Hallinan & Schmieg, LLP Christy Donati, 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 ANYINFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT A SHOULD NOT BE CONSTRUED TO BEANATTEMPT TO COLLECTA DEBT, BUT ONLYENFORCEMENT OFA LIENAGAINST PROPERTY" 2790! WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-2737 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL ASSOCIATION s/b/m to CHASE HOME FINANCE LLC, s/b/m to CHASE MANHATTAN MORTGAGE CORPORATION s/b/m to CHASE HOME MORTGAGE CORPORATION, Plaintiff (s) From JEFFREY L. FRYMOYER (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: $20,909.88 L.L.: Interest from 7/12/12 To Date of Sale ($3.44 per diem) -- $505.68 Atty's Comm: % Due Prothy: $2.25 Atty Paid: $230.25 Other Costs: Plaintiff Paid: Date:' 8/31/12 David D. Buell, Prothonotary (Seal) ?.: - tm WgaAZ_' Deputy REQUESTING PARTY: Name: ALLISON F. WELLS, ESQUIRE Address: PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK BOULEVARD, SUITE 1400 PHILADELPHIA, PA 19103 Attorney for: PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 309519 PRAECIPE FOR WRIT OF EXECUTION-(MOR-. P.R.C.P.3180-3183 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME )FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION Plaintiff v CGAGE FORECLOSURE) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 12-2737-CIVIL-TERM CUMBERLAND COUNTY JEFFREY L. FRIYMOYER Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: Amount Due Interest from 07/12/2012 to Date of Sale ($3.44 per diem) TOTAL CI rv C? -l , r-Ti y ?. , +y $20,909.88 W ap r- X ` 505.68 b ?• c C 2 =? -+rq .{ C.3 CO $21,415.56 _ G Ha linen & Schm , LLP Allison F. Wells, Esq., Id. No.309519 Attorney for Plaintiff Note: Phase attach description of property. PHS # 279096 ?I' #aa.so Pa Am/ 79.00 0 B t` 103.95 It /10-so 01-50 4? a30. a5 - PA ATr? 4,2..15 iI )ea .450 . t. CA.V033 P-* aW09 I pz o+ d Q, d? ? ?, xx U 00 ? ? ?? '?, p O Ud 0 d ?o ? a ?, d ? r ©?, az. Qo oa xz, Z d O ? ? ?` Wo ? z U O ? U ?p ? ? ,..7 "??,. V? W a' ?x ?,?o x? ?? o ?? ? ° ? -o 7 ? i"- N 9 ? ? W W 7 ? ? po ?, O °' ? u' O J a3? 3 ?" ? ? N ?, ? ? wNd d W `" U 0 v w? o? ?? O ° ,?-, ??w ?"' o? w ? ? o a w ? ?, ?© W? w ? ? 7 ?? ? a? mow` ??? ?? 3 ?, ?. ? N O v s ''' d ? ? w PHEI,AN HALLINAN & SCHMIEG, LLP Allison F. Wells, Esq., Id. No.309519 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION Plaintiff V. Attorneys for Plaintiff : COURT OF COMMON PLEAS : CIVIL DIVISION NO.: 12-2737-CIVIL-TERM : CUMBERLAND COUNTY JEFFREY L. FOYMOYER Defendant(s) c F'?1' .. CERTIFICATION U, The undersigned attorney hereby states that he/she is the attorney for the Plaintiff e matter and that the premises are not subject to the provisions of Act 91 because: a'0 55; z the mortgage is an FHA Mortgage (X) the premises is non-owner occupied the premises is vacant Act 91 procedures have been fulfilled w a ?ov .. orr, co = Act 91 is Not Applicable pursuant to Pa Bulletin, Doc No 11-1197, 41 Pa.B. 3943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unswom falsification to authorities. By: / ?llinan & Schmieg, LLP son F. Wells, Esq., Id. No.309519 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION Plaintiff v JEFFREY L. FRYMOYER Defendant(?I,s) COURT OF COMMON PLEAS CIVIL DIVISION NO.: 12-2737-CIVIL-TERM CUMBERLAND COUNTY PHS # 279096 AFFIDAVIT PURSUANT TO RULE 3129.1 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION SBIM TO CHASE HOME MORTGAGE CORPORATION, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 97 QUEEN AVENUE, ENOLA, PA 17025-2338. ,", 1. Name and address of Owner(s) or reputed Owner(s): Name Address (if address cannot be reasonably rn ascertained, please so indicate) " G7 -0m th < W A JEFFREY L. FRYMOYER 312 PINEWOOD DRIVE ? - CAMP HILL, PA 17011-6527 xr ?. Name and address of Defendant(s) in the judgment: to Name Address (if address cannot be reasonably -? ascertained, please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment cre ditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) LVNV FUNDING LLC EDWIN A. ABRAHAMSEN & ASSOC IATES, C/O MICHAEL F. RATCHFORD, ESQUIRE P.C. 120 NORTH KEYSER AVENUE SCRANTON, PA 18504 LVNV Funding, LLC 15 South Main Street, Suite 500 Greenville, SC 29601 Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT Domestic Relations of Cumberland County 97 QUEEN AVENUE ENOLA, PA 17025-2338 13 North Hanover Street Carlisle, PA 17013 Commonlwealth of Pennsylvania Department of Welfare Internal Revenue Service Advisory U.S. Department of Justice U.S. Attorney for the Middle District of PA Federal Building P.O. Box 2675 Harrisburg, PA 17105 1000 Liberty Avenue Room 704 Pittsburgh, PA 15222 228 Walnut Street, Suite 220 PO Box 11754 Harrisburg, PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: Phelan & Sc mieg, LLP Allison F. Wells, Esq., Id. No.309519 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION Plaintiff V. JEFFREY L.IFRYMOYER Defendant(s) TO: ALL PANTIES IN INTEREST AND CLAIMANTS COURT OF COMMON PLEAS CIVIL DIVISION NO.: 12-2737-CIVIL-TERM CUMBERLAND COUNTY NOTICE OF SHERIFF'S SALE = 40 r-. -" OF REAL PROPERTY z c CIO - Owner(s): JEFFREY L. FRYMOYER :rr, a Property: 97 QUEEN AVENUE ?d 3 ° ENOLA, PA 17025-2338 , ;- rn Improvements:' Residential dwelling ca Judgment amount: $20,909.88 The above-captioned property is scheduled to be sold at the CUMBERLAND County Sheriffs Sale on 12/05/2012 in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 at 10:00 AM. Our recprds indicate that you may hold a mortgage, judgment, or other interest with respect to the property which'' may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale.', Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to C NTACT YOUR OWN ATTORNEY as we are not permitted to give you legal advice. LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro, County of Cumberland and Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point on the northern side of Queen Avenue (50 feet wide) at the southeastern corner of Lot No. 13 on the hereinafter mentioned Plan of Lots; thence along Lot No. 13 North 09 degrees 22 minutes 30 seconds West a distance of 140 feet to a point; thence North 80 degrees 37 minutes 30 seconds East a distance'of 20 feet to a point; thence by Lot No. 15 on said Plan South 09 degrees 22 minutes 30 seconds East a distance of 140 feet to a point on Queen Avenue; thence by Queen Avenue South 80 degrees 37 minutes 30 seconds West a distance of 20 feet to a point, the place of BEGINNING. HAVING THEREON ERECTED a townhouse. BEING Lot No. 14 on a Final Subdivision Plan No. 2 for Robert D. and Donna R. Leisenring, his wife, made January 17, 1980 and February 13, 1980 by D. P. Raffensperger Associates and recorded in the Cumberland County Recorder's Office in Plan Book 37, Page 98. TITLE ,-0 SAID PREMISES VESTED IN Jeffrey L. Frymoyer, single man, by Deed from Gerald W. Hottinger and Barbara J. Nelson, h/w, dated 05/22/1986, recorded 05/22/1986 in Book X!i, 31, Page 61. PREMISES BEING: 97 QUEEN AVENUE, ENOLA, PA 17025-2338 PARCEL NO. 09-13-1002.325 PHELAN HALLINAN & SCHMIEG, LLP Melissa J. Cantwell, Esq., Id. No.308912 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 ~~ ~~ G ~~ ~~~ -~~ o -_ ~ _ . Attorney for Plaintiff `~ w ° ~_S IN THE COURT OF COMMON PLEAS ~~ G OF CUMBERLAND COUNTY, PENNSYLVANIA ~ JPMORGAN CHASE BANK, NATIONAL CUMBERLAND COUNTY ~ ASSOCIATION SB/M TO CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN COURT OF COMMON PLEAS MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION CIVIL DIVISION Plaintiff, , v. JEFFREY L. FRYMOYER Defendant(s) No.:12-2737-CIVIL-TERM AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.1(a) Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c) on each of the persons or parties named, at that address, set forth on the Affidavit and as amended if applicable. A copy of the Certificate of Mailing (Form 3817) and/or Certified Mail Return Receipt stamped by the U.S. Postal Service is at hed h eto E ' elissa J. Cantwell, Esq., 0.308912 ~o~ 3 Q ZQ~Z Attorney for Plaintiff Date: IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the niaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PHS # 279096 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION S/B/M TO CHASE HOME MORTGAGE CORPORATION Plaintiff v. JEFFREY L. FRYMOYER Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION N0.:12-2737-CIVIL-TERM CUMBERLAND COUNTY PHS # 279096 AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION S/B/M TO CHASE HOME MORTGAGE CORPORATION, Plaintiff in the above action, by the undersigned attorney, sets forth as of the date the Praecipe for the Writ of Execution was filed, the following information concerning the real property located at 97 QUEEN AVENUE, ENOLA, PA 17025-2338. Name and address of Owner(s) or reputed Owner(s): Name 2. 3. JEFFREY L. FRYMOYER SAME AS ABOVE Name and address of Defendant(s) in the judgment: Name Address (if address cannot be reasonably ascertained, please so indicate) 312 PINEWOOD DRIVE SHIREMANSTOWN, PA 17011-6527 Address (if address cannot be reasonably ascertained, please so indicate) Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address (if address cannot be reasonably ascertained, please indicate) LVNV FUNDING LLC C/O MICHAEL F. RATCHFORD, ESQUIRE LVNV FUNDING, LLC EDWIN A. ABRAHAMSEN & ASSOCIATES, P.C. 120 NORTH KEYSER AVENUE SCRANTON, PA 18504 15 SOUTH MAIN STREET, SUITE 500 GREENVILLE, SC 29601 4. Name and address of last recorded holder of every mortgage of record: Name Address (if address cannot be reasonably ascertained, please indicate) None. Name and address of every other person who has any record lien on the property: Name Address (if address cannot be reasonably ascertained, please indicate) EAST PENNSBORO TOWNSHIP 98 SOUTH ENOLA DRIVE ENOLA, PA 17025 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address (if address cannot be reasonably ascertained, please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which ma be affected by the sale: y Name Address (if address cannot be reasonably ascertained, please indicate) TENANT/OCCUPANT 97 QUEEN AVENUE ENOLA, PA 17025-2338 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE, PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O. BOX 2675 DEPARTMENT OF WELFARE HARRISBURG, PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH, PA 15222 U.S. DEPARTMENT OF JUSTICE 228 WALNUT STREET, SUITE 220 U.S. ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG, PA 17108-1754 FEDERAL BUILDING I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: NOV 3 0 2071 By: Phelan Hallman Melissa J. Cantwell, Esq., Id. No.308912 Attorney for Plaintiff +~s', m ~. o~~ ~' ~, ~~v, ~~ ~, . ~~~ ~~ .___y~.. ~~ ~ ~. aooa2'r~ o~ ~~2 ~~.~ -s a w ~. c.. N ,,,,. C.. ~. R ~~ ~' ?, _~ ~F L. ?~. If t 4 iF %~ • 1 fC G ti ~, ~ ,~ „~" N `kf ~ C ~1 ~ ~S ~ CO '~ ~ Q! ~ , C~ W ~ ~ ~!. j r,+ ~ ~ ~ ~, 116 v^ ~ p e'+ '~ e ~ ra n' n '~r ~C ; ~. ,fit. ~+ +OC- ~• ~~NpO 7 ~ i ~r.4I ~, ~` T` ~ ~ ~ e . ~ ~ ~ a - ~ ~ ~~ ~ ~ ~ c ~~' ~ {~ ~ ' ' ~ 'A ~ ~ d ~ ~ ~ ~ . * ~ '~' ~ ~ ~ 7t Q ~. ~ ~' ~ ~ ~ ~ i ~ cC~ 7- ..< ~ ~ .. ~ ~ 9' a R7 ~ ~ a ~ ..., n ~ , ~~ ~; .... ». '~ ~ ~ ~~~ i >>~ .~, ~~ ~ ~t Q{ R ~ 'c ~. L1 ~ 8 /~ ~~ _ .. _.. ~~ 8 M u+ ~ t' jai ~ ~ vii vie ~ ~ rn . ~ ~ £ O i~ ~. '~QtY~dZ' ~ tF~ilYl~ 2i.Q+L t+6c33S F3Z1.[Zt+QOtl ~~ ~ i~'4i LQ u MMIII g~ i._. ~~TT ____...._._~ _, O ~~ a. ~ ! 1 ~ ~ ~ ~ ~_ ~.v~~ x~ ~¢ .Q' R ~ ~. ^c ~ ~. ~ A S°. A ~, ~~ o~ ~,~' ~~ ro A ~ o r- o ..~ ;~ fi 7 i h ,`3 .~~. n s ~ + i ~,. ~ * '~ ~. ~ ' rt ~ * cap ~ ~,: .. ~. ~ ~ ~, ~ ~ 1t ' ~ A ~ 1 i+ : . ~ Tl .-. . 1.~ ; ~ ' ~ " ~ ~ ~ ~ ~ ~ ~ C!J ~ ~ t f y~} YwA k F V ~ L7 ~j ~ G ~ ~ ~ ~ ~ ~ ~ ~ ~ '+f ~ v+t R ~ ..~, ~ ~ ~ +r P n ~' ~' d ~~ ~ ~ ~ ~ ~ ~ . . ~ ~ ~ ,~ '~ ~ ~ Q.'~S~ ~, ' ~ , ~ ..: ~ ~ , ti ~~. ~ ~ a ~;' ~ ~, } .~~~ .~ a ~ ~ t ~~~ - t "'~$ ~~~ ~. ~ A. ~ ~ ~~~ ~~ ~~n~ C ,d .~ A S- A, t-. d ~ n s ~'~Mr+wr ~~ ~ ~ ~Qa42~72~g 3f 2fltZ °~4!''~'CtlCM~ t 8143 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson i..'! „_�, rr Sheriff _ u Jody S Smith Chief Deputy 20!3 JU'l —6 A 1 i 11 : 12 Richard W Stewart " ('!���gg,,@@ �^ /� t� (` pp���jj Solicitor OFFICEOF THE'.,RERIFF C�,il'1(B,�BLA14D CCOU € Y PENNSYLYAMA JP Morgan Chase Bank, NA vs. Case Number Jeffrey L. Frymoyer 2012-2737 SHERIFF'S RETURN OF SERVICE 09/27/2012 07:26 PM -Deputy Shawn Gutshall, 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 97 Queen Avenue, East Pennsboro Township, Enola, PA 17025, Cumberland County. 10/04/2012 12:51 PM -Deputy Ronald Hoover, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personally handing a true copy to a person representing themselves to be the Defendant,to wit: Jeffrey L. Frymoyer at 312 Pinewood Drive, Lower Allen Township Annex, Camp Hill, PA 17011, Cumberland County. 12/05/2012 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 2/6/2013 02/04/2013 As directed by Daniel Schmieg, Attorney for the Plaintiff, Sheriffs Sale Continued to 4/3/2013 04/03/2013 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, Room 303, Carlisle, PA on April 3, 2013 at 10:00 a.m.. He sold the same for the sum of$51,000.00 to Steve Moyer of Moyer and Pletcher Development Group, LLC, on behalf of Kristi Toohey, 156 Creekside Drive, Enola, PA 17025 being the buyer in this execution, paid to the Sheriff the sum of$ 04/26/2013 Proposed Schedule Of Distribution Posted on 4/26/13 05/10/2013 Distribution of Schedule as Proposed on 5/10/13 SHERIFF COST: $2,267.81 SO ANSWERS, '°`---`- May 10, 2013 RbNW R ANDERSON, SHERIFF `7 0 p� �. a as sz) (c)CountySuite Sheriff,'releocoft,Inc. ,M J Proposed SCHEDULE OF DISTRIBUTION Date Filed: April 26, 2013 Writ No. 2012-2737 Civil Term JPMorgan Chase Bank, National Association, S/B/M to Chase Home Finance LLC, S/B/M to Chase Manhattan Mortgage Corporation, S/B/M to Chase Home Mortgage Corporation Vs Jeffrey L. Frymoyer 97 Queen Avenue Enola, PA 17025 Sale Date: April 3, 2013 Buyer: Moyer and Pletcher Development Group, LLC Bid Price: $ 51,000.00 Total Due Per Order of Court to Re-Assess Damages: $ 30,136.61 DISTRIBUTION: Receipts: Cash on Account (09/10/2012): $ 1,500.00 Cash on Account (04/03/2013): 5,100.00 Cash on Account (04/19/2013): 49,400.00 Total Receipts: $ 56,000.00 Disbursements: Sheriffs Costs $ 1,967.81 Legal Search 300.00 Transfer Tax (Local) 1,090.00 Transfer Tax (State) 1,090.00 Debbie Lupold East Pennsboro Township Tax Collector 352.18 (2013 Spring Taxes) East Pennsboro Township 2,256.70 Attorney Joseph Schalk 1,500.00 LVNV Funding, LLC, c/o Atty Michael F. Ratchford 3,880.87 JPMorgan Chase Bank, National Association, S/B/M to 30,136.31 Chase Home Finance LLC, S/B/M to Chase Manhattan Mortgage Corporation, S/B/M to Chase Home Mortgage Corporation Jeffrey L. Frymoyer 13,426.13 Total Disbursements: ($56,000.00) Balance for distribution: 00.00 So Answers: Ronny R. Anderson Sheriff JPMORGAN CHASE BANK, NATIONAL COURT OF COMMON PLEAS ASSOCIATION S/B/M TO CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CIVIL DIVISION CORPORATION S/B/M TO CHASE HOME MORTGAGE CORPORATION NO.: 12-2737-CIVIL-TERM Plaintiff , V. CUMBERLAND COUNTY JEFFREY L. FRYMOYER PHS #279096 Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE LLC,SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION SB/M TO CHASE HOME MORTGAGE CORPORATION,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 97 QUEEN AVENUE,ENOLA,PA 17025-2338. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained,please so indicate) JEFFREY L. FRYMOYER 312 PINEWOOD DRIVE CAMP HILL,PA 17011-6527 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) SAME AS ABOVE 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) LVNV FUNDING LLC EDWIN A. ABRAHAMSEN& ASSOCIATES, C/O MICHAEL F. RATCHFORD,ESQUIRE P.C. 120 NORTH KEYSER AVENUE SCRANTON,PA 18504 LVNV Funding, LLC 15 South Main Street,Suite 500 Greenville,SC 29601 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) None. 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained, please indicate) None. 6. Name and'address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address(if address cannot be reasonably ascertained,please indicate) None. 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 97 QUEEN AVENUE ENOLA,PA 17025-2338 Domestic Relations of 13 North Hanover Street Cumberland County Carlisle,PA 17013 Commonwealth of Pennsylvania P.O. Box 2675 Department of Welfare Harrisburg,PA 17105 Internal Revenue Service Advisory 1000 Liberty Avenue Room 704 Pittsburgh,PA 15222 U.S. Department of Justice 228 Walnut Street,Suite 220 U.S. Attorney for the Middle District of PA PO Box 11754 Federal Building Harrisburg,PA 17108-1754 I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: Phelan & Sc mieg, LLP Allison F. Wells,Esq., Id.No,309519 Attorney for Plaintiff JPMORGAN CHASE BAND,NATIONAL ASSOCIATION COURT OF COMMON PLEAS S/B/M TO CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION S/B/M TO CIVIL DIVISION CHASE HOME MORTGAGE CORPORATION Plaintiff NO.: 12-2737-CIVIL-TERM V. JEFFREY L. FRYMOYER CUMBERLAND COUNTY Defendant(s) TO: ALL PARTIES IN INTEREST AND CLAIMANTS NOTICE OF SHERIFF'S SALE OF REAL PROPERTY Owner(s): JEFFREY L. FRYMOYER Property: 97 QUEEN AVENUE ENOLA,PA 17025-2338 Improvements: Residential dwelling Judgment amount: $20,909.88 The above-captioned property is scheduled to be sold at the CUMBERLAND County Sheriffs Sale on 12/05/2012 in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 at 10:00 AM. Our records indicate that you may hold a mortgage,judgment, or other interest with respect to the property which may be extinguished by the sale. You may wish to attend the sale to protect your interests. A schedule of Distribution will be filed by the Sheriff on a date specified by the Sheriff not later than 30 days after sale. Distribution will be made in accordance with the schedule unless exceptions are filed thereto within 10 days after the filing of the schedule. If you have any questions regarding the type of lien or the effect of the Sheriffs Sale upon your lien, we urge you to CONTACT YOUR OWN ATTORNEY as we are not permitted to give you legal advice. JPMORGAN CHASE BANK,NATIONAL ASSOCIATION COURT OF COMMON PLEAS S/B/M TO CHASE-HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION S/B/M TO CIVIL DIVISION CHASE HOME MORTGAGE CORPORATION NO.: 12-2737-CIVIL-TERM Plaintiff VS. CUMBERLAND COUNTY JEFFREY L. FRYMOYER Defendant(s) NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: JEFFREY L. FRYMOYER 312 PINEWOOD DRIVE CAMP HILL,PA 17011-6527 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house(real estate)at 97 QUEEN AVENUE,ENOLA,PA 17025-2338 is scheduled to be sold at the Sheriff's Sale on 12/05/2012 at 10:00 AM in the Cumberland County Courthouse,South Hanover Street, Carlisle,PA 17013 to enforce the court judgment of$20,909.88 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE LLC,S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION S/B/M TO CHASE HOME MORTGAGE CORPORATION (the mortgagee)against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one, the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFFS SALE DOES TAKE PLACE. 1. If the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10) days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 LEGAL DESCRIPTION ALL THAT CERTAIN piece or parcel of land situate in the Township of East Pennsboro,County of Cumberland and Commonwealth of Pennsylvania,more particularly bounded and described as follows,to wit: BEGINNING at a point on the northern side of Queen Avenue(50 feet wide)at the southeastern corner of Lot No. 13 on the hereinafter mentioned Plan of Lots;thence along Lot No. 13 North 09 degrees 22 minutes 30 seconds West a distance of 140 feet to a point;thence North 80 degrees 37 minutes 30 seconds East a distance of 20 feet to a point;thence by Lot No. 15 on said Plan South 09 degrees 22 minutes 30 seconds East a distance of 140 feet to a point on Queen Avenue;thence by Queen Avenue South 80 degrees 37 minutes 30 seconds West a distance of 20 feet to a point,the place of BEGINNING. HAVING THEREON ERECTED a townhouse. BEING Lot No. 14 on a Final Subdivision Plan No.2 for Robert D. and Donna R.Leisenring,his wife,made January 17, 1980'and February 13, 1980 by D.P. Raffensperger Associates and recorded in the Cumberland County Recorder's Office in Plan Book 37,Page 98. TITLE TO SAID PREMISES VESTED IN Jeffrey L. Frymoyer, single man, by Deed from Gerald W. Hottinger and Barbara J. Nelson, h/w, dated 05/22/1986, recorded 05/22/1986 in Book X 31, Page 61. PREMISES BEING: 97 QUEEN AVENUE,ENOLA,PA 17025-2338 PARCEL NO.09-13-1002.325 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-2737 Civil COUNTY pF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due JPMORGAN CHASE BANK,NATIONAL ASSOCIATION s/b/m to CHASE HOME FINANCE LLC,s/b/m to CHASE MANHATTAN MORTGAGE CORPORATION s/b/m to CHASE HOME MORTGAGE CORPORATION, Plaintiff(s) From JEFFREY L. FRYMOYER (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: $20,909.88 L.L.: Interest from 7/12/12 To Date of Sale($3.44 per diem) -- $505.68 Atty's Comm: % Due Prothy:$2.25 Atty Paid: $230.25 Other Costs: Plaintiff Paid: Date: 8/31/12 David D. Buell,Prothonotary ] (Seal) �- Deputy REQUESTING PARTY: Name: ALLISON F.WELLS,ESQUIRE Address:PHELAN HALLINAN&SCHMIEG,LLP TRUE CiGf -`I ;yz��g:l RECORD 1617 JFK BOULEVARD,SUITE 1400 In Testimony whereof, i here unto set my hand and the seal of said Cou at Carlisle,Pa. PHILADELPHIA,PA 19103 This 3�s+ day of 20--Attorney for: PLAINTIFF Prothonotary Telephone: 215-563-7000 Supreme Court ID No.309519 i On September 10, 2012 the Sheriff levied upon the defendant's interest in the real property situated in East Pennsboro, Cumberland County, PA, known and numbered 97 Queen Avenue, Enola, PA 17025 fully described on Exhibit "A" filed with this writ and by this reference incorporated herein. Date: September 10, 2012 Claudia Brewbaker, Real Estate Coordinator 01 :11 d h- d3S MZ JJW3HS 3Hi '0 CUMBERLAND LAW JOURNAL Writ No. 2012-2737 Civil Term JP MORGAN CHASE BANK,NA VS. JEFFREY L. FRYMOYER Atty.: Daniel Schmieg By virtue of a Writ of Execu- tion NO. 12-2737-CIVIL-TERM, JP- MORGAN CHASE BANK,NATIONAL ASSOCIATION s/b/m TO CHASE HOME FINANCE LLC, s/b/m TO CHASE MANHATTAN MORTCAGE CORPORATION s/b/m TO CHASE HOME MORTGAGE CORPORA- TION vs. JEFFREY L. FRYMOYER, owner(s) of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumberland County, Pennsylvania, being 97 OUEEN AVENUE, ENOLA, PA 17025-2338. Parcel No. 09-13-1002-325. Improvements thereon:RESIDEN- TIAL DWELLING. JUDGMENT AMOUNT: $20,909- .88. 41 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: October 26, November 2 and November 9, 2012 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 Coyn4 Editor SWORN TO AND SUBSCRIBED before me this 9 day of November, 2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY IC My commission Expires Apr 28,2014 The Patriot-News Co. 2020 Tlachnology Pkwy the r10 )w ews Suite 300 Mechanicsburg, PA 17050 Now you know Inquiries - 717-255-8213 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 Holly Blain, 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. PUBLICATION COPY This ad ran on the date(s)shown below: 10/26/12 2012-2737 Civil Term P MORGAN CHASE BANK,NA r 11/02112 VS. JEFFREY L.FRYMOYER 11/09/12 Atty-. Daniel Schmieg By virtue of a Writ of Execution NO. 12-2737-CIVIL-TERM . . . . . ... JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE LLC,S/B/M Sworn a d s scribed be e S 19 y of ovember, 2012 A.D. TO CHASE MANHATTAN MORTCAGE CORPORATION SIBIM TO CHASE HOME MORTGAGE CORPORATION V& JEFFREY L FRYMOYER Notary Public owner(s)of property situate in the TOWNSHIP OF EAST PENNSBORO, Cumberland County,Pennsylvania,being (Municipality) 97 OUEEN AVENUE,ENOIA 17025-2338 COMMONWEALTH OF PENNSYLVANIA Parcel No.09.13-1002-325 Notarial Seal (Acreage i or street address) Sherrie L.Owens,Notary Public Improvements thereon:RESIDENTIAL Lower Paxton Twp.,Dauphin County DWELLING My Commission Expires Nov 26,2015 JUDGMENT AMOUNT-$20,909-88 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND }SS: 1, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that the Sheriff's Deed in which Kristi Toohey is the grantee the same having been sold to said grantee on the 3rd day of April A.D., 2013, under and by virtue of a writ Execution issued on the 31 st day of Au ust, A.D., 2012, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 2737, 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 s/b/m to Chase Home Morwage Corporation against Jeffrey L. Frymoyeer is duly recorded as Instrument Number 201318604. IN TESTIMONY WHEREOF, I have hereunto set my hand and al of said office this day of A.D. Recorder of Deeds R der of Cumberland County,Carlisle,PA My commiss fires the Fast Monday of Jan.2014