HomeMy WebLinkAbout12-2951IN THE COURT OF COMMON PLEAS OF CUMBERLAND C'OUNTI' PENNSYLVANIA
CIVIL DIVISION -`
JPMORGAN CHASE BANK, ,
NATIONAL ASSOCIATION, s/b/m/t
CHASE HOME FINANCE LLC, s/b/m/t NO.: /a d?5? CI V1 ?T?1WI - -
Chase Manhattan Mortgage Corporation,
Plaintiff, TYPE OF PLEADING:
VS.
CIVIL ACTION-COMPLAINT
IN MORTGAGE FORECLOSURE
MOHAMMED R. DAVOOD and
FATH IMA Z. DAVOOD,
Defendants.
TO DEFENDANTS
You are hereby notified to plead to the ENCLOSED
COMPLAINT WITHIN TWENTY (20) DAYS
FROM SERVICE HEREOF
ATTOR EY FOR PLAINTIFF
I HEREBY CERTIFY THAT THE ADDRESS
OF THE PLAINTIFF IS:
I I 1 I Polaris Parkway
Columbus, OH 43240
FILED ON BEHALF OF PLAINTIFF:
JPMorgan Chase Bank, National
Association, s/b/m/t Chase Home Financc
LLC, s/b/m/t Chase Manhattan Mortgage
Corporation
COUNSEL OF RECORD FOR TI-IIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
Brian M. Kile, Esquire
Pa. I.D. #89240
AND THE DEFENDANTS IS
4195 Nantucket Drive
Mechanicsburg, PA 17050
ATTORNEY FOR PLAINT IFF - -
CERTIFICATE OF LOCATION
I HEREBY CERTIFY THAT THE LOCATION OF
THE REAL ESTATE AFFECTED BY THIS LIEN IS
4195 Nantucket Drive
Hampden Twp.
(CITY, BORO, TOWNSHIP,WARD)
ATTORN Y FOR PLAINTIFF 4
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION, s/b/m/t
CHASE HOME FINANCE LLC, s/b/m/t NO.:
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
MOHAMMED R. DAVOOD and
FATHIMA Z. DAVOOD,
Defendants.
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against the claim set forth in the
following pages, you must take action within twenty (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with the
court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the case may proceed without you and a judgment may be entered against you by the
court without further notice for any money claimed in the complaint or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BEI.OVI'.
THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A L.?WYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE;
TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFFR
LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
*********************
Cumberland County Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166 or Toll Free (800) 990-9108
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
CIVIL DIVISION
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION, s/b/m/t
CHASE HOME FINANCE LLC, s/b/m/t NO.:
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
MOHAMMED R. DAVOOD and
FATHIMA Z. DAVOOD,
Defendants.
CIVIL ACTION - COMPLAINT IN MORTGAGE FORECLOSURE
JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t
Chase Manhattan Mortgage Corporation, by its attorneys, Grenen & Birsic, P.C., files this
Complaint in Mortgage Foreclosure as follows:
1. The Plaintiff is JPMorgan Chase Bank, National Association, s/b/m't Chase I lome
Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, which has its principal place of
business at 1111 Polaris Parkway, Columbus, OH 43240 and is authorized to do business in the
Commonwealth of Pennsylvania.
?. The Defendants, Mohammed R. Davood and Fathima Z. Davood, are individuals
whose last known address is 4195 Nantucket Drive, Mechanicsburg, Pennsylvania 17050.
3. On or about July 2, 2003, Defendants executed a Note in favor of Washington
Savings Bank, FSB ("WSB") in the original principal amount of $114,700.00. A true and
correct copy of said Note is marked Exhibit "A," attached hereto and made a part hereof
4. On or about July 2, 2003, as security for payment of' the aforesaid Note,
Defendants made, executed and delivered to WSB a Mortgage in the original principal amount of
$114,700.00 on the premises hereinafter described, said Mortgage being recorded in the Office
of the Recorder of Deeds of Cumberland County on July 10, 2003, at Mortgage Book: Volume
1822, Page 357. A true and correct copy of said Mortgage containing a description of' the
premises subject to said Mortgage is marked Exhibit "B," attached hereto and made a part hereof.
5. WSB assigned the aforesaid Mortgage to Chase Manhattan Mortgage Corporation
pursuant to the terms of a certain Assignment of Mortgage recorded in the office of the Recorder
of Deeds of Cumberland County on April 21, 2004, at Mortgage Book Volume 707, Page 2909.
A true and correct copy of said Assignment is marked Exhibit "C," attached hereto and made a
part hereof.
6. Defendants are the record and real owners of the aforesaid mortgaged premises.
7. Defendants are in default under the terms of the aforesaid Mortgage and Note for,
inter alia, failure to pay the monthly installments of principal and interest when due. Defendants
are due for the August 1, 2010 payment.
8. On or about November 5, 2010, Defendants were mailed combined Act 91 and
Act 6 Notices, in compliance with the Homeowner's Emergency Mortgage Assistance Act, Act
91 of 1983 and Act 6 of 1974. 41 P.S. 101, et seq.
9. The following amounts are due to Plaintiff on the Mortgage as of February 28,
2011:
Principal $102,987.93
Interest from 7/1/10 through 2/28/11 $ 4,1 19.52
Late Charges $ 218.54
Escrow Deficiency $ 662.29
Corporate Advances $ 28.00
Attorneys' Fees $ 650.00
Foreclosure Costs $ 342.00
TOTAL $1 09,008.28
WHEREFORE, Plaintiff demands an in rem judgment against the Defendants in the sum
of $109,008.28, together with interest, costs, fees, and charges collectible under [he note and
mortgage including but not limited to attorneys fees and costs. and for the tbreclosurc and sale of
the mortgaged property.
GRENEN & BIRSIC, P.C.
BY: ?>C c
Kristine M. Anthou, Esquire
Attorney for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281 7650
THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION
OBTAINED WILL BE USED FOR THAT PURPOSE.
EXHIBIT "A"
NOTE Loan ID II
Multistate FHA. Case No
July 2nd, 2003 Camp Hill, PENNSYLVANIA
I Date 1 I Cayl [State]
4195 Nantucket Drive, Mechanicsburg, PENNSYLVANIA 17050
(Property Addrensl
1. PARTIES
"Borrower" means each person signing at the end of this Note, and the person's successors and assigns. "Lender"
Ineatls The Washington Savings Bank, FSB
and its successors and assigns.
2. BORROWER'S PROMISE TO PAY; INTEREST
In return for a loan received from Lender, Borrower promises to pay the principal sum of one Hundred
Fourteen Thousand Seven Hundred- - - - - - - - - - - - - - - - - - - -- - Dollars
(U.S. $ 114, 700. oo ) plus interest, to the order of Lender. Interest will be charged on unpaid principal, from
the date of disbursement of the loan proceeds by Lender, at the rate of Six
percent ( 6.000 %) per year until the full amount of principal has been paid.
3. PROMISE TO PAY SECURED
Borrower's promise to pay is secured by a mortgage, deed of trust or similar security instrument that is dated the
same date as this Note and called the "Security Instrument." The Security Instrument protects the Lender from losses
which ought result if Borrower defaults under this Note.
4. MANNER OF PAYMENT
(A) Time
Borrower shall make a payment of principal and interest to Lender on the first day of each month beginning on
September 1st, 2003 Any principal and interest remaining on the first day of August, 2033
will be due on that date, which is called the "Maturity Date."
(B) Place
Payment shall be made at 4201 Mitchellville Road, Ste. 300, Bowie, Maryland 20716
or at such place as Lender may designate in writing by notice to Borrower.
(C) Amount
Each monthly payment of principal and interest will be in the amount of U.S. $ 687.69 This amount will
be part of a larger monthly payment required by the Security Instrument, that shall be applied to principal, interest and
other items in the order described in the Security Instrument.
(D) Allonge to this Note for Payment Adjustments
If an allonge providing for payment adjustments is executed by Borrower together with this Note, the covenants of
the allonge shall be incorporated into and shall amend and supplement the covenants of this Note as if the allonge were a
part of this Note. [Check applicable box]
? Graduated Payment Allonge ? Other [specify)
? Growing Equity Allonge
5. BORROWER'S RIGHT TO PREPAY
Borrower has the right to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the
first day of any month. Lender shall accept prepayment on other days provided that Borrower pays interest on the
amount prepaid for the remainder of the month to the extent required by Lender and permitted by regulations of the
Secretary. If Borrower makes a partial prepayment, there will be no changes in the due date or in the amount of the
monthly payment unless Lender agrees in writing to those changes
6. BORROWER'S FAILURE TO PAY
(A) Late Charge for Overdue Payments
If Lender has not received the full monthly payment required by the Security instrument, as described in Paragraph
4(C) of this Note by the end of Fifteen calendar days after the payment is due, Lender may collect
a late charge in the amount of Your percent ( 4.000 %) of the overdue
amount of each payment.
(B) Default
If Borrower defaults by failing to pay in full any monthly payment, then Lender may, except as limited by
regulations of the Secretary in the case of payment defaults, require immediate payment in full of the principal balance
remaining due and all accrued interest. Lender may choose not to exercise this option without waiving its rights in the
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event of any subsequent default. In many circumstances regulations issued by the Secretary will litnit Lender's rights to
require immediate payment in full in the case of payment default,,. This Note does not authorize acceleration when not
permitted by HUD regulations. As used in this Note, "Secretary" means the Secretary of Housing and Urban
Development or his or her designee
(C) Payment of Costs and Expenses
If Lender has required immediate payment in full, as described above, Lender may require Borrower to pay costs
and expenses including reasonable and customary attorneys' fees for enforcing this Note to the extent not prohibited by
applicable law. Such fees and costs shall bear interest from the date of disbursement at the same rate as the principal of
this Note.
7. WAIVERS
Borrower and any other person who has obligations under this Note waive the right, of presentment and notice of
dishonor "Presentment" means the right to require Lender to demand payment of amount., due. "Notice of dishonor"
means the right to require Lender to give notice to other persons that amount., due have not been paid.
9. MING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to Borrower under this Note will be
given by delivering it or by nailing it by first class mail to Borrower at the property address above or at a different
address if Borrower has given Lender a notice of Borrower's different address
Any notice that must be given to Lender under this Note will be given by first class [nail to Lender at the address
stated in Paragraph 4(B) or at a different address if Borrower is given a notice of that different address.
9. OBLIGATIONS OF PERSONS UNDER THIS NOTE
It more than one person signs this Note, each person if fully and personally obligated to keep all of the promises
made in this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or
endorser of this Note is also obligated to do these things. Any person who takes over these obligation,, including the
obligations of a guarantor, surety or endorser of this Note, is also obligated to keep all of the promises trade in this
Note. Lender may enforce its rights under this Note against each person individually or against all signatories together.
Any one person signing this Note may be required to pay all of the amours owed under this Note.
BY SIGNING BELOW, Borrower accepts and agrees to the tern and covenants contained in this Note.
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(Seal)
aoh R. Davood -Borrower
(Seal)
-Borrower
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EXHIBIT "B"
1
RECORD A VD RI TURN TO
THE WASH INCT )N SAVINGS BANK, FSB
4201 MITCI TELL' ILLE ROAD, SUITE 300
BOWIE, Nil1 2071 ,
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ISlwce Alcove Tltic Line For Recording Dntal
COmmonwi :nith of Pennsylvania MORTGAGE
THIS t, IORT SAGE ("Security lastruureat") is given on July 2nd, 2003
Mohammed R. ',)avood and Fathima Z. Davood
! -- e; i P. ZIEGLE'
! .:30HER OF DEEDS
' ?ERLAND COUNTY
93 JUL 10 PM 12 30
FHA Casc No.
Loan ID NINUIRMID
The Mortgagor is
("Borrower ). Tl is Security Instrument is given to The Washington Savings Bank, FSB
, which is organized and existing under the laws of THE UNITED
STATES OF AK9R1CA and whose address is 4201 Mitchellville Road, Ste.
300, Bowie, .Maryland 20716 ("Lender"). Borrower owes lender the
principal su n of One Hundred Fourteen Thousand Seven Hundred and no/100- - - - - - - -
- - - - - - )ollars (U.S. S 114, 700.00 ). This debt is evidenced by Borrower's note dated the same
date as this Securty Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier,
due and pa)able co August 1st, 2033 . This Security Instrument set:ures to Lender: (a) the
repayment of the iebt evidenced by die Note, with interest, and all renewals, extensions and modifications of the Note;
(b) the payi ietit o f 811 other sums, with interest, advanced under paragraph 7 to protect the security of this Security
Instrument; and (() the perforniance of Borrower's covenants and agreements under this Security Instrument and the
Note. For his pt rpose, Borrower does hereby mortgage, grant and convey to the Lender the following described
property located i i Cumberland County, Pennsylvania:
See attached Exhibit "A"
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which has the address of
4195 Nantucket Drive,
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("Property Address");
Loan ID # Sow
Pennsylvania 17050
Izip CWCI
Mechanicsburg
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TOGETHER WITH all die improvements now or hereafter erected of die property, and all easements,
appurtenances and fixtures now or hereafter a part of die property. All replacements and additions shall also be covered
by this Security Instrument. All of die foregoing is referred to in this Security Instrument as the "Property."
BORROWER COVENANTS that Borrower is lawfully seized of tie estate hereby conveyed and has the right to
mortgage, grant and convey the Property and that the Property is unencumbered, except for encumbrances of record.
Borrower warrant.; and will defend generally the title to the Property against all claims and demands, subject to any
encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenant,; for national use and non-uniform covens;its.with
lin»ted variations by jurisdiction to constitute a uniform security instrument covering real property.
Borrower and Lender covenant and agree as follows:
UNIFORM COVENANTS.
1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and interest
on, the debt evidenced by the Note and late charges due under the Note.
2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly
payment, together with the principal and interest as set forth in die Note and any late charges, a sum for (a) taxes and
special a.C;esslnents levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property,
and (c) premiums for insurance required under paragraph 4. In any year in which die Lender must pay a mortgage
insurance premium to the Secretary of Housing and Urban Development ("Secretary"), or in any year in which such
preutium would have been required if Lender still held die Security instrument, each nunthly payment stall also include
either: (i) a sum for the annual mortgage insurance premium to be paid by Lender to die Secretary, or (ii) a monthly
charge instead of a mortgage insurance premium if this Security Instrument is held by die Secretary, in a reasonable
amount to be determined by die Secretary. Except for die mouldy charge by die Secretary, these items are called
"Escrow Items" and the sums paid to Lender arc called "Escrow Funds."
Lender may, at any tine, collect and hold amounts for Escrow Items in an aggregate anxmnt not to exceed the
maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act
of 1974, 12 U.S.C. Section 2601 et seq. and implementing regulations, 24 CFR Part 3500, as they may be amended
from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated disbursement:
or disbursements before the Borrower's payments are available in die account may not be based on amounts due for the
i mrtgage insurance prenmium.
If die amounts held by Lender for Escrow Items exceed the anxoun; penmitted to be held by RESPA, Lender shall
account to Borrower for the excess funds as required by RESPA. If die amnunc; of funds held by Lender at any time
are mot sufficient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to rnake dp
the shortage as permitted by RESPA.
The Escrow Funds are pledged as additional security for all suns secured by this Secutiry Instrument. If Borrower
tenders to Lender the full payment of all such sums, Borrower's account shall be credited with die balance remitting for
all installment itenns (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become
obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior to
a foreclosure sale of die Property or its acquisition by Linder, Borrower's account shall be credited with any balance
remaining for all installments for items (a), (b), and (c). F
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3. Application of Payments. All paynamts under paragraphs 1 and 2 shall be applied by Lender as folCAws:
f LM, to lie mortgage insunn" premium to be paid by Lender to the Secretary or to the monthly charge by the
Secretary instead of the monthly mortgage insurance preinium;
Second, to any taxes, special assessments, leaselrild payments or ground rents, and fire, flood and otter hazard
insurance premiums, as required;
Third, to interest due under the Note;
Fourth, to amortization of the principal of the Note; and
Fifth, to late charges due under the Note.
4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements oil the Property, whether
now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which
Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires.
Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against
loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by
Lander. The insurance policies and any renewals shall be held by Lender and shall include loss payable clauses in favor
of, and in a fornh acceptable to, Lender.
In the event of loss, Borrower shall give Lender imnncdiate notice by mail. Lender may make proof of loss it' not
nude promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment
for such loss directly to Leader, instead of to Borrower and to Lender jointly. All or any pan of the insurance proceeds
may be applied by Lender, at its option, either (a) to die reduction of the indebtedness under die Now and this Security
Instrument, tint to any delinquent amounts applied in the order in paragraph 3, and then to prepayment of principal, or
(b) to the restoration or repair of the damaged Property. Any application of die proceeds to the principal shall not
extend or postpone die due date of die monthly paynreuts which are referred to in paragraph 2, or change the annount of
such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the
Note and diis Security Instrument shall be paid to the entity legally entitled thereto.
Iii the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishes the
indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser.
5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application;
Leaseholds. Borrower shall occupy, establish, and use die Property as Borrower's principal residence within sixty days
after die execution of this Security Instrument (or within sixty days of a later sale or transfer of the Property) and shall
continue to occupy die Property as Borrower's principal residence for at least one year after the date of occupancy,
unless Lender determines that requirement will cause undue hardship for Borrower or unless extenuating circumstances
exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower
shall not commit waste or destroy, damage or substantially change die Property or allow the Property to deteriorate,
reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan
is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower
shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information
or statements to Lender (or failed to provide Lender with any material information) in connection with die loan
evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of die Property
as a principal resideoce. If this Security Instrument is oil a leasehold, Borrower shall comply with tie provisions of the
lease. If Borrower acquires fee title to the Property, the leasehold and tee title shall not be merged unless Lender agrees
to the merger in writing.
6. Condemnation. The proceeds of any award or slain for damages, direct or consequential, in connection with
any condemnation or other taking of any part of die Property, or for conveyance in place of condemnation, are hereby
assigned and shall be paid to Lender to the extent of the full anaunt of the indebtedness that remains unpaid under the
Note and dais Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the Note
and this Security hnstrunhent, first to any delinquent amounts applied in die order provided in paragraph 3, and then to
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prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of
the mondily payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess
proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall
be paid to the entity legally entitled thereto.
7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all
governmental or municipal charges, tines and impositions that are not included in paragraph 2. Borrower shall pay these
obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lender's
interest in die Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these
payments.
If Borrower fails to make these payments or the payments required by paragraph 2, or fails to perform any other
covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly
affect Lender's right,; in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or
regulations), then Lender ntay do and pay whatever is necessary to protect die value of the Property and Leader's rights
in the Property, including payment of taxes, hazard insurance and other items mentioned in paragraph 2.
Any an?ouim disbursed by Lender under this paragraph shall become an additional debt of Borrower and be secured
by this Security Instrument. These amounts shall bear interest from the date of disbursement, at the Note rate, and at
the option of tinder, shall be immediately due and payable.
Borrower shall promptly diu:harge any lien which has priority over this Security Instrument unless Borrower: (a)
agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Linder; (b) contests in
good faith die lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion
operate to prevent die enforcement of the lien; or (c) secures from the holder of the lien an agreement satisfactory to
Lender subordinating the lien to this Security Instrument. If Lender detern»nes that any part of the Property is subject
to a lien which may attain priority over this Security Instrument, Lender nay give Borrower a notice identifying the lien.
Borrower shalt satisfy the lien or take one or inure of die actions set forth above within 10 days of the giving of notice.
8. Fees. Lender may collect fees and charges authorized by the Secretary.
9. Grounds for Acceleration of Debt.
(a) Default. Linder may, except as limited by regulations issued by the Secretary, in the case of payment
defaults, require immediate payment in full of all sums secured by this Security Instrument ir:
(i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument
prior to or on the due date of die next monthly payment, or
(ii) Borrower defaults by failing, for a period of thirty days, to perfom? any other obligations contained in
this Security Instrument.
(b) Sale Without Credit Approval. Linder shall, if permitted by applicable law (including Section 341(d) of
the Gam-St. Gernhain Depository Institutions Act of 1982, 12 U.S.C. 1701j-3(d)) and with die prior approval of
the Secretary, require immediate payment in full of all sinus secured by this Security Instrument if:
(i) All or part of die Property, or a beneficial interest in a trust owning all or pan of the Property, is sold
or otherwise transferred (other than by devise or descent), and
(ii) The Property is not occupied by die purchaser or grantee as his or her principal residence, or the
purchaser or grantee does so occupy the Property but his or her credit has tint been approved in accordance
with die requl remetim of the Secretary.
(c) No Waiver. If circumstances occur that would permit Lender to require immediate paymnut in full, but
Lender does not require such payments, Lender does not waive its rights with respect to subsequent events.
(d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secretary will limit
Lender's rights, in die case of payment defaults, to require immediate payment in full and foreclose if not paid.
This Security Instrument does not authorize acceleration or foreclosure if not permitted by regulations of the
Secretary. F's'
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(e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined
to be eligible for insurance under the National Housing Act widen 60 days front the date hereof, Lender may, at
its option, require immediate payment in full of all surns secured by this Security Instrument. A written
statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining
to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility.
Notwithstanding the roregoing, this option may not be exercised by Lender when the unavailability of insurance
is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary.
10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full because
of Borrower's failure to pay an antourn due under the Note or this Security Instrument. This right applies even after
foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all
amounts required to bring Borrower's account current including, to the extent they arc obligations of Borrower under
this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly
associated widh the foreclosure proceeding. Upon reinstatement by Borrower, this Security Instrument and the
obligations that it secures shall remain in effect as if Lender had not required immediate payment in full. However,
Lender is not required to permit reinstatement if: (i) Lender has accepted reinstatement after the commencement of
foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure proceeding,
(ii) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect
the priority of die lien created by this Security Instrument.
11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the tittle of payment or
modification of amortization of the sums secured by this Security instrument granted by Lender to any successor in
interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor in interest.
Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for
payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand
made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right
or remedy shall not be a waiver of or preclude the exercise of any right or remedy.
12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and agreements of
this Security instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the
provisions of paragraph 9(b). Borrower's covenants and agreements shall be joint and several. Any Borrower who
co-signs this Security Instrument but does not execute the Note: (a) is co-Signing this Security Instrument only to
nortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument, (b) is
not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other
Borrower may agree to extend, modify, forbear or make any accommodations with regard to the tennis of this Security
Instrument or die Note without that Borrower's consent.
13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by
mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the
Property Address or any other address Borrower designates by notice to Lender. Any notice to fender shall be given by
first class mail to tender's address stated herein or any address Lender designates by notice to Borrower. Any notice
provided for in this Security Instrument shall be deemed to have been given to Borrower or lender when given as
provided in this paragraph.
14. Governing Law; Severability. This Security instrument shall be governed by Federal law and the law of the
jurisdiction in which the Property is located. In the event that any provision or clause of this Security instrument or the
Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note
which can be given effect without the conflicting provision. To this end the
provisions of this Security Instrument and the Note are declared to be severable.
15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument.
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PAF115t: - 022520112 N ge 5 of x www.Morlragtilankih0a3yate0ns.conh
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16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of
any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting
the Property that is in violation of any Environmental Law. The preceding two sentences shall not apply to the
presence, use, or storage on the Property of small quantities of Hazardous Substances that
are generally recognized to be appropriate to normal residential uses and to maintenance of the Property.
Borrower shall promptly give Lender written notice of any investigation, clainh, demand, lawsuit or other
action by any governmental or regulatory agency or private party involving die Property and any Hazardous Substance
or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental
or regulatory authority, that any removal or other remediation of any Hazardous Substances affecting the Property is
necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law.
As used in this paragraph 16, "Hazardous Substances" arc those substances defined as toxic or hazardous substances
by Eavimninental Law and die following substances: gasoline, kerosene, other flammable or toxic petroleum products,
toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive
materials. As used in this paragraph 16, "Environmental Law" nheans federal laws and laws of the jurisdiction where
the Property is located that relate to health, safety or environmental protection.
NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows:
17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues of
die Property. Borrower authorims Lender or Lender's agents to collect die rents and revenues and hereby directs each
tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of
Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents
and revenues of the Property as trustee for the benefit of Leader and Borrower. This assigmment of rents constitutes an
absolute assignment and not an assigmment for additional security only.
If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as
trustee for benefit of Lender only, to be applied to the sans secured by the Security instrument; (b) Lender shall be
entitled to collect and receive all of doe rents of the Property; and (c) each tenant of the Property slhull pay all rents due
and unpaid to Lender or Lender's agent on Lender's written demand to the tenant.
Borrower has not executed any prior assignment of die rents and has not and will not perforn any act that would
prevent Lender front exercising its rights under this paragraph 17.
Lender shall not be required to enter upon, take control of or maintain the Property before or after giving notice of
breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is a breach. Any
application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This
assignment of rents of the Property shall terminate when die debt secured by the Security Instrument is paid in full.
18. Foreclosure Procedure. If Lender requires Immediate payment in full under paragraph 9, Lender ma)
foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred
in pursuing the remedies provided in this paragraph 18, including, but not limited to, attorneys' fees and costs of
title evidence.
If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires
immediate payment in full under paragraph 9, the Secretary may Invoke the nonjudicial power of sale provided in
the Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C. 3751 el seq.) by requesting a foreclosure
commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act.
Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under
this paragraph 18 or applicable law.
19. Release. Upon payment of all suns secured by this Security Instrument, dhis Security Instrument and the estate
conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy dhis Security
Instrument without charge to Borrower. Borrower shall pay any recordation costs. P--1 J
Initials: M Lb
PAR16G. - 02252002 Nge F of x www.M"rtgiageBankingSystems.com
BK 1822PG0362
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Loan ID N4MMOM
20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in
proceedings to enforce this Security Instrument, and hereby waives the benefit of any preseat or future laws providing
for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption.
21. Reinstatement Period. Borrower'; time to reinstate provided in paragraph 10 shall extend to Due hour prior to
the commencement of bidding at a sherifrs sale or other .sale pursuant to this Security Instrument.
22. Purchase Money Mortgage. If any of the debt secured by this Security Instrument is lent to Borrower to
acquire title to tie Property, this Security Instrument shall be a purchase money mortgage.
23. Interest Rate After Judgment. Borrower agrees that die interest rate payable after a judgment is entered on
the Note or in an action of mortgage foreclosure shall be the rate payable from time to time under the Note.
24. Riders to this Security Instrument. If one or more rides are executed by Borrower and recorded together
with this Security Instrument, die covenants of each such rider shall be incorporated into and shall amend and
supplement die covenants and agreements of this Security Instrument as if die rider(s) were a part of this Security
hhstrunhent. [Check applicable box(es)[
? Condominium Rider ? Growing Equity Rider ? Other [specify]
® Planned Unit Development Rider ? Graduated Payment Rider
BY SIGNIN BELOW, Borrower accepts and agrees to the terns contained in this Security Instrument and in any
rider(s) exec by Borrower and recorded with it. `
WItRCS: /' )??eo /_ ,(
_($Cdl)
ad R. Davood -Borrower
t:Q?14.« atYOOC.? _ (Seal)
Fathima Z. Davood Borrower
-Borrower
(Seal)
-Borrower
-Borrower
-Borrower
PAPIMC. - 022.52092 Page 7 of x %iviv.AfortgxgeBenkingSystems.com
8K 182 M0363
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Loan ID # qm?
Certirr to of Residence r
1, cillUJ C . f X11 r, + do hereby certify that the correct address of the within-
named Lender is, 4201 Mitehelly Ike Road, Ste. 300, Bowie, Maryland 20716
Witness my hand this 2nd day of July,
-Agent of Lender
COMMONWEALTH OF PENNSYLVANIA, CKn bQA' (d?,? County ss:
On this, 2nd day of July, 2003 before ntc, the undersigned officer, personally appeared
Mohammed R. Davood and Pathima Z. Davood
known to n1e (or satisfactorily proven) to be the person(s) whose mante(s) are sub::cribed to the within
instrument and acknowledged that THRY executed the saute for the purposes herein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My Conunission Expires:
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Title of Officer
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EXIHBZT «A)a
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ALL THAT CERTAIN lot or tract of ground situate in Hampden Township, Cumberland County,
pennsylvaata, more particularly bounded and described as follows, to wit:
BEOINNINO at a point on the southern right-OP MW line of Nantucket Drive at the northwest
corner of Lot No. 69; thence along said right-of waY line by a curve to the left, said curve
having a radius of 312 feet and an are distance of 40.77 feet to a point, being the northwest
corner of Lot No. 70; thence along Lot No. 70 and partly through a partition wall, South 24
degrees 27 minutes 40 seconds Fast, 152.47 feet to a point, being the southwest comer at Lot
No. 70; thence along the southern line of Lot No. 69, South 65 degrees 32 minutes 20 seconds
West, 20 feet to a point, being the southeast corner of Lot No. 66; thence along Lot No. 68 and
partly through a partition wall, North 24 degrees 27 minutes 40 seconds West, 176.88 feet to a
point, being the piece of BEGINNING.
CONTAiN1NO 3,691 square fat, tnore or less.
BEING Lot No: 69 on a plan of Beaumont Square, recorded In Plan Book 62, Page 51.
HAYINGTHEREON ERECTED a two•story dweiing known and numbered as 4195 Nantucket
Drive, Mechanicsburg, PennsyivaWa.
BKl.8*22PG0365
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PLANNED UNIT DEVELOPMENT RIDER
THIS PLANNED UNIT DEVELOPMENT RIDER is made this 2nd day of July, 2003 and
is incorporated into and shall be deemed to amend and supplement the Mortgage, Deed of Trust or Security Deed
("Security Instrument") of the same date given by the undersigned ("Borrower") to secure Borrower's Note ("Note") to
The Washington Savings Bank, FSB
("Lender") of the same date and covering the property described in the Security Imarument and located at:
4195 Nantucket Drive, Mechanicsburg, PENNSYLVANIA 17050
IPropeny Address]
The Property Address is a part of a planned unit development ("PUD") known as:
Beaumont Square
INanre of Planned Unit Development]
PUD COVENANTS. In addition to the covenants and agreements nude in the Security Instrument, Borrower and
Lender further covenant and agree as follows:
A. So long as the Owners Association (or equivalent entity holding title to common areas and facilities), acting as
trustee for the homeowners, maintains, with a generally accepted insurance carrier, a "[Waster" or "blanket" policy
insuring the property located in the PUD, including all improvements now existing or hereafter erected on the
mortgaged prenuses, and such policy is satisfactory to Lender and provides insurance coverage in the amounts, for
doe periods, and against the hazards Lender requires, including fire and other hazards included within the term
"extended coverage." and loss by flood, to the extent required by the Secretary, then: (i) Lender waives the
provision in Paragraph 2 of this Security Instrument for the monthly payment to Lender of one-twelfth of the yearly
premium installments for hazard insurance on the Property, and (ii) Borrower's obligation under Paragraph 4 of this
Security Instrument to maintain hazard insurance coverage on the Property is deemed satisfied to the extent that the
required coverage is provided by the Owners Association policy. Borrower shall give Leader prompt notice of any
lapse in required hazard insurance coverage and of any loss occurring from a hazard. In the event of a distribution
of hazard insurance proceeds in lieu of restoration or repair following a loss to the Property or to common areas and
facilities of die PUD, any proceeds payable to Borrower are hereby assigned and shall be paid to Lender for
application to the sums secured by this Security Instrument, with any excess paid to the entity legally entitled
thereto.
B. Borrower prontises to pay all dues and assessments imposed pursuant to the legal instruments creating and governing
the PUD.
C. If Borrower does not pay PUD dues and assessments when due, then Lender may pay them. Any amount,
disbursed by Lender under this paragraph C shall become additional debt of Borrower secured by the Security
Instrument. Unless Borrower and Lender agree to other terms of payment, these amounts shall bear interest from
FHA PUD Hider - 12195
Muttisme I I" Version Amended 1997
PAVQOC - 11221211112 Page I of 2 www.MortgageBnikingSystems.com
T Certify this to be recorded
Tn Cumberland County Pq
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Recorder of Deeds
BK i 822PGO366
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Loan ID #qmmm
die date of disbursement at the Note rate and shall be payable, with interest, upon notice from Lender to Borrower
requesting payment.
BY SIGNING BELOW, Borrower accepts and agrees to the temis and provisions contained in this PUD Rider.
(Seal)
Rob R. bavoo I -Borrower
Byu J cwwc? (Seal)
Fathima Z. Davood -Borrower
-Borrower
(Seal)
-Borrower
(Seal)
-Borrower
(Seal)
-Borrower
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BK 1822PG0367
EXHIBIT "C"
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ASSIGMWM OF MORTGAGE/DEED O r MST
1OR VALUE RECEIVED. THE WASENOTON SAVINGS BATIK, FSB, "Assignor", does hereby,
+vithout reeOutse, and without representation or warranty of arty Idt4 grant, b3 pk4 toll, "an transfer
:md set over unto Chase Muthw2 m? 'on and/ar =Rips. 0 Hark Blvd, Monagg Building 3 .1" Floor Suite 140 Jacksonville Florida 32256"Assigrtee", that armift MotrpgcMeed o;
'trust secured by the ptvpcM uitumd. in C umborl n Cp tyM Peoesy =ice as tlsr w described in
said Mortgege/Dctd of Tn4 wbichMedtgogbMeed of Trust hereby aasspotid is 11An pu-dcularly
identified by the Warne of tlse granton, Jett, original artwltat, tad recording retbrence as follows:
GRANTOWMORTGAGOR: Mobatntned R, Davood wd Fad?ima Z. 09vaod
GPANTSVMUSTEE:
MORTGAGEEMEMICM. . Dit washinaton Im inaR T32nk FSI3
DATE OF MORTGAG&DSED aF TRUST: rev?. 2003
OMOWAI, AMOUNT LEBEWFOLID =-CORD DAIT ?o 7?
n. ?
gt Jrq,?ncl.n0 1 2Z/ 57
'ITVW i'MhH- with nil rights nrir nnn mrrna5rAr nrrlFrlrlr Irl andt411ty iatflW I?ir'1 lilr; dll,.dl?lHof t,,. ,?} ?',
3ocurnents and rights relating to said Mortme/Deed of Trust,
,c s
N
See Exhibit "A" amwhcd hereto and made o part hereof,
Tex IDS 10-16-1058-146
The improvements thereon being knovM a6 4195 NanWY41 XkiVC. Mechanicsburg, PA 17030.
To have and to h,lJ wit, tlic *aid A944411. its 6ucrxaeore and assigns, subject, naverthelc5s, to
the equity of redemption of the acid Gran(or/Manpgor in said Mor4pseMeed of Tr-
IN WC"fl`'ESS WHEREOF, k Assignor has caused this Aesignment of MOrtga900ced of Tru$t
to be duly executed this 21 dey Of AuEust 2003.
TIE WASIENGTON SAVINGS BANK, FS13
S7'A'r)~ OF MARYLAND
COUNTY OF CALVERT,
on this Z2 d#y of As!= 2003. before me gvaB err la erioncd Be Rym For in
Public of the state of Maryland aforesaid sold for the COUNTY of Calvert residing thvrcin, personally
appeared Michelle IiaVa]Gttaii who actmowledged himselUberselfto be the Assistant StmaL _af ThA
Washinin n SuAnna Ratty-M), a corporation, and that he/she, as such Astisttmt Secretary, being
authorized to do so, excattte4 dte foregoing insttument bearing the data Of A 110M 12, 200 for the
purposes therein contained, by signing the name of the carpOMrICP t by ht11 sdl7lter a as 'sr W1 I,,,,.,;
R+ceraferlL PPN FQIyES++??
Sky PL 'c
IN WrrNPSS WMMBY, I hereunto net trig hand and official Seal-
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-$ MY ?NoloryPublic (5grv7,r Missioro .'•
M t'Amm1551on Expires: 51206 rr? n l '71--I4 r.?i n EXPIRES '
Y t? but 7 11" '. C •., 3126106
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Trag is to certify that this in6tYument has been prcpwcd under a supaMciob of the Washingro?ffr -" .e
Bank one of the imerrssted panics,
(I k1 b? _
Michele Waters, Assistant Secretory
hoof, 707 POP-969
THE WASHINGTON RAVINGS BANK
4201 Mft0holIviNe Road
suite Spa
Bowie, MD 20716-3167
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UB01MN1tt0 all M qk MtalhbO wl?ttal+tt0 aaa e<NNOKYN ?flr• at ala goM?wet
wa?dlr{ t70 tpoaea Nets` uld ef?E6wJ eq IYta by & aura to tb. lafk, mold ea,..
aaseiefItawltt f"kIOW-1 htuaauraWrou.aseal?wlw.,?.,sadeswasifei?••t
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tb# 701 fAMK1 G" On mud= one d4a do. N. grab 09 Moue as m6t.4.. w -0-44
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pwlfy tf Vao o aaf017aa Malt, NO &d" 4wm OY Owww 10 *~. WaL 11a,as twat w a
poCSC trlry me plow of afDgaip".
CO&TAWM 0.691 eadem k%% mate M LOL
' hwo let me. was a PL0 of IL-"wat aaaw., taeuled Is PAM SA a0, plop a1,
w?wNG TNa1tKMl Sett. rwo-.ee? d..?tind ?ns?++ ? ^"am? u f79d Nant+mros
Emwe., awhadaataa0, MOtOMAM,
1 4. i t *,JS L:.) be i-ecui-dcd
1:111d, COLIllty PA
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600 707 PACE P-910
Recorder, of Deeds
VERIFICATION
0'491rs , hereby states that he/she is of
JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance I.LC, s/b/m/t
Chase Manhattan Mortgage Corporation, Plaintiff in this matter, and is authorized to make
this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage
Foreclosure are true and correct to the best of my knowledge, information and belief.
The undersigned understands that this statement is made subject to the penalties of 18 Pa.
C.S. Sec. 4904 relating to unsworn falsification to authorities.
DATE: q[ c 2a`Z
File #,: 075-10663
Name:
Title: U( Le- PreS f J,,-?
Name: Davood
X14 y- 9 Pm is 31?;
FORM 1
Teen
'/?c??? a J
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
vs.
Deferdant(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 a lawyer 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 no 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 requested firancial 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 Concil ation 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 out 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 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 out
,easonable 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.
Respectfully submitted:
Date
Signature of Counsel for Plaintiff
FORM 2
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Date
Cumberland County Court of Common Pleas 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:
CUSTOMERIPRIMARY APPLICATION
Borrower name (s):
Property Address:
City:
Is the property for sale?
Yes ? No ? Listing date:
State: _ Zip:
Price: $
Realtor Name _ Realtor Phone:
Borrower Occapied: Yes ? No F
Mailing Address (if different)
City: State: Zip:
Phone Numbers: Home: Office: _
Cell: Other: _
Email:
# of people in household: How long?
CO-BORROWER
Mailing Address:
City: State: Zio:
Phone Numbers: Home: Office:
Cell: Other:
Email:
# of people in household: How long?
FINANCIAL INFORMATION
First Mortgage Lender:
Type of Loan: _
Loan Number: Date You Closed Your Loan:
Second Mortgage Lender:
Type of Loan:
Loan Number:
Total Mortgage Payments Amount: $ Included Taxes and 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:
Home: $ _
Other Real Estate: $ _
Retirement =unds: $
Investments: $
Checking: $
Savings: $ _
Other: $
Automobile #1: Model
Value:
Amount oweo:
Automobile #2: Model:
Amount owed:
Other transoortation (automobiles. boats, motorcvcles)
Year: Amount owed
Value:
Model:
Value:
Monthly Income
Name of Empioyers:
1.
2. --- -
3. _
Additional Income Description (not wages):
1. -- -- -- - -
2.
Borrower Pay Days:
Value:
Year.
Monthly Expenses: (Please only include expenses you are currently paving)
EXPENSE AMOUNT EXPENSE AMOUNT
_
Mortgage Food
_
2" ge Utilities _
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. (not covered)
Auto fuel/repairs Other Prop. Payment-
Instal I. Loan Payment Cable TV -
Child Support/Alim. Spending Money
Day/Child Care/Tuft. Other Expenses
Amount Available for Monthly Mortgage Payments Based on Income and 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
Monthly Gross
Monthly Gross
Monthly Gross
Monthly Amount:
Monthly Amount:
Co-Borrower Pay Days:
Fax:
Year:
Monthly Net
Monthly Net
Monthly Net
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!'
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name):
Phone:
Servicing Company (Name):
Contact: Phone: _
AUTHORIZATION
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
Borrower Signature Date
Please forward this document along with the following information to lender and
lender counsel:
V Proof on income!
V Past 2 bank statements
V Proof of any expected income for the last 45 days
V Copy of a current utility bill
V Letter explaining reason for delinquency and any supporting documentation
V (hardship letter)
Listing agreement (if property is currently on the market)
V Copy of 2 years of federal income tax returns
V Copy of deed
FORM 3
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
vs.
Defendant(s)
REQUEST FOR CONCILIATION CONFERENCE
Civil
Pursuant to the Administrative Order dated , 2012 governing the Cumberland
County Residential Mortgage Foreclosure Diversion Program, the undersigned hereby certifies as
follows:
1. Defendant is the owner of the real property which is the subject of this mortgage
foreclosure action;
2. Defendant lives in the subject real property, which is defendant's primary
residence;
3. Defendant has been served with a "Notice of Residential Mortgage Foreclosure Diversion
Program: and has taken all of the steps required in that Notice to be eligible to participate in a
court-supervised conciliation conference.
The undersigned verifies that the statements made herein are true and correct. I understand that
statements are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to
authorities.
Signature of Defendant's Counsel/Appointed Date
Legal Representative
Signature of Defendant
Signature of Defendant
Date
Date
FORM 4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff(s)
vs.
Defendant(s)
AND NOW, this day of
Civil
, 20 , the defendant/borrower in
the above-captioned residential mortgage foreclosure action having filed a Request for
Conciliation Conference verifying that the defendant/borrower has complied with the
Administrative Rule requirements for the scheduling of a Conciliation Conference, it is hereby
ORDERED AND DECREED that:
1. The parties and their counsel are directed to participate in a court-supervised
conciliation Conference on
at . M. in
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
2. At least twenty-one (21) days prior to the date of the Conciliation Conference, the
defendant/borrower must serve upon the Plaintiff/lender and its counsel a copy of the
"Cumberland County Residential Mortgage Foreclosure Diversion Program Financial
Worksheet" (Form 2) which has been completed by the defendant/borrower. Upon
agreement of the parties in writing or at the discretion of the Court, the Conciliation
Conference ordered may be rescheduled to a later date and/or the date upon which
CASE MANAGEMENT ORDER
service of the completed Form 2 is to be made may be extended. Upon notice to the
Court of the defendant/borrower's failure to serve the completed Form Z with the
time frame set forth herein or such other date as agreed upon by the parties in writing
or ordered by the Court, the case shall be removed from the Conciliation Conference
schedule and the temporary stay of proceedings shall be terminated.
3. The defendant/borrower and counsel for the parties must attend the Conciliation
Conference in person and an authorized representative of the plaintiff/lender must
either attend the Conciliation Conference in person or be available by telephone
during the course of the Conciliation Conference. The representative of the
plaintiff/lender who participates in the Conciliation Conference must possess the
actual authority to reach a mutually acceptable resolution, and counsel for the
plaintiff/lerder must discuss resolution proposals with the authorized representative
in advance of the Conciliation Conference. If the duly authorized representative of
the plaintiff/lender is not available by telephone during the Conciliation Conference,
the court will schedule another Conciliation Conference and require the personal
attendance of the authorized representative of the plaintiff/lender at the rescheduled
Conciliation Conference
4. At the Conciliation Conference, the parties and their counsel shall be prepared to
discuss and explore all available resolution options which shall include: bringing the
mortgage current through a reinstatement; paying off the mortgage; proposing a
forbearance agreement or repayment plan to bring the account current over time;
agreeing to tender a monetary payment and to vacate in the near future in exchange
for not contesting the matter; offering the lender a deed in lieu of foreclosure;
entering into a loan modification or a reverse mortgage; paying the mortgage default
over sixty months; and the institution of bankruptcy proceedings.
5. All proceedings in this matter are stayed pending the completion of the scheduled
conciliation conference.
BY THE COURT,
J.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
yat?tti,?p flt ??trr?t,tr/??b
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
L' 12 JUN I I P 2: 16
PENNSYLVANIA
JP Morgan Chase Bank, NA I Case Number
vs. 2012-2951
Mohammed R. Davood (et al.)
SHERIFF'S RETURN OF SERVICE
06/05/2012 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Fathima Zameena Davood, but was unable to locate
her 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 Fathima Zameena
Davood. Request for service at 4195 Nantucket Drive, Mechanicsburg, Pennsylvania 170$0 the
Defendant was not found. Deputies were advised, by real estate listing agent Fathima Zameena Davood
no longer resides at this address.
06/05/2012 Ronny R. Anderson, Sheriff, who being duly swom according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Mohammed R. Davood, 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 Mohammed R Davood.
Request for service at 4195 Nantucket Drive, Mechanicsburg, Pennsylvania 17050 the Defendant was not
found. Deputies were advised, by real estate listing agent Mohammed R. Davood has been hospitalized
for the past month.
SHERIFF COST: $84.00
June 06, 2012
(c) CountySuite Shel Teleosott, Inc.
SO ANSWERS,
/?Z ??aa-
RON R 'ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV.
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION, s/b/m/t
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
MOHAMMED R. DAVOOD and
FATHIMA Z. DAVOOD,
Defendants.
1.1 v 1L Ll v 131UIN N ' t E
c-
Mr
NO
20 v
i -=
-urn
.:
12-2951 70
° c.)
:3:c >--TI
Y
TYPE OF PLEADING zo a
G
MOTION FOR SERVICE OF
COMPLAINT IN MORTGAGE
FORECLOSURE PURSUANT TO
SPECIAL ORDER OF COURT
FILED ON BEHALF OF PLAINTIFF:
COUNSEL OF RECORD FOR THIS
PARTY:
Brian M. Kile, Esquire
Pa. I.D. # 89240
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV
JPMORGAN CHASE BANK, CIVIL DIVISION
NATIONAL ASSOCIATION, s/b/m/t
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation, NO.: 2012-2951
Plaintiff,
vs.
MOHAMMED R. DAVOOD and
FATHIMA Z. DAVOOD,
Defendants.
MOTION FOR SERVICE OF COMPLAINT IN MORTGAGE FORECLOSURE
PURSUANT TO SPECIAL ORDER OF COURT
AND NOW, comes the Plaintiff, JPMorgan Chase Bank, National Association
Chase Home Finance LLC s/b/m/t Chase Manhattan Mortgage Corporation, by and through
attorneys, GRENEN & BIRSIC, P.C., and files the within Motion for Service of Complaintlin
Mortgage Foreclosure Pursuant to Special Order of Court under Pennsylvania Rule of
Procedure 430 as follows:
1. On or about May 9, 2012, Plaintiff filed a Complaint in Mortgage Foreclo
against the Defendants, Mohammed R. Davood and Fathima Z. Davood, at the above-capti
number and term.
2. On or about May 9, 2012, Plaintiff delivered to the Sheriff of C
County a copy of the Civil Action - Complaint in Mortgage Foreclosure filed by Plaintiff at
above-captioned number and term along with direction cards requesting that the Defendants
served a copy of the Complaint at his last known address being 4195 Nantucket Dri`
Mechanicsburg, PA 17050.
3. On or about June 6, 2012, Plaintiff received Notices from the Cumberland Coun
Sheriffs Office indicating that attempts were made to serve the Defendants, Mohammed R.
Davood and Fathima Z. Davood, with a copy of the Complaint at their last known address bein;
4195 Nantucket Drive, Mechanicsburg, PA 17050 but there was no answer. A true and correct
copy of the Sheriff's return is marked as Exhibit "A", attached hereto and made a part hereof.
4. An Affidavit of the Plaintiff stating the nature and extent of the investigation
which has been made to determine the whereabouts of Defendants, Mohammed R. Davood an,
Fathima Z. Davood, and the reasons why service of the Complaint in Mortgage Foreclosure
cannot be made, is marked Exhibit "B", attached hereto and made a part hereof.
5. Pursuant to Cumberland County Local Rule 208.3(a)(2), no Judge has rulf
upon any other issue in this case or any related matter.
6. Pursuant to Cumberland County Local Rule 208.3(a)(9), the Defendants are prc
se and no attorney has entered an appearance of record on behalf of the Defendants.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court direct the She
of Cumberland County to serve Defendants, Mohammed R. Davood and Fathima Z. Davc
with the Complaint in Mortgage Foreclosure by posting a copy of the Complaint on the prope
at 4195 Nantucket Drive, Mechanicsburg, PA 17050 and permit the Plaintiff to serve
Defendants by mailing a true and correct copy of the Complaint in Mortgage Foreclosure
certified mail, return receipt requested and by First Class U.S. Mail, postage pre-paid to 41
Nantucket Drive, Mechanicsburg, PA 17050. Service of the Complaint shall be deemed
and valid upon posting by the Sheriff and mailing by the Plaintiff.
GRENEN & BIRSIC, P.C.
BY:
Brian M. Kile, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
EXHIBIT "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
?4,,ti?tit? u1 La[?nLM?4rb
t
JP Morgan Chase Bank, NA Case Numbe
VS .
Mohammed R. Davood (et al.) 2012-2951
SHERIFF'S RETURN OF SERVICE
06/05/2012 Ronny R. Anderson, Sheriff, who being duly swam according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Fathima Zameena Davood, but was unable to locat
her 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 Fathima Zame na
Davood. Request for service at 4195 Nantucket Drive, Mechanicsburg, Pennsylvania 17050 the
Defendant was not found. Deputies were advised, by real estate listing agent Fathima Zameena Dav ad
no longer resides at this address.
06/05/2012 Ronny R. Anderson, Sheriff, who being duly swam according to law, states that he made a diligent sei
and inquiry for the within named defendant to wit: Mohammed R. Davood, but was unable to locate hi
his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure and Notice of Reside
Mortgage Foreclosure Diversion Program as not found as to the defendant Mohammed R. Davood.
Request for service at 4195 Nantucket Drive, Mechanicsburg, Pennsylvania 17050 the Defendant was
found. Deputies were advised, by real estate listing agent Mohammed R. Davood has been hospitaliz
for the past month.
SHERIFF COST: $84.00 SO ANSWERS,
June 06, 2012 RON R ANDERSON, SHERIFF
in
not
(c) CountySuite Sheriff, Teleosoft, Inc.
EXHIBIT "B"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION, s/b/m/t
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
Plaintiff,
vs.
MOHAMMED R. DAVOOD and
FATHIMA Z. DAVOOD,
Defendants.
CIVIL DIVISION
NO.: 2012-2951
AFFIDAVIT PURSUANT TO PA. R.C.P. 430
COUNTY OF ALLEGHENY )
) SS
COMMONWEALTH OF PENNSYLVANIA )
Before me, a notary public, in and for the foregoing county and
personally appeared Brian M. Kile, Esquire, of GRENEN & BIRSIC, P.C. attorneys for
and deposes and says that the following accurately reflects efforts made to ascertain the ex
whereabouts of the Defendants named in the above-captioned matter:
(a) On June 7, 2012 , Plaintiff mailed to the United States Postmaster at
Mechanicsburg, PA 17050a request to be furnished with a forwarding
address of Defendants,
(b) On July 6, 2012, Plaintiff sent a second request to the United States
Postmaster at Mechanicsburg, PA 17050, but as of July 17, 2012
ff
has not received any response.
(c) Examinations were made of the Mechanicsburg Area Telephone
Directory; said examination indicated that the Defendants are listed at
4195 Nantucket Drive, Mechanicsburg, PA 17050.
(d) Examinations were made of the Cumberland County Voter Registration
Records; said examination failed to yield any useful information re
the whereabouts of Defendants.
(e) A computer records search of a nationwide database indicates that the
Defendants reside at 4195 Nantucket Drive, Mechanicsburg, PA 17050.
Finally, affiant deposes and says that after the foregoing investigation, the P
believes and avers that the Defendants, Mohammed R. Davood and Fathima Z. Davood,
4195 Nantucket Drive, Mechanicsburg, PA 17050.
GRENEN & BIRSIC, P.C.
BY: ALG
Brian M. Kile, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Sworn to an subscribed before me
this r 7 day of , 2012.
??1Totary Public
COMMONWEALTH OF PENNSYLVANIA
Notarial SW
Joanne M. Wehror, NOWY PAlic
City of Pittaburph, ANs? sa;?y 99i?nty
Mycommiseion gp?e, P?3x8
Membc•. PervriyPrlBrt?t ?,63"?^ ,_?. _
at
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION, s/b/m/t
CHASE HOME FINANCE LLC, s/b/m/t
Chase Manhattan Mortgage Corporation,
CIVIL DIVISION
NO.: 2012-2951
Plaintiff,
vs.
MOHAMMED R. DAVOOD and
FATHIMA Z. DAVOOD,
Defendants.
ORDER OF COURT
AND NOW, to wit, this
day of
2012,
consideration of the within Motion for Service of the Complaint in Mortgage Foreclosu
Pursuant to Special Order of Court, it is hereby ORDERED, ADJUDGED and DECREED th
the Sheriff of Cumberland County is hereby directed to serve Defendants, Mohammed
Davood and Fathima Z. Davood, with a true and correct copy of Plaintiffs Complaint
Mortgage Foreclosure by posting the property at 4195 Nantucket Drive, Mechanicsburg, P
17050 and Plaintiff is permitted to serve Defendants by certified mail, return receipt request(
and by First Class U.S. Mail, postage pre-paid at 4195 Nantucket Drive, Mechanicsburg, P
17050. Service on the Defendants shall be deemed complete and valid upon posting by tt
Sheriff and mailing by the Plaintiff.
BY THE COURT:
J.
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the within Motion
Service of the Complaint in Mortgage Foreclosure Pursuant to Special Order of Court and
of Court was mailed to the following on this 171 day of 7
2012, by first class, U.S. Mail, postage pre-paid:
Mohammed R. Davood
4195 Nantucket Drive
Mechanicsburg, PA 17050
Fathima Z. Davood
4195 Nantucket Drive
Mechanicsburg, PA 17050
GRENEN & BIRSIC, P.C.
B1.,
Brian M. Kile, Esquire
Attorneys for Plaintiff
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
z
JP MORGAN CHASE BANK, NATIONAL
ASSOCIATION, s/b/m/t CHASE HOME
FINANCE LLC, s/b/m/t Chase Manhattan
Mortgage Corporation,
Plaintiff
IN THE COURT OF COMMON PLEAS
THE NINTH JUDICIAL DISTRICT
V.
MOHAMMED R. DAVOOD and
FATHIMA Z. DAVOOD,
Defendants
NO. 2012-2951 CIVIL TERM
IN RE: MOTION FOR SPECIAL SERVICE
ORDER OF COURT
AND NOW, this ? day of January, 2012, upon consideration of PI
Motion for Service Pursuant to Special Order of Court, it is ordered and directed
service of Plaintiff's Complaint in Mortgage Foreclosure in this case upon
Defendants, Mohammed R. Davood and Fathima Z. Davood, may be made (1) by Fi
Class and Certified Mail, return receipt requested, no signature required, at the la
known address, 4195 Nantucket Drive, Mechanicsburg, PA 17050, service to be
complete upon mailing; (2) by posting a copy of the same on the most public porti
of the property located at 4195 Nantucket Drive, Mechanicsburg, PA 17050; and (3)
publication once in the Cumberland County Law Journal and once in a newspaper
general circulation in Cumberland County, Pennsylvania, in the form directed by
applicable Pennsylvania Rules of Civil Procedure and Cumberland County Rules
Procedure.
SUBSEQUENT papers may be served by first-class mail to Defendant at
aforesaid Nantucket Drive address, with service to be deemed complete upon mailing.
BY THE COURT,
Thomas A. Placey, C.P.J.
Distribution:
Brian M. Kile, Esq.
Grenen & Birsic, P.C.
One Gateway Center, Ninth Floor
Pittsburgh, PA 15222
For Plaintiff
? Mohammed R. Davood
4195 Nantucket Drive
Mechanicsburg, PA 17050
Defendant, pro se
N
C:i
G,
V Fathima Z. Davood
4195 Nantucket Drive
Mechanicsburg, PA 17050
Defendant, pro se
es &ta4 1,W
A`
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION, SB/M/T
CHASE HOME FINANCE LLC, S/B/M/T
CHASE MANHATTAN MORTGAGE
CORPORATION,
Plaintiff,
vs.
MOHAMMED R. DAVOOD AND
FATHIMA Z. DAVOOD,
CIVIL DIVISION
c
NO.: 2012-2951
=m
TYPE OF PLEADING -0
Zp
Praecipe to Reinstate Civil ActidW -• '?'
Complaint in Mortgage Foreclosure
FILED ON BEHALF OF PLAINTIFF:
Defendants. JPMorgan Chase Bank, National
Association, s/b/m/t Chase Home Finance
LLC, s/b/m/t Chase Manhattan Mortgage
Corporation
COUNSEL OF RECORD FOR THIS
PARTY:
Kristine M. Anthou, Esquire
Pa. I.D. #77991
GRENEN & BIRSIC, P.C.
One Gateway Center
Ninth Floor
Pittsburgh, PA 15222
(412) 281-7650
Qu{ell.ispd a?,\
eW- 9-79-7Y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA
JPMORGAN CHASE BANK, CIVIL DIVISION
NATIONAL ASSOCIATION, S/B/M/T
CHASE HOME FINANCE LLC, S/B/M/T
CHASE MANHATTAN MORTGAGE NO.: 2012-2951
CORPORATION,
Plaintiff,
vs.
MOHAMMED R. DAVOOD AND
FATHIMA Z. DAVOOD,
Defendants.
PRAECIPE TO REINSTATE CIVIL ACTION -
COMPLAINT IN MORTGAGE FORECLOSURE
TO:PROTHONOTARY
SIR/MADAM:
Kindly reinstate the Civil Action - Complaint in Mortgage Foreclosure with respect to the
above-referenced matter and mark the docket accordingly.
GRENEN & BIRSIC, P.C.
Kristine M. thou, Esquire
Attorneys for Plaintiff