HomeMy WebLinkAbout12-3107i
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
MICHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929
LESLIE RASE, ESQ., ATTORNEY I.D. NO. 58365 r'
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
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TELEPHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF ; CIVIL DIVISION
CUMBERLAND COUNTY
vs. ? No: 1 ?' 3Id7 ('lVi l
Travis A. Harper
561 Conodoguinet Avenue
Carlisle, PA 17015
Maygin E. Barbour
561 Conodoguinet Avenue
Carlisle, PA 17015
DEFENDANTS
COMPLAINT - CIVIL ACTION
MORTGAGE FORECLOSURE
NOTICE
YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE
FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND
NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILING IN
WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU
ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE
ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE
COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY
OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR
CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN
GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO
PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
169.1 Pd a
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Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION
PRACTICES ACT YOU ARE ADVISED THAT THIS LAW
FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY
INFORMATION OBTAINED WILL BE USED FOR THAT
PURPOSE.
NOTICIA
LE HAN DEMANDADO A USTED EN LA CORTE. SI USTED QUIERE
DEFENDERSE DE ESTAS DEMANDAS EXPUESTAS EN LAS PAGINAS SIGUIENTES,
USTED TIENE VIENTE (20) DIAS DE PLAZO AL PARTIR DE LA FECHA DE LA
DEMANDA Y LA NOTIFICACION. USTED DEBE PRESENTAR UNA APARIENCIA
ESCRITA O EN PERSONA O POR ABOGADO Y ARCHIVAR EN LA CORTE EN FORMA
ESCRITA SUS DEFENSAS O SUS OBJECIONES A LAS DEMANDAS EN CONTRA DE SU
PERSONA. SEA AVISADO QUE SI USTED NO SE DEFIENDE, LA CORTE TOMARA
MEDIDAS Y PUEDE ENTRAR UNA ORDEN CONTRA USTED SIN PREVIO AVISO O
NOTIFICACION Y POR CUALQUIER QUEJA O ALIVIO QUE ES PEDIDO EN LA
PETICION DE DEMANDA. USTED PUEDE PERDER DINERO O SUS PROPIEDADES O
OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE
ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO,
VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION
SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE
CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
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SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE, ATTORNEY I.D. NO. 78447
MICHAEL CLARK, ESQ., ATTORNEY I.D. NO. 202929
LESLIE RASE, ESQ., ATTORNEY I.D. NO. 58365
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association
PLAINTIFF
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
VS.
Travis A. Harper
561 Conodoguinet Avenue
Carlisle, PA 17015
Maygin E. Barbour
561 Conodoguinet Avenue
Carlisle, PA 17015
DEFENDANTS
NO:
COMPLAINT IN MORTGAGE FORECLOSURE
Plaintiff, JPMorgan Chase Bank, National Association, the address of which is, 3415
Vision Drive, Columbus, Ohio 43219, brings this action of mortgage foreclosure upon the
following cause of action:
1. (a) Parties to Mortgage:
Mortgagee: Mortgage Electronic Registration Systems, Inc., as nominee for
Sovereign Bank, its successors and assigns
Mortgagor(s): Travis A. Harper and Maygin E. Barbour
(b) Date of Mortgage: July 16, 2009
(c) Place and Date of Record of Mortgage:
Recorder of Deeds
Cumberland County
Document ID# 200933457
Date: September 29, 2009
The Mortgage is a matter of public record and is incorporated herein as provided
by Pa. R.C.P. No. 1019(g). A true and correct copy of the Mortgage is attached
hereto and marked as Exhibit "A" and incorporated herein by reference.
(d) Assignments:
Assignor: Mortgage Electronic Registration Systems, Inc., as nominee for
Sovereign Bank, its successors and assigns
Assignee: JPMorgan Chase Bank, National Association
Date of Assignment: February 27, 2012
Recording Date: March 8, 2012
Instrument No.: 201206927
2. Plaintiff is, therefore, either the original Mortgagee named in the Mortgage, the legal
successor in interest to the original Mortgagee, or is the present holder of the mortgage by
operation of law.
3. The real property which is subject to the Mortgage is generally known as 561
Conodoguinet Avenue, Carlisle, PA 17015 and is more specifically described as attached
as part of Exhibit "A".
4. Each Mortgagor named in Paragraph 1 executed a note as evidence of the debt secured by
the Mortgage (the "Note"). A true and correct copy of the Note is attached and marked as
Exhibit "B".
The names and mailing addresses of the Defendants are:
Travis A. Harper, 561 Conodoguinet Avenue, Carlisle, PA 17015
Maygin E. Barbour, 561 Conodoguinet Avenue, Carlisle, PA 17015
6. The interest of each individual Defendant is as Mortgagor, Real Owner, or both.
7. The Mortgage is in default because the monthly installments of principal and interest and
other charges stated below, all as authorized by the Mortgage, are due as of September 1,
2010 and have not been paid, and upon failure to make such payments when due, the
whole of the principal, together with charges specifically itemized below are immediately
due and payable.
8. The following amounts are due as of August 29, 2011:
Principal Balance Due $124,923.33
Interest Currently Due and Owing at 6% $8,090.97
From August 1, 2010 through August 29, 2011
Escrow Advances $2,374.20
Property Inspection $82.30
Property Preservation $793.00
TOTAL $136,263.80
9. Interest will continue to accrue each day that the debt remains unpaid, as well as other
expenses, costs and charges collectible under the Note and Mortgage.
10. In addition to the above amounts, reasonably incurred attorneys fees and costs as well as
proof of title in conformity with the mortgage documents and Pennsylvania law, shall be
sought by Plaintiff and included in any request for judgment.
11. Notice pursuant to the Homeowners' Emergency Mortgage Assistance Act of 1983, 35 P.S.
§ 1680.402c, et seg., was sent to each individual Mortgagor at their mailing address and/or
the mortgaged property address by first-class mail and certified mail. Copies of the material
part of the Notice are attached hereto as Exhibit "C" in accordance with Pa.R.C.P. 1019(i).
12. Pursuant Pa.R.C.P. 1019(d), the Notice sent to the Defendant(s) contains the information
required by the act of March 14, 1978 (P.L. 11, No. 6), 41 P.S. § 403 et seq., and separate
Notice of Intention to Foreclose is not required.
WHEREFORE, Plaintiff respectfully requests that this Court enter judgment in rem in
favor of Plaintiff and against Defendants, jointly and severally, in the amount set forth in
paragraphs 8 and 9, together with interest, attorneys' fees and for other expenses, costs, and
charges collectible under the Note and Mortgage and for the foreclosure and sale of the
mortgaged premises.
SHAPIRO & DeNARDO, LLC
Date:
BY:
Attorneys for Plaintiff
S & D File No. 11-039163
F?
n
Prepared By:
laeicti Merritt
101 S. rsarge Street
York, PA 17401
(717) 771-9430
Return To.
Sovoroign Bank, b CS-10-6432-C"
601 Penn Street
Reading, PA 19601
Parcel Number:
29-18-1384-005 6 005A
Premises:
561 Coriodoguinet Avenue
CarlisiS, PA 17015
ISpac, AbaVc 7bts Lice For Aeeordtae DsM1
DEFINITIONS PURL MUM >rsm y MORTGAGE MIN
Words used in multiple sections of this document are Mrsed below and other words are defined in
Sections 3, 11, 13, 18, 20 and 21. Certain rules regarding the usgo of words used in this document are
also provided in Section 16.
(A) "Security Instrument" means this document, which is dated July 16, 2009
together with all Riders to this document.
(B) "1orrower" Is Travis A Harper and Maygin E Barbour
Borrower is the mortgagor under this Security instrument.
(C) "MERS" 18 Mortgago Bleetronic Registration Systems, Ino. IvMRS is a separate corporation lost Is
acting solely as a nominea for Lander and LaWer's successors and assigns. MERS is the mortgagee
under this Security Instrument. MFRS is organized and existing under the laws of Delaware, and MYERS
1PBr ?rnnn • aeryo iamly . Fanaia M,mrraddia Mac UIIIFOAM 1116TRUM ST WWH MERS
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has a mailing address of P.O. Box 2026, Flint, Ml 48501-20And a street address of 3300 S.W. 34th
Avenue, Suitt 101, Ocala, FL 34474. The MFRS telephone aumber is (888) 679-MFRS.
(D) "Lender" is Rovoreign Ban);
Lender is a Bedeeal Savings Bank
organized and euistlng under the laws of The United States Qtf AmeziCa
Lendees address is 1120 Berkshire Blvd. , Wyomissing, PA 19610
(L) "Note" means the promissory note signed by Borrower and dated JULY 16, 2009
The Nore states that Borrower owes Lender one Hundred Twenty six Thousand Four
hundred $i.ghty And Zero/100 Dollars
(U.S. $126,490.00 ) plus interest. Borrower has promised to pay this debt In regular Periodic
Payments and to pay the debt In fall not later than August 01.1 2039
(p) 'Property" means the property that Is described below under the heading "Transfer of Rights In the
Property."
(C) "Loan" means the debt evidenced by the Note, plus interest, any prepayment charges and late charges
due under the Note, and all sums due under this SecurIty Instrument. plus Interest.
(H) "Rtlders" means all Riders to this Security instrument that are executed by Borrower. The following
Riders are to be executed by Borrower [cheek bon as applicable),
F 1 Adjustable Rate Rider H Condominium Rider Second Home Rider
Balloon Rider Punned Unit Developrncnt Rider P1.4 Family Rider
Q VA Rider [7 Biweekly Payment Rider Othcr(s) [specify)
(1) 'Applicable Law" means all controlling applicable federal, state and local statutes, regulations,
ordinances and administrdtive rules and orders (that have the effect of law) as well as all applicable final,
non1?ap opemmunity munlty As As judicial opinions.
opinions Daft, (,n Fees, and Assessments" means all dues, fives, ames,rruats and other
charges that are imposed an Borrower or the Property by a condominium assoeWon, homeowners
association or similar organi2stion.
(I) "Idtxtroalc Foods Transfer" means any transfer of funds, other than a transaction originated by
check, draft, or similar paper instrument, which id initiated through an electronic terminal, telephonic
instrument, computer, or magnetic tape so as to order, instruct, or authcebr a financial Institution to debit
or credit an scoounr. Such term includes, but fs not limited to, polnt-of'-sale transfers, automated teller
nwhine triweactiono, transfers initiated by telephone, wife transfers, end automated clearinghouse
transfers.
(L) "Escrow Items" means those items that are described In Section 3.
(K "Miscellaneous Proceeds" means any compemlion, settlement, award of damages, or proceeds paid
by any third party (other than insurance proceeds paid under the coverrtgcs described fn Section 5) for: 01
damage to, or destruction of, the Property; (ii) condemnation or other taking of all or any part of the
Property; (ill) conveyance in lieu of condemnation; or (iv) misrepresentations of, or omissions as to, the
-
value andlor condition of the Property.
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(N) "Mortgage Insurance" means insurance protecting Lender against the nonpayment of, or default on,
the Loan.
(O) "Periodic Payment" means the regularly scheduled amount due for (1) prlw ipal and interest under the
Note„ plus (ii) any-amounts under Section 3 of this Scoacity Instr a cont. lit (I) "RESPA" means the Rea] Estate Settltartent Procedures Act (12 U.S.Section ded frog.) and tits o
implementing ragulatian, Regulation X (24 C.E.R. Part 3504), as they might
time, or any additional. or successor le&ladon or regulation that governs the some subject matter. As used
In this Security Instrument, "RESPA" refers to all requirements and restrictions that are imposed In regard
to a "federally related mortgage loan" even if the Loan does not qualify as a "federally related mortgage
loan" under RESPA. that has taken tide to the Property, whether or
(Q) "Successor is Interest of Borrower" moans any party
not that party has assumed Borrower' s obligations under the Note and/or this Security Instrument.
TRANSFER OF RIGHTS IN THE PROPERTY
This Security Instrument secures to Lender: W the repayment of the Loan, and all renewals, extendons and
modifications of the Note; and (it) the performance of Borrower's covenants and agreements under this
security Instrument and the Note. For this purpose, Borrower does hemby mortgage, grant and oonvey to
MERS (solely as nominee for Lender end Lander's successors and assigns) and to the successors and
assigns of MFRS, the: following desoribed property located in the Country (Name o tuned in Jur ddicion]
of Cumberland
see Attached
which currently h=the address of 561 Conodogudnet Avenue ISpeetl
Carlisle (city], Pennsylvania 1703.5 (Zip Code]
("Property Address"):
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TOOETHBR WITH all the improvements now or hereafter erected on the Property. end all
casements, appurtenances, and fixtures now or hereafter a part of the property. All replacements and
additions shall also be covered by this Security instrument. All of the foregoing is refierred to In this
Security Instrument as•the "Property." Borrower understands and agrees that MFRS holds only legal title
to the interests granted by Burrower in this Security Instrument, but, if necessary to comply with law or
custom, MERS (as nominee for Lander and Lender's successors and assigns) has the tight. to exercise any
or all of those interests, including, but not limited to, the right to foreclose and sell the Props ; andi to
take any action required of Lender Including, but not limited to, releasing and eanrzling this Security
Instrument.
BORROWER COVENANTS that Borrower is lawfully seised of the estate hereby ? keyed n leas
unencumbered,
the right to mortgage, grant and convey the Property and that the Property
encumbrances of record. Borrower warrants and will defend generally the title to the Property against all
claims and demands, subject to any encumbrances of record.
THIS SECURITY INSTRUMENT combines uniform covenants for national use and non-uniform
covenants with limited variations by jurisdiction to constitute a uniform security Instrument covering real
property.
UNIFORM COVENANTS, Borrower and Lender covenant and agree as follows;
1. Payment of Principal, Interest, Escrow Item, Prepayment Charges, and Late Charges,
Borrower shall pay when due the principal of, acid interest on, the debt evidenced by the Note and any
prepayment charges and late charges due under the Note. Borrower shall also pay funds for Escrow Items
pursuant to S,xtion 3. Payments due under the Note and this Security Instrnaneat shall be trade in U.S.
currency. However, if any check or other hi utanent received by Lender as payment under the Note or this
Security Instrument is returned to Lender unpaid, Lender may require that any or all subsequent payments
due under the Note and this Security Instrument be made in ona or more of the following forms, as
selected by Lender-, (a) cash; (b) money order, (c) certified check, bank check, treasurer's check or
cashier's check, provided any such cheek is drawn upon an institution whose deposits are insured by a
federal agency, instrumentality, or entity; or (d) Electronic Funds Transfer.
Payments are deemed received by Lender when received at the location designated In the Note or at
such otter location as may be designated by Lender In accordance with the notice provisions in Section 1S.
Lender may return any payment or partial payment if the payment or pertdal payments are Insufficient to
bring the Loan current. Lender may accept any payment or partial payment insufficient to bring the Loan
current, without waiver of any rights hereunder or prejudice to its rights to raft= such payment or partial
payments in the future, but Lender is not obligated to apply such payments at the time such payments are
accepted. If each Periodic Payment is applied as of its scheduled due date, then Lender need not pay
interest on unapplied thirds. Lender may hold such unapplied funds until Borrower makes payment to bring
the Loan current. If Borrower does not do so withln a reasonable period of titae, Lender shall either apply
such funds or return them to Borrower. If floc applied earlier, such funds will be applied to the outstanding
principal balance under the Note immediately prior to foreclosure. No ofi et or claim which Borrower
might have now or In the future against Lender shall relieve Borrower from making payments due under
the Note and this Security lnstrument or performing the covenants and agreements secured by this Security
Instrument
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2. Application of payments or Proeaub. Except as otherwise described in this Section 2, all
payments accepted and applied by Lender shall be applied In the following order of priority: (a) interest
due under the Note; (b) principal due under the Note; (c) amounts due under Section 3. Such payments
shall be applied to each Periodic Payment in the order in which it became due. Any remaining amounts
shall be applied first to late charges, second to any other amounts due under this Security Instrument, and
than to reduce the prinolpal balance of the Note.
if Lender receives a payment from Borrower for a delinquent Periodic Payment which includes a
sufficient amount to pay any late charge due, the payment may be applied to the delinquent payment and
the late charge. If more than one Periodic Payment is outstanding. Lender may apply any payment received
from Borrower to the re payrwrit of the Periodic Payments If, and to the extent that, each payment
can be paid in full. To the extent that any excess exists after the payment is applied to the full payment of
one or more Periodic Payments, such excess may be applied to any late charges due, Voluntary
propuyments shall be applied first to any prepayment charges and then as described in the Note.
Any application of payments, Insurance proceeds, or Miscellaneous Proceeds to principal due under
the Note shall not extend or postpone the due date, or change the amount, of this Periodic Payments.
3. Funds for Escrow Rents. Borrower shall pay to Lender on the day Periodic Payments are due
under the Note, until the Note is paid in full, a sum (the "Funds") to provide for payment uorunt dgs, ue
for: (a) taxes and assessments and other items which can attain priority over Wit Security
lien or encumbrance on the Property; (b) lessehold payments or ground rents on the Property, If arty; (c)
premiums for any and all insurance required by Lander under Section 5; and (d) Mortgage of Mortgage
premiums, if any, or any sums payable by Borrower to Lender in lieu of the payment
Insurance premiums In accordance with the provisions of Section 10. These items are called "Escrow
Items." At origination or at any time during the term of the Loan. Lender may require that Community
Association Dues, Fees, and Assessments, if any, be escrowed by Borrower, and such dues, fees and
assessments shall be an Escrow Item. Borrower shall promptly fumish to fender all notices of amounts to
be paid under this Section. Borrower shall pay Lender the Funds for Escrow Items unless Lender waives
Borrower's obligation to pay the Funds for any or all Escrow Items. Lender may waive Borrower's
obligation to pay to Lender Funds for any or all Escrow Items at any time. Any such waiver may only be
In writing. In the event of such waiver, Borrower shell pay directly. when and where payable, the amounts
due fbr any Escrow Items for which payment of 17unds has been waived by Leader and, if Leader requires,
shall ibmish to Lender reeeipis evidenolog such payment within such time period as Lender may require.
Borrower's obligation to make such payments and to provide receipts shall for all purposes be deemed to
be a covenant and agreement contained In this Security Instrurwnt. as the phrase "covenant artd agreement"
Is used in Section 9. If Borrower is obligated to pay Escrow Items directly, pursuant Borrower fails to pay the amount due for an Escrow Item, Lender may exercise its rights tinder Section
9
and pay such amount and Borrower shall then be obligated under Section 9 to repay to Lender any such
amount. Lender may revoke the waiver os to any or all Escrow Items at any time by a notice given in
accordance with Section 15 and, upon such revocation, Borrower shall pay to Lender all funds, and in
such amounts, that are then required under this Section 3. FOR _
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Lender may, at any thee, collect and hold Funds in an amount (A) suffieitnt to permit Lender to apply
the Funds at the time specified under RBSPA, and (b) not to exceed the maximum amount a tender can
require under RESPA. Lender shall estimate the amount of Funds due an the basis of current data and
reosonable estimates of expenditures of fbtwa Escrow Items or otherwise in accordance with Applicable
Law.
The Funds shall be held in an Institution whose deposits arc insured by a federal agency,
Instrumattallty, or entity (including Lender, If Lender is an institution whose deposits are so insured) or in
any Federal Homy Loan Bank. Lender shall apply the Funds to pay the Escrow items to later than the time
specified under RESPA- Lender shall not charge Borrower for holding and applying the Funds, annually
onaly2ing the escrow account, or verifying the Escrow hems, unless Tender pays Borrower interest on the
Funds and Applicable Law permits Lender to make such a charges Unless an agreement is made in writing
or Applicable, Low requires interest to be paid on the Funds, Lender" not be required to pay Borrower
any interest or earnings on the Funds. Borrower and Lender can agree in writing, however, that interest
shall be paid on the Funds. Lender shall give to Borrower, without charge, an annual skswmdng of the
Funds as required by RBSPA.
If there is a surplus of Funds held in escrow, as defined under RBSPA, Lender shall account to
Borrower for the excess funds In accordance with RESPA. If there is a shortage of Funds held in escrow,
as defined under RESPA, Lender shall notify Borrower as required by MPA, and Borrower shall pay to
Lender the amount necessary to make up the shortage In accordmee with RESPA, but in no more then 12
monthly payments. If theta is n deficiency nd of Funds hold In Borrower decal cpay to Lender the row, as defined under FtMPnA, Lender m?ll
notify Borrower as required by MPA,
up the deficiency in accordance with tt.ESPA, but in uo more than 12 monthly payments.
Upon payment in fell of all sums secured by this Security 'Instrument, Lender shall promptly refund
to Borrower any Funds held by Lender.
4. Cpargar; Liens. Borrower shall pay all taxes, assessments, charges, fines, and Impositions
attributable to the Property which can attain priority over this Security Inarumenk leasehold payments or
ground rents on the Property, if any, and Community Association Dues, Pees, and Assessments, If any. To
the extent that these items are Escrow Items, Borrower shall pay them in the mamaer provided in Section 3.
Borrower shall promptly discharge arty lien which has priority over this Security Instrument unless
Borrower: (a) agrees in writing to the payment of the obligation scoured by the lien In a the len manner acre tabth
to Lender, but only so long as Borrower is performing such agrecm at; (b)lc Lender' s opinion nod tis to
by, or defends against enforcement of the lien in, legal proceedings which prevent the enforcement of the lien while those proceedings are pending, but only until such proceedings
are concluded: or (c) secures from the holder of the lien an agreement satisfactory to Lender subordinating
the lien to this Security Instrument. If Lender determines that any part of the Property is subject to a lien
which can attain priority over this Security Instrument, Lcnder my give Borrower a notice Identifying the
lien. Within 10 days of the date on which that notice is given, Borrower shall satisfy the lien or take one or
more of the actions set forth above in this Section 4.
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Lender may require Borrower to pay a one-lima charge for a real estate tax verification ond/or
reporting service used by Leader In connection with this Loan.
5. Property insurance, Borrower shall keep the Improvements now existing or hereafter erected on
the Property insured against loss by fire. hazards included widdn the term "extended coverage," and any
other hazards including, but not limited to, earthquakes and floods, for which Lender requires insurance.
This Insurance shall be maintained in the amounts (including deductible levels) and for the periods that
Lender requires. What Lender requires pursuant to the preceding sentences can change during the term of
the Loan. The insurance carrier providing the insurance shall be chosen by Borrower subject to Lender's
right to disapprove Borrower's ehotoe, which right shall not be exercised unreasonably. Lender may
require Borrower to pay, in connection with this .Loan, either! (a) a one-time charge for flood zone
determination, eardfrostion and trucking services; or (b) a one-time charge for flood zone detertnlnatlon
and certification services and subsequent charges each time ramappings or simiiar changes occur which
reasonably might afti'eet such determination or certification. Borrower shall also be responsible for the
payment of any fees imposed by the Federal Emergency Management Agency In connection with the
review of any flood zone determination resulting from an objection by Borrower.
It Borrower falls to maintain any of the coverages described above, Lender may obtain insurance
coverage, at Lender's option and Borrower's expense, Lender is under no obligation to purchase any
particular type or amount of coverage. Therefore, sucli coverage shat) cover Lender, but might or might
not protect Borrower, Borrower's equity in the property, or the contents of the Property, against any risk,
hazard or liability and might provide greater or lesser coverage than was previously in effect. Borrower
acknowledges that the oust of the insurance coverage so obtained tnlght significantly exceed the cost of
insurance that Borrower could have obtained. Any amounts disbursed by Lender under this Section 5 shall
become additional debt of Borrower secured by this Security Instrument. These amounts shall bear interest
at the Note rate from the date of disbursement and shall be payable, with such interest, upon notice from
tender to borrower requesting paymam,
All insurance policies required by Lender and renewals of such policies shall be subject to Lender's
right to disapprove such poliela. shall include a standard mortgage clause, and shall name Lender as
mortgagee and/or as an additional loss payee Lander shall have the right to hold the policies and renewal
certificates. If Gender requires, Borrower shall promptly give to Lender all receipts of paid premiums and
renewal notices, if Borrower obtains any form of Insurance coverage, not otherwise required by Lander,
for damage to, or destruction of, the Property, such policy shall Include a standard mortgage clause and
shall name Lander as mortgagee and/or as an additional loss paym
in the event of loss, Borrower slant give prompt notica to the insurance wrier and Lender. Lender
may make proof of loss if not made promptly by Borrower. Unless Leader and Borrower otherwise egret
in writing, any Insurance proceeds, whether or not the underlying insurance was required by Lender, shall
be applied to restoration or repair of the Property, if the restoration or repair is c onomically fcesible and
Lcttdee s security is not lessened. During such repair and restoration period, Luxkz shalt have the right to
hold such insurance proceeds until Lender has had an opportunity to inspect such Property to ensure the
work has been completed to Lender's satisfaction, provided that such inspection shall be undertaken
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promptly. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series
of progress payments as the work is completed. Unksa an agreement Is made in writing or Applicable Law
requires interest to be paid an sueb insurance proceeds, Lender shall not be required to pay Borrower any
interest or earnings on such proceeds. Pees for public adjusters, or other third parties, retained by
Borrower shall not be paid out of the insurance proceeds and shall be the sole obligation of Borrower. If
the restoration or repair is not economically feasible or Lenders tecurity would be lessened, the insurance
proceeds shall be applied tBorrower. uch Insuranthis Security Inowitem ce proceeds shall be applied In?the oor not rder provided Jforlin
paid
the excess, if any,
Section 2.
If Borrower abandons the Property, Lender may Este, negotiate and settle any available insurance
claim and related matters. If Borrower does not respond within 30 days to a notice from Lender that the
insurance carrier has offered to settle a oialm, then Landes may negodate and settle the claim. The 30-day
period will begin when the notice is given. In either event, or if Lender acquires the Property under
Section 22 or otherwise, Borrower hereby assigns to Lander (a) Borrower's rights to any insurance
proceeds in an amount not to exceed the amounts unpaid under the Note or this Security Instrument, and
(b) any other of Borrower's rights (other than the right to any refund of unearned premiaid the
$orrower) under all insurance policies covering the Property, insofar as such rights we applicable
coverage of the Property. Lender may use the Ineurance proceeds either to repair or restre time Property or
to pay amounts pnpaid under the Note or this Security Instrument whether or not thou due,
6. Occupancy. Borrower shall occupy, establish, and use the Property as Borrower's principal
realdenea within 60 days after the execution of this Security Instrument and shall continue to occupy the
Property as Borrower's principal residence for at least one year after the date of ocoupaaoy, unless Lender
otherwise agrees In writing, which consent shall not be unreasonably withheld, or unless extenuating
circumstarim exist which are beyond Borrower's control.
7. Preservation, Maintenance and Protection of the Property; Inspections. Borrower shall not
destroy, damage or impair the Property, allow the Properly to deteriorate or.oommit waste on the
Property. Whether or not Borrower Is residing in the Property, Borrower shall maintain the Property in
order to prevent the Property from deterioradng or decreasing in value due to its condition. Unless it is
determined pursuant to Section S that repair or restoreflon is not econotn-ccally feasible, Borrower shall
promptly repair the Property if damaged to avoid further deterioration or damage, If insurance or
condemnation proceeds are paid in connection with damage to, or the taking of the Property, Borrower
shall be responsible for repairing or restoring the Property only if Lender has released proceeds for such
purposes. Lender may disburse proceeds for the repairs and restoration in a single payment or in a series of
progress payments as the work is completed. If tho hisurance or condemnation proceeds am not sufficient
to repair or restore the Property, Borrower is not relieved of Borrower's obligation for the completion of
such repair or restoration.
Lender or its agent may make reasonable entries upon and inspeodons of the Property. If it has
reasonable cause, Lender may inspect the Interior of the improvootent o the Property. Lender bi ll give
Borrower notice at the time of or prior to such an interior inspection f mg such
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B. Borrower's Loan Application. Borrower shall be in default It during the Loon application
process, Borrower or any persons or entities acting at the direction of Borrower or with Borrower's
knowledge or consent gave materially false, misleading, or inaccurate information or statements to Lender
(or failed to provide Linder with materiel information) in connection with the Loan. Material
representations iclude, but are not limited to, representations concerning Borrower's occupancy of the
Property as Borrower's principal residenoe.
9. Protection of Leader's Interest in the Property and Rlghis Under this Security Instrument, If
(a) Borrower falls to perform the covmmts and agreements contained in this Security Instrument, (b) there
is a legal proceeding that might significantly affect Lender's Interest in the Property and/or rights under
this Security Instrument (such use proceeding in bankruptcy, probate, for condemnation or forfaiture, fbr
enforcement of a lien which may attain priority over this Security Instrument or to enforce laws or
regulations), or (o) Borrower bas abandoned the Property, then Lander may do and pay for whatever is
reasonable or appropelate to protect Lender's interest In the Property and rights under this Security
Instrument. hcluding protecting and/or assessing the value of the Property, and securing and/or repairing
the Property. Luotice a actions can include, but are not limited to; (a) paying any sums secured by a lien
which has priority over this Security Instrument; (b) appearing in court; and (e) paying reasonable
attorneys' fees to protect fit interest in the Property and/or rights under this Security Instrument, including
its secured position to a bankruptcy proccoding. Securing the Property includes, but is not limited to,
entering the Property to make repairs, change locks, replace or board up doors and windows, drain water
from pipes, eliminate building or other code violations or dangerous conditions, and have utilities turned
on or off. Although Lender may take action under this Section 9, Lender does no have to do so and is not
under any duty or obligation to do so. It is agreed that Lender incurs no liability for not taking any or all
actions authorized under this Sanction 9.
Any amounts disbursed by Lender under this Section 9 shall became additional debt of Borrower
secured b this Security disbursement and shell be payable, t with such interest, upon notice from Lender to Borrower requating
payment.
If this Security Instrument is on a leasehold, Borrower shall comply with all the provisions of the
lease If Borrower acquires fee title to the Property, the leasehold and the fee title shall not merge unless
Lender agrees to the morger in writing condition of making the Loan,
10. Mortgage 1<asuranee. If Lender required Mortgage Insurance ce as as a reason,
Mortgage shall pay the premiums required to maintain. the to be available ace con is dition from the o mortgage If, for tgage an reInssurer that
gorTower
she insurance coverage required by Lend. ceases
previously provided suoh Insurance and Borrower was required to make separately designated payments
toward the premiums for Mortgage insurance, Borrower shall pay the premiums required to obtain
coverage substantially equivalent to the Mortgage Inmranae previously in of ; at a cost substantially
equivalent to the cost to Borrower of the Mortgage Insurance previously in effbet, tow an alternate
mortgage Insurer selected by Lander. If substantially equivalent Mortgage Insurance coverage is not
available, Borrower shall continue to pay to Lander the amount of the separately designated ? and retain wort: duo when the insurance coverage ceased to be in effect. Lender' will accept
payments as a non-refundable loss reserve in Ilcu of Mortgage Insurance. Such loss reserve shall be
non-refundable, notwithstanding the fact that the Loan is ultimately paid in full, and lender shall not be
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fequired to pay Borrower any Interest or earnings on such loss reserve. Lender can no longer require loss
reserve payment if Mortgage Insurance coverage (in the amount and for the period that Lender requires)
provided by an Insurer selected by Linder again becomes available, is obtained, and Lender requires
separately designated payments toward the premiums for Mortgage Insurance. If Lender required Mortgage
Insurance as a condition of making the Low and Borrower was required to make separately designated
payments toward the premiums for Mortgage Insurance. Borrower shall pay the premiums required to
maintain Mortgage Insuuatrce m eijeot, or w provide a non-reflu?dabie lass reserve, sail[ Lender's
requirerruu nt for Mortgage Insurance ends in soeordance with any written agreement between Borrower and
Lender providing for such tccrnlnadon uu uuntii terndaation is required by Applicable Law. Nothing in this
Section l0 ailects we obligation to pay Interest at the rate provided in the Note.
Mortgage insurance reimburses Lender (or any entity that purchases the Note) for certain losses is
may now if Borrower does not repay the loan as agreed Borrawer is not a Party to the Mortgage
Insurance.
Mortgage insurers evaluate their total risk on all such insurance in force from time to time, an may
enTer into agreements with other parties that sbare or modify their risk, or reduce losses. These agreements
are on terms and canditioas chat are satisfactory to the mortgage Insure' and the other party (or parties) to
these agreements, These agreements may require the mortgage insurer to make payments using any source
of funds that the mortgage Insurer may have available (which may include fltads obtained from Mortgage
Insurance premiums).
As a result of these agreements, Lender, any purchaser of the Nate, another Insurer, any reinsurt>r,
any other entity, or any i0liatc of any of the foregoing, may receive (directly or indirectly) ??C hen
derive from (& might be characterized as) a portion of Borrower's payments far Mortgage
exchange for sharing or modifying the mortgage insurer's risk, or reducing lasses. If such agreement
provides that an affiliate of bender takes a share of the insurer's risk in exchange far a shore of the
premiu
(a) Any ms paid suto the ch anreemehthe is will not affect the amounts that Borrower reinsurance."
agreed to pay for Insurance, or an other Mortgowager will own for Mortgage Inspr acct, and disy will not enti Borrower to any reefund. amount
(b) Any such agreements will not affect the rights Borrower has - if any • with respect to the other law. Mortgago Insurance under the Homeowners Protection Act of 11"S nrdaobtatn eaaceilTh
eoi?he
may include the right to recava certain disclosures, is request
Mertpgc Insurance, to have the Mortgage Insurance terminated automatically, and/or to receive a
refund of any Mortgage Insurance premiums that wero unearned at time time or such cancellation or
termination.
Si. Assignment of Misediancous Proceeds; Ferfelture. All Miscellaneous lemccods are hereby
assigned to and shall be paid to Lender.
If the property is damaged, such Miscellaneous Proceeds shall be applied to restoration or repair of
the Property, If the restoration or repair is economically iltasible and Leader's security is not lessened.
During such repair and restoration period, Lender shell hove the right to hold such Miscellaneous proceeds
until Lender has had an opportunity to inspect such Property to ensure the work has been compl t dtto
Lender's satisfaction, provided that such inspection shall be undertaken promptly. Lender may pay
k Is
repairs and restoration In a single disbursement our in asLowpequirrees intereest to be paid on such
completed. Unless an agreement t is is made is writing Applicable
Miscellaneous Proceeds. Lender shall not be required to pay Borrower any interest or earnings on such
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Miscellaneous Proceeds. If the restoration or repair is not economically feasible or Lender's security would
eo?P orty eeInstrument,
be lessened, the h iseetlaneeus Proceeds shall be applied lo the sums; secured e bylthis
Shall be
whether or not than due, with the excess, if any, p d to
applied in the order provided for in Section 2.
In the event of a total taking, destruction, or lose In value of the Property, the Miscellaneous
Proceeds shall be applied to the stuns secured by this Security Instrument, whether or not then duo with
the excess, if any, paid to Borrower.
In the evert of a partial taking, destruction, or loss in value of the Property in which the fair market
value of the Property immediately before the partial taking, destruction, or lose in value is equal to or
greater than the amount of the sums seemed by this Security Instrument Immediately before the part
taking, destruction, or lass in value, unless Borrower and Leader otherwise agree In wr(ting, the secured by this Security Instrument shell be reduced by the amount of the Miscellaneous
Proceeds
multiplied by the following friction. (o) the total amount of the sums secured immediately before the
partial caking, destruction, or loss din value estruction, divided ooes In value. Anynbala nee shalll bajod to Borrower.
Immediately before the partial taking,
In the event of a partial taking, destruction, or lass in value of the Property In which the fair market
value of the Property immediately before the partial taking, destruction, or loss In value is less than the
amount of the sum secured immediately before the perdu] taking, destruction, or loss In value, unless
Borrower and Lender otherwise agree in writing, the Mscellancous Proceeds shall be applied to the sums
secured by this Security Instrument whether or not the sums are then due.
if the Property is abandoned by Borrower, or if, after notice by Lender to Borrower that the
Opposing Party (as defined in the next sentence) offers to matte an award to settle a claim for damages,
Borrower falls to respond to Lender within 30 days after the date the notice is given, Lander is authorized
to collect and apply the Miscellaneous Proceeds elther to restoration or repair of the Property or to the
aunts secured by this Security Instrument, whether or not then due. Opposing Party" means the third patty
that owes Borrower Miscellaneous Proceeds or the party against whom Borrower has a right of action in
regard to Miscellaneous Proceeds,
Borrower shall be In default if any action or proceeding, whether cavil or criminal, Is begun thot, in
Lender's judgment, could result in forfeiture of the Properly or other material impairment of Lenders
interest in the Property or rigPhts under this Security Instrument. Borrower can cure such a default and, if
acceleration has occurred, reinstate as provided in Section I% by causing the action or proceeding to be
dismissed with a ruling that, in Lender's judgment, precludes forfeiture of the Property or other material
impairment of Lender's interest In the Property or rights under this Security Instrument. The proceeds of
any award or claim for domagcs that are attributable to the impairment of Lender's interest In the Properly
are hereby ouigned and "15 a paid to Lender.
All Miscellaneous Proceeds that eta not applied to restoration or repair of tho Property shall be
applied in the order provided for In Section 2.
l2. Borrower Not Released; Forbearance By Lender Not a Waiver. $xteaslon of the time for
payment or modification of amortization of the sums secured by ibis Security Instrument granted by Lender
to Borrower or any Successor in Interest of Borrower shall not oporate to release the liability of Borrower
or an Successors in Interest of Borrower. Lender shall lo extend tim for payment: or not be required to commence opro eedirv against
motti11jecessor in zWon of the Interest sums seer ed by tb s Security l?ument by reason of any demand made by the original
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Borrower or arty Successor in interest of Borrower. Any forbearance byL from third pasotrs entities or
remedy including, without limitation. Landoes acceptance of p yme
Successors id interest of Borrower or in amounts less than the amount then due, shall not be a waiver of or
preclude the exercise of any right or remedy.
13. Joint and Several Liability; C ants; Successors add Assigns Bound. Borrower covenants
who
and agrees that Borrower' a obligations and liability shall be joint and several. However, any Borrower
this
ca-siga9 this Security Instrument but does not execute the Note (? o-?na<': the is eo- Property in thithe
Security Instrument only to mortgage, grant and convey the cosign scoured by this Security
tatters of this Security Insmtrnenr, (b) Is not personally obligated to pay the stuns to extend, modify, forbear or
Instrument; and (e) agrees that Lender and any other Borrower can agree
make any accommodations with regard to the terms of this Security Instrument or the Note without the
signer's consent.
Subject to the provisions of Section 18, any Successor in Interest of 13wrower who assumes
Borrower's obligations under this Security Instrument in writing, and Is approved by Lender, shall obtain
Instrument. Borrower shell net be released from
(lability ts under under this this Se Security c instrument unless Lender agrees to such release In
all errr`s obligations rights and and benefits
Borro rowe
writing. The covenants and agreements of this Security tnstrurnent shall bind (except as provided in
Section 20) and benefit the successors and assigns of Lender.
14. Loan Charges. Lender may charge Borrower ties for services performad in connection with
Borrower's det'ault, for the purpose of protoctlnt; Lender's Interest in the Property and rights under this
Security instrument, including, but not limited to, attorneys fees, property inspection and valuation fees.
in regard to any other fees, the absence of express authority in this Security msaament to cbarge a specific
fee to Borrower shall not be construed as a prohibition on the charging of suchLfgW Lender may not charge
fees that are expressly prohibited by this Security Instrument or byApplicable
d that law is finally interpreted so
If the Loan is subject to a law which sets maximurn [Dart obarges. ?
to dueed ce the
that the interest or other loan charges collected o shto be at bcollect reduced inY connectim amount with the Loan
permitted limits, then: (a) any such loan charge
charge to the permitted litnit; and (b) any stuns already collected from Borrower which exceeded permitted
limits will be refunded to Burrower. Lender may choose to make this rAnd by reducing the principal
owed under the Note or by making a direct payment to Borrower. if a tofund reduces principal, the
reduction will be treated as a prepayment without any prepayment thane (whether or not a
prepayment charge is provided touia1 nder the Note).. Borrower's acceptance of any such refund made by
direct payment to Borrower will constitute a waiver of any right of action Borrower might have arising out
of saeh overcharge.
Ys. Notices, All notices given by Borrower or Lender in connection with this Security instrument
most be in writing. Any notice to Borrower in connection with this Security Instrument shd to deemBorrower d t s
have been given to Borrower when mailed by first class mail or when actually
notice address if sent by other means. Notice to any one Borrower shall constitute notice to all Borrowers
unless Applicable Law expressly requires otherwise. The notice address shall be the property Address Lander. B unless Borrower o has ee aced o of address. If Lender specifies atprocedure
forrreporting ]Borrower, s
address, Borr then owow Ber'sorrower change shall only report a chango of address through that specified procedure,
changnotifye of Lender
There may be only ant designated notice address undo' this Security instrument at any one time. Any
of
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notice to Lender shall be given by delivering it or by mailing it by first class mail to Lender's address
stated herein unless Lender has designated another address by notice to Borrower. Any notice in
connection with this Security Instrument shall not be deasned to have been given to Lender until actually
received by Leader. If any notice required by this Security Instrument is also required under Applicable
Law, the Applicable Law requirement will satisfy the corresponding requirement tinder this Security
Instrument. shall be
16. Governing Law; Severability; Rules of Contraction. This Security Instruintent
governed by federal law and the law of the jurisdiction in which the Property is located All rights and
obligations contained in this Security Instrurnant are subject to any requirements and limitations of
Applicable Law. Applicable Law might explicitly or Implicitly allow the parties to agree by contract or it
might be silent, but such silence shall not be construed as a prohibition against agreement by contract, In
the event that any provision or clause of this Security instrument or tho 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.
As used in this Security Instrument: (a) words of the masculine gander shall moan and include
corresponding Neuter words or words of the feminine gender; (b) words in the singular shall mean and
include the plural and vice versa; and (c) the word "tray" gives sole discretion without any obligation to
tape any mloo.
17. Borrower's Copy. Borrower shall be given one copy of the Note and of this Security Instrument.
18. Transfer of the Property or a Beneficial haterest In Borrower. As used In this Section 18,
Interest In the Property" mesas any legal or beneficial interest In the Property, Including, but not limited
in, those beneficial interests transferred in a bond for deed, contras for deed, installment sales contract or
escrow sgreement, the intent of which is the transfer of title by Borrower at a future date to a purchaser.
If all of any part of the Property or any Interest in ft Property is sold or transferred (or if Borrower
is not a natural person and a beneficial interest In Borrower is sold or transferred) without Lender`s prior
by Leender if such exercise syprth Security
ohibited by
this opt on shall not be payment In
written Instrrumen However, Leader
Applicable Law.
If Lender exercises this option, Lender shall give Borrower notice of acceleration. The notice shall
provide a period of not less then 30 days from the data the notice is given in accordmtce with Section 15
within which Borrower must pay all sums secured by this Security Instrument. If Borrower fail by pay
these sutras prior to the expiration of this period, Lender may invoke any remedies permt y this
Secxaity instrument without further notice or demand on Harrower.
19. Borrower's Right to Relastate After Aeaddration. If Borrower meets certain conditions,
Borrower shall have tha right to have enforcement of this Security Instrument discontinued at any time
prior to the earliest of. (a) five days before We of the Property pursuant to any power of sale contained in
this Security Instrument; (b) such other period as Applicable Law might specify for the termination of
Borrower's right to reinstate; or (c) entry of a Judgment enforcing this Security Instrument Those
conditions are that Borrower: (a) pays Lender all sons which then would be due under this Security
Instrument and the Note as if no acceleration had occurred-, (b) cures any default of any other covenants or
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agrcemrrrtq; (c) pays all expenses incurred in enforcing this Security Instrument, Ipclud'Ing, but not limited
to, reasarable attorneys' fees, property lasprelion sad valuantm ties, and other fees incurred for the
purpasa of protecting lender's intorrst in the Ptopet?y and nigher under this Security Instrument; and (d)
takes such action ss Lender may reasonably require to 8ssute tluu Leer's interest in the property and
rights under this Seeclriry Instruument. and Barrovver's obligation to pay the quire scoured by this Security
iastruraent, shah continua unchanged. LQnd?Y require that Borrower pay such reinstatement sums and
expenses in one or more of the following firms, es selected by Lander: (a) cash; (b) money order; (c)
certified check, bank check, treasurer's etteok or cashlees cheek, provided any such oheok Is drawn upon
an institution whose deposits are insured by a federal agency, imtrumontality or Ttity; or (d) Electronic
Funds Transfer. Upon reinstatement by Borrower, this Security Instrument and obligations secured hereby
shall remain fully offective as if no acceleration had occurred- However, this right to reinstate shall not
apply in the can of acceleration under Section IS.
20. Sale of Nate; Change of Loan Servicer; Notice of Grtevaaee. The Note or a partial interest in
the Note (together with this Scoarity instrument) = be sold o or mom times without ) hat conotice to
Borrower. A sale might result in a change in the entity (known ??? other mortgage at co loan
periodic Payments due under the Note and this Security Instrument and p
servicing obligations under the Note, this Security Instrument, and Applicable Law. There also might be
one or more changes of the Loan Servicer unmisted to a sate of the Note. If there is a change of the Loan
of the
Servicer, Borrower will be given written notice of h obarig bahicmade and h will state anyhe name and informationaddress oSpA
new Loan Servicer, the address to which payments other
requires In connection with a notice of transfer of servicing. If the Note is soli add thereafter b?Lo?eO?
serviced by a Loan Servicer other than the purchaser of the Note, the rnortgay
to Borrower will remain with the Loan Servicer or be transferred to a sucoessor Loan Servicer and are not
assumed by the Note purchaser unless otherwise provided by the Note purchaser.
Neither Borrower nor Lender may commence, join, or be joined to any judicial action (as either an
individual litigant or the member of a crass) that arises from the other party's actions pursuant to this
Security Instrument or that alleges that the other party has breached any provision of, or arty duty owed by
reason of, this Security Instrument, until such Borrower or Lender has notified the other party (with such
notice given in compliance with the requirements of Section 1S) of such alleged breach mid afforded the
other parry hereto a reasonable period after the giving of such notice to take corrective action. If
Applicable Law provides a time period which must elapse before certain Thaction can e notice be taken, that time
period will be deemed to be reasonable for purposes of this pa qM of acccivitIon and
opportunity to cure given to Borrower pursuant to Section 221 and the notice of acceleration given to
Borrower pursuant to Section 18 shall be deemed to satisfy the notice and opportunity to take corrective
action provisions of this Section 20.
al. Uar:ardous Substances. As used in this Section 21: (e) "Hazardous Substances" are those
substances defined as toxic or hazardous substances, pollutants, or wastes by Environmental Law and
following substances: psoline, kerosene, other flammable or toxic petroleum products, toxic pesticides
and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials;
(b) "Environmental Law" means federal laws and laws of the Jurisdiction here the Pr ppopud and aced that
relate to health, safety or environmental protection; (c)
action, rcmedlal action, or removal action, as defined lu Rnvironrrtentui Law; and (d) an "Environmental
Condition" misers a condition that can cause, contribute to, or otherwise trigger an Environmental
Cleanup.
----------
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646
Borrower shall not cause or pcmrit the presence, use, disposal, uoregej or release of any Hazardous
Substances, or threaten to release any Hazardous Subs==, on or in the Property. Borrower shall not do,
nor allow anyone arse to do, attyth3nB at frogg the Pro (eJ OW is In violation of al Environmental
Law, (b) whiwi creates an Ennronatcotal Corxtttion, or c) whrah, due to the presence. toe, or release of a
Hazardous Substance, create a condition that adversely at&cis value of the P? ray. he precedin
two sonterreea "it not apply io the presence, use, or Storage on the Prap?y of smallTqumnlties of
Hazardous Substances that are enerally recognized to be appropriate to normal resldential uses and to
maintenance of the Property (iac?uding, but not llmited to, hazardous sub?nces in consumer products).
Borrower shall promptly give Lender written notice of (%).any Invalidg tiant claim, datrtnnd, lawsuit
or other action b6yy nay governmental or regulatory agency or pnvale pity fnvolvmg the Property and any
Hazardous Substance or Environmental Law of which Borrower has actual knowledge, (b) any
Environmental Condition. Including but not limited to, spilling, leaking, discharge. release or eat of
relent: of any Hazardous Substance, and (o) any eondt n amid by the presence, use at release of a
Hazardous Substance which adversely affects the value of the Property. If Borrower learns, or is notified
by any governmental or regulatory authority, or any private party, that any removal or other remediation
of an Hazardous Substance affectg the Ptoperry lS necesrary. Borrower shall promptly take all necessary
remedial actions In accordance Wiinth Envirornaantal Law. Nothing herein shall create any obligation on
Lender for an Environmental Clamp,
NON-UNIFORM CO'VgMANTS. Borrower and Lender fifrdter covenant end agree as follows:
22. Acceleration; Remedies. Lender shall give notice to Borrower prior to acceleration following
Sorrowees breach of any covenant or agreement in this Security Instrument (bet not prior to
acceleration under Section 18 unless Applicable Law provides otherwise). Leader shall notify
Borrower of, among other things: (a) the default; (b) the sedan required to cure the default; (c) when
the default must be cared; and (d that failure to cute the default as ecitled may result in
acceleration of the sums secured by this Security Instrument, foredesure by udleiai proceeding and
Sala of the Property. Lender shall further inform Borrower or the right to reinstate after acceleration
and the right to assert in the foreclosure proceedln the non-existence of a default or any other
defense of Borrower to acceleration and foreclosure. Ithe default is net cared as specified Lender at
Its option may, require immediate ppayment In tail of all sums secured by this Security knstrrmtent
without further demand and may foradose this Security Instrument by Jgdidat proceeding. Lender
,ball be entitled to collect all expenses incurred In pursuing the remedies Provided in thiia section 22,
including, but not timited to, attorneys fees and costs of Title evidence to the extent permitted by
Applicable Law,
23, Release. Upon payment of all sums secured by this Security Wuument, this Security Instrument
and the estate conveyed sbWI terminate and become void. After such occurrerim Lender shall discharge
and satisfy this Security Instrument Borrower shall pay any recordation costa. Lender may charge
Borrower a fee for releasing this Security Instrume but only If the fee is paid to a third party for services
rendered and the charging ofthe fee IS parmsitted under Applicable Law.
24, Waivers. Borrower, to the extent permitted by Applicable Law, waives and releases any error or
defeats in proceedings to enforce this Security lnstrumen4 and hereby waives the benefit of any present or
future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale.
and horneslesd exemption.
25. Reinstatement Periad. Borrower's time to relustateprovided in Station 19 shall extend to one hour
prier to the commencement of bidding at a sheriff s sale or other sale pursusrtto this Security Instrument.
26. Purchase Money Mortgage. If sny of the debt secured by this Security Instrument is lent to
Borrower to acquire title to the Property, this Security Instrument shall be a purchase money mortgage.
27. Interest Rate Attar ludgment. Borrower agrees that the ipterest rate payable after a)hillgmatrt is
entered an the Note or in an action of mortgage foreclosure shall be the rate payable from time to time
A . Vogl$ FYmrr • F@A* MulFddir M,c U111FeAM iNeTRUMENT WITH MIME VMi6^(P111 itl119i1
Vl,Ptr Inil{y? 15 YI It
WYINF6 K,,ww A"McIYI 8wfrw, Al
?
Al
BY SIONING BELOW, Borrower accepts and agrees to the terms and covenants contained in this
Security Instrument and in any Rider executed by Borrower and recorded with it.
Witnesses:
_ I_ In (Seal)
Travis A Harpiar -Borrowor
- (Seal)
-Borrower
(Seal)
Dtzpgir BSYboux -Borrower
(Seal)
-Borrower
(Seal) (Seal)
-Borrower .Borrower
_ (Seal)
-Borrows
_ (Saal)
-Borrower
VMPId ..... . Stnpln Fardlr - F?enirr 1,4adFredd6 Mio UNIFORM INSTRUMENT WICK usa6 Q ?/' UM Po9e til? al?l?
W¦aa" Kluwor AwAdgvrih*l inilBls: E6
!/I
COMMONWMTH OF PENNSYfrVANtA, Cumberland County as:
on this, the I Gth day of July, 2009 , before me, tho
undersigned officer, pcrsorally appeared Travis A Harper and tltaygin 8 24u**ur
known to me (or
satisfactorily proven) to be the person(s) whose name(s) is/are subscribed to the within Instrument and
acknowledged that WsWthey executed the same for the purposes herain contained.
M WjTt4ESS WjjBRE0F,1 hereunto set my hand and official seal.
My Commission Expires:
MFIUtU1i _
A-d aNataltEdtpNM 0? ?_•.?..-
SQ 2011
my -I L
Tkk of omeer
Ciertiticate of Residence Ja ?, do hereby certify that
1, ?/
the correct address of the within-named Mortgagee is 3300 S.W. 34th Avenue, Suite 101, Ocala, FL
34474, P.O. Box 2026, Flint, NU 48501-2026. day of July, 2009
Witness my hand this 14th y
Agent or Mongagan
i
Is FMnhr Mao+kaddto Mee eNIFON IM UMINT Wr<N MEBB For...
i ai 77
Wa t4d Wwa Flnandd So l-s InhMlc ?f?? Pu90
Exhibit A
Legal Description
561 Conodoguinet Avenue
Carlisle, PA 17015
Parcel No. 29-18-1384-045 & 005A
Parcel No. I
Am that parcel of land $i odd a Mid?eetarEbel ship,
Cumberland county, Pecu%aylvania,
foil owar
BStiINNm at an existing iron pin located at the northwest corner
lands of the cixantese; thence aloog Lot. No. 4 of the
of *the r
hereinafter. n&mori subdivision Plan north 210 5511 34K West a
distance of 35.74 feet to a concrete Momimant:; thence along other
lands of the Grantor Sough 6210 38''39" Bast a dietanoe of 79.66
feet to an iron pins thence Aong Zot go. 6 of the hewolua.fter
named Subdivision Plain gouth 819 461 480 West a'dfetan of 40.08
feet to a point; thetrtoe aLlong other lands of the Grantee Worth
666 31' 19" West a di.etooce of 79.76 feet to an aX aging iron
pin, the point and place or BEGGING.
BRWG Lot No. 5 on the Prel itninary/Final Aulx v? nicn Plan for
angles Cronstug 'golf course recorded in. the Office of the.
in
R,scqrder of needs Plan Back 81, Page il and s and containing 3?O tequar a test .
Pla
Farce! No. 2
ALL those certain two (2) treats of land with improvements
uhereon erected situate in Meadow'Brolaark, KKorth Lot Not a].0$ and
ToWnshi.p, GuRgarlalr?d County,
109, section 3, of a Plan of Lots laid out by Charles C. Swarner,
said Plan of Lots being recorded in the Office of the Reeordor of
heads in and for Cumberland County at Carlisle, Pe nsylvbedal ifollaws:
Plgn„(3 O 3, Page 34, and being more partioularly. dos*r1 its
TRACT n wf or. to Raymond,Laao Votbca+r, oorneiConodogulof
n r
one the eastern ling of said Lot, North 23 degrees
Avanuei +thsnae al formerly,
Avenues
08 minutes East,. 1LOD Peet to a point; at tho oorner of said Lot and
lands now or foriaer3$ of Charles C.• Swarners thence along said lairds
now or rormorly 'or said Swa.rnor's south 66 degrees 52 minutes East,.
40 feet to a stake, the northwest corner. 01! Lot No, 109, Tract No. 2
herein: thence along the y00tafeet to a pointdonosaid.Conodoguinet
degrees 08 08 minutes West,
Avemin ; thence along said Avenue, North 66, degreew 52 tc ini4tes West,
Ao feet to a stake, the. Place or BEGINNING.
No. 2: BBCi1NN7Nt? at a make corner of Lot No, io8, Tract
TRACT
No. I here?ln, and Conodoaulnet Avenue; thence North 23 degreen 08
minutes Eaat,,CXQO feet to- a stake corner to Lot No. 108 on lands now
or formerly of Cbarles C. Swarner;..thence along said lands now or
formerly of Charles C. 8warner, south 66 regress 52 minutes Nasty 40
feet to a. stake corner of Lot No. 110 and lends now or farmerly•of
said Charles C. Swarner; thenae South 21 degrees 08 minutes West,
100 feet to a stake, corner of Lot No. 110 and said Conodoguinet
Avenue; thence along said Avenue, North 66 degrees 52 minutes West,
40 foot to'a stake, the Place of BEGIRMIX0.
ag1NO Lot Mon. 108 and 109s section $, of a Plan of L6ts laid
out by Chhrles C. Swarner and recorded as aforesaid on which there ?
is ereated*s. frame dwelling house.
ROBERT P. ZIEGLER
RECORDER OF DEEDS
CTMBERLAND COUNTY
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
717-240-6370
instrument Number - 200933457 *Total Pages - 20
Recorded On 91x9!3009 At 10:53:0$ AM
* Instrument Type - MORTGAGE
Invoice Number - 53196 User ED - RAK
* Mortgagor - AARFER, TRAVIS A
* Mortgagee - MORTGAGE ELECTRONIC REGISTRATION SYSTEMS INC
* Customer - GHAT 1tC1Ari
*FEES
STATE SPRIT TAX $0.50
STATE JCS/ACCESS TO $10.00
JOS-21CE
RECORDING FEES -
$41.50
RECORDER OF DEEDS
PARCEL CERTx6'YCATION $20.00
FEES
AFFGRD"LE HOUSING
$11.50
$2 00
Certification Page
DO NOT DETACH
This page is now part
of this legal document.
COUNTY ARCHIV-3 FEE
ROD ARCHIVES FEE $3.00
TOTAL PAID $88.50
X Certify this to be recorded
in Cumberland County PA
RECORDER O D EDS
+ . information denoted by an Asterfik may change daring
the verification process and may not be reneeted on this page.
11111011111111
L
July 16, 2009
IDotel
b
NOTE
Carlisle
(OW)
561 Conodoguinat Avenuo
Carltalo, PA 17015
Plic rty Addnu]
PEt?7SYI.VANIA
1Stetoi
L BORROWER'S PROMISE TO PAY
In return for a loan that I have received, I promise to pay U S. $12 6, 480.00 (this amount is called "Principal"),
plus interest, to the order of the Lender. The Leader is Sovereign Hank
I will make all payments under this Note in the form of cash, check or money order.
I understand that the Lender may transfix this Note. The Lender or anyone who takes this Note by transfer and who is
entitled to receive payments under this Note is called the "Note Holder."
2. INTERES'T' .
Interest will be charged on unpaid principal until the full amount of Principal has been paid. I will pay lnterest at a yearly
rate of G.000 %.
The interest rate required by this Section 2 is the rate I will pay bath before and after nay default described in Section 6(B)
oftws Note.
3. PAYMENTS
(A) Time and Place of Payments
I will pay principal and interest by makiag a payment every month.
I WM make my monthly payment on the lot day of each mouth beginning on September 01, 2009 . I will
make these payments every month until I have pald all of the principal and interest and any other charges descn'bcd below that I
may owe under this Note. Each monthly payment will be applied as of its scheduled due date and will be applied to interest
before Principal. 4 on August 01, 2039 , I still owe amounts under this Note, I will pay those amounts in full on
that date, which it called the "Maturity Date."
I will make my monthly payments atll30 Borkabiro Blvd., Wyomiaaing, PA 19610
or at a different place if required by the Note Holder.
(B) Amount of Monthly Payments
My monthly payment will be in the amount of U.& S 758.32
4. BORROWER'S RIGHT TO PREPAY
I have the right to make payments of Principal at may time before they are due. A payment of Principal only is known as a
"Prepaymeat." When I make a Prepayment, I w$! tell the Note Holder-in writing that I am doing so. I may not designate a
payment as a Prepayment If I have not made all the monthly payments dux under the Note.
I may make a full Prepayment or partial Prepayments without paying a Prepayment charge. The Note Holder will use my
Prepayments to reduce the amount of Principal that I owe under this Note. However, the Note Holder may apply my
Prepayment to the accrued and mpaid interest on the Prepayment amount, before applying my Prepayment to reduce the
Principal amount of the Note. If I make a partial Prepayment, there will be no changes in the due date or in the amount of my
monthly payment unless the Note Holder agrees in writing to those changes,
x iam-F MED FATE N016• "Its FWWV • Fuwk M WFlWas feu UMWo; a IMM MUff
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I
5. LOAN CHARGES
If a law, which applies to this loan and which sets maximum loan charges, is finally ln*preted so that the interest or other
loan charges collected or to be collected in connection with this loan exceed the permitted limits, then: (a) airy such loan charge
shall be reduced by the amount necessary to reduce the charge to the permitted limit; sad (b) any sums already collected from
me which exceeded permitted limits will be refunded to me. The Note Holder may choose to make this refimd by reducing the
Principal I owe under this Note or by malting a direct payment to mm If a refund reduces Pfincipal, the reduction will be treated
as a partial Prepayment.
6. BORROWER'S FAILURE TO PAY AS REQUIRED
(A) Late Charge for Overdue Payments
If the Note Holder has not received the full amount of any monthly payment by the and of riftoou calendar days
alter the date it is due, I will pay a late charge to the Note Holder. The amount of the charge will be 4.000 % of
my overdue payment of principal and interest. I will pay this late charge promptly but only once on each late payment.
(B) Default
If I do not pay the full amount of each monthly payment on the date it is due, I will be in default.
(C) Notice of Default
If I am in default, the Note Holder may send me a written notice telling me that if I do not pay the overdue amount by a
certain date, the Note Holder may require me to pay immediately the full amount of Principal which has not been paid and all
the interest that I owe on that amouat. That date must be at least 30 days alter the data on which the notice is mailed to -me or
delivered by other means.
(D) No Waiver By Note Holder
Even ii, at a time when I am In default, the Note Holder does not require me to pay immediately In full as described
above, the Note Holder will still have the right to do so if I am in default at a later time.
(E) Payment of Note Holder's Costs and Expanses
If the Note Holder has required me to pay, immodiately in full as descrlbed above, the Note Holder will have the right to
be paid back by me for all of its costs and expenses in enforeing this Note to the extent not prohibited by applicable law. Those
expenses include, for example, reasonable attorneys` fees.
7. GIVING OF NOTICES
Unless applicable law requires a different method, any notice that must be given to me under this Note will be given by
delivering it or by mailing it by first class mail to me at the Property Address above or at a different address if I give the Note
Holder a notice of my different address
Any notice that must be given to the-Note Holder under this Note will be given by delivering it or by mailing it by first
class mail to the Note Holder at the address stated in Section 3(A) above or at a different address if I am given a notice of that
different address.
8. OBLIGATIONS OF PERSONS UNDER THIS NOTE
If more than one person signs this Note, each person Is fully and personally obligated to keep all of the promises made In
this Note, including the promise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is
also obligated to do these thhngs Any person who takes over these obligations, including the obligations of a guarantor, surety
or endorser of this Note, Is also obligated to keep all of the promises made In this Note. The Note Holder may enfbree its sights
under this Note against each person individually or against all of us together. This means that awry one of us may be required to
pay, all of the amounts owed winder this Note.
9. WAIVERS
I and any other person who has obligations under this Note waive the nights of Presentment and Notice of Dishonor.
'Presentment" means the right to require the Note Bolder to demand payment of amounts due. "Notice of Dishonor" means the
right to require the Note Holder to give notice to other persons that amounts due have not been paid.
??.®........nw .•n.cN018• ?1p1? FM18j • h""kIdWFleddle MOt UNIFOpAI iNSrA11NEH1'
wat?nIqurr?rFlnindBswvtas MiNUa?a viwvs po9:Itema
_ rnEx?
10. UNIFORM SECURED NOTE
This Note is a uniform instrumoat with limited variations in some jurisdictions. In addition to the protections given to the
Note Holder under this Note, aMortgage, Deed of Trust, or Security Deed (the "Security Insvnumeat"), dated the same date as
this Note, protects the Note Holder from possible losses which might result if I do not keep the promises which I make in this
Note. Tbat Security Instrument describes how and under what conditions I may be required to make immediate payment in bill
of all amounts I owe under this Note. Some of those conditions are described as follows:
If all or any part of the Property or any Interest in the Property is sold or transferral (or if Borrows is
not a natural person and a beneficial interest in Borrower is sold or transtbrr4 without Lender's price written
consent, Leader may require immediate payment in full of all sums secured by this Security Instrument.
However, this option shall not be exseisod by Larder if such exerciso is prohibited by Applicable Law.
If Lender exercises this option, Leader shall give Borrows notice of acceleration Tbo notice shall
provide a period of not less than 30 days from the data the notice is given in u=rd=cc with Section 15
within which Borrower must pay all sums secured by this Security Iastuumrent. If Borrower fails to pay these
sums price to the expiration of this period, Leader may invoko any remedies permitted by this Security
Imtu ent without Author notice or demand on Borrower.
WITNBSS TEE HAND(S) AND SEAL(S) OF THE UNDERSIGNED.
(Seal) G'
Travis A Harper -Borrower HoomiWi7nn -Dwo er
(sew)
.Borower
(Sew)
PAY TO THE ORDER OF .Borrower
JP MORGAN CHASE BANK, 1q. A.
WITHOUT RECOURSE
SOVEREIGN $4K i
OFFICER -Ikmwa
(Seal) (Seal)
•Borrowa -Borrower
(SIgn Oilglnal Only]
_._....BMon-SWS1eFm1V-Fmr&M&dFWd*JAwUR1F0W4VIS DMW
W#k= IGwr R,mdd sWka
k"r 614 hg *39113
r4?6
Chase Home Finance LLC (FL5-7734)
PO BOX 44090
Jacksonville, FL 32231-4090
November 5, 2010
TRAVIS A HARPER
561 CONODOGUINET AVE
CARLISLE PA 17015-8972
Acceleration Warnins (Notice of Intent to Foreclose)
Account: , he Loan")
Property Address: 561 CONODOGUINET AVE
CARLISLE, PA 17015 (the "Property")
Dear TRAVIS A HARPER:
ACT 91 NOTICE
CHASE O
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
the attached eases.
The HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE PROGRAM
Cn1TNCF,I.ING AGENCY WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF
The name, address, and phone number of Consumer Credit Counselins Asencies serving
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain
it. You may also want to contact an attorney in your area. The local bar association may
be able to help you find a lawyer.
EXI?6?'E "C?
It, t-,,*x .1
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFECTA
SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE
PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS
LOAN ACCT. NUMBER:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
TRAVIS A HARPER
MAYGIN E BARBOUR
561 CONODOGUINET AVE
CARLISLE, PA 17015
SOVEREIGN BANK
Chase Home Finance LLC
HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE.
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three [3] days for mailing).
During that time, you must arrange and attend a "face-to-face" meeting with one of the Consumer Credit
Counseling Agencies listed at the end of this NoticeTHIS MEETING MUST OCCUR WITHIN
THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR
HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the Consumer Credit
Counseling Agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30)
days after the date of this meeting.The names, addresses. and telephone numbers of designated Consumer Credit
Counseling Agencies for the county in which the Property is located are set forth at the end of this Noticdt is
only necessary to schedule one face-to-face meeting. Advise your lendeimmediatelyof your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default). You
have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance
Program ("HEMAP"). To do so, you must fill out, sign, and file a completed HEMAP application with one of
the designated Consumer Credit Counseling Agencies listed at the end of this Notice. Only Consumer Credit
Counseling Agencies have applications for the program and they will assist you in submitting a complete
application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a
foreclosure action, your application MUST be forwarded to Pennsylvania Housing Finance Agency
("PHFA") and received within thirty (30) days of your face-to-face meeting with the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A
MEETING WITH A COUNSELING AGENCY WITHIN THIRTY-THREE (33) DAYS OF THE
POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN
THIRTY (30) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY
PREVENTED FROM STARTING A FORECLOSURE ACTION AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME
PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY
TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.
You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (bring it up to
date).
NATURE OF THE DEFAULT-The Mortgage debt held by the above lender on your Property located at:
561 CONODOGUINET AVE, CARLISLE, PA 17015 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS starting 09/01/2010 through
11/05/2010, and the following amounts are now past due.
If you have any questions about the amounts below, please contact us as soon as possible at (800) 848-9380.
Total Monthly Payments Past Due: $2,716.26
Late Charges: $0.00
Insufficient Funds (NSF) Fees: $0.00
Other Fees and Advances*: $0.00
Amount Held in Suspense: $41.92
TOTAL AMOUNT DUE TO CURE DEFAULT : $2,674.34
*Other Fees and Advances include those amounts allowed by your Note and Security
Instrument. If you need additional information regarding any of these amounts, please
contact us at the number provided below.
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of
this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$2,674.34, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30)-DAY PERIOD. Payments must be made in the form of cash, cashier's check,
mongX order, or certified check and sent to
Regular Mail: Chase Home Finance LLC
PO BOX 78420
Phoenix, AZ 85062-8420
Overnight Mail: Chase Home Finance LLC
Attention PO BOX 78420
1820 East Sky Harbor Circle South
Phoenix, AZ 85034-9700
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage dehtThis
means that the entire outstanding balance of this debt will be considered due immediately and you may lose
the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
foreclose upon your mortgaged Property
IF THE MORTGAGE IS FORECLOSED _UL O)' N-The mortgaged Property will be sold by the sheriff to
pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney fees
that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will
have to pay all reasonable attorney fees actually incurred by the lender even if they exceed $50.00. Any
attorney fees will be added to the amount you owe the lender, which may also include other reasonable costs.
If you cure the default within the THIRTY (30)-DAY period, you will not be required to pay attorney
fees.
OTHER LENDER REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -If you have not cured the default
within the THIRTY (30)-DAY period and foreclosure proceedings have begunyou still have the ri t o rre
the default and prevent the sale at a?„ time ime = to one hour before the Sheriff's Sale. You may do so by
pUing the total amount then Mast due plus any late or other charges then due. reasonable attorney fees and
costs connected with the foreclosure sale, and any other costs connected with the Sheriff's Sale as specified in
writing by the lender, and by performing an other r Qnir ments under he mortgageCuring your default in
the manner set forth in this Notice will restore your mortgage to the same position as if you had never
defaulted.
EARLIEST POSSIB .. SHERIFF'S SALE DAM-It is estimated that the earliest date that such a
sheriff's sale of the mortgaged Property could be held would btapproximately five to six (5-6) months
from the date of this Notice A notice of the actual date of the Sheriff's Sale will be sent to you before the
sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER :
Name of Lender: Chase Home Finance LLC
Address: Mail Code OH4-7356
3415 Vision Drive
Columbus, OH 43219-6009
Phone Number: (800) 848-9380
Fax Number: (614) 422-7912
Contact Person: Justin Powell-Wilburn
E-mail Address: Justin.L.Powell-Wilburn@chase.com
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the
mortgaged Property and your right to occupy it. If you continue to live in the Property after the sheriff's sale, a
lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE-You might be eligible to sell or transfer your home to a buyer or
transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are
satisfied. To determine eligibility, you must contact our office to verify the assumability of your Property.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR
YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Sincerely,
Collections Department
Chase Home Finance LLC
(800) 848-9380
(800) 582-0542 TDD / Text Telephone
Enclosures
1. Federal Trade Commission Pamphlet
2. HEMAP Consumer Credit Counseling Agencies
3. Homeowner's Assistance Brochure
CERTIFIED MAIL: Return Receipt Requested and First Class Mail
An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers
about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration,
"Borrowers should beware of any organization that attempts to charge a fee for housing counseling or
modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams
should be reported to PreventLoanScams.org, or by calling (888) 995-HOPE. Chase offers loan
modification assistance free of charge (i.e., no modification fee required). Please call us immediately at
(800) 848-9380 to discuss your options. The longer you delay the fewer options you may have.
Chase Home Finance LLC is a debt collector.
BR860
Chase Home Finance LLC (FL5-7734)
PO BOX 44090
Jacksonville, FL 32231-4090
November 5, 2010
8-746-51545-0001820-001-011-000-000-000
MAYGIN E BARBOUR
561 CONODOGUINET AVE
CARLISLE PA 17015-8972
Acceleration Warning (Notice of Intent to Foreclose)
Account: 'the Loan")
Property Address: 561 CONODOGUINET AVE
CARLISLE, PA 17015 (the "Property")
Dear MAYGIN E BARBOUR:
ACT 91 NOTICE
CHASE O
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
N
the attached cages.
The HO EOWNE S' EMER .ENCY MORTGAGE ASSISTANCE. PRO AM
COUNSELING AGENCY WITHIN THIRTY-THREE (33) DAYS OF THE DATE OF
TMq NnTi(''F._ Take thic Notiee with vnu when you meet with the CounselinLy A2encv.
The name, address, and phone number of Consumer Credit Counseling Agencies serving
9.1
impaired hearing may call 17171780-186
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help explain
it. You may also want to contact an attorney in your area. The local bar association may
be able to help you find a lawyer.
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PUES AFECTA
SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENIDO DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUEDE SER ELEGIBLE PARA UN PRESTAMO POR EL PROGRAMA
LLAMADO "HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE
PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S):
PROPERTY ADDRESS:
LOAN ACCT. NUMBER:
ORIGINAL LENDER:
CURRENT LENDER/SERVICER:
MAYGIN E BARBOUR
TRAVIS A HARPER
561 CONODOGUINET AVE
CARLISLE, PA 17015
SOVEREIGN BANK
Chase Home Finance LLC
HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENCY
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE FOR
EMERGENCY MORTGAGE ASSISTANCE.
IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND YOUR
CONTROL,
IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YOUR
MORTGAGE PAYMENTS, AND
IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY THE
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECLOSURE-Under the Act, you are entitled to a temporary stay of
foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three [3] days for mailing).
During that time, you must arrange and attend a "face-to-face" meeting with one of the Consumer Credit
Counseling Agencies listed at the end of this NoticeTHIS MEETING MUST OCCUR WITHIN
THIRTY-THREE (33) DAYS OF THE DATE OF THIS NOTICE. IF YOU DO NOT APPLY FOR
EMERGENCY MORTGAGE ASSISTANCE YOU MUST BRING YOUR MORTGAGE UP TO DATE.
THE PART OF THIS NOTICE CALLED "HOW TO CURE YOUR MORTGAGE DEFAULT" EXPLAINS
HOW TO BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIES-If you meet with one of the Consumer Credit
Counseling Agencies listed at the end of this Notice, the lender may NOT take action against you for thirty (30)
days after the date of this meeting.The names addresses- and telephone numbers of designated Consumer Credit
Counseline Agencies for the county in which the Property is located are set forth at the end of this Noticdt is
only necessary to schedule one face-to-face meeting. Advise your lendeimmediatelyof your intentions.
APPLICATION FOR MORTGAGE ASSISTANCE-Your mortgage is in default for the reasons set
forth later in this Notice (see following pages for specific information about the nature of your default). You
have the right to apply for financial assistance from the Homeowners' Emergency Mortgage Assistance
Program ("HEMAP"). To do so, you must fill out, sign, and file a completed HEMAP application with one of
the designated Consumer Credit Counseling Agencies listed at the end of this Notice. Only Consumer Credit
Counseling Agencies have applications for the program and they will assist you in submitting a complete
application to the Pennsylvania Housing Finance Agency. To temporarily stop the lender from filing a
foreclosure action, your application MUST be forwarded to Pennsylvania Housing Finance Agency
("PHFA") and received within thirty (30) days of your face-to-face meeting with the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A
MEETING WITH A COUNSELING AGENCY WITHIN THIRTY-THREE (33) DAYS OF THE
POSTMARK DATE OF THIS NOTICE AND FILE AN APPLICATION WITH THE PHFA WITHIN
THIRTY (30) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY
PREVENTED FROM STARTING A FORECLOSURE ACTION AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THESE TIME
PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY
TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
AGENCY ACTION-Available funds for emergency mortgage assistance are very limited. They will be
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that time, no
foreclosure proceedings will be pursued against you if you have met the time requirements set forth above.
You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION IN
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATION
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLLECT
THE DEBT.
(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT (bring it up to
date).
NATURE OF THE DEFAULT-The Mortgage debt held by the above lender on your Property located at:
561 CONODOGUINET AVE, CARLISLE, PA 17015 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS starting 09/01/2010 through
11/05/2010, and the following amounts are now past due.
If you have any questions about the amounts below, please contact us as soon as possible at (800) 848-9380.
Total Monthly Payments Past Due: $2,716.26
Late Charges: $0.00
Insufficient Funds (NSF) Fees: $0.00
Other Fees and Advances*: $0.00
Amount Held in Suspense: $41.92
TOTAL AMOUNT DUE TO CURE DEFAULT : $2,674.34
*Other Fees and Advances include those amounts allowed by your Note and Security
Instrument. Ifyou need additional information regarding any of these amounts, please
contact us at the number provided below.
HOW TO CURE THE DEFAULT-You may cure the default within THIRTY (30) DAYS of the date of
this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$2,674.34, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME DUE
DURING THE THIRTY (30)-DAY PERIOD. Payments must be made in the form of cash, cashier's check,
money order. or certified check and sent to
Regular Mail: Chase Home Finance LLC
PO BOX 78420
Phoenix, AZ 85062-8420
Overnight Mail: Chase Home Finance LLC
Attention PO BOX 78420
1820 East Sky Harbor Circle South
Phoenix, AZ 85034-9700
IF YOU DO NOT CURE THE DEFAULT-If you do not cure the default within THIRTY (30) DAYS of
the date of this Notice, the lender intends to exercise its rights to accelerate the mortgage debtThis
means that the entire outstanding balance of this debt will be considered due immediately and you may lose
the chance to pay the mortgage in monthly installments. If full payment of the total amount past due is not
made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal action to
foreclose upon your mortgaged Property
IF THE MORTGAGE IS FORECLOSED UPON-The mortgaged Property will be sold by the sheriff to
pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency before
the lender begins legal proceedings against you, you will still be required to pay the reasonable attorney fees
that were actually incurred, up to $50.00. However, if legal proceedings are started against you, you will
have to pay all reasonable attorney fees actually incurred by the lender even if they exceed $50.00. Any
attorney fees will be added to the amount you owe the lender, which may also include other reasonable costs.
If you cure the default within the THIRTY (30)-DAY period, you will not be required to pay attorney
fees.
OTHER 1,ENDF.R REMEDIES-The lender may also sue you personally for the unpaid principal balance
and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE -If you have not cured the default
within the THIRTY (30)-DAY period and foreclosure proceedings have begunyou still have the right to curl
paving the total amount then pa due- 12l us a plate or other charges then due. reasonable attorney fees and
costs connected with the foreclosure sale and any other costs connected with the Sheriff's Sale as specified in
writing by the lender, and by performing= other requirements under the mortgageCuring your default in
the manner set forth in this Notice will restore your mortgage to the same position as if you had never
defaulted.
FARL IEST POSSIBLE SHERIFF'S SALE DATE-It is estimated that the earliest date that such a
sheriff's sale of the mortgaged Property could be held would batpproximately five to six (5-6) months
from the date of this Notice A notice of the actual date of the Sheriff s Sale will be sent to you before the
sale. Of course, the amount needed to cure the default will increase the longer you wait. You may find out at
any time exactly what the required payment or action will be by contacting the lender.
HOW TO CONTACT THE LENDER :
Name of Lender: Chase Home Finance LLC
Address:
Phone Number:
Fax Number:
Contact Person:
E-mail Address:
Mail Code OH4-7356
3415 Vision Drive
Columbus, OH 43219-6009
(800) 848-9380
(614) 422-7912
Justin Powell-Wilburn
Justin.L.Powell-Wilburn@chase.com
EFFECT OF SHERIFF'S SALE-You should realize that a Sheriff's Sale will end your ownership of the
mortgaged Property and your right to occupy it. If you continue to live in the Property after the sheriff's sale, a
lawsuit to remove you and your furnishings and other belongings could be started by the lender at any time.
ASSUMPTION OF MORTGAGE-You might be eligible to sell or transfer your home to a buyer or
transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage are
satisfied. To determine eligibility, you must contact our office to verify the assumability of your Property.
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS
DEBT.
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT
HAD OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS
RIGHT TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR
YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDING
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION BY
THE LENDER.
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Sincerely,
Collections Department
Chase Home Finance LLC
(800) 848-9380
(800) 582-0542 TDD / Text Telephone
Enclosures
1. Federal Trade Commission Pamphlet
2. HEMAP Consumer Credit Counseling Agencies
3. Homeowner's Assistance Brochure
CERTIFIED MAIL: Retum Receipt Requested and First Class Mail
An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers
about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration,
"Borrowers should beware of any organization that attempts to charge a fee for housing counseling or
modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams
should be reported to PreventLoanScams.org, or by calling (888) 995-HOPE. Chase offers loan
modification assistance free of charge (i.e., no modification fee required). Please call us immediately at
(800) 848-9380 to discuss your options. The longer you delay the fewer options you may have.
Chase Home Finance LLC is a debt collector.
BR860
s
A Q f VERIFICATION 1 f `?
r l ?a ` ? .. Yy hereby states that he/she is V I ?• ` e y d
u
of JPMorgan Chase Bank, N.A., in this matter and is authorized to make this Verification.
The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are
true and correct to the best of his/her knowledge, information and belief.
The undersigned understands that this statement is made subject to the penalties of 18 Pa.
C.S. Sec. 4904 relating to unworn falsification to authorities.
DATE: "I a ?0 I
&\?Jl W 101? T C" l' Pnn?
Company: JPMorgan Chase Bank, N.A.
S&D FILE NO: 11-039163
Travis A. Harper and Maygin E. Barbour
Fax Server 5 / 17 / 2012 11: 31 : 52 AM '?AGF 7. /'J C 5 Fax S°"
?tx .t P ainf (s)
VS..
?(AV PY' 6t 1/0
L.. rjy'k)f Defendant(s)
r..
l ry -
IN'1'1-117 COURT OFC OMM,ON PLEAS Of
CUMBERLAND COUNTY, =
PENq\1SYLV ANIA -
-er-.
.? - -T
19-3101 Civil >` { r
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 ably; to participate in a court-supervised conciliation conference in an effort to resolve this
matter Nvith your lender.
If you du not have a larivyer, you must take the t'ollowing stelis to he eligible for n
conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact
MidPenn Legal Services at (717) 243-9100 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 that legal representative within twenty (20) days of the
appointment date, Dui ing that meeting. you must provide the legal representative with all requested
financial information so thata 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 ofthe service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportuiiit)! to meet with a representative ofyour
lender in an attempt to «ork out reasonable arrangements with your lender before the mortgage
forecl05Ure suit proceeds forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be
eligible fora 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 inforniation so chat 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)
(lays of the service upon you of the foreclosure complaint. I .f you do so and <,a conciliation coin Terence is
scheduled,, you will have an opportunity to meet with a representative of your tender in an attempt to
work out reasonable arrangements with your Ierider before the mortgage foreclosure suit proceeds.
forward,
IF YOU WISH TO SAVE YOUR IIOME, YOU MUST ACT QUICKLY AND
TAKE THE STEPS REQUERED BY THIS NOTICE. THIS PKOCRAM IS FREE.
Respectfully submitted':
?t 1 1
Date ?' -
[Signature of Counsel for Plaintiff]
Fax Server 5/17/2012 11:31:53 AM FAGF. ?/C^5 F."X 5P- Pr
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:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different):
City:
Phone Numbers:
State: Zip:
Yes ? No ? Listing Date: Price:$?
Realtor Phone:
Yes ? No ?
State: Zip:
Home Office:
Cell: Other:
Email: -
# of people in household How Long?
Mailing Address:
City:
Phone Numbers:
Email:
# of people in household
State: Zip:
Home: Office:
Cell: Other:
How Long?
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 & Insurance:
Date of Last Payment:
Primary Reason for Default:
Is the Loan in Bankruptcy? Yes ? No
Fax Server 5/17/2012 11:31:53 AM 'AGE
If yes, provide names, location of court, case number & attorney
c./C?)5 Fp,x Sc=er
Assets
Home:
Other Real Estate:
Retirement Funds:
Investments:
Checking:
Savings:
Other.
Amount Owed Value
$ $
$ $
$
$ $
Automobile #1: Model: Year:,,, --
Amount awed: Value:
Automobile #2: Model: Year:
Amount Owed: Value:-
Other transportation (automobiles boats, motorcycles): Model:
Year: Amount Owed: Value:
Monthly Income:
Name of Employers-
1.
3
Additional Income Description (not wages):
I.- monthly amount:
2, monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
tip.. e.........e..41t- ^A%r inrhvda RYnPncaa vnll are currently navine)
1YIV lpll i:rA iW4J. i aw
EXPENSE .?. v - - -----
AMOUNT EXPENSE
AMOUNT
Mona a Food
2 Mort a e Utilities
Car Payment(s) Condo/Neigh. Fees
Auto Insurance Med. not covered
Auto fuel/re airs Othec o . Payment
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Money
Da /Child Care/Tuit. Other E)-------
Amount Available for Monthly Mortgage Payments Based on Income & Expenses:
Have you been working with a Housing Counseling Agency?
Yes 0 No 0
If yes, please provide the following information:
Counseling Agency:
Counselor:
Phone (Office): Fax: 13
Fax Server
Email:
V yo
5/17/2012 11:31.53 AM ^AGE 5/n1J5 F P,
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEMAP) assistance?
Yes Q 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 0 No ?
If yes, please indicate the status of those negotiations:
Please provide the following information, if know, regarding your lender or lender's loan
servicing company:
bender's Contact (Name):
Phone:
Servicing Company (Name):
Contact: Phone:
It-We, , authorize the above
named to use/refer this information to my lenderlservicer for the sole
purpose of evaluating m financial situation for possible mortgage options. I/We
understand that IIWe amlare under no obligation to use the services provided by the
above named
Borrower Signature
Co-Borrower Signature
Date
Date
Please forward this document along with the following information to lender and
lender's counsel:
Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting
documentation
(hardship letter)
Listing agreement (if property is currently on the market)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
LIE is
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
2' 12 JUN I I Pl?-- 2: 16
PENNSYLvA??{'a
JP Morgan Chase Bank, NA
VS.
Travis A. Harper (et al.)
Case Number
2012-3107
SHERIFF'S RETURN OF SERVICE
05/22/2012 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: Maygin E. Barbour, 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 Maygin E. Barbour. Request
for service at 7 Pine Road, Apartment 605, Mount Holly Springs, Pennsylvania 17065 the Defendant was
not found. Deputies were advised, Maygin E. Bkarbour has not resided at this address in over three
years.
05/22/2012 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: Travis A. Harper, 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 Travis A. Harper. Request for
service at 7 Pine Road, Apartment 605, Mount Holly Springs, Pennsylvania 17065 the Defendant was not
found. Deputies were advised, Travis A. Harper has not resided at this address in over three years.
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: Travis A. Harper, 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 Travis A. Harper. Request for
service at 561 Conodoguinet Avenue, Carlisle, Pennsylvania 17015 is vacant. The Carlisle Postmaster
has advised, the forwarding order for Travis A. Harper has expired.
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: Maygin E. Barbour, 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 Maygin E. Barbour. Request
for service at 561 Conodoguinet Avenue, Carlisle, Pennsylvania 17015 is vacant. The Carlisle Postmastei
has advised, the forwarding order for Maygin E. Barbour has expired.
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: Occupant of 561 Conodoguinet Avenue, Carlisle,
Pennsylvania 17015, but was unable to locate them 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 Occupant. Request for service at 561 Conodoguinet Avenue, Carlisle,
Pennsylvania 17015 is vacant.
SHERIFF COST: $152.00
June 06, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Telecsoft, Inc.
f, dA 0 1171, ,v11:;l
J/1:!/LV1L 11. J1. 17 'J A1'1 r!'fVL
atnttF.l(s)
VS..
1N11.113COUkT O COMN ON PLEAS Or
CUIvIBERLAND COUNTY,
PENNSYLVANIA
Defendant(s) Civil
NOTICE OF RESIDENTIAL ]' ORTGAGE FORECLOSURE
DIVERSION PROGRAM
r-n
?C)
You have been served with a foreclosure complaint that: could cause y ou to lose your homc.
If you oWVn and live .in the residential: property'wili.ch'is. the subject of this foreclosure action,
you may be able to, participate in a court-supervised conciliation' Con erence in all efiortto resolve this
171atter with your lender.
If you. do not have a lawyer, you must take the following stelis'to be eligible ror it
conciliation conference. First; within nti?enty(20) days oF.youi.ieceiptof this notice .you ml. t contact
MidPcnn Legal Services at (717) 24' )-9400 extension 2510 or (800) 822-5285 extension .2510 and
request appointhient of a leryal representative at nocharge to you. Office you have been appointed a ie al
rcpresentat.vc, you must I3ro111piIv n1Cet with that legal representative within twenty (20) days of the V
appointment date, D011112 that meeting, you must provide the legal representative with all requested
Financial, infoi•matioii so diata Ican resolution proposal can be preplared oil your behalf. If yoll and }'our
l,-,,at representative complete a finartciaf wcrksheet in the format aitachcd Hereto; the legal representative
,a ill prepare and file a Request for Conciliation Conference with the Court, ivikli Must be led with the
Court within sixty (GO) days of the service upon }you oftlie foreclosure complakit..I.fyou do so and a
conciliation conference is scheduNd, you will ha el an oppatuhity to in,,etwith a. representative ot'your
lender in an attempt to work out reasonable arr,inaements with your lender befiire. the :nortgago
foreclosure suit proceeds forward.
If you aare.reprewnted by a l.twyer; you anal your lawyer must take the fo1101Vin6 steles to be
eligible for a conciliation conference. It is not necessary for you to contact Midl'enn Legal. Service for
the appointment of a,legal representativc, 14owever.. you must provide, your lawyer with all requested
l1naiicial infarnlation so rhat a loan resolution proposal can be prepared on your Eicllal% If you mid your
lawyer complete a financial worksheet in the format attaclied hereto'. your lawyer.will prepare and file a
Request for Conciliation Conference. witli th. Court, wliich must be filed with die Court Nvithin sixty (60)
clays of the service upon you o f (h Foreclosure coin plaint;,If you do so and A conciIiation con Ference is
schedulcd, you will have an opportunity to meet with a repremntative of your ;ender in an attempt to
work nut reasonable arrangements,w.ith your lender before the mortgage iorcc€osure suit proceeds.
forward.
IF YOU «'isll TO S WE YOM HOME. You NVIUS'r A01 QIJICICLY AND
TAKE'THE STEPS REQUIRED BY THIS NOTICE. TH1S PRQGRAIFI IS FREE,
Respectfully submitted.
?i`?? Utitl !'
Date
[Signature of Counsel for Plaintiff]
?a
c.,
r_.
A QA
Cumberland County Residential Mortgage Foreclosure Diversion Program
Financial Worksheet
Bate
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:
Borrower name(s):
Property Address:
City:
Is the property for sale?
Realtor Name:
Borrower Occupied?
Mailing Address (if different):
City:
Phone Numbers:
Email:
# of people in household
Mailing Address:
City:
Phone Numbers:
State: Zip:
Yes ? No ? Listing Date: Price:$
Realtor Phone:
Yes ? No ?
State: Zip:
Home, Office:
Cell: Other:
How Long?
State: Zip:
Home: Office:
Cell: Other:
Email:
# of people in household How Long?
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 & Insurance:
Date of Last. Payment:
Primary Reason for Default:
Is the Loan in Bankruptcy? Yes ? No ?
1 U A V V ,i V l+A
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: Year:
Amount Owed: Value:
Automobile #z: Model: Year:
Amount Owed: Value:_
Other transportation (automobiles, boats, motorcycles): Model:
Year: Amount Owed: Value:.
Monthly Income:
Name of Employers:
1.
3.
Additional Income Description (not wages):
I . monthly amount:
? monthly amount:
Borrower Pay Days: Co-Borrower Pay Days:
Monthly Expenses: (Please only include expenses you are currently oavine)
EXPENSE AMOUNT EXPENSE AMOUNT
Morta a Food
2 Mortgage Utilities
Car Payment(s) CondolNei h. Fees
Auto Insurance Med. not covered)
Auto fuel/re airs Other prop. Pa ent
Install. Loan Payment Cable TV
Child Su ort/Alim. Spending Mone
Da /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): Fax:
2
r dR J:.. V G..
Email:
J/ A!/ L V A L A l V i
Have you made application for Homeowners Emergency Mortgage Assistance Program
(HEIvtAP) assistance?
Yes D 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 0 No ?
if yes, please indicate the status of those negotiations:
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:
1[we, , authorize the above
named to use/refer this information to my lenderlservicer for the sole
purpose of evaluating m financial situation for possible mortgage options. [/We
understand that I/We amlare under no obligation to use the services provided by the
above named
Borrower Signature Date
Co-Borrower Signature
Date
Please fonvard this document along with the following information to lender and
lender's counsel:
Proof of income
Past 2 bank statements
Proof of any expected income for the last 45 days
Copy of a current utility bill
Letter explaining reason for delinquency and any supporting
documentation
(hardship letter)
tit Listing agreement (if property is currently on the market)
SHAPIRO & DeNARDO, LLC ; :. QL Ep-OF FICA
BY: CHRISTOPHER A. DeNARDO, ESQUIRE rift PpofNaTAR
ATTORNEY I.D. NO: PA Bar # 78447 2012 JUL ] ] y
3600 HORIZON DRIVE, SUITE 150 'Of 10: 4 5
KING OF PRUSSIA, PA 19406 CUNRERL COUNTY
,ggo
TELEPHONE: (610)278-6800 PE SYLVAWIA
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association COURT OF COMMON PLEAS
PLAINTIFF ; CIVIL DIVISION
CUMBERLAND COUNTY
VS.
NO: 12-3107
Travis A. Harper and Maygin E. Barbour
DEFENDANTS '
PRAECIPE FOR REINSTATEMENT
TO THE PROTHONOTARY:
Kindly reinstate the Complaint in the above-captioned matter.
SHAPIRO & DeNARDO, LLC
BY: _
Christopher A. DeNardo, Esquire
Attorney for Plaintiff
31??S?S
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson « ..Ed -li . `t- iC
Sheriff pf
'tv' tip l iiitlfl I ?C C C ! 1. .a?
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
'?)E- , - ,F
2012 J IL 23 AM 8.16
CUMBERLAND C01UN .°i
PENNSY! VAI
JP Morgan Chase Bank, NA
vs. Case Numbe
Travis A. Harper (et al.) 2012-3107
SHERIFF'S RETURN OF SERVICE
07/16/2012 03:42 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on Jul 16
2012 at 1542 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Travis A. Harper, by making known unto himself personally, at 1220 Spring Road,
Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him
personally the said true and correct copy of the same. i7
PUTY
07/16/2012 03:42 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on Jul 16
2012 at 1542 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the
within named defendant, to wit: Maygin E. Barbour, by making known unto Travis Harper, adult in charge
at 1220 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same lime
handing to him personally the said true and correct copy of the same.
HALL, DEPUTY
SHERIFF COST: $50.00
July 17, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHEF: A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA., PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Travis A. Harper anal Maygin E. Barbour
DEFENDANTS
__ _7
;~
- ,', „
~.. ;`..,
COURT OF CO',MMON PLE,~ S
CIVIL DIVISION
CUMBERLAND COUNTY
N0:12-3107
PRAECIPE FOR JUDGMENT FOR FAILURE TO ANSWER
AND ASSESSMENT OF DAMAGES
Enter Judgment IN REM in the amount of $151,643.78 in favor of the; Plaintiff and
against the Defendants, jointly and severally, for failure; to file an answer to Plaintiffs Complaint
in Mortgage Foreclosure within 20 days from service thereof and assess Plaintiffs damages as
follows and calculated as stated in the Complaint:
Principal of Mortgage Debt Due and Unpaid $124,923.33
Interest continuing from August 1, 2010 $16,240.12
Property Inspection $162.30
Property Preservation $2,846.00
Attorney Fees & Costs of Foreclosure ~z, $1,838.00
TOTAL ~~y $151,643.78
BY: ~~
Christopher A. DeNardo, Esquire
o r Plainti
A.ND NOW, judgment is entered in favor of the Plaintiff and ainst dants an
damages are assessed as above in the sum of $151,643.78.
w
Pro. ro~thy.
11-039163
acv-~~\1~.5d~ U
Ck~ 14 c,~~~ I S
~~agass7
~~~h~ ~..~I~~
SHAI'IRO & DeNARDO, LLC
BY: CHRISTOPHEF: A. DeNARDO, ESQUIRE
ATTORNEY L.D. NO: PA Bar # 78447
3600 HORIZON DR[VE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association
3415 Vision Drive
Columbus, OH 43219
PLA[NTIFF
COURT OF COiVIMON PLE1~,S
CUMBERLANL) COUNTY
l O: I-~1()7
VS.
[ C~~.11(4 1. ~1fRi'~lt'~'
~Ellil
'tiaw°~in 1. Barbour
DEFENDAN~'C(S)
STATE OF: Pennsylvania
COUNTY OF: Mont og mery
AFFIDAVIT OF NON-MILITARY SERVICE
THE UNDERSIGNED being duly sworn, states that he/she; is over the age of eighteen
years and competent to make this affidavit and the following averments are based upon
information contained in the records of the Plaintiff or servicing agent of the Plaintiff and that
the above captioned Defendants last known address is as set forth in. the caption and they are not
to the best of our knowledge, information or belief, in the Military or Naval Service of the
United States of America or its Allies as defined in the Soldiers and Sailors Civil Relief Act of
1940. as amended.
SHAPIRO,&'~D/~~NA.RDO, LLC
Christopher A. DeNardo, Esquire
Sworn to and subscribed
~ .,_ .
,..
before n-ie this ~ ~ ~ ~~_ day
rV .
f~' '~,p~ fir. ~, ,201
~ `!- 2.
'~--.,._.. ,~y ~,, y is .--
NOtai'~ t'ilbhi[[[C...
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY LD. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF~' PRUSSIA, PA 19406
TELF,PHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Travis A. Harper and Maygin E. Barbour
DEFENDANTS
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 12-3107
CERTIFICATION OF MAILING NOTICE UNDER RULE 237.1
The undersigned hereby certifies that a Written Notice of Intention to File a Praecipe for
the Entry of Default Judgment was mailed to the defendant (s) and to his, her, their attorney of
record, if any, after the default occurred and at least (10) days prior to the date of the filing of the
Praecipe. Said Notice was sent on the date set forth in the copy of said Notice attached hereto,
August 7, 2012 to the following Defendants:
Travis A. Harper, 1220 Spring Road, Carlisle, PA 17013
Maygin E. Barbour, 1220 Spring Road, Carlisle, PA 17013
~-~--_ ;r ~ ' ~~` _ ;
Tiffany Donnell., Legal Assistant
to Christopher A.. DeNardo, EsQuire for
Shapiro &DeNardo, LLC
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & DFILE N0. 11-039163
JPMorgan Chase Bank, National Association ;
PLAINTIFF ;
VS.
Travis A. Harper and Maygin E. Barbour ;
DEFENDANTS
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO. 12-3107
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Travis A. Harper
DATE OF NOTICE: August 7, 2012
You are in default because you have failed to enter a written appearance personally or by attorney
and file in writing with the court your defenses or objections to the claims set forth against you. Unless you
act within ten (10) days from the date of this notice, a Judgment may be entered against you without a
hearing and you may lose your property or other important rights. You should take this notice to a lawyer at
once. if you do not have a lawyer or cannot afford one, go to or telephone the following office to find out
where you can get legal help:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
i~`O'I'1FIC't~,C~I~N IMI'ORTr1)ti`'I'h:
t'sted sr cncctentra ct~ cstado de rcbelditt pc~r no Itaber tc:~m,~tdi:~ la accian rec)uirida de :~;u p~trte en
~~~t~• ~us~~. :~1 nu tonutr Itt action clebidtt clenu•o de un t4rrnino de die (1 U) dins de la l~:~ha do csta
ne~tilie~tcit~n. el tribuna I?c~dt•4i, sits necesidad de com~arareccr usted in cone o cscuchar hrectba
al~~tnta. dictar sentcnci~t en su contra. l"~sted httede perder bienia )`' otrr~s dercchos impcirtantes.
Dek~r lle~ar esta nr~tific~~cion a ttn abogado inunediatanlente. 4i ustcd no time a1~r7~~~ttlc+ ~~ si no
Rene dinerc~ sulicicntc ptn-a tal scrt~ici«. ~~a~>~t en persona o llat~tre por a°lelc~nc~ a la cif"icing cuya
direction se eitcucntra ~~scrita aba)o Iaar~t a~•erignar dcnulc sc l~uede ccanse~.;>.tir r~tssitertciit le~~al:
Cun3berland C:ountr~ La~~ti~yer IZef~rral Ser~~icc
Cttn~berl~>nd Cottnty }3ar 1ssc~ci~rtic~n
32 Sc~utia 13aliord ~~trcet
Carlisle I':1 171
717-249- ± I EiG
Pl'R~Li.~~'iN'!''I'O 'I'hlh, FAIR L)h~I3'I" COL,LI:C'I'IOi~` 1'Itf'~C"I`IC'C~:~~ f1~T ~'OU 111th;
:1I)~'ISII) 7'II.-~"C `I'IIIS 1.f1~ti` I~TRi'11 IS I)I?I~.illf;I)'I'() BI r~ DC?I3"I' Ct)I~I.,I~,C"I'OIZ
:~`I~"!'Clll'"I'I~G 'C"O CY)L.I_,h:G`I' A I)E13'I', ;1~1' I!~I~()ItV1:1'I'1()Iti C)13'I';11?VC?I) `'PILL.. I3I~;
l`SI~,D 1~ OR 'I'Ilr~~l' I'tItPt)~E~.
I'I::IZ~C?NS 'I'(3 ~'c~II(?1\fl 1tlJl..tT Z7.lxNt)'1 IC"I:; ~IN~I' "1'(?:
1 t~Y~ i~ '~. 1 [arl~er. 122Q 5prin~~ Rand. Carlisle. 1'r~ 17(:)1
'~~la~~~in 1~~. [3art~ortr, I?ZU S1~rin;~ Road. C ~trlislc. 1':~l 1701?
_. ,
,` j _ _
C'h~t5tupit~a r~.~ll~Narda 1=scluir~~
Shttl~ira K UeNarclc~, I.[.C.'
;lttcu•ryey liar 1'laintifT
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-b800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association ;
PLAINTIFF
VS. '
Travis A. Harper and Maygin E. Barbour
DEFENDANTS
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 12-3107
NOTICE OF INTENTION TO TAKE DEFAULT
UNDER Pa.R.C.P. 237.1
IMPORTANT NOTICE
TO: Maygin E. Barbour
DATE OF NOTICE: August 7, 2012
You are in default because you have failed to enter a written appearance personally or by attorney
and file in writing with the court your defenses or objections to the claims set forth against you. Unless you
act within ten (10) days from the date of this notice, a Judgment may be entered against you without a
hearing and you may lose your property or other important rights. You should take this notice to a lawyer at
once. If you do not have a lawyer or cannot afford one, go to or telephone the following ofFice to find out
where you can get legal help:
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249.3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT 'YOU ARE ADVISED
THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR ATTEMPTING TO
COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
ti O'I' I F I C:4 C; I (.~ ~' 11'I I' (:) R"I':11L' "I' C
l!~t~Cl ~;~ tni:uentl<, cn est~lc]a de rel~+;;lda por llo ilal~er t~~~rnacli~ la aecic7n requirici~l cl~ s1l pane en
~st~ ett>h. ~1! llcl tan~tu• la aeeion cleE,ida dcrtlro de tm termil~o cle slier (,I(1~> clias de la l'ecl~l, de esta
u~~tilicaci~~n. el trihtlna pozlra, sin nceesidati plc conlpararecer llstetl irl corn. o c:scl~lcha.r preilba
al~~ull,l.. ~lictur ~~nlc~ncia en su ct~nlra. l)sted ]~ui;de ]~el•d~~t• bitncs ~r c~tr~~s clel•echos in~E~ort,lntes.
i)ehe lie~~ar esta notilieacion a ulla~bagada ilnmeliiatanr~ltte. Si usted no belle aba~..ado ~~ si na
li~~ne ~iil~ero sufieiel~te Para tai st,~rr-icic~, vati~a en pel-sona o llan~e par t~aefbno a la al~eirul cuva
~Itl'eCC't~Jil Se i:nCUeCltl'a t:serltl ~Iba]c) ]Yclril iii"l;t'lLttllt' (lalllle se pIICCIe eal7se~lllr ilsslt4llC`lil legal:
C'unliJerlancl Count~• L.a~~~yer I~tef~:rral Service
Cllnl~ierland Col~uat~' i3ar :~lssaeiatian
3? Sautll 13ec1lurd ~~trcct
Carl is[e. I':1 l 7{113
7 l 7-~=#cI_ i 1 GG
I'['ItST.-:1ti~i" "C() 'I"i-III: FAII21)L:I3"I' C()LI.:I?C'I'IOti PI2.~C I'IC'I~~> t1C'I' 1'C)l- :\It~~
:11)1'ISID 'I"1IA'I" "I'I-IIS LAW F'IItA~I IS I1hF11~I?I) "~CC) I3I% A I?C~I~"I' E'OL.I,~C'I'(,)12
.~'[••I'I::~It''I'I`f~ `I'O C'OLLIC"C :~ I}LLI3'I'..~~N~' I\I~'ORi~I1~'I'LC)iti C)I3'I':VtiI?I~ «'IL.L I3I?
l~SCU FOiZ •['IiA'1' I'l!I2I'OSI/.
PI~IZS(~NS 'I'E) ~~4'I [(:)1\1 (tl~lhl~~~? ~7. I ,t~'C)'l I~ l~~ tiL N l~ 'I~C):
'l~ravis :~. llarher. 1 ??0 Spritl~; lZaacl. Carlisle. PF1 (7(JI3
1i.lr~~i!~ 1-:. 13ar(~otll~. !.'?0 ~pri~t~ iZ.ua~f. Carlisle. I'r~ 170]3
Ctu I~taph~r r~. ll~:~'Glrcla, I;syuire.
Shtl~airo cl Dc;Narclr.>, ITC'
Attt71-rlev for I'laintif'f
SHAPIRO & DeNAl2D0, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING Oh PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association ~ COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. ~ CUMBERLAND COUNTY
Travis A. Harper and Maygin E. Barbour
DEFENDANTS NC):12-3107
CERTIFICATE OF SERVICE
I, Christopher A. DeNardo, Esquire, Attorney for the Plaintiff, hereby certify that I have
served by first class mail, postage prepaid, true and correct copies of the attached papers upon
the following person(s) or their attorney of record:
Travis A. Harper, 1220 Spring Road, Carlisle, PA 17013
Maygin E. Barbour, 1220 Spring Road, Carlisle, PA 17013
Date Mailed: ~~ I ~ _
SHAPIRC- & DeNARDO, LLC
BY: ~~
Christopher A. DeNardo, Esquire
Attorney for Plaintiff
SHAPIRO & DeNARDO, LLC
BY: CHKISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA., PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Travis A. Harper and Maygin E. Barbour
DEFENDANTS
CC-URT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNTY
N0:12-3107
CERTIFICATION OF ADDRESS
I hereby certify that the correct address of the judgment creditor (Plaintiff) is:
JPMorgan Chase Bank, National Association
3415 Vision Drive
Columbus, OH 43219
and that the last kno~,vn addresses of the judgment debtors (Defendants) are:
Travis A. Harper
1220 Spring Road
Carlisle, PA 17013
Maygin E. Barbour
1220 Spring Road
Carlisle, PA 17013
SHAPIRC- & DeNARI:-O, LLC
BY: ~-'~-x~ -
Christopher A. DeNardo, Esquire
Attorney Ior Plaintiff
11-039163
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
David D. Buell
Prothonotary
Travis A. Harper
] 220 Spring Road
Carlisle, P,A 17013
JPMorgan Chase Bank, National Association ~ COURT OF CC-MMON PL1=;AS
PLAINTIFF CIVIL DIVISION
VS. ~ CUMBERLAND COUNTY
Travis A. Harper and Maygin E. Barbour
DEFENDANTS NO: 12-3107
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below-.
David D. I3ue11
Prothonotary
[:KX] Judgment by Default
[ ]Judgment: for Possession e
[ ]Judgment: on Award of Arbitration w~ a~h~
[ ]Judgment; on Verdict
[ ]Judgment on Court Findings
IF YOU HAVE AN'Y QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY CHRISTOPHER A. DENARDO, ESQUIRE AT (610;1278-6800.
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
Cumberland County Clerk
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
David D. Buell
Prothonotary
Maygin E. Barbour
1220 Spring Road
Carlisle, PA 17013
JPMorgan Chase Bank, National Association ~ COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
~~5, CUMBERLAND COUNTY
Travis A. Harper and Maygin E. Barbour
DEFENDANTS NO: 12-3107
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
David D. Buell
Prothonotary
[XX] Judgment by Default
~, "~~ #'~
[ ]Judgment for Possession "
[ ]Judgment on Award of Arbitration ,~IaSI~~
[ ]Judgment on Verdict
[ ]Judgment on Court Findings
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CAI:L:
ATTORNEY CHRISTOPHER A. DENARDO, ESQUIRE AT (610)278-6800.
iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
PRAECIPE FOR WRIT OF EXECUTION
Caption:
JPMorgan Chase Bank, National Association
PLAINTIFF
vs.
'T'ravis A. Harper and Maygin E. Barbour
DEFENDANT(S)
,~
TO THE PROTHONOTARY OF THE SAID COURT: - ~~ -
.. .._ .. .
The undersigned hereby certifies that the below does not arise out of a retail installm~3rat-safe:, cot~ract, or
account based on a confession of judgment, but if it does, it is based on the appropriate ori~i~l proceer~ing filed
pursuant to Act 7 of 1966 as amended; and for real property pursuant to Act 6 of 1974 as amendec(
Issue writ of execution in the above matter to the Sheriff of Cumberland County, for debt, interest and costs, upon
the following described property of the defendant(s)
See attached Legal Description
PRAECIPE FOR ATTACHEMENT EXECUTION
Issue writ of attachment to the Sheriff of Cumberland Gounty, for debt, interest and costs, as above,
directing attachment against the above-named garnishee(s) for the following property (if real
estate, supply six copies of the description; supply four copies of lengthy personalty list)
and all other property of the defendant(s) in the possession, custody or control of the said garnishee(s).
(Indicate) Nndex this writ against the garnishee(s) as a lis pendens against real estate of the
defendant(s) described in the attached exhibit.
Date:___~ ~ ~G. ~~- Signature:
Print Name: Christopher A. DeNardo, Esquire
/~, Address: 3600 Horizon Drive, Suite 150
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King of Prussia, PA 19406
Attorney for: Plaintiff
Supreme Court ID # PA Bar # 78447
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(~,~-~ Ic~ooa~iS
~~a$a3S?
OConfessed Judgment
OOther 3 ~~,~
File No.
Amount Due $151,643.78
Interest September 31, 2012 to_ March 6,
2013 is $3,913.70
Atty's Comm
Costs -
~l~,a ,~ I2~ Tn~e~
WRIT OF EXECUTION and/or ATTACHMENT
COMMONV~'EALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO. 12-3107 Civil
C[VIL ACTION - LAGN
TC) "THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION Plaintiff (s)
From TRAVIS A. HARPER AND 1VIAYGIN E. BARBOUR
~ 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 -evied upon in the possession
o f"
G.~RNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishees} is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s r or otherwise disposing thereof;
(; } [f 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 1~een added as a
garnishee and is enjoined as above stated.
.Amount I_)ue: 5151,643.78 L.L.:.50
Interest FROM SEPTEMBER 3l, 2012 TO MARCH 6, 2013 IS $3,913.70
Atty's Comm: 4% Due Prothy: $2.25
Atty Paid: $365.00 Other Costs:
Plaintiff Paid,
Dare: 10/25/12 "~
VJ ~f ~ ~. ~ ~-C--~~
David D. Bue rothonotary ~
(.Seal) By: _ ~u.~!-
Dep ty
RE'QUEST'ING PARTY:
Name: CHRISTOPHER A. DENARDO, ESQUIRE
Address: SHAPIRO & DENARDO, LLC
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
Attorney for: PLAINTIFF
Trlephone:610-278-6800
Supreme Court ID No. 78447
Parcel No. 1
ALL that parcel of land situate in North Middleton Township, Cumberland County,
Pennsvlvania, bounded and described as follows:
BEGINNING at an existing iron pin located at the northwest corner of other lands of the
Grantee; thence along Lot No. 4 of the hereinafter named. Subdivision Plan North 21 ° 55' 24"
West a distance of 35.74 feet to a concrete monument; thence along other lands of the Grantor
South 69° 38' 39" East a distance of 79/66 feet to an iron pin; thence along L,ot No. 6 of the
hereinafter named Subdivision Plan South 21° 46' 48" West a distance of 40.08 feet to a point;
thence along other lands of the Grantee North 66° 31' 19" West a distance of 79.76 feet to an
existing imn pin, the point and place of BEGINNING.
BEING Lot No. 5 on the Preliminary/Final Subdivision Plan for Eagles Crossing C1olf Course
recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in
Plan Book 81, Page 149, and containing 3,020 square feet.
Parcel No. 2
ALL those certain two (2) tracts of land with improvements thereon erected situate in Meadow
Brook Park., North Middleton Township, Cumberland County, Pennsylvania, known as Lot No.
108 and 109, Section 3, of a. Plan of Lots laid out by Charles C. Swarner, said Plan of Lots being
recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle,
Pennsylvania, in Plan Book 2, page 34, and being more particularly described as follows:
TRACT NO l.: BEGINNING at a stake at the corner of Lot No. 107 belonging now or fi~nnerly
to Raymond Lee Fetter, and Conodoguinet Avenue; thence along the eastern line of said Lot,
North 23 degrees 08 minutes East, 100 feet to a point at the corner of said Lot and lands now or
fornerly of said Swarner, South 66 degrees 52 minutes East, 40 feet to a stake, the northwest
corner of L,ot No. 109, Tract No. 2 herein; thence along the western like of said L,crt No. 109,
Sough 23 degrees 08 minutes West. 100 feet to a point on the said Conodogtiiinet Avenue, thence
along said. !venue, North 66 degrees 52 minutes West, 40 feet to a stake, the Place of
BEGINNING.
TRACT N(_). 2: BEGINNING at a stake corner of Lot No. 108, Tract No. 2 herein, anal
Conodoguinet Avenue; thence North 23 degrees 08 minutes East, 100 feet to a stake corner to
Lot No. 108 on lands now or formerly of Charles C. Swarner; thence along said lands now or
formerly of Charles C. Swarner; thence South 23 degrees 08 minutes West, 1.00 feet to a stake,
corner of Lot No. 1 10 and said Conodoguinet Avenue; thence along said Avenue, North 66
degrees 52 minutes West, 40 feet to a stake, the Place of BEGINNING.
BEING Lot Nos. 108 and 109, Section 3, of a Plan of Lots laid out by Charles C. Swarner and
recorded as aforesaid on which there is erected a frame dwelling house.
PARCEL Nos. 29-18-1384-005 & 29-18-1384-OOSA
-BEING the same premises which Angela K. Hockensmith and Dennis Hockensmith, her
husband. by Deed dated July 16, 2009 and recorded in the Cumberland County Recorder of
Deeds office on September 29, 2009 as Deed Instrument Number 20093345(, granted and
conveyed unto Travis A. Harper and Maygin E. Barbour, both single people., as :Ioint Tenants
with Right of Survivorship and not as Tenants in Common.
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQ.
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Travis A. Harper and Maygin E. Barbour
DEFENDANTS
`'
COURT OF COMMON PLF,AS
CIVIL DIVISION
CUMBERLAND COUNTY
NO: 12-3107
AFFIDAVIT PURSUANT TO RULE 3129.1
JPMorgan Chase Bank, National Association, Plaintiff in the above action, sets forth, as
of the date the praecipe for the writ of execution was filed, the following information concerning
the real property located at 561 Conodoguinet Avenue, Carlisle, PA 17015.
2
3
Name and address of Owner(s) or Reputed Owner(s)
Travis A. Harper
1220 Spring Road
Carlisle, PA l 7013
Maygin E. Barbour
1220 Spring Road
Carlisle, PA 17013
Name and address of Defendants in the judgment:
Travis A. Harper
1220 Spring Road
Carlisle, PA 17013
Maygin E. Barbour
1220 Spring Road
Carlisle, PA 17013
Name, and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
JPMorgan Chase Bank, National Association
3415 Vision Drive
Columbus, OH 43219
4. Name and address of the last recorded holder of every mortgage of record:
JPMorgan Chase Bank, National Association, Plaintiff
3415 Vision Drive
Columbus, OH 43219
5. Name and address of every other person who has any record lien on the property:
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
6. Name and address of every other person who has any record interest in the property and
whose interest maybe affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
561 Conodoguinet Avenue
Carlisle, PA 17015
I vez7fy that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
SHA~~~ & DeNARDO, LLC
BY: K~ - ______
Christopher A. DeNardo, Esquire
I l -0391(13
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 1~0
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association
PLAINTIFF
VS.
Travis A. Harper and Maygin E. Barbour
DEFENDANTS
_, ; i _::
~„ ' J i ~'~' ' ~
COURT OF COMMON PLEAS
CIVIL DIVISION
CUMBERLAND COUNT'
NO: 12-3107
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
'TO: Travis A. Harper
1220 Spring Road
Carlisle, PA 17013
Your house (real estate) at:
561 Conodoguinet Avenue, Carlisle, PA 17015
29-18-1384-005 & 29-18-1384-OOSA
is scheduled to be sold at Sheriffs Sale on March 6, 2013 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
at 10:00AM to enforce the court judgment of $151,643.78 obtained by JPMorgan Chase Bank,
National Association against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The; sale will be cancelled if you pay back to JPMorgan Chase Bank, National
Association. the amount of the judgment plus costs or the back payments, late charges,
costs, and reasonable attorneys fees due. To find out how much you must. pay, you may
call:(610)278-6800.
2. You maybe 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 maybe able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two of how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND ~'OU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
a
5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling (610)278-6800.
6. You maybe able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call 717-240-6390.
8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the 1--roperty as if the sale never happened.
9. You. have a right to remain in the property until the full amount due is paid to the Sheriff
and t:he Sheriff gives a deed to the buyer. At that time, the buyer may bring legal
proceedings to evict :you.
10. You may be entitled to a share of the money, which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff no later than
thirty days after the Sheriff Sale. This schedule will state who will be receiving the
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10)
days after the date of filing of said schedule.
1 l . Y"ou may also have other rights and defenses or ways of getting your house back„ if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN (JET LEGAL HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUAN'C TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
11-039163
Parcel No. l
ALL that parcel of land situate in North Middleton Township, Cumberland County,
Pemisylvania, bounded and described as follows:
BEGINNING at an existing iron pin located at the northwest corner of other lands of the
Grantee; thence along Lot No. 4 of the hereinafter named Subdivision Plan North 21 ° SS' 24"
West a distance of 35.74 feet to a concrete monument; thence along other lands of the Grantor
South 69° 38' 39" East a distance of 79/66 feet to an iron pin; thence along I,ot No. 6 of the
hereinafter Warned Subdivision Plan South 21 ° 46' 48" West a distance of 40.08 feet to a point;
thence along other lands of the Grantee North 66° 31' 19" West a distance of ?9.76 feet to an
existing iron pin, the point and place of BEGINNING.
BEING Lot No. 5 on the Preliminary/Final Subdivision Plan for Eagles Crossing Golf Course
recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in
Plan Book. 81, Page 149, and containing 3,020 square feet.
Parcel No. ~!
ALL those certain two (2) tracts of Land with improvements thereon erected situate in Meadow
Brook Park, North Middleton Township, Cumberland County, Pennsylvania, known as Lot No.
108 and 109, Section 3, of a Plan of Lots laid out by Charles C. Swarner, said Plan of Lots being
recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle,
Pennsylvania, in Plan Book 2, page 34, and being more particularly described as follows:
TRACT NC) L• BEGINNING at a stake at the corner of Lot No. 107 belonging now or formerly
to Raymond. L.ee Fetter, and Conodoguinet Avenue; thence along the eastern line of said Lot,
North 23 degrees 08 minutes East, 100 feet to a point at the corner of said Lot and lands now or
formerly of said Swarner, South 66 degrees 52 minutes East, 40 feet to a stake, the northwest
corner of Lot No. 109, Tract No. 2 herein; thence along the western like of said Lot No. 109,
Sough 23 degrees 08 minutes West, 100 feet to a point on the said Conodoguinet Avenue, thence
along said Avenue, North 66 degrees 52 minutes West, 40 feet to a stake, the Place of
BEGINNING.
TRACT NO. 2: BEGINNING at a stake corner of Lot No. 108, Tract No. 2 herein, and
Conodoguinet Avenue; thence North 23 degrees 08 minutes East, 100 feet to a stake corner to
Lot No. l08 on lands now or formerly of Charles C. Swarner; thence along said lands now or
formerly of Charles C. Swarner; thence South 23 degrees 08 minutes West, 100 feet to a stake,
corner of L,ot No. 1 10 and said Conodoguinet Avenue; thence along said Avenue, North 66
degrees 52 minutes West, 40 feet to a stake, the Place of BEGINNING.
BEING Lot Nos. 108 and 109, Section 3, of a Plan of Lots laid out by Charles C. Swarner and
recorded as aforesaid on which there is erected a frame dwelling house.
PARC'EI. Nos. 29-18-1384-U05 & 29-18-1384-OOSA
BEING the same premises which Angela K. Hockensmith and Dennis Hockensmith, her
husband, h}~ Deed dated July 16, 2009 and recorded in the Cumberland County Recorder of
Deeds office on September 29, 2009 as Deed Instrument Number 200933456, granted and
conveyed unto Travis A. Harper and Maygin E. Barbour, both single people, as Joint Tenants
with Right of Survivorship and not as Tenants in Common.
~-~-~-----
��"SH�������U��o�% ����U���� ��� CUMBERLAND COUNTY
ERIFF'S�� ��" " "��~� ��"
RonnyR An6erson ' F// E D-»FF/p�
Sheriff HE PRO .H��--'`��
Jody SSnnith
7�/��&� �� �� Ul� ��
Chief Deputy `-^^'^"' ° ^'' '° �°
Richard VVStewart CUMA TY
Solicitor mpp'Cemr'*aS�s**p PEWNSy/�yA^-|—`' '
Jp Morgan Chase Bank, NA Case Number
vo. | 2O12'31O7
Travis A. Harper(et al.) |
SHERIFF'S RETURN OF SERVICE
O1/O2/2O13 03:03 PM - Deputy Amanda Cobaugh, being duly sworn according to law, states service was performed
by pouting o true copy of the requested Real Eobaba Writ, Notice and Description, and So|a Handbill in the
above titled action, upon the property located at 561 Conodoguinet Avenue, Carlisle, PA 17015,
Cumberland County.
01/03/2013 10:05 AM -Deputy Valerie Weary, being duly sworn according to |aw, served the naquaohmd 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 toa person representing themselves toba the Defendant, towit:
Travis A. Harper at 1220 Spring Road, Carlisle Borough, Carlisle, PA 17013, Cumberland County.
01/03/2013 10:05 AM ' Deputy Valerie Weary, being duly sworn according to |avv, aanwad the requested Real Estate
Writ, Notice and Deacripdon, in the above titled ootion, by making known its contents and at the same
time personally handing a true copy tno person representing themselves ho batnavio harper-fianca'oio,
who accepted as"Adult Person in Charge"for&1aygin E. Barbour at 1220 Spring Rnad, Carlisle Bonough,
Carlisle, PA17O13. Cumberland County.
03/07/2013 Ronny R.Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had
been given according to|aw, he exposed the within described premises at public venue or outcry otthe
Cumberland County
Courthouee, 1 Courthouse Square, Cadin|o. Cumber|adCounh/. on March 6, 2013 at 10:00 o.m. He sold
the same for the sum cf$ 1.00tu Attorney Christopher Danovdo. on behalf nfJP Morgan ChaaeBank.
National Association, being the buyer in this execution, paid to the Sheriff the sum of$
SHERIFF COST: s1.7G8.48 SO ANSWERS,
May O8. 2U13 R(JmmYR ANDERSON, SHERIFF
,
ley-
IC:
c a n `
i
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQ.
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: {610}278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Travis A. Harper and Maygin E. Barbour
DEFENDANTS NO: 12-3107
AFFIDAVIT PURSUANT TO RULE 3129.1
JPMorgan Chase Bank,National Association, Plaintiff in the above action, sets forth, as
of the date the praecipe for the writ of execution was filed, the following information concerning
the real property located at 561 Conodoguinet Avenue,Carlisle, PA 17015.
1. Name and address of Owner{s}or Reputed Owner{s}
Travis A. Harper
1220 Spring Road
Carlisle, PA 17013
Maygin E. Barbour
1220 Spring Road
Carlisle, PA 17013
2. Name and address of Defendants in the judgment:
Travis A. Harper
1220 Spring Road
Carlisle, PA 17013
Maygin E. Barbour
1220 Spring Road
Carlisle, PA 17013
3. Name and last known address of every judgment creditor whose judgment is a record lien
on the real property to be sold:
JPMorgan Chase Bank, National Association
3415 Vision Drive
Columbus, OH 43219
4. Name and address of the last recorded holder of every mortgage of record:
JPMorgan Chase Bank, National Association, Plaintiff
3415 Vision Drive
Columbus, OH 43219
5. Name and address of every other person who has any record lien on the property:
PA Department of Revenue
Bureau of Compliance
P.O. Box 281230
Harrisburg, PA 17128-1230
6. Name and address of every other person who has any record interest in the property and
whose interest may be affected by the sale:
Cumberland County Domestic Relations
13 North Hanover Street
Carlisle, PA 17013
7. Name and address of every other person of whom the plaintiff has knowledge who has
any interest in the property which may be affected by the sale:
TENANT OR OCCUPANT
561 Conodoguinet Avenue
Carlisle, PA 17015
I verify that the statements made in this affidavit are true and correct to the best of my
personal knowledge or information and belief. I understand that false statements herein are
made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to
authorities.
SHA &DeNARDO, LLC
BY:
Christopher A. DeNardo, Esquire
11-039163
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank, National Association F COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Travis A. Harper and Maygin E. Barbour
DEFENDANTS NO: 12-3107
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Maygin E. Barbour
1220 Spring Road
Carlisle, PA 17013
Your house(real estate) at:
561 Conodoguinet Avenue, Carlisle, PA 17015
29-18-1384-005 & 29-18-1384-005A
is scheduled to be sold at Sheriffs Sale on March 6, 2013 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
at 10:00AM to enforce the court judgment of$151,643.78 obtained by JPMorgan Chase Bank,
National Association against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay back to JPMorgan Chase Bank,National
Association the amount of the judgment plus costs or the back payments, late charges,
costs, and reasonable attorneys fees due. To find out how much you must pay, you may
call:(610)278-6800.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one, the more
chance you will have of stopping the sale. (See notice on page two of how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE,
5. If the Sheriff s Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling(610)278-6800.
6. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call 717-240-6390.
8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
9. You have a right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
10. You may be entitled to a share of the money, which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff no later than
thirty days after the Sheriff Sale. This schedule will state who will be receiving the
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten(10)
days after the date of filing of said schedule.
11. You may also have other rights and defenses or ways of getting your house back, if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
11-039163
Parcel No. I
ALL that parcel of land situate in North Middleton Township, Cumberland County,
Pennsylvania, bounded and described as follows:
BEGINNING at an existing iron pin located at the northwest corner of other lands of the
Grantee; thence along Lot No. 4 of the hereinafter named Subdivision Plan North 21° 55' 24"
West a distance of 35.74 feet to a concrete monument; thence along other lands of the Grantor
South 69° 38' 39"East a distance of 79/66 feet to an iron pin; thence along Lot No. 6 of the
hereinafter named Subdivision Plan South 21' 46' 48" West a distance of 40.08 feet to a point;
thence along other lands of the Grantee North 66° 31' 19"West a distance of 79.76 feet to an
existing iron pin, the point and place of BEGINNING.
BEING Lot No. 5 on the Preliminary/Final Subdivision Plan for Eagles Crossing Golf Course
recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in
Plan Book 81, Page 149, and containing 3,020 square feet.
Parcel No. 2
ALL those certain two (2) tracts of land with improvements thereon erected situate in Meadow
Brook Park, North Middleton Township, Cumberland County, Pennsylvania, known as Lot No.
108 and 109, Section 3, of a Plan of Lots laid out by Charles C. Swarner, said Plan of Lots being
recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle,
Pennsylvania, in Plan Book 2,page 34, and being more particularly described as follows:
TRACT NO 1: BEGINNING at a stake at the corner of Lot No. 107 belonging now or formerly
to Raymond Lee Fetter, and Conodoguinet Avenue; thence along the eastern line of said Lot,
North 23 degrees 08 minutes East, 100 feet to a point at the corner of said Lot and lands now or
fonnerly of said Swarner, South 66 degrees 52 minutes East, 40 feet to a stake, the northwest
corner of Lot No. 109, Tract No. 2 herein; thence along the western like of said Lot No. 109,
Sough 23 degrees 08 minutes West, 100 feet to a point on the said Conodoguinet Avenue, thence
along said Avenue, North 66 degrees 52 minutes West, 40 feet to a stake, the Place of
BEGINNING.
TRACT NO. 2: BEGINNING at a stake corner of Lot No. 108, Tract No. 2 herein, and
Conodoguinet Avenue; thence North 23 degrees 08 minutes East, 100 feet to a stake corner to
Lot No. 108 on lands now or formerly of Charles C. Swarner; thence along said lands now or
formerly of Charles C. Swarner; thence South 23 degrees 08 minutes West, 100 feet to a stake,
corner of Lot No. 110 and said Conodoguinet Avenue; thence along said Avenue, North 66
degrees 52 minutes West, 40 feet to a stake, the Place of BEGINNING.
BEING Lot Nos. 108 and 109, Section 3, of a Plan of Lots laid out by Charles C. Swarner and
recorded as aforesaid on which there is erected a frame dwelling house.
PARCEL Nos. 29-18-1384-005 & 29-18-1384-005A
BEING the same premises which Angela K. Hockensmith and Dennis Hockensmith, her
husband,by Deed dated July 16, 2009 and recorded in the Cumberland County Recorder of
Deeds office on September 29, 2009 as Deed Instrument Number 200933456, granted and
conveyed unto Travis A. Harper and Maygin E. Barbour,both single people, as Joint Tenants
with Right of Survivorship and not as Tenants in Common.
SHAPIRO & DeNARDO, LLC
BY: CHRISTOPHER A. DeNARDO, ESQUIRE
ATTORNEY I.D. NO: PA Bar # 78447
3600 HORIZON DRIVE, SUITE 150
KING OF PRUSSIA, PA 19406
TELEPHONE: (610)278-6800
S & D FILE NO. 11-039163
JPMorgan Chase Bank,National Association COURT OF COMMON PLEAS
PLAINTIFF CIVIL DIVISION
VS. CUMBERLAND COUNTY
Travis A. Harper and Maygin E. Barbour
DEFENDANTS NO: 12-3107
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: Travis A. Harper
1220 Spring Road
Carlisle, PA 17013
Your house (real estate) at:
561 Conodoguinet Avenue, Carlisle, PA 17015
29-18-1384-005 &29-18-1384-005A
is scheduled to be sold at Sheriffs Sale on March 6,2013 at:
Cumberland County Sheriffs Office
1 Courthouse Square
Carlisle, PA 17013
at 10:00AM to enforce the court judgment of$151,643.78 obtained by JPMorgan Chase Bank,
National Association against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay back to JPMorgan Chase Bank,National
Association the amount of the judgment plus costs or the back payments, late charges,
costs, and reasonable attorneys fees due. To find out how much you must pay, you may
call:(610)278-6800.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open the
judgment, if the judgment was improperly entered. You may also ask the Court to
postpone the sale for good cause.
3. You may be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights. The sooner you contact one,the more
chance you will have of stopping the sale. (See notice on page two of how to obtain an
attorney.)
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE
OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE.
5. If the Sheriffs Sale is not stopped, your property will be sold to the highest bidder. You
may find out the price bid by calling(610)278-6800.
6. You may be able to petition the Court to set aside the sale if the bid price was grossly
inadequate compared to the value of your property.
7. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.
To find out if this has happened you may call 717-240-6390.
8. If the amount due from the buyer is not paid to the Sheriff, you will remain the owner of
the property as if the sale never happened.
9. You have a right to remain in the property until the full amount due is paid to the Sheriff
and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal
proceedings to evict you.
10. You may be entitled to a share of the money,which was paid for your house. A schedule
of distribution of the money bid for your house will be filed by the Sheriff no later than
thirty days after the Sheriff Sale. This schedule will state who will be receiving the
money. The money will be paid out in accordance with this schedule unless exceptions
(reasons why the proposed distribution is wrong) are filed with the Sheriff within ten(10)
days after the date of filing of said schedule.
11. You may also have other rights and defenses or ways of getting your house back,if you
act immediately after the sale.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Cumberland County Lawyer Referral Service
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
717-249-3166
PURSUANT TO THE FAIR DEBT COLLECTION PRACTICES ACT YOU ARE
ADVISED THAT THIS LAW FIRM IS DEEMED TO BE A DEBT COLLECTOR
ATTEMPTING TO COLLECT A DEBT. ANY INFORMATION OBTAINED WILL BE
USED FOR THAT PURPOSE.
11-039163
Parcel No. 1
ALL that parcel of land situate in North Middleton Township, Cumberland County,
Pennsylvania, bounded and described as follows:
BEGINNING at an existing iron pin located at the northwest corner of other lands of the
Grantee; thence along Lot No. 4 of the hereinafter named Subdivision Plan North 21° 55' 24"
West a distance of 35.74 feet to a concrete monument; thence along other lands of the Grantor
South 69° 38' 39" East a distance of 79/66 feet to an iron pin; thence along Lot No. 6 of the
hereinafter named Subdivision Plan South 21' 46' 48" West a distance of 40.08 feet to a point;
thence along other lands of the Grantee North 66° 31' 19"West a distance of 79.76 feet to an
existing iron pin, the point and place of BEGINNING.
BEING Lot No. 5 on the Preliminary/Final Subdivision Plan for Eagles Crossing Golf Course
recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania in
Plan Book 81, Page 149, and containing 3,020 square feet.
Parcel No. 2
ALL those certain two (2) tracts of land with improvements thereon erected situate in Meadow
Brook Park, North Middleton Township, Cumberland County, Pennsylvania, known as Lot No.
108 and 109, Section 3, of a Plan of Lots laid out by Charles C. Swamer, said Plan of Lots being
recorded in the Office of the Recorder of Deeds in and for Cumberland County at Carlisle,
Pennsylvania, in Plan Book 2,page 34, and being more particularly described as follows:
TRACT NO 1: BEGINNING at a stake at the corner of Lot No. 107 belonging now or formerly
to Raymond Lee Fetter, and Conodoguinet Avenue; thence along the eastern line of said Lot,
North 23 degrees 08 minutes East, 100 feet to a point at the corner of said Lot and lands now or
formerly of said Swamer, South 66 degrees 52 minutes East, 40 feet to a stake, the northwest
corner of Lot No. 109, Tract No. 2 herein; thence along the western like of said Lot No. 109,
Sough 23 degrees 08 minutes West, 100 feet to a point on the said Conodoguinet Avenue, thence
along said Avenue, North 66 degrees 52 minutes West, 40 feet to a stake, the Place of
BEGINNING.
TRACT NO. 2: BEGINNING at a stake corner of Lot No. 108, Tract No. 2 herein, and
Conodoguinet Avenue; thence North 23 degrees 08 minutes East, 100 feet to a stake corner to
Lot No. 108 on lands now or formerly of Charles C. Swamer; thence along said lands now or
formerly of Charles C. Swamer; thence South 23 degrees 08 minutes West, 100 feet to a stake,
corner of Lot No. 110 and said Conodoguinet Avenue; thence along said Avenue, North 66
degrees 52 minutes West, 40 feet to a stake, the Place of BEGINNING.
BEING Lot Nos. 108 and 109, Section 3, of a Plan of Lots laid out by Charles C. Swarner and
recorded as aforesaid on which there is erected a frame dwelling house.
PARCEL Nos. 29-18-1384-005 &29-18-1384-005A
BEING the same premises which Angela K. Hockensmith and Dennis Hockensmith, her
husband,by Deed dated July 16, 2009 and recorded in the Cumberland County Recorder of
Deeds office on September 29, 2009 as Deed Instrument Number 200933456, granted and
conveyed unto Travis A. Harper and Maygin E. Barbour, both single people, as Joint Tenants
with Right of Survivorship and not as Tenants in Common.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-3107 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION Plaintiff(s)
From TRAVIS A. HARPER AND MAYGIN E. BARBOUR
(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: $151,643.78 L.L.: .50
Interest FROM SEPTEMBER 31,2012 TO MARCH 6,2013 IS$3,913.70
Atty's Comm: % Due Prothy: $2.25
Atty Paid: $365.00 Other Costs:
Plaintiff Paid:
Date: 10/25/12
David D.Buell, rothonotary6'4�k&(Seal) By: Cccw �
D uty
REQUESTING PARTY:
Name: CHRISTOPHER A. DENARDO,ESQUIRE
Address:SHAPIRO& DENARDO,LLC
3600 HORIZON DRIVE,SUITE 150
KING OF PRUSSIA,PA 19406
Attorney for: PLAINTIFF
Telephone: 610-278-6800
Supreme Court ID No.78447
TRUE COPY FROM RECORD
In Testimony whereof,I here unto set my hand
and the seal of said Court at disle,P
This day of� 20
P othonota
On October 31, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
North Middletown Township, Cumberland County, PA,
Known and numbered as, 561 Conodoguinet Avenue,
Carlisle, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: October 31, 2012
By:
ke—Astate Coordinator
CUMBERLAND LAW JOURNAL
Writ No. 2012-3107 Civil TRACT NO I: BEGINNING at a
stake at the corner of Lot No. 107
JP Morgan Chase Bank,NA belonging now or formerly to Ray-
vs. mond Lee Fetter, and Conodoguinet
Avenue; thence along the eastern
Travis A. Harper, line of said Lot,North 23 degrees 08
Maygin E. Barbour minutes East, 100 feet to a point at
Atty.: Christopher DeNardo the corner of said Lot and lands now
Parcel NO.I or formerly of said Swamer,South 66
ALL that parcel of land situate in degrees 52 minutes East, 40 feet to
North Middleton Township,Cumber- a stake,the northwest corner of Lot
land County,Pennsylvania,bounded No. 109, Tract NO.2 herein; thence
and described as follows: along the western like of said Lot No.
BEGINNING at an existing iron 109, Sough 23 degrees 08 minutes
pin located at the northwest comer West, 100 feet to a point on the said
of other lands of the Grantee;thence Conodoguinet Avenue,thence along
along Lot NOA of the hereinafter said Avenue, North 66 degrees 52
named Subdivision Plan North 21° minutes West,40 feet to a stake,the
55'24"West a distance of35.74 feet Place of BEGINNING.
to a concrete monument; thence TRACT NO.2: BEGINNING at a
along other lands of the Grantor stake comer of Lot No. 108, Tract
South 69° 38' 39" East a distance NO.2 herein, and Conodoguinet
of 79/66 feet to an iron pin; thence Avenue; thence North 23 degrees
along Lot NO.6 of the hereinafter 08 minutes East, 100 feet to a stake
named Subdivision Plan South 21° corner to Lot No. 108 on lands now
46'48"West a distance of 40.08 feet or formerly of Charles C. Swamer;
to a point;thence along other lands thence along said lands now or for-
of the Grantee North 66°31'19"West merly of Charles C. Swamer;thence
a distance of79.76 feet to an exist- South 23 degrees 08 minutes West,
ing iron pin, the point and place of 100 feet to a stake,corner of Lot No.
BEGINNING. 110 and said Conodoguinet Avenue;
BEING Lot NO.5 on the Prelimi- thence along said Avenue, North 66
nary/Final Subdivision Plan for Ea- degrees 52 minutes West,40 feet to
gles Grossing Golf Course recorded in a stake,the Place of BEGINNING.
the Office of the Recorder of Deeds in BEING Lot Nos. 108 and 109,
and for Cumberland County, Penn- Section 3,ofa Plan of Lots laid out by
sylvania in Plan Book 81,Page 149, Charles C.Swarner and recorded as
and containing 3,020 square feet. aforesaid on which there is erected a
Parcel NO.2 frame dwelling house.
ALL those certain two (2) tracts PARCEL Nos. 29-18-1384-005&
of land with improvements thereon 29-18-1384-005A.
erected situate in Meadow Brook BEING the same premises which
Park, North Middleton Township, Angela K. Hockensmith and Dennis
Cumberland County, Pennsylvania, Hockensmith,her husband,by Deed
known as Lot No. 108 and 109,Sec- dated July 16,2009 and recorded in
tion 3, of a Plan of Lots laid out by the Cumberland County Recorder
Charles C.Swarner,said Plan of Lots of Deeds office on September 29,
being recorded in the Office of the 2009 as Deed Instrument Number
Recorder of Deeds in and for Cum- 200933456, granted and conveyed
berland County at Carlisle,Pennsyl- unto Travis A.Harper and Maygin E.
vania,in Plan Book 2,page 34, and Barbour,both single people,as Joint
being more particularly described Tenants with Right of Survivorship
as follows: and not as Tenants in Common.
60
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952,been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 25, February 1, and February 8, 2013
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time, place and character of publication are true.
i ]Lisa Marie Coyne, E itor
SWORIQ TO AND SUBSCRIBED before me this
da of Februar 2013
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
i 2012.911!!'"
Jip Morpn Chiw4 98K 1 MA
Vs k _
71Ws A.HarPaF
MaY01n E Barbour
Atty: Chi Dnardo
Parcel NO.1
ALL that parcel of,land situate in North
j Middleton'Township,Cumberland County,
Pennsylvania, bounded and described as
follows.
BEGINNING at an existing itonpin located
at the,northwest comer of otherlands of the
Grantee; thence along Lot NO.4 of the
hereinafter named Subdivision Plan North
21°55'24"West a distance of35.74 feet to
a concrete monument;thence along other
lands of the Grantor South 69° 38' 39"
East a distance of 79166 feet to an iron Pin;
thence along Lot NO.6 of the hereinafter
named Subdivision Plan South 21°46'48"
,West a distance of 40.08 feet to:a point;
thence along other lands of the Grantee
North W.31'19"West a distance of19.76
Teet to an eidsting iron pin,the point and
place ofBEGINNING
r jdJ4 is dte.Office of We
Recorder of Deeds in and for Cumberland
County,Pennsylvania in plan Book 81,Page
149,and containing'X020 sctateet.
Parcel NO.2
ALL those certain two(2)'tracls of land
with improvements thereon erected
situate in Meadow Brook Park, North
Middleton'lbwnship,Cumberland County,
Pennsylvania,known as Lot No. 108 and
109,Section 3,of a Plan of Lots laid out by,
Charles C.Swamer;said Plan of Lots being
recorded m the Office of the Recorder of
Deeds m and for Cumberland County at
Carlisle,pennghania,in Plan Book 2,page
34,andbeing more pa&Warly described as
follows:
TRACT NO I:BEGINNING at a stake at
the comer of Lot No..107 belonging now
or formerly'to Raymoqd Lee Fetter,and
Conodoguinet Avenue; thence along the
eastern We of said Lot,North'23 degrees
08 minutes East,100 feet to a point at
the comer of said Lot and lands now or
formerly of said Swarner,South 66 degrees
52 minutes East,40 feet to a stake,the
northwest comer of Lot No. 109,M-Ad
NO.2 herein; thence along the western
like of said Lot No.109,Sough 23 degrees
08 minutes West.100 feet to a point on
the said Conodogn*t Avenue, thence
along said Avenue}North 66 degrees 52
minutes West,40 feet to a stake,the Place
of BEGINNING.
TRACE NO.2: BEGINNING at a stake
comer of Lot No.1q,Tract NO.2 herein,
and Conodoguinet u6:,thence North
23 degrees 08 minutes East,100 feet to a
stake comer to Lot No.108 on lands now
or formerly of Charles C.Swamer,thence
along said lands now formerly of Charles
C. Swarner, thence South 23 degrees 08
minutes West,100 feet to a stake,comer
of Lot N,o. 110 and said Conodoguinet
Avenue;thence along said Avenue,North
66 degrees 52 minutes West,40 feet to a
stake,the Place of BEGINNING.
BEING Lot Nos.108 and 109,Section 3,ofa
Plan of Lots laid out by Charles C.Swamer
and recorded as aforesaid on which there is
erected a frame dwelling house,
pARCEL Nos. 29-18-1384-005 & 29-18-
138g-OOSA ,
BEING the same premises which Angela'
K Hockensmith and'Dennis Hockensmith,
her husband,by Deed dated July 16,2009
and recorded in the Cumberland County
Recorder of peeds office on September
29, 2009 as Deed Instrument Number
The Patriot-News Co.
2020 Technology Pkwy
. 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
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
f
ICATION COPY This ad ran on the date(s)shown below:
01/22/13
01/29/13
c.__ �-
A I
02/05/13
Sworn to bscribed before me thi 4 day of February, 2013 A.D.
a . I
m, A ?_.elpl k
Nntajat Pkidlit,'
commo OF PENNSYLVANIA
Notarial Seal
Holly Lynn Warfel,Notary Public
Washington Twp.,Dauphin County
My Commission Ex ores Dec.12,2016
MEMBER,PENNSYLVANIA ASSOCIATION Of NOTARIES
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ISS:
I, Robert P. Ziegler, Recorder of Deeds in and for said County and State do hereby certify that
the Sheriff's Deed in which JPMorg:an Chase Bank,National Association is the grantee the same having
been sold to said grantee on the 6th day of March A.D., 2013, under and by virtue of a writ Execution
issued on the 25th day of October, A.D., 2012, out of the Court of Common Pleas of said County as of
Civil Term, 2012 Number 3107, at the suit of JPMorizan Chase Bank,National Association against
Travis A. Hamer and Maygin E. Barbour is duly recorded as Instrument Number 201315019.
IN TESTIMONY WHEREOF, I have hereunto set my hand
�jZ10-
and seal of said office this O day of
A.D. C2 D 43 .
Recorder of Deeds
of timberland County,Calisle,PA
PACormises Expires the First Monday of Jan.2014
BANK OF AMERICA,N.A., IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
VS. CIVIL ACTION—LAW
NO. 12-3177
JOHN TERRY,JR.,
Defendant
ORDER
AND NOW,this 7,w,- day of June,2014, on agreement of the parties,the conciliation
scheduled for June 27,2014, is continued to Friday,July 18,2014, at 3:15 p.m. in Chambers of the
undersigned.
BY THE COURT,
Kevin A. ess, P. J.
--'-�Nathan Wolf, Esquire
For the Plaintiff
.., aime Haley, Esquire
For the Defendant
Am
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