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Home My WebLink About12-3212IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, VS. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. FO DEFENDANTS You are hereby notified to plead to the ENCLOSED COMPLAINT WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF ATTORNEY FOR PLAIN IFF CIVIL DIVISION NO.: I-3a?a C?? TYPE OF PLEADING: -71 CIVIL ACTION-COMPLAINT IN MORTGAGE FORECLOSUIt1_ =' -- FILED ON BEHALF OF PLAINTIFF: JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 I HEREBY CERTIFY THAT THE ADDRESS OF THE PLAINTIFF IS: I I 1 I Polaris Parkway Columbus, OH 43240 AND THE DEFENDANTS' IS: .3509 Sandvalley Road Richfield, PA 17086 ATTORN FOR PLAIN IFF Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 CERTIFICATE OF LOCATION I HEREBY CERTIFY THAT THE LOCATION OF THE REAL ESTATE AFFECTED BY THIS LIEN IS: 1340 Kiner Boulevard Carlisle. PA 17015 Monroe Township (CITY, BORO, TOWNSHIP) ATTO .NEY FOR PLAINTIFF C-y Ck-? 13$'la`I 12 a -7 s.?t l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL CIVIL DIVISION ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, NO.: Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claim set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL, SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL CIVIL DIVISION ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, NO.:. Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. CIVIL ACTION COMPLAINT IN MORTGAGE FORECLOSURE JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, by its attorneys. Grenen & Birsic, P.C.. files this Complaint in Mortgage Foreclosure as follows: The Plaintiff is JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation which has its principal place of business at 1111 Polaris Parkway, Columbus, OH 43240 and is authorized to do business in the Commonwealth of Pennsylvania. 2. The Defendants, Beverly M. Haulman and James L. Foltz, are individuals whose last known address is 3509 Sandvalley Road, Richfield, Pennsylvania 17086. 3. On or about March 5, 2008, Defendants executed a Note in favor of JPMorgan Chase Bank, N.A. in the original principal amount of $164,379.00. A true and correct copy of said Note is marked Exhibit "A," attached hereto, and made a part hereof. 4. On or about March 5, 2008, as security for payment of the aforesaid Note, Defendants made, executed, and delivered to JPMorgan Chase Bank, N.A. a Mortgage in the original principal amount of $164,379.00 on the premises hereinafter described, said Mortgage being recorded in the Office of the Recorder of Deeds of Cumberland County on March 11, 2008, at Instrument Number 200807294. A true and correct copy of said Mortgage containing a description of the premises subject to said Mortgage is marked Exhibit "B," attached hereto, and made a part hereof. 5. JPMorgan Chase Bank, N.A. assigned all of its right, title, and interest in and to aforesaid Mortgage to Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation pursuant to a certain Assignment of Mortgage, recorded in the Office of the Recorder of Deeds of Cumberland County on November 15, 2010, at Instrument Number 201033135. A true and correct copy of said Assignment is marked Exhibit "C.," attached hereto, and made a part hereof. 6. Defendants are the record and real owners of the aforesaid mortgaged premises. 7. Defendants are in default under the terms of the aforesaid Mortgage and Note for, inter alia, failure to pay the monthly installments of principal and interest when due. Defendants are due for the June 1, 2010 payment. S. Plaintiff was not required to send Defendants, Beverly M. Haulman and James L. Foltz, written notice pursuant to 35 P.S. §1680.403C (Homeowner's Emergency Mortgage Assistance Act of 1983, Act 91 of 1983) prior to the commencement of this action for the reason that the aforesaid Mortgage is insured by the Federal Housing Administration under Title II of the National Housing Act (12 U.S.C, §1707 1715z 18). 9. On or about September 27, 2010, Defendants were mailed Notices of Intention to Foreclose Mortgage in compliance with Act 6 of 1974, 41 P. S. §101, et seq. 10. The following amounts are due to Plaintiff on the Mortgage as of March 31, 2012: Principal $159,730.92 Interest from 05/01/10 through 3/31/12 $ 21,047.99 Late Charges $ 155.91 Escrow Deficiency $ 4,673.72 Corporate Advances $ 5,063.38 Attorneys' Fees $ 700.00 Foreclosure Costs $ 467.60 TOTAL $191,839.52 WHEREFORE, Plaintiff demands an in rem judgment against the Defendants in the sum of $191,839.52, together with interest, costs., fees, and charges collectible under the note and mortgage including but not limited to attorneys fees and costs, and for the foreclosure and sale of the mortgaged property. GRENEN & BIRSIC, P.C. BY(/ i ;i c Kristine -M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 THIS IS AN ATTEMPT TO COLLECT A DEBT, AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. EXHIBIT "A" NOTE F}fit Case No. Multistate March 5, 2008 [Date] 1340 Kiner Blvd Carlisle, PA 17015 [Proporty Address] 1. PARTIES "Borrower" means e JP' Morgan Chase Bank, N. a hank which is organized and its successors and assi Z. BORROWER'S PROI In return for a loan r One hundred sixty-fourth Dollars (U.S. $ 164,379.01 from the date of disburscm percent( 6.875 3. PROMISE TO PAY SI Borrower's promise tt as this Note and called the Borrower defaults under th 4. MAINTNER OF PAYMI (A) Time Borrower shall April, Ist 2038 will be due (B) Place Payment shall bl 3,115 Vision Drive, Columl by notice to Borrower. (C) Amount Each monthly pt will be part of a larger m other items in the order do (D) Allonge to this If an allonge pr the allonge shall be incorp this Note. [Check applicab ?Graduated Paym 5. BORROWER'S RIGS Borrower has the rig day of any month. Lender the remainder of the mont partial prepayment, there writing to those changes. ?Wl F11A Muttist -tR (ozto(.oz . ® V!d? Mo"gage Solutfor Pa9u 1 0 Z b person signing a. the end of this Note, and the person's successors and assigns. "Lender" means td existing under tae laws of the United States of America S. SE TO PAY; INTEREST eivedfrom Lender„ Borrower promises to pay the principal sum of sand three hundred seventy-nine ), plus interest, to the order of Lender. Interest will be charged on unpaid principal, nt of the loan proceeds by Lender, at the rate of Six & 875/1000 %) per yaar until the full amount of principal has been paid. CURED pay is secured by a mortgage, deed of trust or similar security instrument that is dated the same date Security Instrument." The Security Instrument protects the Lender from losses which might result if t Note. ake a payment o. principal and interest to Lender on the first day of each month beginning on 2008 . Any principal and interest remaining on the first day of March that date, which is called the "Maturity Date." made at JPMorgan Chase Bank, N.A., clo Chase Home Finance, LLC us, OH 43219 or at such place as lender may designate in writing nent of principal and interest will be in the amount of U.S. $ 1,079.86 .'T'his amount (hly payment required by the Security Instrument, that shall be applied to principal, interest and ibed in the Security Instrument. to for payment adjustments iding for payment adjustments is executed by Borrower together with this Note, the covenants of led into and shall amend and supplement the covenants of this Note as if the allonge were a part of box] Allonge L_.1Growing Equity Allonge UOtLer [spacify] 'TO PREPAY to pay the debt evidenced by this Note, in whole or in part, without charge or penalty, on the first hall accept prepayment on other days provided that Borrower pays interest on the amount prepaid for to the extent required by Lender and permitted by regulations of the Secretary, If Borrower makes a ill be no changes in the due date or in the amount of the monthly payment unless Lencler agrees in Fixed Rate Note -10/95 (000)521-7291 IniOals: 6. BORROWER'S FAILU (A) Late Charge for If Lender has no 4(C) of this Note, by the ec of Four (B) Default If Borrower defai of the Secretary in the case all accrued interest. Lender . default. In many circumsta full in the case of payment in this Note, "Secretary" mf (C) Payment of Cosi If Lender has me expenses including reasona law. Such fees and costs sh :E TO PAY lverdue Payments received the full monthly payment required by the Security Instrument, as described in Pa..agraph 1 of fifteen calendar days after the payment is due, Lender may collect a late charge in th- amount percent ( 4.000 0/,) of the overdue amount of each laymen.. Its by failing to pay in full any monthly payment, then Lender may, except as limited by regulations of payment default,;, require immediate payment in full of the principal balance remaining due and may choose not to exercise this option without waiving its rights in the event of any subsequent ces regulations issced by the Secretary will limit Lender's rights to require immediate payment i!f efaults. This Note does not authorize acceleration when not permitted by HUD regulations. 1s used ms the Secretary of.`Housing and Urban Development or his or'her designee. and Expenses tired immediate payment in full, :as described above, Lender may require Borrower to pay costs and le and customary attorneys' fees for enforcing this Note to the extent not prohibited by applicable 11 bear interest from the date of disbursement at the same rate as the principal of thu; Note; 7. WAIVERS Borrower and any o ter person who hrs obligations under this Note waive the rights of presentment and notice of dishonor. "Presentment" m tans the right to require Lender to demand payment of amounts due. "Notice of dishonor" means the right to require Lender to gi a notice to other persons that amounts due have not been paid. 8. GIVING OF NOTICES Unless applicable law equires a different method, any notice that must be given to Borrower under this Note will be given by delivering it or by rnar rng it by first class mail to Borrower at the property address above or at a different address if' Borrower has given Lender a notice of Borrow.-es different address. Any notice that must a given to Lender under this Not, will be given by first class mail to Lender at the address stated in Paragraph 4(B) or at a diffe-ent address if Borrower is given a notice of that different address. q. OBLIGATIONS OF P SONS UNDER THIS NOTE If more than one pers n signs this Note, each person is fully and personally obligated to keep all of the promises made in this Note, including the pro ise to pay the full amount owed. Any person who is a guarantor, surety or endorser of this Note is also obligated to do these tngs. Any person who takes over these obligations, including the obligations of a guarantor, surety or endorser of this Note, is lso obligated to keep all of the promises made in this Note. Lender may enforce its rights under this Note against each person it Uvidually or against all signatories together. Any one person signing this Note may be required to pay all of the amounts owed under this Note. BY SIGNING , Borrower accepts and agrees to the terms and covenants contained in this Note. _ (Seal) y Q ?? 1 l e?p (Seal) -Borrower Beverly M. f.aulman Hi; :uwer ? PAL W L _ _ -- (Seal) _ (Seal) -Boaow,r Jkoes L. Foltz -Hmouror _ (Seal) (Seal) -Bonow,:r •Bi:ncwer _ (Seal) - (Seal) -Boaow,x -Rojower rdM? -1 R (0210).02 Page 2 of 2 P1 EXHIBIT "B" ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 200807294 Recorded On 3/11/2008 At 1:51:16 PM * Instrument Type - MORTGAGE Invoice Number - 16135 User ID - MBL * Mortgagor - FOLTZ, JAMES L * Mortgagee - JPMORGAN CHASE BANK N A * Customer - COMMUNITY LAND TRANSFER * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $10.00 JUSTICE RECORDING FEES - $23.50 RECORDER OF DEEDS AFFORDABLE HOUSING $11.50 COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $50.50 * Total Pages - 11 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA °p cuye RECORDER '2 D ED,' 7 two " - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. II?Illllilllll(IIIIIIIIIN 5D p Prepared By Return To: JPMorgan Chase Custody Services P.O. Box 9000 Monroe. LA 71211 Parcel Number: Premises' 22240771006 1340 Kiner Blvd Carlisle, PA 17015 ISpaca Above TMs Line For Recording Natal -- 11A Case No. Commonwealth of Pennsylvania MORTGAGE ? THIS MORTGAGE ("Security Instrument") is given on March 5, 2009 The Mortgagor is Beverly M. Haulman, a single woman and James L. Foltz, a single man ('Borrower"). This Security Instrument is given to JPMorgan Chase Bank, N.A., a national banking association which is organized and existing under the laws of the United Stat,-s of America and whose address is I I I I Polaris Parkway, Columbus, OH 43240 ("Lender"). Borrower owes Lender the principal sum of One hundred sixty-four thousand three hundred seventy-nine and 00/100 Dollars (U.S. S 164,379.00 j. This debt is evidenced by Borrower's note dated the same date as this Security Instrument ("Note"), which provides for monthly payments, with the full debt, if not paid earlier, due and payable on March 1, 2039 . This Security Instrument secures to Lender: (a) the repayment of the debt evidenced by the Note, with interest, and all renewals, extensions and modifications of the. F11A Pennsylvania Mortgage - 4196 I 'I Ps J? I II?IIIII III?I I I II??I) I II Ill) I II l Vi of HMonp Oe sal,oml. M. 1800)521-7291 it N Note; (b) the payment of all other sums, with interest, advanced under paragraph 7 to protect the security of this Security Instrument; and (c) the performance of Borrower's covenants and agreements under this Security Instrument and the Note. For this purpose, Borrower does hereby mortgage, grant and convey to the Lender the following described property located in CUMBERLAND County, Pennsylvania: Sce attached Schedule A which has the address of 1340 Killer Blvd (Street) Carlisle [City], Pennsylvania 17015 [Zip OAt1 ("Properly Address"); TOGETHER WITH all the improvements now or hereafter erected on the properly, and 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 referred to in this Security Instrument as the "Property.' BORROWER COVENANTS that Borrower is lawfully seized of the estate hereby conveyed and has the right to mortgage, grant and convey the Property and that the Properly is unencumbered, except for 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 properly. Borrower and Lender covenant and agree as follows: UNIFORM COVENANTS. 1. Payment of Principal, Interest and Late Charge. Borrower shall pay when due the principal of, and interest on, the debt evidenced by the Note and late charges due under the Note. 2. Monthly Payment of Taxes, Insurance and Other Charges. Borrower shall include in each monthly payment, together with the principal and interest as set forth in the Note and any late charges, a sum for (a) taxes and special assessments levied or to be levied against the Property, (b) leasehold payments or ground rents on the Property, and (c) premiums for insurance required under paragraph 4. In any year in which the Lender must pay a mortgage insurance premium to the Secretary of Housing and Ur) an Devetppment ("Secretary"), or in any year in which such premium would have been required if Lender still held the Security Instrurr ent, each monthly payment shall also include either: (i) a sum for the mom (Z -4R(PA) Iow2) Pepe 2 W 6 annual mortgage insurance premium to be paid by Lender to the Secretary, or (ii) a monthly charge instead of a mortgage insurance premium if this Security Instrument is held by the Secretary, in a reasonable amount to be determined by the Secretary. Except for the monthly charge by the Secretary, these items are called "Escrow Items" and the sums paid to Lender are called "Escrow Funds." Lender may, at any time, collect and hold amounts for Escrow Items in an aggregate amount not to exceed the maximum amount that may be required for Borrower's escrow account under the Real Estate Settlement Procedures Act of 1974, 12 U.S.C. Section 2601 et seq. and implementing regulations, 24 CFR Part 3500, as they may be amended from time to time ("RESPA"), except that the cushion or reserve permitted by RESPA for unanticipated disbursements or disbursements before the Borrower's payments are available in the account may not be based on amounts due for the mortgage insurance premium. If the amounts held by Lender for Escrow Items exceed the amounts permitted to be held by RESPA, Lender shall account to Borrower for the excess funds as required by RESPA. If the amounts of funds held by Lender at any time are not sufficient to pay the Escrow Items when due, Lender may notify the Borrower and require Borrower to make up the shortage as permitted by RESPA. The Escrow Funds are pledged as additional security for all sums secured by this Security Instrument. If Borrower tenders to Lender the full payment of all such sums, Borrower's account shall be credited with the balance remaining for all installment items (a), (b), and (c) and any mortgage insurance premium installment that Lender has not become obligated to pay to the Secretary, and Lender shall promptly refund any excess funds to Borrower. Immediately prior ro a foreclosure sale of the Property or its acquisition by Lender, Borrower's account shall be credited with any balance remaining for all installments for items (a), (b), and (c). 3. Application of Payments. All payments under paragraphs I and 2 shall be applied by Lender as follows: Fist to the mortgage insurance premium to be paid by Lender to the Secretary or to the monthly charge by the Secretary instead of the monthly mortgage insurance premium; con to any taxes, special assessments, leasehold payments or ground rents, and fire, flood and other hazard insurance premiums, as required; Third to interest due under the Note; Furth to amortization of the principal of the Note; and Fifth to late charges due under the Note. 4. Fire, Flood and Other Hazard Insurance. Borrower shall insure all improvements or, the Property, whether now in existence or subsequently erected, against any hazards, casualties, and contingencies, including fire, for which Lender requires insurance. This insurance shall be maintained in the amounts and for the periods that Lender requires. Borrower shall also insure all improvements on the Property, whether now in existence or subsequently erected, against loss by floods to the extent required by the Secretary. All insurance shall be carried with companies approved by Lender. The insurance politics and any renewals shall be held by Lender and shall include loss payable clauses in favor of, and in a form acceptable to, Lender. In the event of loss, Borrower ',hall give Lender immediate notice by mail. Lender may make proof of loss if not made promptly by Borrower. Each insurance company concerned is hereby authorized and directed to make payment for such oss directly to Lender, instead of to Borrower and to Lender Jointly. All or any part of the insurance proceeds may be applied by Lender, at its option, either (a) to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order in paragraph 3, and then to prepayment of principal, or (b) to the restoration or repair of the damaged Property. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments which are referred to in paragraph 2, or change the amount of such payments. Any excess insurance proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security Instrument shall be paid to the entity legally entitled thereto. ClnNab: -4R(PA) (0ea2) rage 3 0 9 In,the event of foreclosure of this Security Instrument or other transfer of title to the Property that extinguishes the indebtedness, all right, title and interest of Borrower in and to insurance policies in force shall pass to the purchaser. 5. Occupancy, Preservation, Maintenance and Protection of the Property; Borrower's Loan Application; Leaseholds. Borrower shall occupy, establish, and use the Property as Borrower's principal residence within sixty days after the execution of this Security Instrument (or within sixty days of a later sale or transfer of the Property) and shall continue to occupy the Property as Borrower's principal residence fo'r at least one year after the date of occupancy, unless Lender determines that requirement will cause undue hardship for Borrower, or unless extenuating circumstances exist which are beyond Borrower's control. Borrower shall notify Lender of any extenuating circumstances. Borrower shall not commit waste or destroy, damage or substantially change the Property or allow the Property to deteriorate, reasonable wear and tear excepted. Lender may inspect the Property if the Property is vacant or abandoned or the loan is in default. Lender may take reasonable action to protect and preserve such vacant or abandoned Property. Borrower shall also be in default if Borrower, during the loan application process, gave materially false or inaccurate information or statements to Lender (or failed to provide Lender with any material information) in connection with the loan evidenced by the Note, including, but not limited to, representations concerning Borrower's occupancy of the Property as a principal residence. If this Security Instrument is on a leasehold, Borrower shall comply with the provisions of the lease. If Borrower acquires fee title to the Property, the leasehold and fee title shall not be merged unless Lender agrees to the merger in writing. 6. Condemnation. The proceeds of any award or claim for damages, direct or consequential, in connection with any condemnation or other taking of any part of the Property, or for conveyance in place of condemnation, are hereby assigned and shall be paid to Lender to the extent of the full amount of the indebtedness that remains unpaid under the Note and this Security Instrument. Lender shall apply such proceeds to the reduction of the indebtedness under the Note and this Security Instrument, first to any delinquent amounts applied in the order provided in paragraph 3, and then to prepayment of principal. Any application of the proceeds to the principal shall not extend or postpone the due date of the monthly payments, which are referred to in paragraph 2, or change the amount of such payments. Any excess proceeds over an amount required to pay all outstanding indebtedness under the Note and this Security instrument shall be paid to the entity legally entitled thereto. 7. Charges to Borrower and Protection of Lender's Rights in the Property. Borrower shall pay all governmental or municipal charges, fines and impositions that are not included in paragraph 2. Borrower shall pay these obligations on time directly to the entity which is owed the payment. If failure to pay would adversely affect Lenders interest it the Property, upon Lender's request Borrower shall promptly furnish to Lender receipts evidencing these payments. If Borrower fails to make these payments or the payments required by paragraph 2, or fails to perform any other covenants and agreements contained in this Security Instrument, or there is a legal proceeding that may significantly affect Lender's rights in the Property (such as a proceeding in bankruptcy, for condemnation or to enforce laws or regulations), then Lender may do and pay whatever is necessary to protect the value of the Property acid Lender's rights in the Property, including payment of taxes, hazard insurance and other items mentioned in paragraph 2. Any amounts disbursed by Lender under this paragraph shall become an additional debt of Borrower and be secured by this Security Instrument. These amounts shall bear interest from the date of' disbursement, at the Note rate, and at the option of Lender, shall be immediately due and payable. Borrower shall promptly discharge any lien which has priority over this Security Instrument unless Borrower: (a) agrees in writing to the payment of the obligation secured by the lien in a manner acceptable to Lender; (b) contests in good faith the lien by, or defends against enforcement of the lien in, legal proceedings which in the Lender's opinion operate to prevent the enforcement of the lien; or (c) secures cJ„ 4R(PA) (o502) ?>npe 4 or 9 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 may attain priority over this Security Instrument, Lender may give Borrower a notice identifying the lien. Borrower shall satisfy the lien or take one or more of the actions set forth above within 10 days of the giving of notice. 8. Fees. Lender may collect fees and charges authorized by the Secretary. 9. Grounds for Acceleration of Debt. (a) Default. Lender may, except as limited by regulations issued by the Secretary, in the case of payment defaults, require immediate payment in full of all sums secured by this Security Instrument if: (i) Borrower defaults by failing to pay in full any monthly payment required by this Security Instrument prior to or on the due date of the next monthly payment, or (it) Borrower defaults by failing, for a period of thirty days, to perform any other obligations contained in this Security Instrument. (b) Sale Without Credit Approval. Lender shalt, if permitted by applicable law (including Section 341(d) of the Garn-St. Germain Depository Institutions Act of 1982, 12 U.S.C. 1701 701j-3(d)) and with the prior approval of the Secretary, require immediate payment in full of all sums secured by this Secunty Instrument iE (i) All or part of the Property, or a beneficial interest in a trust owning all or part of the Property, is sold or otherwise transferred (other than by devise or descent), and (ii) The Property is not occupied by the purchaser or grantee as his or her principal residence, or the purchaser or grr.ntee does so occupy the Property but his or her credit has not been approved in accordance with the requirements of the Secretary'. (e) No Waiver. If circumstances occur that would permit Lender to require immediate payment in full, but Lender does not require such payments, Lender does not waive its rights with respect to subsequent events. (d) Regulations of HUD Secretary. In many circumstances regulations issued by the Secrclary will limit Lender's rights, in the case of payment defaults, to require immediate payment in full and foreclose if not paid. This Security instrument does not authorize acceleration or foreclosure if not permitted by regulations of the Secretary. (e) Mortgage Not Insured. Borrower agrees that if this Security Instrument and the Note are not determined to be eligible for insurance under the National Housing Act within 60 days from the date hereof, Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument. A written statement of any authorized agent of the Secretary dated subsequent to 60 days from the date hereof, declining to insure this Security Instrument and the Note, shall be deemed conclusive proof of such ineligibility. Notwithstanding the foregoing, this option may not be exercised by Lender when the unavailability of insurance is solely due to Lender's failure to remit a mortgage insurance premium to the Secretary. 10. Reinstatement. Borrower has a right to be reinstated if Lender has required immediate payment in full because of Borrower's failure to pay an amount due under the Note or this Security Instrument. This right applies even after foreclosure proceedings are instituted. To reinstate the Security Instrument, Borrower shall tender in a lump sum all amounts required to bring Borrower's account current including,. to the extent they are obligations of Borrower under this Security Instrument, foreclosure costs and reasonable and customary attorneys' fees and expenses properly associated with the foreclosure proceeding Upon reinstatement by Borrower, this Security Instrument and the obligations that it secures shall remain in effect as if Lender had not required immediate payment in full. However, Lender is not required to permit reinstatement if: (i) Lender has accepted reinstatement after the commencement of foreclosure proceedings within two years immediately preceding the commencement of a current foreclosure -4R(PA) (0502) Pape 5 of 9 proceeding, (it) reinstatement will preclude foreclosure on different grounds in the future, or (iii) reinstatement will adversely affect the priorityof the lien created by this Security Instrument. 11. Borrower Not Released; Forbearance By Lender Not a Waiver. Extension of the time of payment or modification of amortization of the sums secured by this Secunty Instrument granted by Lender to any successor in interest of Borrower shall not operate to release the liability of the original Borrower or Borrower's successor in interest. Lender shall not be required to commence proceedings against any successor in interest or refuse to extend time for payment or otherwise modify amortization of the sums secured by this Security Instrument by reason of any demand made by the original Borrower or Borrower's successors in interest. Any forbearance by Lender in exercising any right or remedy shall not be a waiver of or preclude the exercise of any right or remedy, 12. Successors and Assigns Bound; Joint and Several Liability; Co-Signers. The covenants and agreements of this Security Instrument shall bind and benefit the successors and assigns of Lender and Borrower, subject to the provisions of paragraph 9(b). Borrowers covenants and agreements shall be joint. and several. Any Borrower who co-signs this Security Instrument but does not execute the Note- (a) is co-signing this Security Instrumem only to mortgage, grant and convey that Borrower's interest in the Property under the terms of this Security Instrument; (b) is not personally obligated to pay the sums secured by this Security Instrument; and (c) agrees that Lender and any other Borrower may agree to extend, modify, forbear or make arty accommodations with regard to the terms of this Security Instrument or the Note without that Borrowers consent. 13. Notices. Any notice to Borrower provided for in this Security Instrument shall be given by delivering it or by mailing it by first class mail unless applicable law requires use of another method. The notice shall be directed to the Property Address or any other address Borrower designates by notice tc Lender. Any notice to Lender shall be given by first class mail to Lendcr's address stated herein or any address Lender designates by notice to Borrower. Any notice provided for in this Security Instrument shall be deemed to have been given to Borrower or Lender when given as provided in this paragraph. 14. Governing Law; Severability. This Security Instrument shall be governed by Federal iaw and the law of the jurisdiction in which the Property is located. In the event that any provision or clause of this Security Instrument or the Note conflicts with applicable law, such conflict shall not affect other provisions of this Security Instrument or the Note which can be given effect without the conflicting provision. To this end the provisions of this Security Instrument and the Note are declared to be severable. 15. Borrower's Copy. Borrower shall be given one conformed copy of the Note and of this Security Instrument. 16. Hazardous Substances. Borrower shall not cause or permit the presence, use, disposal, storage, or release of any Hazardous Substances on or in the Property. Borrower shall not do, nor allow anyone else to do, anything affecting the Property that is in violation of any Environmental Law, The preceding two sentences shall not apply to the presence, use, or storage on the Property of small quantities of Hazardous Substances that are generally recognized to be appropriate to normal residential uses and to maintenance of the Property. Borrower shall promptly give Lender written notice of any investigation, claim, demand, lawsuit or other action by any govemmental or regulatory agency or private party involving the Property and any Hazardous Substance or Environmental Law of which Borrower has actual knowledge. If Borrower learns, or is notified by any governmental or regulatory authority, that any removal or other remediation of any Hazardous Substances affecting the Property is necessary, Borrower shall promptly take all necessary remedial actions in accordance with Environmental Law. As used in this paragraph 16, "Hazardous Substances" are those substances defined as toxic or hazardous substances by Environmental Law and the following substances: gasoline, kerosene, other flammable or toxic petroleum products, toxic pesticides and herbicides, volatile solvents, materials containing asbestos or formaldehyde, and radioactive materials. As used in this paragraph 16, (0 4R(PA) (DW2j P.P. a .1 9 m "Environmental Law" means federal laws and laws of the jurisdiction where the Property is located that relate to health, safety or environmental protection. NON-UNIFORM COVENANTS. Borrower and Lender further covenant and agree as follows: 17. Assignment of Rents. Borrower unconditionally assigns and transfers to Lender all the rents and revenues of the Property. Borrower authorizes Lender or.Lendees agents to collect the rents and'revenues and hereby directs each tenant of the Property to pay the rents to Lender or Lender's agents. However, prior to Lender's notice to Borrower of Borrower's breach of any covenant or agreement in the Security Instrument, Borrower shall collect and receive all rents and revenues of the Property as trustee for the benefit of Lender and Borrower. This assignment of rents constitutes an absolute assignment and not an assignment for additional security only. If Lender gives notice of breach to Borrower: (a) all rents received by Borrower shall be held by Borrower as trustee for benefit of Lender only, to be applied to the sums secured by the Security Instrument; (b) Lender shall be entitled to collect and receive all of the rents of the Property; and (c) each tenant of the Property shall pay all rents due and unpaid to Lender or Lender's agent on Lender's written demand to the tenant. Borrower has not executed any prior assignment of the rents and has not and will not perform any act that would prevent Lender from exercising its rights under this paragraph 17. Lender shall not be required to enter upon, take control of or maintain the Property before or after giving notice of breach to Borrower. However, Lender or a judicially appointed receiver may do so at any time there is a breach. Any application of rents shall not cure or waive any default or invalidate any other right or remedy of Lender. This assignment of rents of the Property shall terminate when the debt secured by the Security Instrument is paid ir: full. 18. Foreclosure Procedure. If Lender requires immediate payment in full under paragraph 9, Lender may foreclose this Security Instrument by judicial proceeding. Lender shall be entitled to collect all expenses incurred in pursuing the remedies provided in this paragraph 18, including, but not limited to, attorneys' fees and costs of title evidence. If the Lender's interest in this Security Instrument is held by the Secretary and the Secretary requires immediate payment in full under Paragraph 9, the Secretary may invoke the nonjudicial power of sale provided in the Single Family Mortgage Foreclosure Act of 1994 ("Act") (12 U.S.C. 3751 et seq.) by requesting *a foreclosure commissioner designated under the Act to commence foreclosure and to sell the Property as provided in the Act. Nothing in the preceding sentence shall deprive the Secretary of any rights otherwise available to a Lender under this Paragraph 18 or applicable law. 19. Release. Upon payment of all sums secured by this Security Instrument, this Security Instrument and the estate conveyed shall terminate and become void. After such occurrence, Lender shall discharge and satisfy this Security Instrument without charge to Borrower. Borrower shall pay any recordation costs. 20. Waivers. Borrower, to the extent permitted by applicable law, waives and releases any error or defects in proceedings to enforce this Security Instrument, and hereby waives the benefit of any present or future laws providing for stay of execution, extension of time, exemption from attachment, levy and sale, and homestead exemption. 21. Reinstatement Period. Borrower's time to reinstate provided in paragraph 10 shall extend to one hour prior to the commencement of bidding at a sheriffs sale or other sale pursuant to this Security Instrument. 22. Purchase Money Mortgage. Borrower to acquire title to the Property 23. Interest Rate After Judgment entered on the Note or in an action of under the Noic. If any of the debt secured by this Security Instrument is lent to this Security Instrument shall be a purchase money mortgage: Borrower agrees that the interest rate payable after a judgment is mortgage foreclosure shall be the rate payable from time to time ;1-1. gC;?y4R(PA) (0502) r.o. 7 ors a 24. Riders to this Security Instrument. If one or more riders are executed by Borrower and recorded together with this Security I'.nstrument, the covenants of each such rider shall be incorporated into and shall amend and supplement the covenants and agreements of this Security Instrument as if the rider(s) were a part of this Security Instrument. [Check applicable box(es)J. _ ? Condominium Rider ? Growing Equity Rider ? Other (specify( Planned Unit Development Rider ? Graduated Payment Rider BY SIGNING BELOW, Bon•ower accepts and agrees to the terms contained in this Security Instrument and in any rider(s) executed by Borrower and recorded with it. Witnesses:--' C ? K10.T1(Sea]) Bo rower n *BverlyM?rlaun -(Seat) -Bovower -(Seal) -Borrower -(Scab) -Bortower (seal) Ja es'L: FoI_ LZ Borrower -(Seal) -Borrower __(Seal) -Borrower -(Seal) Borrow-'r ?4R(PA)105021 Pnpe 9 0/9 ri Li1,,r1%))t1'1 C/1 v?-- COMMONWEALTH OF PENNSYLVANIA, I>EBANOAI- County ss: On this, 5 L-11 day of ?ftrLh ?? before me, the undersigned officer; personally appeared Beverly M. Haulman James L. Foltz known to me (or satisfactorily proven) to be the person(s) whose name is/are subscribed to the within instrument and acknowledged that he/she/they executed the same for the purposes herein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal My Commission Expires: ::MMON'J'cALTH OF PENNSYLV.: - Notarial Seal MUdred M. O'Donnell, Notary Public Camp Hip Boro, Cumberland County My Commission Fires Aug. 30, 2010 Title of Ofrca Member, P• nnsvlvxnin 43 1W,1 If nn 1i Notaries Certificate or Residence ? '??,? I, 5 L ? Cn N do hereby certify that the correct address of the within-named Lender is }n L' J "i C } 7 L??? r\ ; v e I L /? 7) ,? l/ Witness my hand this J5 L_h day of 0? (fit r? h ['30 ?- L (-Agent a( l,cndcr ? t? (06172) Pepe 9 or 9 C lnllela EXHIBIT "A" ALL THAT CERTAIN lot or piece of ground situate in Monroe Township, Cumberland County, Commonwealth of Pennsylvania, more particularly bounded and described as follows, to wit: BEGINNING at a point located on the northern dedicated right-of-way line of Kiner Boulevard) (a 40-foot right-of-way) and a point on the western boundary line of Lot 2 on the hereinafter referenced plan; thence along the western boundary line of Lot 2, North I 1 degrees 12 minutes 30 seconds West, a distance of 199.92 feet to point at the northwest comer of Lot 2 and on the southern boundary line of lands now or formerly of Ernest E. and Helen P. Garvin; thence along the southern boundary line of lands now or formerly of Garvin, South 71 degrees 19 minutes 46 seconds West, a distance of 168.00 feet to a point at the northeast comer of lands now or formerly of Randall L. and Jennifer M. Lynn; thence along the eastern boundary line of lands now or formerly of Lynn, South I 1 degrees 1 I minutes 26 seconds East, a distance of 199.52 feet to a point located on the northern right-of-way lure of Kiner Boulevard; thence along the northern line of Kiner Boulevard, North 71 degrees 28 minutes 00 second East, a distance of 168.00 feet to a point, the point and place of BEGINNING. CONTAINING 29,916.45 net square feet or 0.6868 acres and being known as 1340 Kiner Boulevard, Carlisle, PA 17015. BEING Lot #1 on the Final Subdivision Plan of Land of William Szysh prepared by Todd Allen Lyons, Registered Professional Land Surveyor, recorded in the Cumberland County Recorder of Deeds Office at Instrument No. 200763758. EXHIBIT "C" f ROBERT P. ZIEGLER RECORDER OF DEEDS CUMBERLAND COUNTY 1 COURTHOUSE SQUARE CARLISLE, PA 17013 717-240-6370 Instrument Number - 201033135 Recorded On 11/15/2010 At 8:22: 32 AM * Instrument Type - ASSIGNMEN T OF MORTGAGE Invoice Number - 76649 User ID - MSW * Mortgagor - FOLTZ, JAMES L * Mortgagee - CHASE HOME FINANCE LLC * Customer - GRENEN & BIRSIC * FEES STATE WRIT TAX $0.50 STATE JCS/ACCESS TO $23.50 JUSTICE RECORDING FEES - $11.50 RECORDER OF DEEDS PARCEL CERTIFICATION $10.00 FEES COUNTY ARCHIVES FEE $2.00 ROD ARCHIVES FEE $3.00 TOTAL PAID $50.!50 * Total Pages - 3 Certification Page DO NOT DETACH This page is now part of this legal document. I Certify this to be recorded in Cumberland County PA /? RECORllER O D EDS t?ao * - Information denoted by an asterisk may change during the verification process and may not be reflected on this page. 111111111111111111111111 Parcel #: 22-24-0771-006 ASSIGNMENT OF MORTGAGE Parcel #22-24-0771--006 Prepared By: Grenen & Birsie, P.C. One Gateway Center, 91h Floor Pittsburgh, PA 15222 Return To: Grenen & Birsic, P.C. One Gateway Center, 91h Floor Pittsburgh, PA 15222 From Beverly M. Haulman and James L. Foltz, Mortgagors To JPMorgan Chase Bank, N.A Mortgagee Mortgage Dated: March 5, 2008 Mortgage Recorded: March 11, 2008 Instrument Number: 200807294 in the Recorder's Office of Cumberland County, Pennsylvania. Amount: $164,379.00 For value received and in ending to be le ally bound hereby, JPMorgan Chase Bank, N.A. (".Assignor") does hereby this day of ?-er. , 2010, grant, sell, assign, transfer, set over and deliver Chase Home Finance LLC, s/b/ n/t Chase Manhattan Mortgage Corporation, ("Assignee"), its successors and assigns, all right, title and interest of Assignor in and to the above- referenced Mortgage together with all of Assignor's rights, remedies, incidents and appurtenances as stated in the Mortgage and all of the right, title and interest of Assignor in the premises described in the Mortgage; and Assignor specifically assigns by this Assignment the debt instrument intended to be secured by the Mortgage. Assignor, its successors and assigns, is making this Assignment of Mortgage without any recourse, representation or warranties. In Witness Whereof, Assignor has caused this Assignment to be executed by its hand and seal, with authority therefore, the day and year first above written. ATTES JPMOR AN CHASE BANK, N,A. ? Kim S By: r- Assistant Secretarv e: Vice PrASlriant Property Address: 1340 Kiner Blvd., Carlisle, PA 17015 Monroe Township I ss: On this, the 411.1 day of 2010, before me, the undersigned officer, personally appeared LZZA?n e. -T;-? %A t&r- who acknowledged himself to be the Vice President of JPMorgan Chase Bank, N.A., and that he, being authorized to do so, executed the foregoing Assignment of Mortgage for the purposes therein contained by signing the name of the corporation by himself as Vice President It Witness Whereof, I hereunto set my hand and official seal. ary Public I do certify that the Assignee's precise address is 3415 Vision Drive, Columbus, Ohio 43219. Commonwealth of Pennsylvania Recorded on this -_ day of Par.cea. 1/22-24-0771-006 ss: A. D. 2010, in the Recorder's Office of the said County, at Mortgage Book Volume Page _ Give under my hand and the seal of the said office the day and year aforesaid. STATE OF COUNTY OF TRICIA MARIA STEVENSON Notary Public, State of Ohio `o- My Comm. Expires May 12, 2015 .OF County of Cumberland WITNESS: Recorder By: VERIFICATION hereby states that he/she is of JPMorgan Cha c Bank, National Association, s/b/m/t Chase Home Finance LLC, Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my knowledge- information and belief' The undersigned understands that this statement is made subject to the penalties of IS Pa. C.S. Sec. 4904 relating to unsworn falsificatio.a to authorities. DATE: #/) J File #: 075-10109 04 Name: _ Jennifer Jordan Vice President Title: Name: Haulman, Beverly M. and Foltz, James L. FORM 1 JPMorgan Chase Bank, National Association, IN THE COURT OF COMMON PLEAS OF } - ' s/b/m/t Chase Home Finance LLC, s/b/m/t .1;.. v Chase Manhattan Mortgage Corporation CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff(s) a -? vs. Beverly M. Haulman and James L. Fcltz ' Defendant(s) Civil NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM You have been served with a foreclosure complaint that could cause you to lose your home. If you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in a court-supervised conciliation conference in an effort to resolve this matter with your lender. If you do not have a lawyer you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717)243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative, at no charge to you. Once you have been appointed a legal representative, you must promptly meet with the legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. IF you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE, Respectfully submitted: Date Signature of Counsel for Plaintiff FORM 2 Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHIP ASSISTANCE To complete your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your _ Please provide the following information to the best of your knowledge: CUSTOMERIPRIMARY APPLICATION Borrower name (s): Property Address: City Is the property for sale? Realtor Name: Yes ? No ? Listing date: Borrower Occupied: Yes ? No ? Mailing Address (if different) City: Phone Numbers: Home: Cell: State: Zip: Price: $ Realtor Phone: State: Zip: _ Office: Other: Email: # of people in household: How long? CO-BORROWER Mailing Address: City: Phone Numbers: Home: Cell: State: Office: Other: Zip: Email: # of people in household: How long? FINANCIAL INFORMATION First Mortgage Lender: _ Type of Loan: Loan Number: _ Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number: Total Mortgage Payments Amount: $ Included Taxes and Insurance: ___i_____ Date of Last Payment: Primary Reason for Default: Is the loan in Bankruptcy? Yes ? No ? If yes, provide names, location of court, case number & attorney: Assets Home: Other Real Estate Retirement Funds Investments: Checking: Savings: Other: Amount Owed: Value: Automobile #1: Model: Amount owed: Automobile #2: Model: Amount owed: Value: Other transportation (automobiles, boats irotorcycles) Model: Year: Amount owed: Value: Monthly Income Name of Employers: 1. 2. 3. _ Additional Income Description (not wages): 1. 2. Borrower Pay Days: - Monthly Gross Monthly Gross Monthly Gross Monthly Amount: - Monthly Amount: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently Davinel EXPENSE AMOUNT EXPENSE AMOUNT Mortgage Food- -- - --- - - 2° Mortgage Utilities Car Payment(s) Condo/Neigh. Fees Auto Insurance Med. (not covered) Auto fuel/repairs Other Prop. Payment Install. Loan Payment Cable TV Child Support/Alim. Spending Money Day/Child Care/Tuft. Other Expenses Amount Available for Monthly Mortgage Payments Based on Income and Expenses: Have you been working with a Housing Counseling Agency? Yes ? No If yes, please provide the following information Counseling Agency: Counselor _ Phone (Office): _ Email: Value: Year: Year: Monthly Net Monthly Net Monthly Net Fax: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes E] No ? If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Phone: Servicing Company (Name): Contact: Phone: AUTHORIZATION I/We, _ authorize the above named _ to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. I/we understand that I/we am/are under no obligation to use the services provided by the above named Borrower Signature Borrower Signature Date Date Please forward this document along with the following information to lender and lender counsel: V Proof on income V Past 2 bank statements V Proof of any expected income for the last 45 days V Copy of a current utility bill V Letter explaining reason for delinquency and any supporting documentation V (hardship letter) Listing agreement (if property is currently on the market) V Copy of 2 years of federal income tax returns V Copy of deed SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 1 I???f? ,i?r ;. At -7 Al 9: r? PEN't yL.VAHI `? Jody S Smith Chief Deputy Richard W Stewart Solicitor JP Morgan Chase Bank, NA I Case Number vs. 2012-3212 Beverly M. Haulman (et al.) SHERIFF'S RETURN OF SERVICE 05/22/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: Beverly M. Haulman, but was unable to locate her in his bailiwick. He therefore deputized the Sheriff of Juniata County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program according to law. 05/2212012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent search and inquiry for the within named defendant, to wit: James L. Foltz, but was unable to locate him in his bailiwick. He therefore deputized the Sheriff of Juniata County, Pennsylvania to serve the within Complaint In Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program according to law. 05/30/2012 02:50 PM - Juniata County Return: And now May 30, 2012 at 1450 hours I, H. Thomas Lyter, Sheriff of Juniata County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: James L. Foltz by making known unto Beverly M. Haulman, Wife of Defendant at 3509 Sandvalley Road, Richfield, Pennsylvania 17086 its contents and at the same time handing to her personally the said true and correct copy of the same. 05/30/2012 02:50 PM - Juniata County Return: And now May 30, 2012 at 1450 hours I, H. Thomas Lyter, Sheriff of Juniata County, Pennsylvania, do hereby certify and return that I served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Beverly M. Haulman by making known unto herself personally, at 3509 Sandvalley Road, Richfield, Pennsylvania 17086 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $55.25 June 05, 2012 (c) CountySuite Shenff, Teleosoft, Inc. SO ANSWERS, RON R ANDERSON, SHERIFF SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?8u,i"lr a{ ?atmt,?er1;??? k, 'Y ? c? y r Richard W Stewart Jody S Smith Solicitor Chief Deputyr 4E ;, F r G ??_,F JP Morgan Chase Bank, NA Case Number vs. 2012-3212 Beverly M. Haulman (et al.) Notes W co 0 r• Q a 0 J W LL x U 0 O OC w J J D Z a 0) o? 0 M Name: James L. Foltz Primary 3509 Sandvalley Road Address: Richfield, PA 17086 Phone: DOB: Served: Personally dult In Cher Posted Other Adult In BEVERLY M. HAULMAN Charge: _ _.........__. ...... -.m. Relation: WIFE OF JAMES L. FOLTZ Alternate Date: 5/30/12 Time: :50P.M Address: - Deputy: DL/JS Mileage: 16RT ._..__ Phone: gop A 0, imp "W"100MOW, Name: Kristine M Anthou Phone: 412-281-7650 Date: 5/29/12 N Time: 10:40A.M. N Mileage: 16RT N N Deputy: DL/JS °' v in M" MARY x iMES ENNIST, Notary Fu?,c, SERVICE COSTS $24.00 L40010" Bon, Junhts County Commission Expires July ? ° MILEAGE/POSTAGE 18.21 f _ __.. AFFIDAVIT 5.00 TOTAL $17-.ZTf REFUND $72.79 Ck.#12130(Payable to Atty.) J N Now, May 22, 2012 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Juniata County to w 7- execute service of the documents herewith and make return thereof according to law. a N Return To: 2 Cumberland County,Sheriffs Office One Courthouse Square Carlisle, PA 17013 onny R Anderson, Sheriff fly . rr j 1 a e J I? m I? 0 TTEIFP7DV! '` SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ? "E y, 4{rte Jody S Smith Richard W Stewart Chief Deputy _;?r " --E ERif-F Solicitor JP Morgan Chase Bank, NA vs. Beverly M. Haulman (et al.) N T N O N to X W SERVICE COVER SHEET Case Number 2012-3212 WOR-MOR OWN ON Category: Civil Action - Complaint in Mortgage Foreclosure Zone: _ew.w Manner. Deputize Expires 06/20/2012 ; Warrant. Notes: to 0 0 Q CL 0 J W U- V Q O W J J 0 Z a C" 0 0 M N N M N r O N .? Alternate Date: 530/12 g Time: 2 50P.M n Address: Deputy: DL/JS Mileage: 16RT Phone: NOW Wdkftm 8do., ,NuiGfa County lic f **SEE JAMES L. FOLTZ RETURN FOR COSTS** Y COMission Exiles July 26, 2015 J W- m Now, May 22, 2012 I, Sheriff of Cumberland County, Pennsylvania do hereby deputize the Sheriff of Juniata County to execute service of the documents herewith and make return thereof according to law. z a Return To: D Cumberland County Sheriffs Office = One Courthouse Square Carlisle, PA 17013 onny R Anderson, Sheriff .f? i i A 3 f IV X i E ' a g 7 i S r, F f r t f S ltp T .?` s 1 6 ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVAN JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. I hereby certify that the address of Plaintiff is: 1111 Polaris Parkway Columbus, OH 43240 the last known address of Defendants is: 3509 Sandvalley Road Richfield, PA 17086 GRENEN &BIRSIC, P.C. Attorneys for Plaintif c CIVIL DIVISION cr: -~~ ~ N '.~ ~ ,~ ~~ C~ f"" z ~ ~ n~ N0.:2012-3212-Civil c v cn ~' .-~r G~ p-n ~ p `~ TYPE OF PLEADINGz ~ p ~ %~ PRAECIPE FOR DEFAULT JUDGMENT (Mortgage Foreclosure) FILED ON BEHALF OF PLAINTIFF: JPMorgan Chase Bank, National Association, s/b/m/t Chase Hom,~e Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 Brian M. Kile, Esquire Pa. I.D. #89240 GRENEN &BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 (~~ ~~ , So~ a~ ~~~ 13~~L ~.~ ~3c~~ `~Ult `r ~~e~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV. JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. CIVIL DIVISION NO.: 2012-3212-Civil PRAECIPE FOR DEFAULT JUDGMENT TO: PROTHONOTARY SIR: Please enter a default judgment in the above-captioned case in favor of Plaintiff and against Defendants, Beverly M. Haulman and James L. Foltz, in the amount of $19$,506.01, which is itemized as follows: Principal $159,730.92 Interest to 8/13/12 $ 25,623.64 Late Charges to 8/13/12 $ 155.91 Escrow Deficiency to 8/13/12 $ 5,473.06 Corporate Advances $ 5,868.38 Attorneys' Fees $ 1,170.00 Foreclosure Costs $ 484.10 TOTAL $198,506.01 together with interest, costs, fees, and charges collectible under the note and mortgage inclu~ but not limited to attorneys fees and costs, and for the foreclosure and sale of the mortgaged property. GRENEN & BIRSIC, P.C. B ~ L ~-t- c_ ~ L _ _ /~-,G ~ Kristin M. Anthou, Es ire Attorney for Plaintiff AFFIDAVIT OF NON-MILITARY SERVICE AND CERTIFICATE OF MAILING OF NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT COMMONWEALTH OF PENNSYLVANIA ) )SS: COUNTY OF ALLEGHENY ) Before me, the undersigned authority, a Notary Public in and for said County and Commonwealth, personally appeared Kristine M. Anthou, Esquire, attorney for and'authorized representative of Plaintiff who, being duly sworn according to law, deposes and says that the Defendants are not in the military service of the United States of America to the best of her knowledge, information and belief and certifies that the Notices of Intent to take Default Judgment were mailed in accordance with Pa. R.C.P. 237.1, as evidenced by the attached copies. Sworn to and subscribed before me this _L~ day of _~,~~ 2012. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION NO.: 2012-3212-Civil Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. TO: Beverly M. Haulman 3509 Sandvalley Road Richfield, PA 17086 DATE OF NOTICE: June 25, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRTTTEr APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NC HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIItE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY CIFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 FIRST CLASS MAIL, POSTAGE PREPAID GRENEN & BIRSIC, P. . Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV. JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION NO.: 2012-3212-Civil Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. TO: James L. Foltz 3509 Sandvalley Road Richfield, PA 17086 DATE OF NOTICE: June 25, 2012 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEr APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE 1N WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING A1vTD YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU DO NC HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEB. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or Toll Free (800) 990-9108 FIRST CLASS MAIL, POSTAGE PREPAID GRENEN & BIRSIC, P.C. B~ ~ ~ ~ ~ ~~~c-~ Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, NO.: 2012-3212-Civil Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. NOTICE OF ORDER, DECREE OR JUDGMENT TO: Beverly M. Haulman 3509 Sandvalley Road Richfield, PA 17086 ( )Plaintiff (XX) Defendant ( )Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on ~ S ( ) A copy of the Order or Decree is enclosed, or (XX) The judgment is as follows: $198,506.01 together with interest, costs, fees, and charges collectible under the note and mortgage inclu~ but not limited to attorneys fees and costs, and for the foreclosure and sale of the mortgaged property. ~-~ Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV. JPMORGAN CHASE BANK, CIVIL DIVISION NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, NO.: 2012-3212-Civil Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. NOTICE OF ORDER. DECREE OR JUDGMENT TO: James L. Foltz 3509 Sandvalley Road Richfield, PA 17086 ( ) Plaintiff (XX) Defendant ( )Additional Defendant You are hereby notified that an Order, Decree or Judgment was entered in the above captioned proceeding on $ ( ) A copy of the Order or Decree is enclosed, or (XX) 'The judgment is as follows: $198,506.01 together with interest, costs, fees, and charges collectible under the note and mortgage includi~ but not limited to attorneys fees and costs, and for the foreclosure and sale of the martgag property. w Deputy WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO. 12-3212 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t CHASE HOME FINANCE LLC, s/b/m/t CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff (s) From BEVERLY M. HAULMAN AND JAMES L. FOLTZ (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: $198,506.01 L.L.: $.50 Interest FROM 8/13/2012 TO SALE - $5,347.46 Atty's Comm: Atty Paid: $206.50 Plaintiff Paid: Date: 8/29/2012 (Seal) Due Prothy: $2.25 Other Costs: David D. Buell, Prothonot Deputy REQUESTING FARTY: Name: KRISTINE ANTHOU, ESQUIRE Address: GRENEN & BIRSIC, P.C. ONE GATEWAY CENTER, NINTH FLOOR PITTSBURGH, PA 15222 Attorney for: PLAINTIFF Telephone: 412-281-7650 Supreme Court ID No. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. CNIL DIVISION NO.: 2012-3212-Civil PRAECIPE FOR WRIT OF EXECUTION (MORTGAGE FORECLOSURE) TO: Prothonotary ~. J ~~ 1 i 7't.:~..I ~~ ~~ -t~' ~--~ ~~ v c-, aca --~ _..f «.a ~_ N c ~~ z> 0 SIR: Please issue a Writ of Execution, directed to the Sheriff of Cumberland County, again the Defendants, Beverly M. Haulman and James L. Foltz, as follows: Amount Due Interest from 8/13/12 to Sale TOTAL -~. So a a "~~ ~a4 ~ Iv~.?S U'~ `!, UM . mil/ [r ss a~.~Pd a~ $198,506.01 $ 5,347.46 $203,853.47 GRENEN & BIlZSIC, P.C. Attorneys for Plaintiff ~ 7.52 S `~+`~ ~. ~. ~ ~..~. C~#J40~f1 ~~ a~9 9~~ I,I;r k of RE ~'T[ ^^ -^ --~ ~-; __~ r ~, -~ . c.~ -:~- c ~' ~,. _ _ _ _ _ _ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA'', CIVIL DIVISION JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, NO.: 2012-3212-Civil ~' ~_ c '" f'J i+W~r+ ~ ~, V c-- ~,~ ~~ .ti r.. ~ -c o s~ c-> ~_ ?C ~ ~ ._ -- ~,;~ r°~ -~ ~.., ~:~ ~.~, `ca~ -~-f °~, -~ - Qr` --+ J ., V S. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the the Praecipe for the Writ of Execution was filed the following information concerning the property of Beverly M. Haulman and James L. Foltz located at 1340 Kiner Blvd., Carlisle, 17015 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF BEVERLY M. HAULr AND JAMES L. FOLTZ OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN MONR E TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1340 KINER BLVD., CARLISLE, A 17015. INST. #200807293. PARCEL #22-24-0771-006. r 1. The name and address of the owners or reputed owners: Beverly M. Haulman James L. Foltz 3509 Sandvalley Road Richfield, PA 17086 2. The name and address of the defendants in the judgment: Beverly M. Haulman 3509 Sandvalley Road James L. Foltz Richfield, PA 17086 3. The name and last known address of every judgment creditor whose judgment is a record li on the real property to be sold: JPMorgan Chase Bank, et al. [PLAINTIFF] 4. The name and address of the last record holder of every mortgage of record: JPMorgan Chase Bank, et al. [PLAINTIFF] 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Commonwealth of Pennsylvania Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property whose interest maybe affected by the sale: None 7. The name and address of every other person whom the plaintiff has knowledge who has interest in the property which maybe affected by the sale: Tenant(s) 1340 Kiner Blvd. Carlisle, PA 17015 I verify that the statements made in the Affidavit are true and correct to the best of personal knowledge, information and belief. I understand that false statements herein are m subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN to and subscribed before me this ~~` day of ~r~,~ ~ ~,i,t A ,~, 2012. _ d_ l/ Cc Notary P lic s3iavlow ~+o Nour vnrrnusN~ `a3ew3w s~oz z wn~ 9a, ~uno~ ~twV~lll-'4E Jo ~jD ~II4nd ~' ~g ~i~i! Fk1:lV3MNOWWO,~ COMMONWEq~TM OF M.V ~~ G.~ Sep ~YC~~ ~~ M~~ ~'-SYL'VAHU ~50C1A7ION OF NOTAI~ _~ _ ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL DIVISION JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, NO.: 2012-3212-Civil '~ r- 3 ~rn c ~ ~a c ~~ ~-- ~ to ~' n zo ~~ o x -- ..~ --- ~,._. -" ~. ~.;:'r ~ y ~~ .~~ ~, .~: -, c:~ -r; -. _,_. o ~-;' --r ~' ~.., .:- Defendants. NOTICE OF SHERIFF'S SALE OF REAL ESTATE TO: Beverly M. Haulman 3509 Sandvalley Road Richfield, PA 17086 TAKE NOTICE that by virtue of the above Writ of Execution issued out of the Court Common Pleas of Cumberland County, Pennsylvania, and to the Sheriff of Cumberland Coun directed, there will be exposed to Public Sale in the Cumberland County Courthouse Commissioners Hearing Room, 2nd Floor 1 Courthouse Square Carlisle, PA 17013 on December 5, 2012, at 10:00 A.M., the following described real estate, of which Beverly r Haulman and James L. Foltz are the owners or reputed owners: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF BEVERLY M. HAULT AND JAMES L. FOLTZ OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN MONR E TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1340 KINER BLVD., CARLISLE, A 17015. INST. #200807293. PARCEL #22-24-0771-006. The said Writ of Execution has been issued on a judgment in the mortgage foreclosure action JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. Beverly M. Haulman and James L. Foltz, Defendants, at Execution Number 2012-3212-Civil in the amount of $203,853.47. A Schedule of Distribution will be filed by the Office of the Sheriff no later than 1 (30) days from the sale date. Distribution will be made in accordance with the Schedule of Distribution u exceptions thereto are filed with the Office of the Sheriff within ten (10) days from the when the Schedule of Distribution is filed by the Office of the Sheriff. GRENEN & BIlZSIC, P.C. /, By: Kristine M. Anthou, Esquire Attorney for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVAI'~IIA CNIL DNISION JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase NO.: 2012-3212-Civil Manhattan Mortgage Corporation, Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. LONG FORM DESCRIPTION ALL that certain lot or piece of ground situate in Monroe Township, Cur County, Commonwealth of Pennsylvania, more particularly bounded and described as fo wit: to BEGINNING at a point located on the Northern dedicated right-of--way line of 'ner Boulevard (a 40 foot right-of--way) and a point on the Western boundary line of Lot 2 o the hereinafter referenced plan; thence along the Western boundary line of Lot 2, North 11 d ees 12 minutes 30 seconds West, a distance of 199.92 feet to point at the Northwest corner of of 2 and on the Southern boundary line of lands now or formerly of Ernest E. and Helen P. G in; thence along the Southern boundary line of lands now or formerly of Garvin, South 71 d ees 19 minutes 46 seconds West, a distance of 168.00 feet to a point at the Northeast corner of ands now or formerly of Randall L. and Jennifer M. Lynn; thence along the Eastern boundary li a of lands now or formerly of Lynn, South 11 degrees 11 minutes 26 seconds East, a distan a of 199.52 feet to a point located on the Northern right-of--way line of Kiner Boulevard; thence lortg the Northern line of Kiner Boulevard, North 71 degrees 28 minutes 00 seconds East, a dis ante of 168.00 feet to a point, the point and place of beginning. CONTAINING 29,916.45 net square feet or 0.6868 acres and being known as 1340 Boulevard, Carlisle, PA 17015. BEING Lot #1 on the Final Subdivision Plan of Land of William Szysh prep Todd Allen Lyons, Registered Professional Land Surveyor, recorded in the Cumberland Recorder of Deeds Office at Instrument No. 200763758. d by aunty PARCEL No. 22-24-0771-006. BEING the same premises which William Szysh, by Deed dated February 29, 200 and recorded in the Office of the Recorder of Deeds of Cumberland County on March 11, 20 8, at Instrument No. 200807293, granted and conveyed unto Beverly M. Haulman and James L. oltz. GRENEN & BIRSIC, P.C. By_ ~ ~~.~ ~,~_~. ~JLC~~ Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLV CIVIL DIVISION JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. NO.: 2012-3212-Civil LONG FORM DESCRIPTION ALL that certain lot or piece of ground situate in Monroe Township, Cum County, Commonwealth of Pennsylvania, more particularly bounded and described as foll wit: BEGINNING at a point located on the Northern dedicated right-of--way line of Boulevard (a 40 foot right-of--way) and a point on the Western boundary line of Lot 2 c hereinafter referenced plan; thence along the Western boundary line of Lot 2, North 11 de 12 minutes 30 seconds West, a distance of 199.92 feet to point at the Northwest corner of and on the Southern boundary line of lands now or formerly of Ernest E. and Helen P. G. thence along the Southern boundary line of lands now or formerly of Garvin, South 71 de 19 minutes 46 seconds West, a distance of 168.00 feet to a point at the Northeast corner of now or formerly of Randall L. and Jennifer M. Lynn; thence along the Eastern boundary l lands now or formerly of Lynn, South 11 degrees 11 minutes 26 seconds East, a distar 199.52 feet to a point located on the Northern right-of--way line of Kiner Boulevard; thence the Northern line of Kiner Boulevard, North 71 degrees 28 minutes 00 seconds East, a di: of 168.00 feet to a point, the point and place of beginning. CONTAINING 29,916.45 net square feet or 0.6868 acres and being known as 1340 Boulevard, Carlisle, PA 17015. BEING Lot #1 on the Final Subdivision Plan of Land of William Szysh prep Todd Allen Lyons, Registered Professional Land Surveyor, recorded in the Cumberland Recorder of Deeds Office at Instrument No. 200763758. ~_ i to the t2 of of by PARCEL No. 22-24-0771-006. ___ , BEING the same premises which William Szysh, by Deed dated February 29, 2008 d recorded in the Office of the Recorder of Deeds of Cumberland County on March 11, 2008 at Instrument No. 200807293, granted and conveyed unto Beverly M. Haulman and James L. Fo tz. GRENEN & BIRSIC, P.C. By: l Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff, vs. BEVERLY M. HAULMAN AND JAMES L. FOLTZ, Defendants. CNIL DIVISION -_:, .. -y _ _ .~ 1 - y r .. r _. NO.: 2012-3212-CNIL `' ~:~; .'_ '~~-~. ~i TYPE OF PLEADING ~ ~- ` -,-. -- - -, _ ~- ,~.- ~_ . _-- f- .. Pa. R.C.P. RULE 3129.2(c)(2) '"~ =~ <° '=~ PURSUANT TO RULE 3129.1 - LIENHOLDER AFFIDAVIT OF SERVICE FILED ON BEHALF OF PLAINTIFF: JPMorgan Chase Bank, National Association s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation COUNSEL OF RECORD FOR THIS PARTY: Kristine M. Anthou, Esquire Pa. I.D. #77991 GRENEN & BIRSIC, P.C. One Gateway Center Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SALE DATE: 12/5/12 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, CIVIL DIVISION NO.: 2012-3212-Civil Plaintiff, vs. BEVERLY M. HAULMAN AND JAMES L. FOLTZ, Defendants. Pa. R.C.P. RULE 3129.2(c)(2) LIENHOLDER AFFIDAVIT OF SERVICE Kristine M. Anthou, Esquire, Attorney for Plaintiff, JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, being duly sworn according to law, deposes and makes the following Affidavit regarding service of the notice of the sale of real property on all persons named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 as follows 1. By letters dated September 17, 2012, undersigned counsel served all persons (other than the Plaintiff) named in Paragraphs 3 through 7 of Plaintiffs Affidavit Pursuant to Rule 3129.1 with a notice of the sale of real property by ordinary mail at the respective addresses set forth in the Affidavit Pursuant to Rule 3129.1. True and correct copies of said Affidavit Pursuant to Rule 3129.1 and Certificates of Mailing and any letters, if returned as of this date, are marked Exhibit "A", attached hereto, and made a part hereof. I verify that the facts contained in this Affidavit are true and correct based upon my personal knowledge, information and belief. GRENEN & BIRSIC, P.C. Kristine M. Anthou, Esquire Attorneys for Plaintiff One Gateway Center, Ninth Floor Pittsburgh, PA 15222 (412) 281-7650 SWORN TO AND SUBS~C}RIBED BEFO~RE~ Mf E THIS DAY OF/ (~~`-~-~'~~ `x,/212• 4 ~' ~ Notary Public COMMONWEALTH OF PENN8YLVANtA Notarial Sssi .__.=,.e~... Joanne M. Wehner, Notary ~'ublic City of Pittaburyh, Allegheny iouf,ty My CorttfniNion Ex fires Juna t S, 2(313 ..~.,...~ _s_ ~."~moEr, pann~ylvaA a Arrrani~iw,~, ~? : e;,:r=e-: ~~ EXHIBIT "A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CNIL DIVISION JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase NO.: 2012-3212-Civil Manhattan Mortgage Corporation, Plaintiff, vs. BEVERLY M. HAULMAN and JAMES L. FOLTZ, Defendants. AFFIDAVIT PURSUANT TO RULE 3129.1 COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND JPMorgan Chase Bank, National Association, s/b/m/t Chase Home Finance LLC, s/b/m/t Chase Manhattan Mortgage Corporation, Plaintiff in the above action, sets forth as of the date the Praecipe for the Writ of Execution was filed the following information concerning the real property of Beverly M. Haulman and James L. Foltz located at 1.340 Kiner Blvd., Carlisle, PA 17015 and is more fully described as follows: ALL THE RIGHT, TITLE, INTEREST AND CLAIM OF BEVERLY M. HAULMAN AND JAMES L. FOLTZ OF, IN AND TO THE FOLLOWING DESCRIBED PROPERTY: ALL THE FOLLOWING DESCRIBED REAL ESTATE SITUATED IN MONROE TWP., CUMBERLAND COUNTY, PENNSYLVANIA. HAVING ERECTED THEREON A DWELLING BEING KNOWN AND NUMBERED AS 1340 KINER BLVD., CARLISLE, PA 17015. INST. #200807293. PARCEL #22-24-0771-006. 1. The name and address of the owners or reputed owners: Beverly M. Haulman James L. Foltz 3509 Sandvalley Road Richfield, PA 17086 2. The name and address of the defendants in the judgment: Beverly M. Haulman 3509 Sandvalley Road James L. Foltz Richfield, PA 17086 3. The 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, et al. [PLAINTIFF] 4. The name and address of the last record holder of every mortgage of record: JPMorgan Chase Bank, et al. [PLAINTIFF] 5. The name and address of every other person who has any record lien on the property: Cumberland Domestic Relations P.O. Box 320 Carlisle, PA 17013 PA Department of Revenue Bureau of Compliance P.O. Box 281230 Harrisburg, PA 17128-1230 Commonwealth of Pennsylvania Department of Welfare P.O. Box 2675 Harrisburg, PA 17105 6. The name and address of every other person who has any record interest in the property and whose interest maybe affected by the sale: None 7. The name and address of every other person whom the plaintiff has knowledge who has any interest in the property which maybe affected by the sale: Tenant(s) 1340 Kiner Blvd. Carlisle, PA 17015 I verify that the statements made in the Affidavit are true and correct to the best of my personal knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. /~~~ ~ c ~~1f~G L. Kristine M. Anthou, Esquire Attorney for Plaintiff SWORN to and subscribed before me this ~}~ day of , 2012. ~~~ CSC ~~" ~, Notary P lic s~arlo o na rt StOt owK s~ q ~~ '~""~'~d~ud ~ do '•~ i~ i~ao~ ~~nnnwwwao coMni of a~y~~,~ ~~ ~ M~eae, ~VNSYI.vMlIA ASSp(7A~ ~ 1S NbT~ ~1 ~ r -~ 00 r." ~ ~ ~ W ~ Y N ~. ~ ~ 0 ~ v CT7 CJ1 ~ ~ ~ ~ ~ ~ ~ to CD p o .~~ ~ ~ ~~ -~ rn C7 O ~ D n c ~ ~ ~G7cp a c°DW ~.~m v ~ ~ o' ~ ~ = a n- ~ m ° ~ O ~ m ~ (D Q° N 0 V ~~ ~ ~ ~ ~ + ~ ~ N Z~ ~ v ~ ~ m D~ N m ( D . ` ~ ~ N. n N ~ rn m fV ~ N S ~ ~ ~ ~\ `~ ~ C fD ~ 'j~ o ~ m `~ ' ~ O O V ~ ~ ~_ ~ ` ~• i v y O t v \ ~ nW ~ =-pp ~ ~ =~a7 ~ ~ C)~ ~ ~ ~ ~ 3 `" ,. 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