The URL can be used to link to this page

Home My WebLink About12-3597KML LAW GROUP, P.C. SUITE 5000 - BNY MELLON INDEPENDENCE CENTER t 701 MARKET STREET 4 PHILADELPHIA, PA 19106 ? tt'4t + (866)413-2311------ JPMORGAN CHASE BANK, NATIONAL T 1 ASSOCIATION, AS SUCCESSOR IN INTERESTi'I'b WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A c/o 3415 Vision Drive Columbus, OH 43219 Plaintiff i WT-11E COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE vs. ELAINE A. DEMARCO Mortgagor(s) and Record Owner(s) 10 East Locust Street Mount Holly Springs, PA 17065 Defendant(s) No.1a -,:?T9 Ct vCIVIL ACTION: MODE -I' FORECLOBURB1 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 the 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 claim in the Complaint of 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. 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 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notifrcacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a 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 continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME C-33 ?'io3.7s , .sI ?tii ?/ Cc! POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the P14FA website http://www.phfa.orsz/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: http://WWW.Dhiladelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866413-2311 or via email at homeretentiongkmilaw roup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/or package you requested will be mailed to the address that you request or faxed if you leave a message with that information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who can be reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 111671FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A., c/o 3415 Vision Drive, Columbus, OH 43219. 2. The name(s) and address(es) of the Defendant(s) is/are ELAINE A. DEMARCO, 10 East Locust Street, Mount Holly Springs, PA 17065, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. On June 07, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to WASHINGTON MUTUAL BANK, FA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on July 26, 2006 as Book 1959, Page 3464.. The Mortgage is/are matter(s) of public record and is/are incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property„). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for October 01, 2011 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of March 31, 2012: Principal Balance .........................................................................................$227,260.64 Variable Interest from 09/01/2011 through 03/31/2012 ...............................$4,980.22 Accrued Late Charges ........................................................................................$551.84 Escrow .............................................................................................................. ($132.19) Property Inspections ...........................................................................................$218.00 Reasonable Attorney's Fee .............................................................................$1,450.00 $234,328.51 If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of Intention to Foreclose has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit "B". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $234,328.51, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the forecl4ure and sa of the mortgage property. By: KML LANE C?'MC i?'Ij, P.? Micha?iviti Mc{eever Pa. ID 56129 Jay E. Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 oshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Attorneys for Plaintiff VERIFICATION hereby states that he/she is y? 1 res??? Y of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, AS SUCCESSOR IN INTEREST TO WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.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 my knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: 5 , ? I - o ? 7-- (?7 Name: Title: Camron Chambers Vice President #111671FC ELAINE A. DEMARCO E..xhibitA PARCEL A ALL THAT CERTAIN tract of land with the improvements thereon emoted, Hereditaments and Appurtenances, Situate in South Middleton Township, Cumberland County, Pe rmsylvania, bounded and described, as follows: On the North by a public road leading from State Highway Route No. 34 to Boiling Springs, said public road being locally known as "the back road to Boiling Springs" on the East by land now or formerly of Ralph Lyford; on the South by land now or formerly of Arnold Garonzik; and on the West by land now or formerly of Arnold Garonzik. CONTAINING 81.3 feet in front on said public road and extending in depth 165 feet on its Eastern boundary, and 185.7 feet along its Western boundary to land n ow or formerly of Arnold Garo= k; and having a width in the rear along its Southern boundary of 65 feel. BEING the same premises which Clarence T. Dorsey and Bertha M. Dorsey, husband and wife, by Indenture dated May 6, 1968 and recorded in the Recorder of Deeds, in and for the County of Cumberland, aforesaid, in Deed Book Volume T22 page 568 &c., granted and conveyed unto Edgar E. Dorsey and Betty K. Dorsey, husband and wife, in fee. PARCEL B ALL THOSE TWO CERTAIN tract of land, Hereditamennts and Appurtenances, Situate in South Middleton Township, Cumberland County, Pennsylvania, bounded and described as follows: TRACT NO. 1. BEGINNING at a point in the public road, opposite a post in the line between the tract herein described and land now or formerly of the Nofsinger heirs; thence South 18 3/4 degrees East 49.5 perches to stones; thence by the same, South 86 1/2 degrees West 33.9 perches to stones at comer of land now or formerly of J.A. Blosser, thence by the same, South 11 1/4 degrees East 78 perches to stones; thence North 68 1 /4 degrees East 40.5 perches to a corner, thence North 28 1/4 degrees West 18 perches; thence North 65 3/4 degrees East, 20.5 perches to a corner of land now or formerly of the Diver firs; thence by the same, North 181/4 degrees West 43 perches to stones at corner of land now or formerly of the Divers heirs and Freidman; thence by said land now or formerly of Freidman, North 20 degrees West 35.6 perches to land now or formerly of James A. Hemphill; thence by the same, South 70 degrees West 3.94 perches to a stake; thence by the same, North 20 degrees West 11.25 perches to an iron pin in the center of the public road; thence by the venter of said road, South 83 3/4 degrees West .9 perch to a point in said road; thence continuing along the center of said road, North 741 /4 degrees 11.6 porches t o the place of BEGINNING. CONTAINING 25 acres and 95 perches, more or less; and being improved with a frame dwelling house. TRACT NO. 2. BEGINNING at a comer of land now or formerly of the Harry heirs and Cumberland Clay Co.; thence South 60 degrees 50 minutes /West 24.4 perches to stones; thence by land now or formerly of Cumberland Clay Co., North 41 degrees West 28 perches; thence by land now or formerly of Hentzler, North 49 degrees 45 minutes East 30.5 perches to a stone near an oak; thence by land now or formerly of Cumberland Clay Co., South 29 degrees 45 minutes East 84 perches to the place of BEGINNING. Me No. PR0M33M Commitment No. 86 9129RS a t:?} alfd unless the Insuring Provisions and Schedules A and B are attached. CONTAINING 5 acres 28 perches, more'or less. BEING the same premises which Edgar E.Dorsey and Betty K. Dorsey, husband and wife, by Indenture dated May 6, 1968 and recorded in the Recorder of Deeds, in and for the County of Cumberland, aforesaid, in Deed Book Volume 252 page 731 8tc., granted and conveyed unto Edgar E. Dorsey and Betty K. Dorsey, husband and wife, in fee. LESS AND EXCEPT THOSE PREMISES CONVEYED BY THE FEE OWNERS TO THOMAS D. DORSEY, SR.. AND TAMMY J. DORSEY, HUSBAND AND WIFE BY DEED DATED 5/23/02 AND RECORDED 5/24102 IN DEED BOOK 251 PAGE 4256, MORE PARTICULARLY DESCRIBED AS FOLLOWS: ALL THAT CERTAIN tract of land with the improvements thereon erected, Hereditaments and Appurtenance, Situate in South Middleton Township, Cumberland County, Pennsylvania, more particularly bounded and described as follows: BEGINNING at a point in East Locust Street, which point is also in the line of lands now or formerly of E. Gene Shetter thence, in, slang and over East Locust Street South 82 degrees 23 minutes 49 seconds East 156.73 feet to a steel pin South of the edge of East Locust Street; thence North 67 degrees 21 minutes 32 seconds. East 23.18 feet to a point on the Southern edge of East Locust Street and in the line of lands now or formerly of Edgar E. and Betty K. Dorsey; thence along the lands now or formerly of Edgar E. and Betty K. Dorsey and through a steel pin, South 33 degrees 20 minutes 00 seconds East 362.92 feet to a steel pin; thence continuing along the lands now or formerly of Edgar E. and Betty K Dorsey South 56 degrees 40 minutes 00 seconds west 132.46 feet to a steel pin in the line of lands now or formerly of E.Gene Shetter; thence along the line of lands now or formerly of Shetter.l, orth 34 degrees 23 minutes 48 seconds West 470 feet through a steel pin and to a point at the place of BEGINNING. 11 CONTAINING 1.282 acres including the dedicated right-of-way and being Lot No. 2 as shown on the Final Subdivision Plan for Edgar E. and Betty K. Dorsey dated June 1, 1987, and recorded in the Office of the Recorder of Deeds in and for Cumberland County in Plan Book 53, plage 89 and being improved with a 2 1 /2 story dwelling known and numbered as 8 East Locust Street, Mt.Holly Springs, PA. BEING Parcel No. 40-13-0124-010. EXCEPTING thereout and therefrom-(if any) the premises as more fully described in the following deed: NONE File No. PROIW333N Cant nW9No::0&9139RS 1 kls It rt?esa?tke ftua rrg Phwkions and Schedules A acrd A are auacW. E..xhibit (B *Exhibit has been redacted to remove all personally identifiable information or non-public information Chase (FL5-7734) PO BOX 44090 Jacksonville, FL 32231-4090 12/27/2011 0000936 01 MB 0.387 -AUTO T8 0 8059 17085-100810 _ -G07-1 #BWNCLNN# #0930619993949397# ELAINE A DEMARCO 10 E LOCUST ST MOUNT HOLLY SPRINGS PA 17065-1008 1??111?11?nl?lll?l?nnul???l?1???1??11???l?lli11??11?11??1??1 CHASE O Acceleration Warning (Notice of Intent to Foreclose) Account: =3493 (the "Loan") Property Address: 10 E LOCUST ST MOUNT HOLLY SPRINGS, PA 17065 (the "Property") Dear ELAINE A DEMARCO: Under the terms of the Mortgage or Deed of Trust ("Security Instrument") securing your Loan, JPMorgan Chase Bank, N.A.("Chase") hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due 10/01/2011. 2. As of 12/27/2011, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $5000.13 are past due. This past-due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3 . If you have any questions about the amounts detailed below, please contact us as soon as possible at (800) 848-9380. Total Monthly Payments $4331.54 Late Fees $492.59 NSF Fees $0.00 Other Fees* $0.00 Advances* $176.00 Amount Held in Suspense $0.00 *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. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of 01/29/2012 set forth in Paragraph 4 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees and other fees, as permitted by applicable law. If you have any reason to dispute the past-due amount listed above, or if you believe your Loan is current, please contact us at the number provided below. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately. If full payment of the amount of default is not made within 33 days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 5. You have the right to cure the default, or anyone acting on your behalf, and pay your account current anytime at least one hour prior to the commencement of bidding at a sheriff's sale or other judicial sale, not more than three times in any calendar year. To do so, you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation which you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default, as specified in writing by the mortgagee d) Pay any reasonable late penalty, if outlined in the mortgage Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 6. If you fail to cure the default on or before 01/29/2012, Chase will accelerate the maturity of the Loan, terminate your credit line if the Loan provides for revolving advances, declare all sums secured by the Security Instrument immediately due and payable and commence foreclosure proceedings, all without further notice to you. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure/attomey fees and other expenses permitted by your loan documents or applicable law. 7. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees related to any foreclosure action we initiate. 8. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay payment. 000093G/BW840 Regular Mail: CHASE PO BOX 78420 PHOENIX, AZ 85062-8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034-9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at (800) 848-9380. 10. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly, your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You 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. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll-free at (800) 569-4287 or at www.hud.gov. Sincerely. Chase (800) 848-9380 (800) 582-0542 TDD / Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS If you are a servicemember who is, or recently was, on "active duty" or "active service" or a dependent of such a servicemember, you may be entitled to certain legal rights and protections, including protection from foreclosure or eviction, pursuant to the Servicemembers Civil Relief Act (50 USC App. §§ 501-596), as amended (the "SCRA") and possibly certain similar state statutes. Eligible service may include: • Active duty (as defined in section 101(d)(1) of title 10, United States Code) with the Army, Navy, Air Force, Marine Corps or Coast Guard • Active service with the National Guard • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration • Active service as a commissioned officer of the Public Health Service • Service with the forces of a nation with which the United States is allied in the prosecution of a war or military action • Service with the National Guard or a state militia under a state call to duty Eligible service also includes any period during which a servicemember is absent from duty on account of sickness, wounds, leave or other lawful cause. If you are such a servicemember, or a dependent of such a servicemember, you should contact Chase Military Services toll-free at (866) 840-5826 to discuss your status. 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 is a debt collector. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BW840 0000936/BW840 Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications - for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. "We can stop your foreclosure!" "9701c success rate!" "Guaranteed to save your home!" These kinds of claims are the tell-tale signs of a foreclosure rip-off. Steer clear of anyone who offers an easy out. Don't Pay for a Promise. Don't pay any business, organization, or person who promises to prevent foreclosure or get you a new mortgage. These so-called "foreclosure rescue companies" claim they can help save your home, but they're out to make a quick buck. Some may request hefty fees in advance - and then stop returning your calls. Others may string you along before disclosing their charges. Cut off all dealings if someone insists on a fee. Send Payments Directly. Some scammers offer to handle financial arrangements for you, but then just pocket your payment. Send your mortgage payments ONLY to your mortgage servicer. Don't Pay for a Second Opinion. Have you applied for a loan modification and been turned down? Never pay for a "second opinion." Imitations = Frustrations. Some con artists use names, phone numbers, and websites to make it look like they're part of the government. If you want to contact a government agency, type the web address directly into your browser and look up any address you aren't sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Pages in your phone directory. Don't click on links or open any attachments in unexpected emails. Talk to a HUD-Certified Counseling Agency - For Free. If you're having trouble paying your mortgage or you've already gotten a delinquency notice, free help is a phone call away. Call 1-888-995 -HOPE for free personalized advice from housing counseling agencies certified by the U.S. Department of Housing and Urban Development (HUD). This national hotline - open 24n - is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD-certified counseling agencies. For free guidance online, visit www.hopenow.com. For free information on the President's plan to help homeowners, visit www.makingbomeaffordable.gov. eft Federal Trade Commission ftc.gov/MoneyMatters Gall 1-888-995-HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPE TM Hotline - open 24/7 - is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD-certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov HOPENOW SuPPOrt d Guidance Fpr Homeowners MAKING HOME AFFORDABLE.GOv IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE, BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEWER OF Case No. )? . 3,54'7 WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. co ELAINE A. DEMARCO Defendant(s) 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 that 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 MidPenq 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 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. 6/5/2012 Date Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet Date Cumberland County Court of Common Pleas Docket # BORROWER REQUEST FOR HARDSHXP ASSISTANCE To complete-your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your _ Please provide the following information to the best of your knowledge: Borrower name(s): Property Address: City: State; Zip: Is the property for sale? Yes ? No ? Listing date: Price: $ Realtor Name: Realtor Phone: Borrower Occupied? Yes No , Mailing Address (if different): City: State:-Zip: Phone Numbers: Home: Office: _ Cell: Other: Email: # of people in household: How long? Mailing Address: City: Phone Numbers: State: Zip: Home: Cell: Email; # ofpeople 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: Prima!y Reason for Default: Office: Other: Is the loan in Bankruptcy? Yes ? No E] 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 #l: Model: Year: Amount owed: Value: Automobile #2: Model: Year: Amount owed: Value: _ Other transportation (automobiles boats mgt rc cles Model: Year Amount owed: Value Monthly Income Name ofEmployers: 1. 3. Additional Income Description (not wages): 1 • monthly amount: 2. monthly amount: Borrower Pay Days: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) Have you been working with a Housing Counseling Agency? Yes ? No [_] If yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): w Fax; Amount Available for Monthly Mortgage Payments Based on Income & Expenses: Email: Have you made application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes EJ No L7 If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes ? No ? if yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): phone: Servicing Company (Name): Contact: Phone: IfWe, , 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. UWe understand that Uwe am/are under no obligation to use the services provided by the above named Borrower Signature Date Co-Borrower Signature Date Please forward this document along with the following information to tender and lender's counsel: Vr Proof of income -V( Past 2 bank statements Y 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) Y Listing agreement (if property is currently on the market) SHERIFF'S OFFICE OF CUMBERLAND COUNTY _ Ronny RAnderson Sheriff „titr ct +Cum6rr f ; Jody S Smith ?D ??? ??, ` Chief Deputy r7 _ w Richard W Stewart r- Solicitor QFFtcE OF THE SNBRIFF JP Morgan Chase Bank, NA Case Nu mber vs. 2012-3597 Elaine A. Demarco SHERIFF'S RETURN OF SERVICE 06/12/2012 06:22 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June 12, 2012 at 1822 hours, he served a true copy of the within Complaint in Mortgage Foreclosure, upon the within named defendant, to wit: Occupant of 10 E. Locust Street, Mount Holly Springs, Pennsylvania 17065, by making known unto Ed Dorsey, current resident at 10 E. Locust Street, Mount Holly Springs, Pennsylvania, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to him personally the said true and correct copy of the same. GA TSH UTY 06/13/2012 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: Elaine A. Demarco, but was unable to locate her in his bailiwick. He therefore returns the within Complaint in Mortgage Foreclosure as not found as to the defendant Elaine A. Demarco. Request for service at 10 E. Locust Street, Mount Holly Springs, Pennsylvania 17065 the Defendant was not found. SHERIFF COST: $35.00 June 14, 2012 SO ANSWERS, M "R-ONISW R ANDERSON, SHERIFF (c) CountySuite Sheriff. Teleosott, In . KML Law Group, P.C. SUITE 5000 - BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215) 627-1322 ATTORNEY FOR PLAINTIFF t AiONOTAR) IN %OURT OF COMMON PLEAS 2912 JUL ?? Cumberland COUNTY CUMBER AND Co'UNTAVIL ACTION - LAW I FNN YL.VANiA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. ELAINE A. DEMARCO 10 East Locust Street Mount Holly Springs, PA 17065 Defendant(s) ACTION OF MORTGAGE FORECLOSURE Term No. 12-3597 PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. By: _ K*t L GROUP, P. Mi ael cKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 omas Puleo Pa. ID 27615 Jay E. Kivitz Pa. ID 26769 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff ? iS?a3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson ;~~~~,_~~: F~(~; Sheriff ''` ' ' Jody S Smith ~` Chief Deputy Cy .'~ •'~ ~~~ ~~~ ~ ~ A~ ~~ ~ t+tr'~, i~."r+ ~~ ~. Richard W Stewart ~ ~~ ~ ' ~~ Solicitor 4F~~C£QF1~ESy~R(rF ~'~~~~~~.~~ 4:~~~~~`. PEt~t~SYLVANIA JP Morgan Chase Bank, NA vs. Elaine A. Demarco Case Number 2012-3597 SHERIFF'S RETURN OF SERVICE 07/10/2012 Ronny R. Anderson, Sheriff who being duly sworn according to law states that he made a diligent sear h and inquiry for the within named defendant, to wit: Elaine A. Demarco, but was unable to locate her in is bailiwick. He therefore deputized the Sheriff of Bucks County, Pennsylvania to serve the within Compl int In Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program accordin to law. 07/31/2012 10:02 AM -Bucks County Return: And now, July 31, 2012 at 1002 hours I, Edward J. Donnelly, Sheri of Bucks County, Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for Elaine A. Demarco the defendant named in the within Complaint in Mortgage Foreclosure and that I a unable to find her in the County of Bucks and therefore return same NOT FOUND. Request for servic at 534 Beacons Court, Apartment B, Bensalem, Pennsylvania 19020 Elaine A. Demarco was not found, current resident does not know the Defendant and The Postmaster has no record in the past five years for the Defendant at this address. SHERIFF COST: $37.00 SO ANSWERS, August 09, 2012 RON R ANDERSON, SHERIFF (c, CounrySuite Sheriff, Telecsoft, Inc. Bucks County Case # 201231646 Invoice to be mailed to County Sheriffs Office Attn: JILL P JENKINS. ESQ Special (nstructions OFFICIAL RECEIPT RECEIPT # 2012 1 13019 TRANSACTION # SM 2012 31154 FOR F KML L~ I~tOilP 07f17f2012 13x43 P-O7f18f201~ PC #0715725 58.00 TOTAL PAIC- 58.00 TOTAL COST 5$•OO CHAN6~E O.OO TH1~C YOU Notes iCTL - S ~' G'1 a ~ ~Un -~-~- zc~t I £~L: v7~z BUCKS COUNTY '' ~ ~ SHERIFF'S RETURIVI 1 of I Filed 7 /8 /2012 in CUMBERLAND COU TY Bucks Case # 20 1 23 1 646 Recd 7/17/201 Special Instructions . Action Civil Action COMPLAINT Plaintiff JP MORGAN CHASE BANK N.A. -VS- Defendant ELAINE A DEMARCO 534 BEACONS CT APT B BENSALEM PA 19020 o '7 a Address Served if Different Served under Pa. R.C.P. #402 (A) (i) Defendant personally served (A) (2) (i) Family Member (A) (2) (i) Adult in Chazge of Residence (A) (2) (ii) Manager/Clerk at Deft's Lodging (A) (2) (iii) Person in Charge of Business By Handling to By Posting Not Served 30 Days Ran Out Defendant Not Defendant Moved Address Vacant _~ Defendant Unknown Deputy needs b Checked Post Office No Forwarding 2E Fera~d+a8-Address ome tter address S e nn ~w .bBero ,U / By Deputy Witness -' At ~~~ o'clock (®/ ~ on '7 3/ / The above document was serv n the defendan information listed ve in ou f Bucks, Commonw Pennsylvania. So answers: as per alth of Sh riff of Buck my Affirmed ubscribed befor me nth's day ~ / R.•' / ~~ Prothontary Affirmed and subscribed before me on this day / / Notary Public My Com. Exp. 07/17/2012 ~~` 11~Y1 gl~l~a- r• KML Law Group, P.C. ;,~ t ~, ` . , , Suite 5000 - BNY Independence Center 701 Market Street ? "~'t" '~' ~i ~;~' lU~ ~~'~4 Philadelphia, PA 19106-1532 215-627-1322 .'" ` ~~ Fad:,,' Ci~U~ ~ `'' t ~~ ,~ v~~ i'i._131s + JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. Plaintiff vs. ELAINE A DEMARCO Mortgagor(s) and Record Owner(s) 10 East Locust Street Mount Holly Springs, PA 17065 Defendant(s) SUGGESTION OF DEATH TO THE PROTHONOTARY: Term No. 12-3597 It is respectfully suggested that Defendant Elaine A. Demarco is deceased, having departed this life on May 16th 2012. By: ~ //'~ '"~ KML LAW GROUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Ji P. Jenkins Pa. ID 306588 lyk Oflazian Pa ID 312912 Attorneys for Plaintiff ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF Cumberland COtTNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. ~, ATTORNEY FOR PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND" COUNTY CIVIL ACTION -LAW Plaintiff vs. ELAINE A DEMARCO Mortgagor(s) and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE Term No. 12-359? 10 East Locust Street Mount Holly Springs, PA 17065 Defendant(s) CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of Plaintiff s Suggestion of Death was sent by first class mail, postage pre-paid, upon the following defendants on the date listed below: ROBERT Truck 110 Lebbie Ln Fairless Hills, PA 19030 Unknown Heirs of Elaine Demarco, Deceased 10 East Locust Street Mount Holly Springs, PA 17065 KML LAW GROUP, P.C. Date: // B Y KMI, LAW GROUP, P.C. Nick Barone Telephone: (215) 627-1322 KNII, Law Group, P.C. SUITE 5000 - BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 (215)825-6365 ATTORNEY FOR PLAINTIFF ,~ . ,. ~.:a.f.~-,,. Q'3{4~ - ~~ ! ~~s fs +/ JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. ELAINE A DEMARCO (Mortgagor and Record Owner) 10 East Locust Street Mount Holly Springs, PA 17065 Defendant(s) No. 12-3597 PRAECIPE TO REINSTATE COMPLAINT AND ADD DEFENDANTS TO THE PROTHONOTARY: Kindly reinstate the Complaint in Mortgage Foreclosure and add to the docket The Unknown Heirs of Elaine A. Demarco, Deceased and Robert Truck, Solely in His Capacity as Heir of Elaine Demarco, Deceased, as Defendants, pursuant to Pa.R.C.P. 401(b)(2). Respectfully submitted, ,.-. By: KML LAW G OUP, P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 ICristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay E. Kivitz Pa. ID 26769 J' 1 P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. LD 312912 Attorneys for Plaintiff 5 Q,~ s11.~~uuloa C~~* ~a jZik ag345d ~~ ~,tJt3t~ ~ , IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY CIVIL. ACTION -LAW ACTION OF MORTGAGE FORECLOSURE FILED-OFFIC": April 25, 2013 OF THE PRO THONOTAR ( 2013 APR 29 PM 4: 00 To whom this may con� 0116 WIM ,tft.ER " P E N INIt Y LVkNIA This is a request that you stop foreclosure on the property at: 10 E Locust St Mt Holly Springs PA 17065. Why has there been a refusal to help us stay in our home of 57 years. We have been a victim of PREDATORY LENDING. ROBERT J TRUCK was the one that set this deal up. He falsified papers that led us to believe that we could buy our home back within 1 year. That was in June 2006. Elaine DeMarco was used to have our house deeded over to her. We faithfully made all the payments. When we realized that we had been defrauded by ROBERT J TRUCK of SAMANTHA ASSOCIATES, we tried to get the LOAN put in our name. CHASE BANK does not care !!! Elaine De Marco tried very hard to help us. She finally told me she was going to disappear. She, herself had a law suit against ROBERT J TRUCK because of the predatory lending schemes. When she (other people also had been part of this law suit) realized she would be indicted, they dropped the case. I DO NOT BELIEVE ELAINE DE MARCO is DEAD. You cannot trust ROBERT J TRUCK. The man is a CON man. Elaine hated him and she told me the only thing she could do was disappear. We have written letters and so has our ATTORNEY— BARIC SCHERER. All the information has been sent to CHASE BANK. THE PA ATTORNEY GENERALS OFFICE also has all the information in our case. Our case is pending right now at the Federal Courthouse in Philadelphia PA. We are waiting for the date that should be coming up shortly. ROBERT J TRUCK tacked on about 100,000 on to the loan, he and others pocketed that money. We will pay the money we borrowed. We just want something in writing that we will be paying for this (our) property that would eventually become ours, again. AFTER 57 YEARS LIVING AT THIS PROPERTY we would like to live out our last years here. PLEASE don't make us move. I'm begging you to understand that we are victims because of RACKETEERING. Why can't we buy back our own property? Perhaps we need to go PUBLIC such as CNN. PHONE: 717 4867117 Edgar E Dorsey, Sr Betty K Dorsey rings PA I 10 E Locust St Mt Holly 7665- 11167 1FC THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT.ANY INFORMATION OBTAINED FROM YOU WELL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: April 17,2013 TO: Robert Truck,Solely in His Capacity as Heir of Elaine Demarco,Deceased 10 East Locust Street Mount Holly,PA 17065 In the Court of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION;SUCCESSOR IN INTEREST Common Pleas BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK of Cumberland County F1KlA WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus,OH432l9Ptaintiff Vs. Action of The Unknown Heirs of Elaine Demarco,Deceased Mortgage Foreclosure Robert Truck-,Solely in His Capacity as Heir of Elaine Demarco,Deceased (Mortgagor(s)and Record Owner(s)) Na.12-3597 10 East Locust Street Mount Holly Springs,PA 17065 Defendant(s) TO: Robert Truck,Solely in His Capacity as Heir of Elaine Demarco,Deceased 10 East Locust Street Mount Holly,PA 17065 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO EN'T'ER 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 17-US NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE,YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER,THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 170I3 717-243-9400 By: Z"r NAIL LAW GROUP,P. . Michael McKeever Pa.ID 56129 Lisa Lee Pa.ID 78020 -. Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 _ bomas Puteo Pa.-H)27615 Jill P.Jenkins Pa.ID 306588 Alyk L.Otlazian Pa.ID 312912 215-617-1322 Attorneys for Plaintiff KML LAW GROUP, P.C. Suite 5000 - BNY Mellon Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/KJA WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. The Unknown Heirs of Elaine Demarco, Deceased Robert Truck, Solely in His Capacity as Heir of Elaine Demarco, Deceased (Mortgagor(s) and Record owner(s)) 10 East Locust Street Mount Holly Springs, PA 17065 Defendant(s) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY No. 12-3597 PRAECIPE TO DISCONTINUE AND END TO THE PROTHONOTARY: Kindly mark the above case Discontinued and Ended without prejudice upon payment of your costs only. KML LAW GROUP, P.C. F/K/A GOLDBECK McCAFFERTY & McKEEVER By: Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P. Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello, Pa. ID 313897 Jennifer Lynn Frechie, Pa. ID 316160 Attorneys for Plaintiff