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Home My WebLink About12-35831 ?cl a (ti PHELAN HALLINAN & SCHMIEG, LLP Mario J. Hanyon, Esq., Id. No.203993 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 263542 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE, LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION 1 111 POLARIS PARKWAY COLUMBUS, OH 43240 Plaintiff V. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 Defendant ATTORNEY FOR PLAINTIFF COURT OF COMMON PLEAS CIVIL DIVISION TERM ofV11 NO. p? - CUMBERLAND COUNTY CIVIL ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE File #: 263542 Ck-+? IlquS/I NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File #: 263542 I. Plaintiff is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE, LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION 1111 POLARIS PARKWAY COLUMBUS, OH 43240 2. The name(s) and last known address(es) of the Defendant(s) are: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 who is/are the real owner(s) of the property hereinafter described. 3. On 02/23/2004 VIRGINIA A. EIDENSCHINK made, executed and delivered a mortgage upon the premises hereinafter described to CHASE MANHATTAN MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Book 1856, Page 362.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File #: 263542 6 The following amounts are due on the mortgage as of 02/29/2012: Principal Balance $101,132.76 Interest $10,745.40 07/01/20 10 through 02/29/2012 Late Charges $219.00 Property Inspections $42.00 Property Preservation $70.00 Escrow Deficit $3,238.16 TOTAL $115,447.32 7 9 10. 11 Plaintiff is not seeking a judgment of personal liability (or an in personam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon. Mortgagor VIRGINIA A. EIDENSCHINK died on 06/08/2010 and, upon information and belief, her surviving heir(s) are TAYLOR SHELLENBERGER, NICHOLAS EIDENSCHINK, and JOSHUA EIDENSCHINK. Plaintiffs representative contacted the Register of Wills of CUMBERLAND COUNTY and was informed that no estate has been raised on behalf of the decedent mortgagor. By executed waiver(s), TAYLOR SHELLENBERGER, NICHOLAS EIDENSCHINK, and JOSHUA EIDENSCHINK waived their right to be named as a defendant in the foreclosure action. Said waiver(s) is/are attached as Exhibit" A ". File #: 263542 12. Plaintiff hereby releases VIRGINIA A. EIDENSCHINK, from liability for the debt secured by the mortgage. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s) in the sum of $115,447.32, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: 4( Mario J. Hanyon, Esquire Attorney for Plaintiff` File #: 263542 LEGAL DESCRIPTION ALL THAT CERTAIN unit designated as Number 8, being a Unit in Long Meadows Townhouses, a condominium, located in the Borough of Wormleysburg, Cumberland County, Pennsylvania, under the Declaration of Condominium as recorded in the Office of the Recorder of Deeds, in and for the County of Cumberland, in Misc. Book 229, page 142, and designated in the Declaration Plans as recorded in the said office in Plan Book 30, Page 85. TOGETHER with all right, title and interest, being a 5.555% interest, of, in and to the common elements as more fully set forth in the aforesaid Declaration of condominium and Declaration Plans. KNOWN AS 8 Campbell Place. PROPERTY ADDRESS: 8 CAMPBELL PLACE, CAMP HILL, PA 17011-2530 PARCEL # 47-19-1590-064-U8 File #: 263542 EXHIBIT "A" S'.ore #0693 w '!7477310565 WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION P.5 63 S'" I, Taylor Shellenberger, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, S/B/VI TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises 8 Campbell Place, Wormleysburg, PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Dater /f By 47/c' (print name) (sign name) Parent and/or Legal Guardian Of Taylor Shellenberger, Minor Heir of Virginia A. Eidenschink, Deceased Vey '13 - .3?.^ -;?e Sore #0698 '17177310565 p,6 WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, Joshua Eidenschink, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises 8 Campbell Place, Wormleysburg, PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriffs sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: oshua Eidenschink, Heir of Virginia A. Eidenschink, Deceased Vey , 6 ^2: 7-1e ?'S Store #0698 '17177310565 p,4 2 (0 -3 5 L1 ?'_ WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, Nicholas Eidenschink, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, SrB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises 9 Campbell Place, Wormleysburg, PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff s sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: --4-"1o2 - // Nicholas,Eidenschink, Heir of Virginia A. Eidenschink, Deceased r, VERIFICATION l A?2 hereby states that he/she is I 7Y ?y lq "'tof JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: /Ishq- File#:263542 Name: EIDENSCHINK NO&4 D. AL-n N e\' Title: V ?C? C-) 16 t)? JPMORGAN CHASE BANK, NATIONAL ASSOCIATION File k 263542 171 ?.. v + t 1 i° hL E E"OTI-'CNflTARY Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JP MORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE, LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION VS. ''n '" kU' -6 AM 9.41 CIT18ERLAND COUNTY PENNSYLVANIA Attorney for Plaintiff COURT OF COMMON PLI CIVIL DIVISION NO. 12-3583-CIVIL : CUMBERLAND COUNTY UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED MOTION FOR SERVICE PURSUANT TO SPECIAL ORDER OF COURT Plaintiff, JP MORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M CHASE HOME FINANCE, LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, respectfully requests that this Honorable Court enter an ORDER Plaintiff's Motion for Service Pursuant to Special Order of Court in the above captioned and in support thereof avers the following: 1. On February 23, 2004, VIRGINIA A. EIDENSCHINK made, executed, delivered a mortgage upon the premises at 8 CAMPBELL PLACE, CAMP HILL, PA 17011. 263 2. The loan is in default as payments due August 1, 2010 and each month are due and unpaid. 3. Real Owner VIRGINIA A. EIDENSCHINK died on June 8, 2010. 4. Plaintiffs representative contacted the Register of Wills of CUMB County and was informed that no estate has been raised on behalf of the decedent mortgagor. 5. By letter dated February 21, 2011, Plaintiff attempted to contact any pos heirs of VIRGINIA A. EIDENSCHINK to inform them of the foreclosure and to request information. Attached hereto, marked as Exhibit "A", are true and correct copies of said letters. 6. Plaintiff performed a Good Faith Investigation in an attempt to identify and the heirs of VIRGINIA A. EIDENSCHINK. Plaintiff discovered an obituary for VIRGINIA EIDENSCHINK that was published on June 10, 2010 in The Patriot-News of Harrisbi According to the obituary, VIRGINIA A. EIDENSCHINK is survived by TAYL SHELLENBERGER, NICHOLAS EIDENSCHINK and JOSHUA EIDENSCHINK. Attac hereto, marked as Exhibit "B", is a true and correct copy of Plaintiffs Affidavit of Good F Investigation. 7. Upon information and belief, the surviving heirs at law and next-of-kin pf VIRGINIA A. EIDENSCHINK are TAYLOR SHELLENBERGER, NICHO EIDENSCHINK and JOSHUA EIDENSCHINK. 263142 8. By letter dated April 11, 2011, Plaintiff contacted TAYLO SHELLENBERGER, NICHOLAS EIDENSCHINK and JOSHUA EIDENSCHINK to inform them of the foreclosure action. Plaintiff attached with its letter, Waivers by Heir of Right to b Named as a Defendant in the Foreclosure Action. Plaintiff also requested information regarding, the heirs of VIRGINIA A. EIDENSCHINK. Attached hereto, marked as Exhibit "C", is a tru and correct copy of Plaintiffs letter. 9. By executed waivers, TAYLOR SHELLENBERGER, NICHOLA EIDENSCHINK and JOSHUA EIDENSCHINK waived their rights to be named as defendan s in the foreclosure action. Said waivers are attached as Exhibit "D". 10. On June 8, 2012, Plaintiff filed an Action in Mortgage Foreclosure. Attach hereto, marked as Exhibit "E", is a true and correct copy of the Complaint in Mortgage Foreclosure. 11. Plaintiff named as a defendant, the unknown heirs, successors, assigns, and all persons, firms or associations claiming right, title or interest from or under the decedent record owner in order to ensure that all possible parties with an interest in said property are notified f these proceedings and in order to ensure that good and marketable title to said property is conveyed by any future sheriffs auction. See Exhibit "E". 12. Because there may be parties with an interest in the mortgaged premises that are unknown, Plaintiff must effectuate service through Special Order of Court. 13. In compliance with Cumberland County Local Rule 208.3(a)(2), Plaintiff av rs that no Judge has previously entered a ruling in this case. 14. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a of its proposed Motion to the Defendants on June 22, 2012, and requested the concurrence. A true and correct copy of Plaintiffs letter pursuant to Local Rule 208.3(9) postmarked certificate of mailing is attached hereto, made part hereof, and marked as Exhi «F„ 15. In response to its June 22, 2012 letter, Plaintiff received a phone call from Cassandra Eckrich, who had previously identified herself as the mother, though not an heir, of the deceased mortgagor. She informed Plaintiff that the mortgaged premises are occupied by a tenant. She also asked for the status of the pending Foreclosure Action. Plaintiff did not receive any other response to its letter. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an pursuant to Pennsylvania Rule of Civil Procedure 430 directing service of the Complaint, and future pleadings, by regular mail, by posting of the mortgaged premises, and by publication. Respectfully submitted, PHELAN =- 4::?-?Ulison Date: 'i3 F. Wells, Esq., Id. No.309519 Attorney for Plaintiff 263 I Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JP MORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE, LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION VS. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Attorney for Plaintiff COURT OF COMMON PLEA CIVIL DIVISION NO. 12-3583-CIVIL CUMBERLAND COUNTY MEMORANDUM OF LAW According to Pa.R.Civ.P. 430(a), a plaintiff may petition the court to provide an to personal service if the plaintiff cannot serve a party personally. The rule requires the affida presented in support of the motion for alternative service to state "the nature and extent of t investigation which has been made to determine the whereabouts of the defendant and the reasc why personal service cannot be made." Pa.R.Civ.P. 430 (a). The purpose of this procedure is provide proof that a good faith effort has been made to effect service under normal methods. 01 after such proof has been offered is the Court authorized to direct another method of substit service. Deer Park Lumber, Inc. v. Major, 384 Pa.Super. 625,559 A.2d 941, 944 (1988), app denied, 525 Pa. 582, 575 A.2d 113 (1990). Plaintiff has attached a report to its Motion, which sets forth the nature and extent of investigation that has been made to determine the whereabouts of the heirs and assigns and reason that such service cannot be made. Attached hereto, marked as Exhibit "B", is a copy of t 263 Affidavit of Good Faith Investigation. A deceased mortgagor need not be named as a party in a foreclosure action. F Land Bank of Baltimore v. King, 294 Pa.86, 143 A. 500 (1928). The personal representatii heir or devisee of a deceased mortgagor, if known, (unless released from liability) must named as a defendant in a mortgage foreclosure action. Moyer v. Diehl, 130 Pa. Super. 115, 1 A. 575 (1938). In the instant action, Plaintiff has appropriately named the unknown hei successors, assigns and all persons, firms, and associations claiming right title or interest from under the decedent mortgagor as a defendant in order to convey clear and marketable title al a foreclosure sheriff's sale. Title companies customarily require foreclosing mortgagees name the unknown parties in order to assure that any potential party with an interest in mortgaged premises has an opportunity to defend the foreclosure. Finally, Plaintiff is seeking only to enforce an in rem judgment through the foreclosure the mortgaged premises and is not pursuing a deficiency judgment in this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to grant requested relief. :PHELAN HALL=SCC Date: V Allison F. W lls, Esq., Id. No.309519 Attorney for Plaintiff 263 Exhibit "A" PHELAN HALLINAN & SCHMIEG, LLP Suite 1400 One Penn Center at Suburban Station 1617 John F. Kennedy Boulevard Philadelphia, PA 19103-1814 215-3204)007, ext. 1200 Fax: 215-567-0072 Sean.McLaughlWedphexom Sean McLaughlin Legal Assistant, Decedent Department February 21, 2011 Occupants & Possible Heirs Of Virginia A. Eidenschink, Deceased 8 Campbell Place Unit 8 Wormleysburg, PA 17043 Representing Lenders in Pennsylvania and New Jersey RE, VIRGINIA A. EIDENSCHINK; 8 CAMPBELL PLACE, UNIT 8, WORMLE'YSBURG, PA 17043 CHASE HOME FINANCE LLC; PH3# 263542 Dear Sir/Madam, Kindly be advised that the Law Offices of Phelan Hallinaa & Schmieg represent CHASE HOME FINANCE LLC, the holder of the mortgage against the abovo-refercnced mortgaged promises. The loan is in default as payments due August 1, 2010 and each month thereafter remain due and unpaid. Our office has been retained to bring a foreclosure action. Our office has been informed that Virginia A. Bidenschink, an owner of the mortgaged premises, has unfortunately passed away. We are attempting to identify and contact Virginia's next-of--kin because they may have been automatically vested with an ownership interest in the mortgaged promises upon Virginia's death under 20 Pa.C.S.A, §301(b). It will be necessary to bring a foreclosure action against the property. If you are an heir of Virginia A. Eidenschink or have any information regarding the heirs of Virginia A. Eidenschink, please contact the undersized at (215) 563-7000, ex. 1200 within seven (7) days of the date of this correspondence. Sean McLaughlin Legal Assistant + This firm is a debt collector. Any infonnodua we TOODWe will be used for that purpose. If your personal liability for the debt has been discharged in bankruptcy, we are only proceeding against the red estate secured by the mortgage. Exhibit "B" AFFIDAVIT OF GOOD FAITH INVESTIGATION File Number: 263542 ' Attorney Firm: Phelan; Hallinan & Schraleg, LLP Subjech. Virginia A. Bidenschink • Current Address: (Cassandra R, EcKrich) 6310 Antilles Court, Mechanicsburg, PA 17050 Property Address; 8 Campbell Place, Wornnleysburg, PA 17043 Mailing Address: (Cassandra R. EcKrILh) 6330 Antilles Court, Mechanicsburg, PA 17050 1. CREDIT INFORMATION A. SOCIAL SECURITY NUMBER Our search verified the following information to be. true and correct Virginia A. Eidenschink - xxx-xx•4124 B. EMPLOYMENT SEARCH Virginia A. Eidenschink - A review of the credit reporting agencies provided no employment information. C. INQUIRY OF CREDITORS Our inquiry of creditors indicated that Virginia A. Eidenschink reside(s) at: 8 Campbell Place, Camp Hiu, PA 17011. 11. INQUIRY OF TEUPHQNE COMPANY A. DIRECTORY ASSISTANCE SEARCH Our office searched directory assistance databases, which had no listing for Virginia A. Eidenschink. B. On 03-28-11 our office searched directory assistance databases, which had no phone number for Virginia A. Pidenschunk, 111. OBITUARY SEARCH A.. Atteropted to find obituary via kitty//oa.newshank.com/ B, Found obituary published June 10, 2010 in the Patriot-News, The (Harrisburg, PA), Sec attached, IV. INQUIRY OF HEIRS AND NEIGHBORS On 03-28-I1 our office was unable to locate any information for Sandy EcKrich, relative of Virginia A. Fidenscliink. On 03-28-11 our office was unable to locate any Information for Taylor Shellenberger, relative of Virginia A. Eidenschlrnk. On 03-28-11 our office was unable to locate any Wonrtation, for Booter Eidensc$fnk, relative of Virginia A., Eidenschink. On 09-2811 our office was unable to locate any information for Brooklynn Stasko, relative of Virginia A. Eidensthidk. bn 03-28-11 our office was unable to locate any information for Bill Wright, relative of Virginia A. Eidenschir& On 03-28-11 our office was unable to locate any information for Joseph Miholic; relative of Virginia A. Eidenschink. On 03-28-11 our office was unable to locate any information for Kenneth Dietzel, relative of Virginia A. Bidenschink. On 03-28-11 odr office was unable to locate any information for William Roberti,-relative of Virginia A, Eidenschuik, On 03-28-11.our office was tunable to locate any informalicm for Paula, relative of Virginia A. Eidenschink. •On 03-28-11 our office attempted to contact Noma9 Paul Eidenschink,'potentlal relative of Virginia A. Eidenschink at! P.O. Box 3171, Bemidji, MN 56619, but was unable tq get any phone number for him, On 03-28-11 our oHlee attempieii to Mitact DL0ne Marii Hendrix, potential relative of Virginia A. Eidenschink at: 106, Dorri Drive, Elizabeth City, NC 27909, but was unable to get any phone number for her. On 0.3-28-11 our office attempted to coritact Tamara D, Winchell, potential relative of Virginia A. Eidenschink al: R0. Box 3171, Bemidji, MN 5661.9, but was unable to get tiny phone number for her. On 03-28-11 OUT office attempted to contact Ruth B, EeKrfch Sr,; potential relative of Virginia A. Eidenschink at: 503 North West Street, Carlisle, PA 17013, but was unable to get any phone number for her. On 03-28-11 our office attempted to ccmtact Stephen R. EcKrich, potential relative of Virginia A. Eidensc.hink at 903 North West Street, Apartment 2FL, Carlisle, PA 17013, but was unable to get any phone number for him. On 0328-11 our office made a phone call in an attempt to contact Joshua Eidenschink, relative of Virginia A. Eidenschink at (717) 763-0401, 8 Campbell Place, Camp Hill, PA 17011: not in aeivim. On 03-28-11 k 03-29-11 our office made several phone calls in an attempt to contact Nicholas Eidenschink, relativa of Virginia A. Eidenschink at (717) 695-7145, 8 Campbell Place, Camp Hill, PA 17011: answering machine. On 03.28-11 our office made it phone call in an attempt to contact Cassandra R. EcKrich, relative of Vifginio A. Eidenschink at (717) 705-%86,6330 Antilles Court, Mechanicsburg, PA 17050: Our office spoke with Cassandra R. EcMch who said she is a mother of Virginia A. Eidenschink & she reside(s) at 63,90 Antilles Court, Mechanicsburg; PA 17050. On 03-28-11 our office made a photo call in an attempt to contact Karen R. EcKrich, potential relative of Virginia A. Eidenschh* at (717) 243-6148,503 North West Street, ,Carlisle, PA 17013: diarniuiecte..d. Using our white,pag" database our office was unable to locate Rely neighbors fnr 8 Campbell Place, Worinley6burg, PA 17043. V. ADDRESS INQUIRY A. NATIONAL ADDRESS UPDATE On 03-28-11 we reviewed the National Address database and found the following information: Virginia A. Bidenschink - 8 Campbell Plate, CAMP Hill, PA 17011. B. ADDITIONAL ACTIVE MAILING ADDRESSES Per our inquiry of creditors, the following is a possible mailing address: no addresses on file.. Vl, OTHER INQUIRIES A. DEATH RECORDS As of 03-2811 Vital Records and all public databases have a death record on file for Virginia A. F..idenschink. VII. ADDITIONAL INFORMATION OF SUBJECT A. DATE 01: BIRTH Virginia A. Eidenschink - 05-25-1966 B. DATE OF DEATH Virginia A. Bidenschink - 06-18-2010 C. A.K.A. " Virginia A. Roberts • Ouf accessible databases have been checked and cross-referenced for the above named individual(s). Please be advised our database information indicates the iubject resides at-the current address 1 hwvby verify that the statempts made herein are true and correct to the best of my knowledge, information and belief al utt"k(Rdavit of investigation is made subject to the penalties of 18 Pa CS, Sec. 4904 relating to unworn f k fi 4tidn to autbotities ,.,, The above information is obtained from availably public records i? -and we are only, liable for the coat of the. affidavit. 'L{-( 11 ObitsArchive.com: Document Display ObitsArchivexom page lof l Patriot-News, The (Harrisburg, PA) - June 10, 2010 Deceased Name: Virginia A. Eidenschink Virginia A. Eidenschink, 44, of Camp Hill; passed :away, Tuesday, June 8, 2010 after a long battle with cancer at Holy Spirit Hospital, Camp Hill. Born May, 25, 1966 in Carlisle, she was a daughter of Cassandra "Sandy" Eckrich of Mechanicsburg. She was employed as'an assistant supervis6f for United Concordia Dental Insurance, Harrisburg. Virginia was a member and employee of VFW Post 6704, Mechanicsburg. She enjoyed spending all her free time with family, especially children and grandchildren. Surviving in addition to her mother are two sons, Joshua Eidenschink of Camp Hill and Nicholas Eidenschink of Camp Hill; one daughter, Taylor Shellenberger of Camp Hill; one grandson, Joshua (Booter) Eidenscliink, Jr.; one granddaughter, Brooklynn Stasko of Mechanicsburg; companion, Bill Wright of Camp Hill; dad, Joseph Miholic of Enola; step-dad, Kenneth Hetzel of Mechanicsburg; and one brother, William Roberts and wife, Paula of Nitro, WV. Also one niece and one nephew. Funeral services will be held at 8:00 pm, Monday, June 14, 2010 at Hoffman-Roth Funeral Home & Crematdry, Inc., 219 North Handver Street, Carlisle, with Rev. Jennifer J. McKenna officiating. A viewing will be held from 5:00 pm until the time of the service on Monday at the funeral home. Memorial contributions may be made to Breast Cancer Awareness, National Breast Cancer Foundation, 2600 Network Blvd., Suite 300, Frisco, TX 75034. To sign the guest book visit www.hoffmanroth.eom: www.pennliye.com/obits Patriot-News, The (Harrisburg, PA) Date: June 10, 2010• Edition: FINAL • Page: AQ9 Record Number: 10061 64593403. . Copyright, 2010, The Patriot News Co. All Rights Reserved. Used with permission. httod/on.newsbanic:com/oa-searoh/we/Archives?p_action=print&p_doci d=1305B80C75A2... 2/28/2011 Exhibit "C" PHELAN HALLINAN & SCHMIEG, LLP 1617 JFK Blvd, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-320-0007 ext.1200 Fax: 215-563-8656 Eddia.Baker®fedpha.com Edward Baker Legal Assistant, Decedent Department April 11, 2011 JOSHUA EIDENSCHINK, HER OF VIRGINIA A. EIDENSCHINK, DECEASED 8 CAMPBELL PLACE WORMLEYSBURG, PA 17043 NICHOLAS EIDENSCH NK, HEIR OF VIRGINIA A. EIDENSCHINK, DECEASED 6330 ANTILLES COURT MECHANICSBURG, PA 17050 TAYLOR SHELLENBERGER, HEIR OF VIRGINIA A. EIDENSCHINK, DECEASED 6330 ANTILLES COURT MECHANICSBURG, PA 17050 RE: Virginia A. Eidenschink 8 Campbell Place, Wormleysburg, PA 17043 Chase Home PYuance, LLC PHS# 263542 Representing Lenders in Pennsylvania and New Jersey Dear Sir or Madam: Kindly be advised that the Law Offices of Phelan Hallinan & Schmieg, LLP represent CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, the holder of the mortgage against the above-referenced mortgaged premises. The loan is in default as payments due August 1, 2010 and each month thereafter remain due and unpaid. Our office has been retained to bring a foreclosure action. Our office has been informed of Virginia A. Eidenschink's unfortunate death. We are sorry for your loss. As a devisee of the estate of Virginia A. Eidenschink, you may have inherited an ownership interest in the mortgaged premises upon her death under 20 Pa C.S.A. § 301(b). Accordingly, it may be necessary to bring a foreclosure action against your interest in the property. Please be advised that you are not personally liable for the debt, as you did not execute the mortgage or note. This letter serves to afford you an opportunity to waive your right to be named as a defendant in the foreclosure action. Please find attached a Waiver which I would appreciate your executing and returning to the undersigned within fourteen (14) days of the date of this correspondence. If the Waiver is timely returned it will not be necessary to name you as a defendant in the foreclosure action. However, if the Waiver is not timely returned and it is believed that you are an heir of the decedent, then -our office may have no choice but to name you as a defendant in the action in order to divest any ownership interest you may have in the property. It is our understanding that Taylor Shellenberger is a minor. As such, it will be necessary for their parent or legal guardian to execute the Waiver on their behalf, Please provide legal documents stating that you are the legal guardian if sign as a legal guardian to the minor. Please note that this waiver does not preclude you from attempting to sell the subject premises and recovering any possible equity in the mortgaged premises prior to the completion of the foreclosure action. If you would like to request a payoff or reinstatement figure, please call (215) 563-7000, and ask for the Foreclosure Resolution Department. If you have any other questions regarding this letter, please contact the undersigned at (215) 563-7000, ex. 1200. Sincerely, 2 B er Legal Assistant * This fore is a debt oollector. Any information we receive will be rued for that p apm If your personal liability for the debt has been discharged in bankmptey, we are only proceeding against the real estate segued by the nwrtgap. WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION 1, Joshua Eidenschink, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code (20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises 8 Campbell Place, Wormleysburg, PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriffs sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: - Joshua Eidenschink, Heir of Virginia A. Eidenschink, Deceased WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, Nicholas Eidenschink, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises 8 Campbell Place, Wormleysburg, PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: Nicholas Eidenschink, Heir of Virginia A. Eidenschink, Deceased WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, Taylor Shellenberger, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises 8 Campbell Place, Wormleysburg, PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriffs sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: BY (print name) (sign tame) Parent and/or Legal Guardian Of Taylor Shellenberger, Minor Heir of Virginia A. Eidenschink, Deceased Exhibit "D" May 16 1109:636 The UPS Store #0698 17177310565 p,4 WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, Nicholas Eidenschink, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 30l(b) of the Pennsylvania Probate, Estates and Fiduciaries Code (20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, &13/M TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises 8 Campbell Place, Wonnleysburg, PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff s sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: -?- 1,2- Nicholas EiderschiIlk, Heir or Virginia A. Eidenschink, Deceased May 16 11 09:54a The UPS Store #0698 17177310565 p.6 WAIVER BY HEIR OF RIGHT TO BE NAMW AS A DEFENDANT' IN FORECLOSURE ACTION 1, ]oshua Eidenschink, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 301(b) of the PeYUnsylvania Probate, Mates and Fiduciaries Code [20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which way I)c instituted by CHASE HOME FINANCE LLC, SI M TO CHASE MANRA7rAN ace, Wormle sbur CPA R 17043 CORPORATION, inva mortgage olving owned by d scoured ecedent at the time of her death. 1lVormleysburg, I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff s sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date. t, T ..__ __~ ~ mm AEiodenschink, Heir of Virginia A. Eidenschink, Deceased May 1611 09:539 The UPS Store #0698 17177310565 0.5 WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION 1, Taylor Sbellenberger, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 301(b) of the Pernnsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. § 301('b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, S/BM TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on promises 8 Campbell Place: Wormleysburg, PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any ftutbcr notice of proceedings of SherifFs sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: ? " ?? ?l (priname) (sign name) Parent and/or Legal Guardian Of Taylor Shellenberger, Minor Heir of Virginia A. Eidenschink, Deceased Exhibit "B" Supreme Court of Pennsylvania Court of Common Pleas For Prothonotary Use Oniv. Civil Cover Sheet -_.- CUMBERLAND County Docket No: S C: T I 0 A The inforntation collected on this form is used s•olelvfbr court administration purposes, This form does not ?- the ltrr and service of xt1 aletrrrnt or + lace dettttin?s or other paper as required lst law of rules ??I c our t. M _ Commencement of Action: I@ Complaint ? Writ of Summons ? Petition 0 Transfer from Another Jurisdiction ? Declaration of Taking Lead Plamtiff's Ntuno: JPMORGAN CHASE BANK, Lead Defendant's Name: UNKNOWN HEIRS, SUCCESSOR NATIONAL ASSOCIATION SIB/M TO CHASE HOME ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIO 'S FINANCE, LLC S/B/M TO CHASE MANHATTAN CLAIMING RIGI IT, OR. IN'T'EREST FROM OR UN l3R MORTGAGE CORPORATION VIRGINIA A, EIDENSCHINK, DECEASED Dollar Amount Requested; r-1 within arbitration hiruts Are money damages requested? ? Yes f$1 No Check one (9 outside arbitration liln'ts Is this a Class Action Suit? ? Yes ® No Is this an I ID,Ip!I? ? Yes ® No Name of Plaintiff/Appellant's Attorney: Meri n J. Hanyori Esg- Id. No,203993 Phelan Hallinan & Schmieg LLP ? Check here If you have no attorney are a Self-Re treaun cd .Pro Se lalti ?ltni) f S E C 1 U N B Nature of the Case: Place an "X" to the left of the OWN ??, case category tha• PRIMARY CASE. If you are making more than one t; cxt consider most fin ortartt. TORT (do no( include Mass Tort) CONTRACT (do not include judgments) ? Intentional ? Buyer Plaintiff C7 Malicious Prosecution ? Debt Collection: Credit Card ? Motor Vehicle ? Debt Collection: Other ? Nuisance ? Premises Liability ? Product Liability (does not include muss tort) ? Employment Dispute: ? Slander/Libel/ Defamation Discrimination ? Other: El Employment Dispute: Other PR FFESSLO.NAL LIABILITY CJ Dental ? Legal C] Medical ? Other Professional: ? Asbestos ? 't'obacco [.-.I Toxic'1'ort - DES [3 Toxic Tort - Implant ? Toxic Waste n Other: Pa.R.L:.R 205.-) ? Other: REAL PROPERTY ? Ejectment ? Eminent Domain/Condemnation U Ground Rent ? Landlord/Tenant Dispute ® Mortgage Foreclosure: Residential ? Mortgage Foreclosure: Commercial ? Partition ? Quiet Title ? Other: most accurately describes your ;pe of claim, check the one that CIVIL APPEALS Administrative Agencies 0 Board of Assessment ? Board of Elections ? Dept. of Transportation ? Statutory Appeal: Other ? Zoning Board ? Other: MISCELLANEOUS ? Common Law/Statutory Arbitra O Declaratory Judgment. ? Mandamus ? Non-Domestic Relations Restraining Order ? Quo Warranto ? Replevin ? Other: Updated Ob lion 11 xm y ? ?C •'? cn PHELAN HALLINAN & SCHMM, LLP Maio J. Hawn Esq., Id. N6203M 1617 JM HoulMl"L Suite 1400 One Perot Center PL>ca Ptdlad bhit, PA 14103 215-563-7000 263542 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE, LLC S1W TO CHASE MANHATTAN MORTGAGE CORPORATION 1111 POLARIS PARKWAY COLUMBUS, OH 43240 Plaintiff V. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, Tm E OR N ERF.ST FROM OR UNDER VIRGINIA A. EIDENSCHIN & DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 Defendant ATTORNEY FOR PLAIIV'i'lFF COURT OF COMMON PLEAS CIVIL DIVISION TERM /?yy NO. i GL- 3 5 4 ?;,(V! CUMBERLAND COUNTY 0M ACTION - LAW COMPLAINT IN MORTGAGE FORECLOSURE A'iY4RN E RETURN PLEAS We hereby =*go wift to be a true dW wNw Dopy of the WOW filed of remand File N: 263342 NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FOR1'II BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT AIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 (800) 990-9108 File a: 263542 1. Plaintiff is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE, LLC S/B/M TO CHASE MANHATTAN MOR'T'GAGE CORPORATION 1111 POLARIS PARKWAY COLUMBUS, OH 43240 2. The name(s) and last known address(es) of the Defendant(s) are: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCIIINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 who is/are the real owner(s) of the property hereinafter described. 3. On 02/23/2004 VIRGINIA A. EIDENSCHINK made, executed and delivered a mortgage upon the premises hereinafter described to CHASE MANHATTAN MOR'T'GAGE CORPORATION which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Book 1856, Page 362.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2010 and each month thereafter are due and unpaid, and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File 11: 263542 6. The following amounts are due on the mortgage as of 02/29/2012; Principal Balance $101,132.76 Interest $10,745.40 07/01/2010 through 02/29/2012 Late Charges $219.00 Property Inspections $42.00 Property Preservation $70.00 Escrow Deficit $3,238.16 TOTAL $115,447.32 7. 8. 9 10. 11 Plaintiff is not seeking a judgment of personal liability (or an in persona m judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defendant(s) has/have received a discharge of personal liability in a bankruptcy proceeding, this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon. Mortgagor VIRGINIA A. EIDENSCMNK died on 06/08/2010 and, upon information and belief, her surviving heir(s) are TAYLOR SHELLENBERGER, NICHOLAS EIDliNSCHINK, and JOSIIUA EIDENSCHINK. Plaintiffs representative contacted the Register of Wills of CUMBERLAND COUNTY and was informed that no estate has been raised on behalf of the decedent mortgagor. By executed waiver(s), TAYLOR SHELL? ENBERGER, NICHOLAS EIDENSCIIINK, and JOSHUA EIDENSCHINK waived their right to be named as a defendant in the foreclosure action. Said waiver(s) is/are attached as Exhibit" A ". f iln 11: 167542 12. Plaintiff hereby releases VIRGINIA A. EIDENSGHINK, from liability for the debt secured by the mortgage. WHEREFORE, Plaintiff demands an 1g =judgment against the Defendant(s) in the sum of $115,447.32, together with interest, costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN & SCHMIEG, LLP By: Maria J. Hanyon, Esquire Attorney for Plaintiff File H: 263542 LEGAL DESCRIPTION ALL THAT CERTAIN unit designated as Number 8, being a Unit in Long Meadows Townhouses, a condominium, located in the Borough of Wormleysburg, Cumberland County, Pennsylvania, under the Declaration of Condominium as recorded in the Office of the Recorder of Deeds, in and for the County of Cumberland, in Misc. Book 229, page 142, and designated in the Declaration Plans as recorded in the said office in Plan Book 30, Page 85. TOGETHER with all right, title and interest, being a 5.555% interest, of, in and to the common elements as more fully set forth in the aforesaid Declaration of condominium and Declaration Plans. KNOWN AS 8 Campbell Place. PROPERTY ADDRESS: 8 CAMPBELL PLACE, CAMP HILL, PA 17011-2530 PARCEL # 47-19-1590-064-U8 File M: 263542 EXHIBIT "A" May 16 11 09;53a The UPS Store #0698 17177310565 P 5 • WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, Taylor Shellenberger, Heir of Virginia A. Eidenschnk, Deceased in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, SBIVi TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises 8 Campbell Place, Worrnleysburg, PA 17043, which property was owned by decedont at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: ? "?v?' // (sign name) Parent and/or Legal Guardian Of Taylor Shellenberger, Minor Heir of Virginia A. Ridenschink, Deceased May 16 11 09:54a The UPS Store #0698 17177310566 P6 WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDAN'T' IN FORECLOSURE ACTION I, Joshua Eidenschink, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 301(b) of the Pennsylvania Probate, Estates and fiduciaries Code [20 Pa C.S,A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LI.,C, SI MI TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured ou premises 8 Campbell Place, Wormleysburg, PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: oshua F-Menschink, Heir of Virginia A. Eidenschink, Deceased May'l6 11 09:53a The UPS Store #0698 17177310565 p.4 ,y WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, Nicholas Eidenschink, Heir of Virginia A. Eidenschink, Deceased in accordance with Section 301(b) of the Pennsylvania Probate, Estates and Fiduciaries Code [20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, SIB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises 8 Campbell Place, Wormleysburg, PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff s sale, and understand that any interest I may have in the mortgaged premises will be. divested upon completion of the foreclosure action. Date: Virginia A. Eidenschink, Deceased VERIFICATION i A DZ. , hereby states that he/she is 1CC Je+Ntof JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE: File#: 263542 Name: EIDENSCHINK N• Ile ` r Title: V t,C e, ?1(?Gj ?(Vl'? JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Fila #' 263.iQ Exhibit "F" u 3 ? o m w a Z3 p" j ? u H o C v.p y U ? C 0. O wra ;TE I ? ( w Q w W ? o a W p C? c°?i ? z :% v ? o N e ? w U a ° w 0 d ?` ? ? ? 7 zz Q a a z > z ^o ? t a ' M z N ed ? nib "" N M d' v1 ?G t? oo z `a y? b v G c °0. .... _...._..... ..._n.._._.. ._._...?. ?-. Q N_ O N N N ti a Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 FAX#: 215-568-7616 June 22, 2012 UNKNOWN HEIR of VIRGINIA A. EIDENSCHINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 RE: JP MORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE, LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION vs. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED ET AL. Civil Docket No. 12-3583-CIVIL Dear Defendant; Enclosed please find a copy of my proposed Motion for Special Service of the Complaint and all future pleadings and Order. In accordance with CUMBERLAND County Local Rule 208.3(9) 1 am seeking your concurrence with the requested relief. Please respond to me within one week, by July 3, 2012. Should you have any further questions or concerns, please feel free to contact me. Otherwise, please be guided accordingly. Sincere , Kathleen P. Lake Legal Assistant PHS# 263542/KPL Phelan Hallinan & Schmieg, LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JP MORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE, LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Vs. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Attorney for Plaintiff : COURT OF COMMON PLEA! CIVIL DIVISION NO. 12-3583-CIVIL CUMBERLAND COUNTY CERTIFICATION OF SERVICE I hereby certify a true and correct copy of the foregoing Plaintiffs Motion for S Service was served by regular mail on Defendant(s) on the date listed below: UNKNOWN HEIR of VIRGINIA A. EIDENSCHINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011 PHELAN HALLIN Dated: 263$42 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JP MORGAN CHASE BANK, NATIONAL COURT OF COMMON PLEAS ASSOCIATION S/B/M TO CHASE HOME CIVIL DIVISION FINANCE, LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION NO. 12-3583-CIVIL vs. CUMBERLAND COUNTY UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED ORDER AND NOW, this ? day of,?? - , 2012, upon consideration of Plaintiff's Motion for Service Pursuant to Special Order of court, it is hereby; ORDERED that Plaintiff may obtain service of the Complaint, and all future pleadings, on the Defendant, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED, by publication of the Complaint in accordance with Pa.R.C.P. 430(b)(1); by mailing a true and correct copy of the Complaint by Regular mail; and by posting the mortgaged premises at 8 CAMPBELL PLACE, CAMP HILL, PA 17011 by the Sheriff or by a non-party competent adult. PHS# 263542/KPL It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. BY T URT- J. P- c-) - C'..7 : xy V U 11 kko (,tiN Ht1 (- .e la,. 14',/1-,"A fSc?M; C 0P; Ps Ka.1 ed PHS# 263542/KPL g e& e° 1~.~~D-~ ~It;t.: PHELAN HALLINAN & SCHMIEG~Li~i #c' PR~TI~Q~tOTAt~ John Michael Kolesnik, Esq., Id. No. 3Q~$$7,7AUq 2~ ~~ ~q• 1617 JFK Boulevard, Suite 1400 CCUU 11 [[ One Penn Center Plaza CU~I~~RLANq C4uNTY Philadelphia, PA 19103 pENNSYLYAN~A 215-563-7000 COURT OF COMMON PLEAS JP MORGAN CHASE BANK, NATIONAL ASSOCIATION SB/M TO CI-SASE HOME CIVIL DIVISION FINANCE, LLC SB/M TO CHASE MANHATTAN MORTGAGE CUMBERLAND COUNTY CORPORATION Plaintiff vs. UNKNOWN HEIRS, SUCCESSORS, No. 12-3583-CIVIL ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendants PRAECIPE TO REINSTATE CIVIL ACTION/MORTGAGE FORECLOSURE TO THE PROTHONOTARY: Kindly reinstate the Civil Action in Mortgage Foreclosure with reference to the captioned matter. PHELAN HiAN & SCHMIEG, LLP By: John Mi Esq., Id. No. 308877 for Plaintiff Date: August 22, 2012 JMK/myh, Svc Dept. File# 263542 ~ ~~u d ~~ °~~ ~a 3at~ ~~a?~? ~o Phelan Hallinan & Schmieg, LLP John Michael Kolesnik, Esq., Id. No. 308877 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 JP MORGAN CHASE BANK, NATIONAL ASSOCIATION SIB/M TO CHASE HOME FINANCE, LLC S/B/M TO C1 ASE MANHATTAN MORTGAGE CORPORATION Plaintiff VS. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendant(s) COURT OF COMMON PLEAS CIVIL DIVISION CUMBERLAND COUNTY No. 12-3583-CIVIL AFFIDAVIT OF SERVICE OF COMPLAINT BY MAIL PURSUANT TO COURT ORDER I hereby certify that a true and correct copy of the Civil Action Complaint in Mortgage Foreclosure in the above captioned matter was sent by regular mail, to the following persons, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED at 8 CAMPBELL PLACE, CAMP HILL, PA 17011-2530 on August 30, 2012, in accordance with the Order of Court dated August 8, 2012 . The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Phelan HaJ.inar & Schmieg, LLP DATE: August 3b, 2012 By: Joh JMK/inyh Art, PHS# 263542 ATTORNEYS FOR PLAINTIFF C "31MBERLANO COUNTY PENNSYLVANIA khael Kolesnik, Esq., Id. No. 308877 ;y for Plaintiff Hallinan & Schmieg, LLP e F E'Ll-0FFIC"" 2013 M R 13 t.MII ''►.4C itiE rah CC"Ut TY PEN N S7'LYr'. It PHELAN HALLINAN, LLP Joseph P. Schalk, Esq., Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE, Court of Common Pleas LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Civil Division 111 POLARIS PARKWAY COLUMBUS,OH 43240 Term Plaintiff No.2012-3583-CIVIL Vs Cumberland County UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL,PA 17011-2530 Defendant MOTION TO LIFT CONCILIATION STAY Plaintiff, Bank of America, Successor (hereinafter "Plaintiff'), by its attorney, Joseph P. Schalk, Esquire, hereby files the within Motion to Lift Conciliation Stay and in support thereof avers as follows: 1. On June 8, 2012, Plaintiff filed a Complaint in Mortgage Foreclosure against Defendant for her failure to make monthly payments of principal and interest upon his mortgage due August 1, 2010, and each month thereafter. A true and correct copy of the Complaint is attached hereto, made part hereof and marked as Exhibit A. 2. On December 14, 2012, Plaintiff completed service of the Complaint in Mortgage Foreclosure by Publication in a newspaper of general circulation in Cumberland County. A true 263542 and correct copy of the Proof of Publication is attached hereto, made part hereof and marked as Exhibit B. 3. Pursuant to the Cumberland County Administrative Order February 28, 2012, which created the Cumberland County Residential Mortgage Foreclosure Diversion Program,the Foreclosure action is stayed for sixty(60) days from the date of service. 4. Within 60 days after service of the complaint, the Defendant may opt into the program by filing a Request for Conciliation Conference with the Court. Upon the filing of the request,the Court will schedule a Conciliation Conference. The program provides that Defendant must contact MidPenn Legal Services within the first twenty (20) days of receipt of notice if not represented by counsel. 5. If more than sixty(60) days has elapsed since the service of Notice of Residential Mortgage Foreclosure Diversion Program and the Defendant has not opted to participate in the Diversion Program Plaintiff may petition the Court to lift the stay and remove the case from the Diversion Program. 6. Defendant failed to opt into the Cumberland County Residential Mortgage Foreclosure Diversion Program within sixty(60) days of service. 7. Since Defendant has opted not to participate in the Diversion Program, it is appropriate for the stay to be lifted. WHEREFORE, Plaintiff respectfully requests that this matter be removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program and the automatic stay be lifted. Respectfully submitted, PHELAN HAL YL6 Date: 0 By; C�� Jo e h P9chalk- , tto ey r Plaintiff 263542 Exhibit A 263542 4n N -4 �O ` s�= op ) c) � 4 -t PHM AN HAL MAN&SCHM EO,LLP Maio L HmoyW Esq.,Id 14o2O3993 1617 JFX HwAevo4 SWOe 1400 ATTORNEY FOR PLAINTIFF Oat F4=C 0M Ph= P &W$O*PA 19103 215.563-7000 263542 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION SIB/M TO CHASE HOME FINANCE, COURT OF COMMON PLEAS LLC SISIM TO CHASE MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION I I I I POLARIS PARKWAY COLUMBUS,OH 43240 TERM Plaintiff NO. i a,• 3 5 4 3 V. CUMBERLAND COUNTY UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,T,TM E OR INTEREST FROM OR UNDER VMINIA A.EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HUI.,PA 17011.2530 Defendant COMPLAINT IN BIEW—GACt l UR1ce 10 be a fts AV p►'f'ft E cur t oom of s p1 EASE RETl1F�t NOW48d of rid File N: 263M NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty(20) days after this Complaint and Notice are served by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so, the case may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY ATTORNEY REFERRAL CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717)249-3166 (800)990-9108 File#: 263542 1. Plaintiff is JPMORGAN CHASE BANK,NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE, LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION I I I 1 POLARIS PARKWAY COLUMBUS, OH 43240 2. The name(s) and last known address(es) of the Defendant(s) are: UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 who is/are the real owner(s) of the property hereinafter described. 3. On 02/23/2004 VIRGINIA A. EIDENSCHINK made, executed and delivered a mortgage upon the premises hereinafter described to CHASE MANHATTAN MORTGAGE CORPORATION which mortgage is recorded in the Office of the Recorder of Deeds of CUMBERLAND County, in Book 1856, Page 362.The mortgage and assignment(s), if any, are matters of public record and are incorporated herein by reference in accordance with Pa.R.C.P. 1019(g); which Rule relieves the Plaintiff from its obligations to attach documents to pleadings if those documents are of public record. 4. The premises subject to said mortgage is described as attached. 5. The mortgage is in default because monthly payments of principal and interest upon said mortgage due 08/01/2010 and each month thereafter are due and unpaid,and by the terms of said mortgage, upon failure of Mortgagor to make such payments after a date specified by written notice sent to Mortgagor, the entire principal balance and all interest due thereon are collectible forthwith. File#: 263542 6; The following amounts are due on the mortgage as of 62/29/2012: Principal Balance $101,132.76 Interest $10,745.40 07/01/2010 through 02/29/2012 Late Charges $219.00 Property Inspections $42.00 Property Preservation $70.00 Escrow Deficit $3,238.16 TOTAL $115,447.32 7. Plaintiff is not seeking a judgment of personal liability (or an in peersonam judgment) against the Defendant(s) in the Action; however, Plaintiff reserves its right to bring a separate Action to establish that right, if such right exists. If Defcndant(s)has/have received a discharge of personal liability in a bankruptcy proceeding,this Action of Mortgage Foreclosure is in no way an attempt to reestablish such personal liability discharged in bankruptcy, but only to foreclose the mortgage and sell the mortgaged premises pursuant to Pennsylvania Law. 8.. Notice of Intention to Foreclose as set forth in Act 6 of 1974 and/or Notice of Default as required by the mortgage document, as applicable, have been sent to the Defendant(s) on the date(s) set forth thereon. 9. Mortgagor VIRGINIA A. EIDENSCHINK died on 06/08/2010 and, upon information and belief, her surviving heir(s)are TAYLOR SHELLENBERGER,NICHOLAS EIDENSCHINK,and JOSHUA EIDENSCHINK. 10, Plaintiffs representative contacted the Register of Wills of CUMBERLAND COUNTY and was informed that no estate has been raised on behalf of the decedent mortgagor. 11. By executed waiver(s),TAYLOR SHELLENBERGER,NICHOLAS EIDENSCHINK, and JOSHUA EIDENSCHINK waived their right to be named as a defendant in the foreclosure action. Said waiver(s) is/are attached as Exhibit" A ". File ll: 263542 E 3 12. Plaintiff hereby releases VIRGINIA A. EIDENSCHINK,from liability for the debt secured by the mortgage. WHEREFORE, Plaintiff demands an in rem judgment against the Defendant(s)in the sum of $115,447.32,together with interest,costs, fees, and charges collectible under the mortgage including but not limited to attorney fees and costs, and for the foreclosure and sale of the mortgaged property. PHELAN HALLINAN& SCHMIEG, LLP Mario J. Hanyon, Esquire Attorney for Plaintiff File#: 263542 LEGAL DESCRIPTION ALL THAT CERTAIN unit designated as Number 8, being a Unit in Long Meadows Townhouses, a condominium, located in the Borough of Wormleysburg, Cumberland County, Pennsylvania, under the Declaration of Condominium as recorded in the Office of the Recorder of Deeds, in and for the County of Cumberland, in Misc. Book 229,page 142, and designated in the Declaration Plans as recorded in the said office in Plan Book 30, Page 85. TOGETHER with all right, title and interest, being a 5.555% interest, of, in and to the common elements as more fully set forth in the aforesaid Declaration of condominium and Declaration Plans. KNOWN AS 8 Campbell Place. PROPERTY ADDRESS: 8 CAMPBELL PLACE, CAMP HILL, PA 17011-2530 PARCEL#47-19-1590-064-U8 File#: 263542 EXH- IB: IT "A" May 16 11 09:53a The UPS Store#0698 17177310565 . p.5 WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I,Taylor Shellenberger, Heir of Virginia A. Eidenschink,Deceased in accordance with Section 301(b) of the Pennsylvania Probate,Estates and Fiduciaries Code [20 Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a foreclosure action which may be instituted by CHASE HOME FINANCE LLC, SB/VI TO CMASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises S Campbell Place, Wormleysburg,PA 17043, which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff's sale,and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: By f (prirtt t�se) (sign name) Parent and/or Legal Guardian Of Taylor Shellenberger,Minor Heir of Virginia A. Eidenschink,Deceased Y f: May 1611 09:54a The UPS Store#0698 17177310565 'Jyp.6 • L 3 WAFMR BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I, Joshua Eidenwhink, Heir of Virginia A. Eidenschink,Deceased in accordance with Section 301(b) of the Pennsylvania Probate,Estates and Fiduciaries Code [20,Pa C.S.A. § 301(b)], hereby waive my right to be named as a defendant in a:foreclosure action which may be instituted by CHASE HOME FINANCE LLC, S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises & Campbell Place, Wormleysburg, PA 17043,which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action, without any further notice of proceedings of Sheriff's sale,and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: oshua Mdmchivl, Heir of Virginia A. Eidenschink, Deceased i May 16 11 09:53a The UPS Store#0698 17177310565 p,4 WAIVER BY HEIR OF RIGHT TO BE NAMED AS A DEFENDANT IN FORECLOSURE ACTION I,Nicholas Eidenschink,Heir of Virginia A. Eidenschink,Deceased in accordance with Section 341(b)of the Pennsylvania Probate,Estates and Fiduciaries Code[20 Pa C.S.A. § 301(b)],hereby waive my right to be named as a defendant in a foreclosure action which maybe instituted by CHASE HOME FINANCE LLC, SIB/M TO CHASE MANHATTAN MORTGAGE CORPORATION, involving a mortgage secured on premises 9 Campbell Place, Wormleysburg, PA 17043,which property was owned by decedent at the time of her death. I hereby consent to the foreclosure action,without any further notice of proceedings of Sheriff's sale, and understand that any interest I may have in the mortgaged premises will be divested upon completion of the foreclosure action. Date: �`�c —�/ .--- Ni dlaa Eidanschink, a,r of Virginia A.Eidenschink, Deceased M f 8 {$y3 k VERIFICATION ILA �1_,,. . � hereby states that he/she is I G 0` !'vtof JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, Plaintiff in this matter, and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my information, and belief. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec.4904 relating to unsworn falsification to authorities. DATE: to Title: JPMORGAN CHASE BANK,NATIONAL ASSOCIATION File#:263542 Name:EIDENSCHINK File k 263542 Exhibit B 263542 PROOF OF PURL,ICATION State of Pennsylvania,County of Cumberland Tackie Cox,Sales Director.of The Sentinel,of the County and State aforesaid,being duly sworn, deposes and says that THE SENTINEL, a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13th, 1881, since which date THE SENTINEL has been regularly issued in said County,and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): December 14, 2012 W,. « 'M It hiterest ,ill 'bV aforesaid notice or a vertisemeot,and ► .a all allegations in the foregoing skatemealt as '" '-.<x•, to titne,place and character of Publication ix "r are Sworn before this a Notary Public tx 1 „ kH x My commission expires: cuts N ION q pt iOty, eoo.geo-�ias �� NOTARIAL BAMBI ANN Nc �NDURN CtiMMiss?a��Fxi.._s PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587,approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND Lisa Marie Coyne,Esquire,Editor of the Cumberland Law Journal,of the County and State aforesaid,being duly sworn,according to law, deposes and says that the Cumberland Law Journal,a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has,since January 2, 1952,been regularly issued weekly in the said County,and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz 7, 2012 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation,and that he is not interested in the subject matter of the aforesaid notice or advertisement,and that all allegations in the foregoing statements as to time,place and character of publication are true. Li" Male Coyne, itor SWORN TO AND SUBSCRIBED before me this 7 dsg 6f, ;2012 Notary NOTARIAL SEAL DEBORAH A COLLINS Notary PubBc CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 PHELAN HALLINAN, LLP Joseph P. Schalk, Esq., Id.No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION SB/M TO CHASE HOME FINANCE, LLC SB/M TO CHASE MANHATTAN MORTGAGE Civil Division CORPORATION 111 POLARIS PARKWAY Term COLUMBUS,OH 43240 No.2012-3583-CIVIL Plaintiff Cumberland County Vs UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL,PA 17011-2530 Defendant CERTIFICATION OF SERVICE I certify that a true and correct copy of Plaintiff's Motion to Lift Conciliation Stay and proposed Order were sent via first class mail to the person listed below on the date indicated: UNKNOWN HEIRS,SUCCESSORS,ASSIGNS, CASSANDRA ECKRICH AND ALL PERSONS,FIRMS,OR ASSOCIATIONS 6330 ANTILLES COURT CLAIMING RIGHT,TITLE OR INTEREST FROM MECHANICBURG, PA 17050 OR UNDER VIRGINIA A.EIDENSCHINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 1701 1-2530 Date: By se Schalk,Esquire tto ey Tor Plaintiff 263542 IN THE COURT OF COMMON PLEAS CUMBERLAND COU*VY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE, Court of Common Pleas LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Civil Division 111 POLARIS PARKWAY COLUMBUS,OH 43240 Term Plaintiff No.2012-3583-CIVIL Vs Cumberland County UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL,PA 17011-2530 Defendant ', ORDER AND NOW,this Z/ of M*&%A , 2013, upon consideration of Plaintiff s Motion to Lift Conciliation Stay in the above captioned matter, it is hereby +' ORDERED and DECREED that this matter is removed from the Cumberland County Residential Mortgage Foreclosure Diversion Program; it is further i ORDERED and DECREED that the automatic Stay is lifted and Plaintiff may proceed with its Mortgage Foreclosure Action. BY THE COURT: J J. c c s MCD rx t --= SSQ.,d,�a �Ce�r,`c�t �s � -"- 2n r— ry a-�'Cs �un(CHciJs� rtP�'S �p N oe`, 3'�, ?~t �� ✓eke%� 5 263542 3/ o -' } pIn, 4 k' k r cc: Joseph P. Schalk,Esq.,Id. No. 91656 Attorney for Plaintiff PHELAN HALLINAN,LLP Joseph P. Schalk, Esq., Id. No. 91656 126 Locust Street Harrisburg, PA 17101 215-563-7000 UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL,PA 17011-2530 CASSANDRA.ECKRICH 6330 ANTILLES COURT MECHANICBURG,PA 17050 t 263542 w OF THE FI PR TTHONOTARY PHELAN HALLINAN, LLP 2613 OR 18 Qy 10: 09 Attorney for Plaintiff Adam H. Davis, Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 CUMBERLAND COUNTY One Penn Center Plaza PENNSYLVANIA Philadelphia, PA 19103 215-563-7000 JP MORGAN CHASE BANK,NATIONAL CUMBERLAND COUNTY ASSOCIATION S/B/M CHASE HOME FINANCE,LLC S/B/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION °S. No. 12-3583-CIVIL UNKNOWN HEIRS,SUCCESSORS, ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against UNKNOWN HEIRS SUCCESSORS ASSIGNS AND ALL PERSONS FIRMS OR ASSOCIATIONS CLAIMING RIGHT TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED, Defendant(s) for failure to file an Answer to Plaintiff's Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $115,447.32 TOTAL $11.5,447.32 I hereby certify that(1) the Defendant's last known address is 8 CAMPBELL PLACE, CAMP HILL,PA 17011-2530, and (2) that notice has been given in accordance with Rule Pa.R.C.P 237.1. Date Adam H. Davis, Esq., Id. No.203034 !Attorney f Plaintiff DAMAGES ARE HEREBY ASSESSED AS INDICATED. DATE: PROTHONOTARY Gti#a89 3s1 - lJoi,c,e (1't�led PHELAN HALLINAN, LLP Attorney for Plaintiff Adam H. Davis,Esq., Id. No.203034 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia,PA 19103 215-563-7000 JP MORGAN CHASE BANK,NATIONAL CUMBERLAND COUNTY ASSOCIATION S/B/M CHASE HOME FINANCE,LLC S/B/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION vs. No.12-3583-CIVIL UNKNOWN HEIRS,SUCCESSORS, ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED AFFIDAVIT OF NON-MILITARY SERVICE The undersigned attorney hereby verifies that he/she is the attorney for the Plaintiff in the above-captioned matter,and that on information and belief, he/she has knowledge of the following facts,to wit: (a) that the Plaintiff is without information sufficient to determine whether the defendant UNKNOWN HEIRS, SUCCESSORS,ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED is not the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors'Civil Relief Act of Congress of 1940, as amended; and (b) that Plaintiff is without information sufficient to determine whether defendant(s)UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED are over 18 years of age and last known address is 8 CAMPBELL PLACE, CAMP HILL, PA 17011-2530. This statement is made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswornn falsification to authorities. Date �� 7/ 0 l Adam H. Davis,Esq., Id. No.203034 Attorney for Plaintiff 263542 t � m af:Apr-13-20131 2.08:52 Department of Defense Manpower Data Center Resdu sc"30 Status Report Pursuant to Servicemembers Civil Relief Act Last Name: EIDENSCHINK First Name:VIRGINIA Middle Name: A Active Duty Status As Of: Apr-17-2013 . 6n Active bury On AatM Duty SWWa Dab Abera ovty sun Dab _ - /Wire Dun Dab s}T:raptg Sarvkn Cwtata�Kn1 NA TM1ia reapMbc Mabels Oib irgMauab'egivC'Y�Gry a�tara E tW on Op *stall Date t tbtl AtlNC OWy±w,tN 367 bays of AtlNe Dvty SUNS Date Y AGTh2 Duly Sun Dab Ao"DO,f W Date sutvf - Servim C Doftnt 'title rovaw sa renetttw�iem tin balriWUat kfi octiva dd7 cutvswitNn�S_�days preced'ug tlw AcUvepyty SIeWSaate - TrmtdeTGbrIXtlyHer ttiW Wda NU6fxtl afa fuNre DeI4iIPUAatire Duty anr.tdw DV4'SUNS Dn[e , QCet MaliSrsUdn Sian DaM bider tiPliSCbiibn End Date sbWZ - Sbntea CO,nppFM NA Tds easPanse mduUn reetnerfM LalNiduatIX bhR,ai unities raxMatl'eany,ro5tlrae6ri u+epanbe a duty 1 Upon searching the data banks of the Department of Defense Manpow-eer'Data:Oenter,-based on the Information that you provided,the above Is the status of the Individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force.NOAA,Public Health,and Coast Guard), This status Includes information on a Servlcemember or his/her unit receiving notification of future orders to report for Active Duty, HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY - IDENTIFYANINDIVIDUAL. Mary M.Snavey-Dixon,Director Department of Defense>Manpower Data Center 4800 Mark Center Drive,Suite 04E25 Arlington,VA 22350 a (Rule of Civil Procedure No. 236) -Revised JP MORGAN CHASE BANK,NATIONAL CUMBERLAND COUNTY ASSOCIATION S/B/M CHASE HOME FINANCE,LLC S/B/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION VS. No. 12-3583-CIVIL UNKNOWN HEIRS,SUCCESSORS, ASSIGNS, AND ALL PERSONS,F RMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Notice is given that a Judgment in the above captioned matter has been entered against you on . By: 3 If you have any questions concerning this matter please contact: Phelan Hallinan, LLP Adam H. Davis, Esq., Id. No.203034 Attorney for Plaintiff 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 215-563-7000 THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE ANA TTEMPT TO COLLECT A DEBT, BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." 263542 JP MORGAN CHASE BANK, NATIONAL COURT OF COMMON PLEAS { ASSOCIATION S/B/M TO CHASE HOME CIVIL DIVISION FINANCE,LLC SBIM TO CHASE MANHATTAN MORTGAGE CORPORATION NO. 12-3583-CIVIL Plaintiff V. CUMBERLAND COUNTY UNKNOWN HEIRS,SUCCESSORS,ASSIGNS, AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK, DECEASED Defendants) TO: UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL,PA 170111-2530 DATF OF NOTICE:. y I THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT THE INDEBTEDNESS REFERRED TO HEREIN, AND ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS CORRESPONDENCE IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT, BUT ONLY AS ENFORCEMENT OF LIEN AGAINST PROPERTY. 1MYOR CAN I`IYO'i'tCl+: YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, T141S OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Office of the Prothonotary CUMBERLAND COUNTY BAR Cumberland County Courthouse ASSOCIATION 1 Courthouse Square CUMBERLAND COUNTY COURTHOUSE Carlisle,PA 17013 2 LIBERTY AVENUE (717)240-6195 CARLISLE,PA 17013 (717)249-3166 By: it:in Lobb,Esq., id.No.3 t2174 for Plaintiff PHS 1#263542 Phclan I-lallinan,LLP 1617 JFK Boulevard,Suite 1400 one Penn Cenmr Plan Philatdelphia.IIA 19107 PHS it 2635'=2 PRAECIPE FOR WRIT OF EXECUTION-(MORTGAGE FORECLOSURE) P.R.C.P. 3180-3183 JP MORGAN CHASE BANK,NATIONAL ASSOCIATION S/B/M TO COURT OF COMMON PLEAS CHASE HOME FINANCE,LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION Plaintiff NO.: 12-3583-CIVIL V. UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS, CUMBERLAND COUNTY FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED Defendant(s) To the Prothonotary: Issue writ of execution in the above matter: c- 3 G CM Amount Due $115.447.32 rrIC3 Interest from 04/19/2013 to Date of Sale $4,365.40 ($18.98 per diem) .,C c� sip �-•�+ 7�n c~; o a am TOTAL $119,812.72 rC CrI" Phelan Hallinan,LLP Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff Note: Please attach description of property. C PHS#263542 v a. as a . sou aj 1 sb .o F. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JP MORGAN CHASE BANK,NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE,LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff V. UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED Defendant(s) PRAECIPE FOR WRIT OF EXECUTION (Mortgage Foreclosure) Filed: Address where papers may be served: UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND Phelan Hallinan LLP A ALL PERSONS,FIRMS,OR ASSOCIATIONS Adam H. Davis,Esq.,Id.No.203034 CLAIMING RIGHT,TITLE OR INTEREST FROM OR Attorney for Plaintiff UNDER VIRGINIA A.EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL,PA 17011-2530 LEGAL DESCRIPTION ALL THAT CERTAIN Unit described as Number 8,being a Unit in Long Meadows Townehouses,a Condominium, located in the Borough of Wormleysburg,Cumberland County,Pennsylvania,under the Declaration of Condominium as recorded in the Office of the Recorder of Deeds,in and for the County of Cumberland,in Miscellaneous Book 229,Page 142,and designated in the Declaration Plans as recorded in the said office in Plan Book 30,Page 85. TOGETHER with all right,title and interest,being a 5.555%interest of, in and to the Common Elements as more fully set forth in the aforesaid Declaration of Condominium and Declaration Plans. UNDER AND SUBJECT to al agreements,conditions and restrictions of record and to the provisions, easements,covenants and restrictions as contained in the Declaration of Condominium,Code of Regulations and Declaration Plan. The Grantee,for itself and its successors and assigns, by the acceptance of this Deed,covenants and agrees to pay such charges for the maintenance of,repairs to,replacement of and expenses in connection with the Common Elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania,and further covenants and agrees that the Unit conveyed by this Deed sha11 be subject to a charge for all amounts so assessed and that,except in so far as Sections 705 and 706 of said Unit Property Act may relieve a subsequent Unit owner of liability for prior unpaid assessments,this covenant shall run with and bind the land or Unit hereby conveyed and all subsequent owners thereof. The Grantee,for and on behalf of itself and its successors and assigns,by acceptance of this Deed, acknowledges that this conveyance is subject in every respect to the Declaration of Condominium and Code of Regulations and all amendments thereto;and the Grantee further acknowledges that each and every provision of the foregoing is essential to the successful operation and management of said condominium property,and in the best interests for the benefit of all Unit owners therein.Grantee and all owners of Units in said condominium covenant and agree,as a covenant running with the land,to abide by each and every provision of said documents. TITLE TO SAID PREMISES IS VESTED IN Virginia A.Eidenschink, by Deed from Campbell Properties,a Pennsylvania General Partnership,comprised of John A. Capello and Jean A. Capello, h/w and Charles A.Delone,Jr.,(erroneously referred to as Charles A. Delone, III, in a prior deed)and Elaine M. Delone, h/w and Frank Procopio and Shirlee J.Procopio,h/w and Robert C.Hughes and Samuel L. Andes, all co-partners, dated 02/20/2004,recorded 03/04/2004 in Book 261,Page 4798. The said VIRGINIA A. EIDENSCHINK departed this life on 06/08/2010, and upon information and belief, her surviving heir(s)are TAYLOR SHELLENBERGER,NICHOLAS EIDENSCHINK,and JOSHUA EIDENSCHINK. By executed waiver(s), TAYLOR SHELLENBERGER,NICHOLAS EIDENSCIIINK, and JOSHUA EIDENSCHINK waived their rights to be named as a defendant in the foreclosure action. PREMISES BEING: 8 CAMPBELL PLACE,CAMP HILL,PA 17011-2530 PARCEL NO.47-19-1590-064-U8 PHELAN HALLINAN, LLP Attorneys for Plaintiff Adam H. Davis, Esq., Id. No.203034 140TAF 01F THE PROTH01 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza 2013 JUN 13 Philadelphia, PA 19103 TY 215-563-7000 CUMBERLAND COUN PENNSYLVANIA 3P MORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M COURT OF COMMON PLEAS TO CHASE HOME FINANCE,LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION Plaintiff NO.: 12-3583-CIVIL V. UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL CUMBERLAND COUNTY PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendant(s) CERTIFICATION The undersigned attorney hereby states that he/she is the attorney for the Plaintiff in the above captioned mat-ter and that the premises are not subject to the provisions of Act 91 because: the mortgage is an FHA Mortgage the premises is non-owner occupied the premises is vacant Act 91 procedures have been fulfilled (X) I Act 91 is Not Applicable pursuant to Pa Bulletin,Doe No I I-1197, 41 Pa.B. 3 943 This certification is made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unworn falsification to authorities. By: Phelan Hallinan,LLP Adam H.Davis,Esq., Id.No.203O34 Attorney for Plaintiff JP MV ORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS I ASSOCIATION S/B/M TO CHASE HOME FINANCE, LLC S/B/M TO CHASE MANHATTAN MORTGAGE CIVIL DIVISION CORPORATION Plaintiff NO.: 12-3583-CIVIL V. CUMBERLAND COUNTY UNKNOWN HEIRS, SUCCESSORS, ASSIGNS,AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED Defendant(s) AFFIDAVIT PURSUANT TO RULE 3129.1 JP MORGAN CHASE BANK,NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE,LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the. following information concerning the real property located at 8 CAMPBELL PLACE,CAMP HILL,PA 17011-2530. I Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained, please so indicate) UNKNOWN HEIRS,SUCCESSORS,ASSIGNS, 8 CAMPBELL PLACE AND ALL PERSONS,FIRMS,OR CAMP HILL,PA 17011-2530 ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED MCD FTJ 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably r— �t= ascertained,please so indicate) C:>—n UNKNOWN HEIRS,SUCCESSORS,ASSIGNS, 8 CAMPBELL PLACE =C:> AND ALL PERSONS,FIRMS,OR CAMP HILL,PA 17011-2530 )L> ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) None. 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) None. PHS 4 263542 5. Name and address of every other person who has any record lien on the property: Name Address(if address cannot be reasonably ascertained,please indicate) None. 6. Name and address of every other person who has any record interest in the property and whose interest may be affected by the sale. Name Address(if address cannot be reasonably ascertained,please indicate) LONG MEADOWS TOWNEHOUSES 2104 MARKET STREET ASSOCIATION CAMP HILL,PA 17011 CIO EDMUND J.BERGER,ESQUIRE LONG MEADOWS TOWNEHOUSES 204 TALL OAK DRIVE ASSOCIATION NEW CUMBERLAND,PA 17070-2347 CIO EDMUND J.BERGER,ESQUIRE LONG MEADOWS TOWNEHOUSES 2 RICHLAND LANE ASSOCIATION WORMLEYSBURG,PA 17043 CIO JAMES STRUPE,PRESIDENT 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 8 CAMPBELL PLACE CAMP HILL,PA 17011-2530 COMMONWEALTH OF PENNSYLVANIA 6TH FLOOR,STRAWBERRY SQ. BUREAU OF INDIVIDUAL TAXES DEPT 280601 INHERITANCE TAX DIVISION HARRISBURG;PA 17128 DEPARTMENT OF PUBLIC WELFARE,TPL P.O.BOX 8486 CASUALTY UNIT,ESTATE RECOVERY WILLOW OAK BUILDING PROGRAM HARRISBURG,PA 17105 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING JOSHUA EIDENSCHINK,IN HIS CAPACITY 8 CAMPBELL PLACE AS HEIR OF VIRGINIA A.EIDENSCHINK, CAMP HILL,PA 1.7011-2530 DECEASED NICHOLAS EIDENSCHINK,IN HIS 6330 ANTILLES COURT CAPACITY AS HEIR OF VIRGINIA A. MECHANICSBURG,PA 17050-5249 EIDENSCHINK,DECEASED PHS #263542 TAYLOR SHELLENBERGER,IN HER 6330 ANTILLES COURT CAPACITY AS HEIR OF VIRGINIA A. MECHANICSBURG,PA 17050-5249 EIDENSCHINK,DECEASED I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities. Date: t7 112-11'3 By: Phelan Hallinan,LLP Adam H.Davis,Esq., Id.No.203034 Attorney for Plaintiff PHELAN HALLINAN,LLP 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza,Philadelphia,PA 19103 215-563-7000 PHS # 263542 J1'P MO'RGAN CHASE BANK, NATIONAL ASSOCIATION COURT OF COMMON PLEAS SB/M TO CHASE HOME FINANCE,LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION Plaintiff NO.: 12-3583-CIVIL VS. , CUMBERLAND COUNTY UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED ,.,, '. c, Defendant(s) ' f nL7J t^ r'T1 rr NOTICE OF SHERIFF'S SALE OF REAL PROPERTY w .. TO: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR =c E5 ASSOCIATIONS CLAIMING RIGHT, TITLE `"', OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 "THIS FIRM IS A DEBT COLLECTOR ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.IF YOU HAVE PREVIOUSLY RECEIVED A DISCHARGE IN BANKRUPTCY, THIS IS NOT AND SHOULD NOT BE CONSTRUED TO BE AN ATTEMPT TO COLLECT A DEBT,BUT ONLY ENFORCEMENT OF A LIEN AGAINST PROPERTY." Your house (real estate) at 8 CAMPBELL PLACE, CAMP HILL,PA 17011-2530 is scheduled to be sold at the Sheriff's Sale on 12/04/2013 at 10:00 AM in the Cumberland County Courthouse, South Hanover Street, Carlisle, PA 17013 to enforce the court judgment of S115,447.32 obtained by JP MORGAN CHASE BANK,NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE,LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION (the mortgagee) against you. In the event the sale is continued, an announcement will be made at said sale in compliance with Pa.R.C.P. Rule 3129.3. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriff's Sale, you must take immediate action: 1. The sale will be canceled if you pay to the mortgagee the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay, you may call: 215-563-7000 x1230. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open the judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. You may also be able to stop the sale through other legal proceedings. You may need an attorney to assert your rights. The sooner you contact one,the more chance you will have of stopping the sale. (See notice on page two on how to obtain an attorney.) YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES TAKE PLACE. 1. If the Sheriff s Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid by calling 215-563-7000. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale. To find out if this has happened, you may call 215-563-7000. 4. If the amount due from the Buyer is not paid to the Sheriff, you will remain the owner of the property as if the sale never happened. 5. You have the right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer. At that time, the buyer may bring legal proceedings to evict you, 6. You may be entitled to a share of the money which was paid for your house. A proposed schedule of distribution of the money bid for your house will be prepared by the Sheriff not later than thirty (30) days after the sale. The schedule shall be kept on file with the sheriff and will be made available for inspection in his office. This schedule will state who will be receiving that money. The money will be paid out in accordance with this schedule unless exceptions (reasons why the proposed distribution is wrong) are filed with the Sheriff within ten (10)days after the filing of the proposed schedule. 7. You may also have other rights and defenses, or ways of getting your home back, if you act immediately after the sale. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION CUMBERLAND COUNTY COURTHOUSE 2 LIBERTY AVENUE CARLISLE,PA 17013 (717) 249-3166 (800)990-9108 SHORT DESCRIPTION By virtue of a Writ of Execution No. 12-3583-CIVIL JP MORGAN CHASE BANK, NATIONAL ASSOCIATION S/B/M TO CHASE HOME FINANCE,LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION V. UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED owner(s)of property situate in the BOROUGH OF WORMLEYSBURG, CUMBERLAND County, Pennsylvania, being 8 CAMPBELL PLACE, CAMP HILL, PA 17011-2530 Parcel No. 47-19-1590-064-U8 (Acreage or street address) Improvements thereon: CONDOMINIUM Judgment Amount: 5115,447.32 Attorneys for Plaintiff Phelan Hallinan, LLP LEGAL DESCRIPTION ALL THAT CERTAIN Unit described as Number 8,being a Unit in Long Meadows Townehouses,a Condominium, located in the Borough of Wormleysburg,Cumberland County,Pennsylvania,under the Declaration of Condominium as recorded in the Office of the Recorder of Deeds, in and for the County of Cumberland, in Miscellaneous Book 229,Page 142, and designated in the Declaration Plans as recorded in the said office in Plan Book 30,Page 85. TOGETHER with all right,title and interest,being a 5.555%interest of,in and to the Common Elements as more fully set forth in the aforesaid Declaration of Condominium and Declaration Plans. UNDER AND SUBJECT to all agreements,conditions and restrictions-of record and to the provisions, easements,covenants and restrictions as contained in the Declaration of Condominium,Code of Regulations and Declaration Plan. The Grantee,for itself and its successors and assigns,by the acceptance of this Deed,covenants and agrees to pay such charges for the maintenance of,repairs to,replacement of and expenses in connection with the Common Elements as may be assessed from time to time by the Council in accordance with the Unit Property Act of Pennsylvania,and further covenants and agrees that the Unit conveyed by this Deed shall be subject to a charge for all amounts so assessed and that,except in so far as Sections 705 and 706 of said Unit Property Act may relieve a subsequent Unit owner of liability for prior unpaid assessments,this covenant shall run with and bind the land or Unit hereby conveyed and all subsequent owners thereof. The Grantee,for and on behalf of itself and its successors and assigns,by acceptance of this Deed, acknowledges that this conveyance is subject in every respect to the Declaration of Condominium and Code of Regulations and all amendments thereto;and the Grantee further acknowledges that each and every provision of the foregoing is essential to the successful operation and management of said condominium property,and in the best interests for the benefit of all Unit owners therein. Grantee and all owners of Units in said condominium covenant and agree,as a covenant running with the land,to abide by each and every provision of said documents. TITLE TO SAID PREMISES IS VESTED IN Virginia A. Eidenschink, by Deed from Campbell Properties, a Pennsylvania General Partnership,comprised of John A. Capello and Jean A. Capello, h/w and Charles A. Delone,Jr.,(erroneously referred to as Charles A. Delone,III, in a prior deed)and Elaine M.DeLone,h/w and Frank Procopio and Shirlee J. Procopio,h/w and Robert C. Hughes and Samuel L. Andes, all co-partners, dated 02/20/2004, recorded 03/04/2004 in Book 261,Page 4798. The said VIRGINIA A. EIDENSCHINK departed this life on 06/08/201.0,and upon information and belief, her surviving heir(s)are TAYLOR SHELLENBERGER,NICHOLAS EIDENSCHINK,and JOSHUA EIDENSCHINK. By executed waiver(s),TAYLOR SHELLENBERGER,NICHOLAS EIDENSCHINK, and JOSHUA EIDENSCHINK waived their rights to be named as a defendant in the foreclosure action. PREMISES BEING: 8 CAMPBELL PLACE,CAMP HILL,PA 17011-2530 PARCEL NO.47-19-1590-064-U8 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-3583 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due JP MORGAN CHASE BANK,NATIONAL ASSOCIATION SB/M TO CHASE HOME FINANCE,LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION Plaintiff(s) From UNKNOWN HEIRS,SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED (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: $115,447.32 L.L.: $.50 Interest FROM 4/19/2013 TO DATE OF SALE($18.98 PER DIEM)-$4,365.40 Atty's Comm: Due Prothy: $2.25 Atty Paid: $172.25 Other Costs: Plaintiff Paid: Date: 6113113 David D.Buell,Prothonotary, (Seal) Deputy REQUESTING PARTY: Name.: ADAM H.DAVIS,ESQUIRE Address:PHELAN HALLINAN,LLP 1617 JFK BLVD,SUITE 1400,ONE PENN CENTER PLAZA PHILADELPHIA,PA 19103 Attorney for:PLAINTIFF Telephone: 215-563-7000 Supreme Court ID No. 203034 PHELAN HALLINAN, LLP � f 3 SEP �d� Attorney for Plaintiff AM 10. 2 3 1617 JFK Boulevard, Suite 1400 00ORE ��0 COUNTY One Penn Center Plaza F1��S YLVA�rI,Q Philadelphia, PA 19103 215-563-7000 JP MORGAN CHASE BANK,NATIONAL ASSOCIATION SB/M TO CHASE HOME CUMBERLAND COUNTY FINANCE, LLC S/B/M TO CHASE COURT OF COMMON PLEAS MANHATTAN MORTGAGE CORPORATION CIVIL DIVISION Plaintiff : NO. 12-3583-CIVIL vs. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendant AFFIDAVIT OF SERVICE OF NOTICE OF SHERIFF'S SALE PURSUANT TO P.R.C.P., 404(2)/403 I hereby certify that a true and correct copy of the Notice of Sheriff Sale in the above captioned matter was sent by regular mail to UNKNOWN HEIRS, SUCCESSORS,ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED on JULY 24, 2013 in accordance with the Order of Court dated AUGUST 8,2012. The property was posted on JUNE 23, 2013. Publication was advertised in THE CUMBERLAND LAW JOURNAL on AUGUST 2, 2013 &in THE SENTINEL on JULY 24, 2013. The undersigned understands that this statement is made subject to the penalties of 18 Pa.C.S. §4904 relating to the unsworn falsification to authorities. a 2 Phelan 11' a DATE: ` �✓ By; Zachary n , Es ., Id. No.310721 Attorn f Pla' tiff i �TAR.Y � cop, ECppy . .� Rt7pRN IN TAE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA JP MORGAN CHASE BANK,NATIONAL COURT OF COMMON PLEAS ASSOCIATION SB/M TO CHASE HOME CIVIL DIVISION FINANCE,LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION NO. 12-3583-CIVIL VS. CUMBERLAND COUNTY UNKNOWN HEIRS,SUCCESSORS,ASSIGNS, AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED ORDER AND NOW,this day of t ,2012,upon consideration of Plaintiffs Motion for Service Pursuant to Special Order of court,it its hereby; ,� - cur � nth�r..pt�► ;f may obtain service of the Complaint, and all future pleadings, on the Defendant, UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED, by publication of the Complaint in accordance with Pa.R.C.P. 430(b)(1); by mailing a true and correct copy of the Complaint by Regular mail;and by posting the mortgaged premises at 8 CAMPBELL PLACE,CAMP HILL, PA 17011 by the Sheriff or by a non-party competent adult. PHS#263542/KPL gloom . r I It is further ORDERED and DECREED that counsel for Plaintiff is hereby directed to file a certificate of service with the Prothonotary's office to assure compliance with this court order. BY THE COURT: J. r . ._ PHS#263542/KPL N O � Name and PHELAN HALLINAN&SCHMIEG $ ( o Address One Penn Center at Suburban,Suite 1400 v of Sender Philadelphia,PA 19103 z Q^ a S � J Line Article Name of Addressee,Street,and Post Office Address Postage w �' C2 5 Number (9 a) 1 **** UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS t-- t D o LAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK, O r M DECEASED �? <, acao CAMPBELL PLACE D N°° AMP HILL,PA 17011-2530 _ 2 4 5 6 * ** 7 **« g «** 12 % VIRGINIA A.EIDENSCHINK,DECEASED PHS# 757375 Total Number of Total Number of Pieces Postmaster,Per(Name of Receiving Pieces Listed by Sender Received at Post Office Employee) 1 LXH- *NOTICE OF SALE: CERTIFICATE OF MAILING* CODE: 1020 AFFIDAVIT OF SERVICE(FNMA) PLAINTIFF CUMBERLAND COUNTY JP MORGAN CHASE BANK,NATIONAL ASSOCIATION SB/M CHASE HOME FINANCE,LLC SB/M TO CHASE MANHATTAN PHS#263542 i MORTGAGE CORPORATION DEFENDANT', SERVICE TEAM/snl 4 UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL COURT NO.:12-3583-CIVIL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED SERVE UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL TYPE OF ACTION PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT, XX Notice of Sheriffs Sale TITLE OR INTEREST FROM OR UNDER VIRGINIA A. SALE DATE: 12/04/2013 EIDENSCHINK,DECEASED AT: 8 CAMPBELL PLACE CAMP HILL,PA 17011-2530 ****PLEASE POST THE PROPERTY*** SERVED Served and made known to UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RI HT TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK DECEASED,Defendant on the day of "AAA 20 B at - o clock F.M.,at 8 CAMPBELL PLACE, CAMP HILL,PA 1701.1-2530,in the manner described below: Defendant personally served. Adult family member with whom Defendant(s)reside(s). Relationship is _Adult in charge of Defendant's residence who refused to give name or relationship. _Manager/Clerk of place of lodging in which Defendant(s)reside(s). _Agent or person in charge of Defendant's office or usual place of business. _ an officer of said Defendant's company. XX Other: POSTED THE PROPERTY Description: Age Height Weight Race Sex Other I, a competent adult,hereby verify that I personally posted the property with a true and correct cop of the Notice of Sheriff's Sale in the manner as set forth herein,issued in the captioned case on the date and at the address indicated above. I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. DATE:_ ?� 74a NAME: PRINTED NAM``E..:��,, ve(fto TITLE:' ? t.C.� S NOT SERVED On the da of 20_,at o'clock_.M.,I, a competent adult hereby state tha—McTendant 13�I Ziecause: _Vacant _Does Not Exist _Moved _Does Not Reside(Not Vacant) _No Answer on at at Service Refused Other: I understand that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. BY: PRINTED NAME: ATTORNEY FOR PLAINTIFF Lawrence T.Phelan,Esq.,Id.No.32227 Francis S.Hallinan,Esq.,Id.No.62695 Daniel G.Schmieg,Esq„Id.No.62205 Michele M.Bradford,Esq.,Id.No.69849 Judith T.Romano,Esq.,Id.No.58745 \\ Jenine R.Davey,Esq.,Id.No.87077 Lauren R.Tabas,Esq.,Id.No.93337 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA ss. COUNTY OF CUMBERLAND Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, Viz August 2, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. L' a Marie Coyne, FAitor SWORN TO AND SUBSCRIBED before me this 2 day of August, 2013 C-111— " � Notary NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH,CUMBERLAND COUNTY My Commission Expires Apr 28,2014 CUMBERLAND LAW JOURNAL NOTICE OF SHERIFF'S SALE house Square, Room 303, Carlisle, PA 17013,to enforce the Court Judg- In the Court of Common Pleas of ment of$115,447.32 obtained by,JP Cumberland County,Pennsylvania MORGAN CHASE BANK,NATIONAL ASSOCIATION s/b/m CHASE HOME NO. 12-3583-CIVIL FINANCE, LLC s/b/m TO CHASE MANHATTAN MORTGAGE CORPO- JP MORGAN CHASE BANK, RATION(the mortgagee),against the NATIONAL ASSOCIATION s/b/m above premises. CHASE HOME FINANCE,LLC PHELAN HALLINAN, LLP s/b/m TO CHASE MANHATTAN Attorneys for Plaintiff MORTGAGE CORPORATION Aug. 2 vs. UNKNOWN HEIRS, SUCCESSORS,ASSIGNS AND ALL PERSONS,FIRMS OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED NOTICE OF SHERIFF'S SALE OF REAL PROPERTY NOTICE TO: UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR AS- SOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDEN- SCHINK,DECEASED Being Premises: 8 CAMPBELL PLACE,CAMP HILL,PA 17011-2530. Being in BOROUGH OF WORM- LEYSBURG, County of CUMBER- LAND, Commonwealth of Pennsyl- vania,47-19-1590-064-U8. Improvements consist of residen- tial property. Sold as the property of UNKNOWN HEIRS, SUCCESSORS, ASSIGNS AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UN- DER VIRGINIA A. EIDENSCHINK, DECEASED. Your house (real estate) at 8 CAMPBELL PLACE, CAMP HILL,PA 17011-2530 is scheduled to be sold at the Sheriff's Sale on December 4, 2013 at 10:00 A.M.,at the CUMBER- LAND County Courthouse, 1 Court- 9 PROOF OF PUBLICATION State of Pennsylvania,County of Cumberland Jackie Cox,Director of Sales,of The Sentinel,of the County and State aforesaid,being duly sworn,deposes and says that THE SENTINEL,a newspaper of general circulation in the Borough of Carlisle,County and State aforesaid,was established December 13th, 1881,since which date THE SENTINEL has been regularly issued in said County,and that the printed notice or publication attached hereto is exactly the same as was printed and published in the regular editions and issues of THE SENTINEL on the following day(s): July 24,2013 COPY OF NOTICE OF PUBLICATION NOTICE OF SHERIFF'S SALE { IN THE COURT OF COMMON PLEAS ant further deposes that he/she is not OF CUMBERLAND COUNTY,PENNSYLVANIA Affi p /NO.12-3683-CIVIL interested in the subject matter of the JP MORGAN CHASE BANK,NATIONAL ASSOCIATION S/B/M CHASE HOME FINANCE,LLC S/B/M TO CHASE MANHATTAN MORTGAGE aforesaid notice or advertisement,and that CORPORATION vs. all allegations in the foregoing statement as UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS, place and character of publication FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST to time, FROM OR.UNDER VIRGINIA A.EIDENSCHINK,DECEASED I are true. NOTICE TO:UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED NOTICE OF SHERIFFS SALE OF REAL PROPERTY Being Premises:8 CAMPBELL PLACE,CAMP HILL,PA 17011-2530 Being in BOROUGH OF WORMLEYSBURG,County of CUMBERLAND, Commonwealth of Pennsylvania,47-19-1590-064-U8 Improvements consist of residential property. Sold'as the property of UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR I + . INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED { Sworn to and subscribed before me this Your house(real estate)at 8 CAMPBELL PLACE,CAMP HILL,PA '17011-2530 is scheduled to be sold at the Sheriff's Sale on 12/04/2013 at 2 „` 10:00 AM,at the CUMBERLAND County Courthouse,1 Courthouse J ' Square,Room 303,Carlisle,PA 17013,to enforce the Court Judgment of $115,447.32 obtained by,JP MORGAN CHASE BANK,NATIONAL ASSOCIATION S/B/M CHASE HOME FINANCE,LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION(the mortgagee),against the ` above premises. i PHELAN HALLINAN,LLP Attorney for Plaintiff Notary PubhC My commission expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Bethany M.Holtry,Notary Public Carlisle Boro,Cumberland County My Commission Expires Sept.26,2015 MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES • r Phelan Hallinan, LLP Jonathan M. Etkowicz, Esq., Id. No.208786 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonathan.etkowicz@phelanhallinan.com 215-563-7000 JP MORGAN CHASE BANK,NATIONAL • Court of Common Pleas • ASSOCIATION S/B/M CHASE HOME FINANCE, LLC S/B/M TO CHASE • Civil Division MANHATTAN MORTGAGE CORPORATION • Plaintiff • CUMBERLAND Court@ 71 v. • No.: 12-3583-CIVIL cn TM' r 1 E a i UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, r-6 r AND ALL PERSONS, FIRMS, OR `' ASSOCIATIONS CLAIMING RIGHT, TITLE OR 1 INTEREST FROM OR UNDER VIRGINIA A. { EIDENSCHINK, DECEASED =' } Defendant PLAINTIFF'S MOTION TO REASSESS DAMAGES Plaintiff, by its Attorneys, Phelan Hallinan, LLP,moves the Court to direct the Prothonotary to amend the judgment in this matter, and in support thereof avers the following: 1. Plaintiff commenced this foreclosure action by filing a Complaint on June 8, 2012. 2. Judgment was entered on April 18, 2013 in the amount of$115,447.32. A true and correct copy of the praecipe for judgment is attached hereto, made part hereof, and marked as Exhibit"A". 3. Pursuant to Pennsylvania Rule of Civil Procedure 1037(b)(1), a default judgment containing a dollar amount must be entered for the amount claimed in the complaint and any item which can be calculated from the complaint, i.e. bringing the interest current. However, new items cannot be added at the time of entry of the judgment. 757375 4. The Property is listed for Sheriffs Sale on December 4, 2013. 5. Additional sums have been incurred or expended on Defendant's behalf since the Complaint was filed and Defendant has been given credit for any payments that have been made since the judgment. The amount of damages should now read as follows: Principal Balance $101,132.76 Interest Through December 4, 2013 $22,098.72 Late Charges $219.00 Legal fees $1,550.00 Cost of Suit and Title $2,106.31 Property Inspections $490.00 Appraisal/Brokers Price Opinion $340.00 Mortgage Insurance Premium/Private Mortgage Insurance $4,430.40 Mortgage Insurance Premium to be paid $553.80 Escrow Deficit $5,581.88 TOTAL $138,502.87 6. The judgment formerly entered is insufficient to satisfy the amounts due on the Mortgage. 7. Under the terms of the Mortgage and Pennsylvania law, Plaintiff is entitled to inclusion of the figures set forth above in the amount of judgment against the Defendant. 8. Plaintiffs foreclosure judgment is in rem only and does not include personal liability, as addressed in Plaintiffs attached brief. 9. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on September 17, 2013 and requested the Defendant's Concurrence. Plaintiff did not receive any response from the Defendant. A true and correct copy of Plaintiffs letter pursuant to Local Rule 208.3(9) and certification of mailing are attached hereto, made part hereof, and marked as Exhibit"B". 10. In compliance with Cumberland County Local Rule 209.3(a)(2), Plaintiff avers that Judge Albert H. Masland entered an order for Special Service dated August 8,2012 . 757375 • WHEREFORE, Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. Phelan Hallinan,LLP DATE: 0'6/-3 By: en. an M. Etkowicz, Esquire TORNEY FOR PLAINTIFF 757375 Phelan Hallinan, LLP Jonathan M. Etkowicz, Esq., Id. No.208786 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonathan.etkowicz@phelanhallinan.com 215-563-7000 JP MORGAN CHASE BANK,NATIONAL • Court of Common Pleas ASSOCIATION S/B/M CHASE HOME • FINANCE, LLC S/B/M TO CHASE • Civil Division MANHATTAN MORTGAGE CORPORATION Plaintiff : CUMBERLAND County v. • No.: 12-3583-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendant MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF'S MOTION TO REASSESS DAMAGES I. BACKGROUND OF CASE VIRGINIA A. EIDENSCHINK, DECEASED executed a Promissory Note agreeing to pay principal, interest, late charges, real estate taxes, hazard insurance premiums, and mortgage insurance premiums as these sums became due. Plaintiffs Note was secured by a Mortgage on the Property located at 8 CAMPBELL PLACE, CAMP HILL, PA 17011-2530. The Mortgage indicates that in the event of a default in the mortgage, Plaintiff may advance any necessary sums, including taxes, insurance, and other items, in order to protect the security of the Mortgage. 757375 In the instant case, Defendant defaulted under the Mortgage by failing to tender numerous, promised monthly mortgage payments. Accordingly, after it was clear that the default would not be cured, Plaintiff commenced the instant mortgage foreclosure action. Judgment was subsequently entered by the Court, and the Property is currently scheduled for Sheriffs Sale. Because of the excessive period of time between the initiation of the mortgage foreclosure action, the entry of judgment and the Sheriffs Sale date, damages as previously assessed are outdated and need to be adjusted to include current interest, real estate taxes, insurance premiums, costs of collection, and other expenses which Plaintiff has been obligated to pay under the Mortgage in order to protect its interests. It is also appropriate to give Defendant credit for monthly payments tendered through bankruptcy, if any. II. LEGAL ARGUMENT TO AMEND PLAINTIFF'S IN REM JUDGMENT It is settled law in Pennsylvania that the Court may exercise its equitable powers to control the enforcement of a judgment and to grant any relief until that judgment is satisfied. 20 P.L.E., Judgments § 191. Stephenson v. Butts, 187 Pa.Super. 55, 59, 142 A.2d 319, 321 (1958). Chase Home Mortgage Corporation of the Southwest v. Good, 537 A.2d 22, 24 (Pa.Super. 1988). The Pennsylvania Superior Court has repeatedly cited the right of a foreclosing creditor to amend its judgment prior to the Sheriffs sale. Nationsbanc Mortgage Corp. v. Grillo, 827 A.2d 489 (Pa.Super. 2003). Morgan Guaranty Trust Co. of N.Y. v. Mowl, 705 A.2d 923 (Pa. Super. 1998). Union National Bank of Pittsburgh v. Ciongoli, 407 Pa.Super. 171, 595 A.2d 179 (1991). The Supreme Court of Pennsylvania recognized in Landau v. Western Pa.Nat. Bank,445 Pa. 117, 282 A.2d 335 (1971),that the debt owed on a Mortgage is subject to change and, in fact, can be expected to change from day to day because the bank must advance sums in order to protect 757375 its collateral. Because a Mortgage lien is not extinguished until the debt is paid, Plaintiff must protect its collateral up until the date of sale. Beckman v. Altoona Trust Co., 332 Pa. 545, 2 A.2d 826 (1939). Because a judgment in mortgage foreclosure is strictly in rem, it is critical that the judgment reflect those amounts expended by the Plaintiff in protecting the property. Meco Reality Company v. Burns, 414 Pa. 495, 200 A.2d 335 (1971). Plaintiff submits that if it goes to sale without the requested amended judgment, and if there is competitive bidding for the Property, Plaintiff will suffer a significant loss in that it would not be able to recoup monies it advanced to protect its interests. Conversely, amending the in rem judgment will not be detrimental to Defendant as it imputes no personal liability. In B.C.Y. v. Bukovich, the Pennsylvania Superior Court reiterated its long standing rule that a Court has the inherent power to correct a judgment to conform to the facts of a case. 257 Pa. Super. 157, 390 A.2d 276 (1978). In the within case,the amount of the original judgment does not adequately reflect the additional sums due on the Mortgage due to Defendant's failure to tender payments during the foreclosure proceeding and the advances made by the mortgage company. The Mortgage plainly requires the mortgagor to tender to the mortgagee monthly payments of principal and interest until the Promissory Note accompanying the Mortgage is paid in full. The mortgagor is also required to remit to the mortgagee sufficient sums to pay monthly mortgage insurance premiums, fire insurance premiums,taxes and other assessments relating to the Property. The mortgagor has breached the terms of the Mortgage, and Plaintiff has been forced to incur significant unjust financial losses on this loan. 757375 III. THE FORECLOSURE JUDGMENT IS IN REM ONLY The within case is a mortgage foreclosure action,the sole purpose of which is to take the mortgaged property to Sheriffs Sale. Pennsylvania law makes clear that an action in mortgage foreclosure is strictly in rem and does not include any personal liability. Newtown Village Partnership v. Kimmel, 424 Pa. Super 53, 55, 621 A.2d 1036, 1037 (1993). Signal Consumer Discount Company v. Babuscio, 257 Pa. Super 101, 109, 390 A.2d 266,270 (1978). Pennsylvania Rule of Civil Procedure 1141(a). However, Pennsylvania law requires that the foreclosure action demand judgment for the amount due. Pa.R.C.P. 1147(6). The purpose of the dollar amount in the in rem judgment is for bidding at the Sheriffs Sale. In the event that a third party real estate speculator were to bid on the mortgaged property at the Sheriffs Sale and become the successful purchaser, Plaintiff would receive the amount of the in rem judgment from the Sheriff IV. INTEREST The Mortgage clearly requires that the Defendant shall promptly pay when due the principal and interest due on the outstanding debt. In addition,the Note specifies the rate of interest to be charged until the debt is paid in full or otherwise satisfied. Specifically, interest from 30 days prior to the date of default through the date of the impending Sheriffs sale has been requested. V. TAXES AND INSURANCE If Plaintiff had not advanced monies for taxes and insurance throughout the foreclosure proceeding, Plaintiff would have risked loss of its collateral. If the Property were sold at a tax sale, Plaintiffs interest very well may be divested, and Plaintiff would sustain a complete loss on the 757375 outstanding balance due on the loan. If the Property were damaged in a fire, Plaintiff would not be able to obtain insurance proceeds to restore the Property if it did not pay the insurance premiums. Most importantly,the Mortgage specifically provides that the mortgagee may advance the monies for taxes and insurance and charge these payments against the escrow account. Plaintiff is simply seeking to have the Court enforce the terms of the Mortgage. VI. ATTORNEY'S FEES The Plaintiffs foreclosure fees are very modest. They cover all of the legal work done throughout the course of the foreclosure action to date, including reviewing the Act 6 or Act 91 letters, loan documents, account records, title reports and supporting documents, preparing and reviewing the mortgage foreclosure complaint, filing and service of the complaint, Rule 237.1 Notice, Department of Defense search, entry of judgment, the writ of execution process, lien holder notices, and all of the other legal work that goes into handling the mortgage foreclosure lawsuit. The Mortgage specifically provides for Plaintiffs recovery of its attorney fees. The amount of attorney's fees requested in the Motion to Reassess Damages is in accordance with the loan documents and Pennsylvania law. Pennsylvania Courts have long and repeatedly concluded that a request of five percent of the outstanding principal balance is reasonable and enforceable as an attorney's fee. Robinson v. Loomis, 51 Pa. 78 (1865); First Federal Savings and Loan Association v. Street Road Shopping Center, 68 D&C 2d 751, 755 (1974). In Federal Land Bank of Baltimore v. Fetner,the Superior Court held that an attorney's fee of ten percent of the original mortgage amount is not unconscionable. 410 A.2d 344 (Pa. Super. 1979). The Superior Court cited Fetner in confirming that an attorney's fee of ten percent included 757375 in the judgment in mortgage foreclosure action was reasonable. Citicorp v. Morrisville Hampton Realty, 662 A.2d 1120 (Pa. Super. 1995). Plaintiffs legal fees are not a percentage but are significantly less than what is permitted by Pennsylvania law. VII. COST OF SUIT AND TITLE Pursuant to the terms of the mortgage, Plaintiff is entitled to recover all expenses incurred in the foreclosure action. The amount claimed for the costs of suit and title are the expenses Plaintiff paid to date as a result of the mortgage default. The title report is necessary to determine the record owners of the property, as Pa.R.C.P. 1144 requires all record owners to be named as Defendants in the foreclosure action. It is also necessary to determine whether there are any prior liens to be cleared, so that the Sheriffs sale purchaser acquires clear title to the property. It is necessary to determine if there are IRS liens on the property, whether the Defendants are divorced (which could affect service of the complaint), and numerous other legal issues. The title bringdown is necessary to identify any new liens on the property or new owners between the time of filing and complaint and the writ date. The Freedom of Information Act inquiries and the investigation into Defendants' whereabouts are necessary to effectively attempt personal service of the complaint and notice of sale on the Defendant. The notice of sale and Rule 3129 notice are required by Pa.R.C.P.3129.1 and 3129.2 to notify all lienholders, owners, and interested persons of the Sheriffs sale date, as their interests will be divested by the Sheriff's sale. Accordingly, the modest sums Plaintiff has incurred for the costs of suit and title were necessary pursuant to Pennsylvania law. The amounts were reasonable and actually incurred. 757375 The mortgage and Pennsylvania law permit Plaintiff to recover these sums through its foreclosure action. As the foreclosure action is in rem only, Plaintiff recovers its judgment from the sale of the property, not out of the Defendant's pockets. Plaintiff should recover the costs of suit and title in their entirety, which will not cause harm to the Defendants. VIII. PROPERTY INSPECTIONS AND PRESERVATION The terms of the mortgage provide for property inspections and property preservation charges. The lender or its agent may make reasonable inspections of the property pursuant to the terms of the mortgage. When a borrower defaults under the terms of the mortgage, the lender may do, or pay for, whatever is reasonable to protect its interest in the collateral, including property maintenance. Any amounts disbursed by the lender for property inspections and preservation become additional debt of the borrower secured by the mortgage. The lender may charge the borrower for services performed in connection with the default, for the purpose of protecting the lender's interest in the property, including property inspections and valuation costs. When a loan is in default,the lender's risk increases. Mortgage companies typically have a vendor visit the premises to determine if any windows need to be boarded up, if the property is vacant, if the grass needs to be cut, or the snow shoveled. If the property inspection reveals any problems at the mortgaged premises, then the mortgage company may proceed to take whatever steps are necessary to secure the collateral, such as boarding windows, winterizing, removing hazards or debris, etc. The mortgage company generally pays a vendor to handle these tasks, which are referred to in the industry as "property preservation". These services avoid code 757375 violations and avoid the property becoming an eyesore in the neighborhood. Property preservation helps maintain property values in the neighborhood. Accordingly, line items included in Motions to Reassess Damages for property inspections and property preservation represent amounts which the mortgage company has paid out of its pocket to preserve its collateral, consistent with the terms of the mortgage contract. Since the terms of the mortgage provide that such expenses by the mortgage company become part of the borrower's debt secured by the mortgage, those expenses are properly included in the Plaintiff's Motion to Reassess Damages. IX. CONCLUSION Therefore, Plaintiff respectfully submits that if the enforcement of its rights is delayed by legal proceedings, and such delays require the mortgagee to expend additional sums provided for by the Mortgage,then the expenses necessarily become part of the mortgagee's lien and should be included in the judgment. Plaintiff respectfully requests that this Honorable Court grant its Motion to Reassess Damages. Plaintiff submits that it has acted in good faith in maintaining the Property in accordance with the Mortgage, and has relied on terms of the Mortgage with the understanding that it would recover the monies it expended to protect its collateral. 757375 WHEREFORE,Plaintiff respectfully requests that this Honorable Court amend the judgment as requested. Phelan Hallinan, LLP DATE: L j �..3 By: &or on. an M. Etkowicz,Esquire orney for Plaintiff 757375 Exhibit "A" 757375 PHELAN HALLINAN, LLP Attorney for Plaintiff Adam H. Davis,Esq.,Id. No.203034 1617 JFK Boulevard,Suite 1400 _� __ — — -- - --- One Penn CenterPlaza — Philadelphia,PA 19103 . 215-563-7000 JP MORGAN CHASE BANK,NATIONAL : CUMBERLAND COUNTY ASSOCIATION S/B/M CHASE HOME : FINANCE,LLC S/B/M TO CHASE : COURT OF COMMON PLEAS MANHATTAN MORTGAGE . CORPORATION CIVIL DIVISION • n "1 . vs. : No.12-3583-CIVIL -,33 =.,,t . rt03 mr. UNKNOWN HEIRS,SUCCESSORS, 20 �© ASSIGNS,AND ALL PERSONS,FIRMS,OR •yt7a/ney Ny c- -.4c, ASSOCIATIONS CLAIMING RIGHT, P10.— 'ARV , s-*1 ''crIsp ' , TITLE OR INTEREST FROM OR UNDER - �[ xn VIRGINIA A.EIDENSCHINK,DECEASED r i'Z ern PRAECIPE FOR IN REM JUDGMENT FOR FAILURE TO 0 .t ANSWER AND ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly enter judgment in favor of the Plaintiff and against UNKNOWN HEIRS, SUCCESSORS.ASSIGNS.AND ALL PERSONS.FIRMS.OR ASSOCIATIONS CLAIMING RIGHT.TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED,Defendant(s)for failure to file an Answer to Plaintiffs Complaint within 20 days from service thereof and for foreclosure and sale of the mortgaged premises, and assess Plaintiff's damages as follows: As set forth in Complaint $115,447.32 TOTAL $115,447.32 I hereby certify th1AI 's last known address is 8 CAMPBELL PLACE, CAMP HILL,PA 17011-251fteeelila notice has been given in accordance with Rule Pa.R.C.P 237.1. //T/ /3 �2- r Date 0 �• _� . Adam t. .�,' I. No.203034 Attorney for'lain. • DAMAGES A E REBY ASSESSED AS INDICATED. / / DATE: i ? / _ / 1#HO • A._ 263542 Exhibit "B" 757375 PHELAN HALLINAN, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallman, LLP Representing Lenders in Pennsylvania September 17,2013 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 RE: JP MORGAN CHASE BANK,NATIONAL ASSOCIATION S/B/M CHASE HOME FINANCE,LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION v. UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED Premises Address: 8 CAMPBELL PLACE CAMP HILL,PA 17011 CUMBERLAND County CCP,No. 12-3583-CIVIL Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9),I am seeking your concurrence with the requested relief that is,increasing the amount of the judgment. Please respond to me within 5 days, by 9/23/2013. Should you have further questions or concerns,please do not hesitate to contact me. Otherwise,please be guided accordingly. V- trul yours, Jo than M. Etkowicz,Esq.,Id.No.208786 Attorney for Plaintiff Enclosure 757375 h O d Name and Phelan Natlinan.LLP ''cr �; ' Address 1111110i 1617 WE Bouleonrd,Suite 14041 -` — > N, Of Sender One Penn Center Plana. Philadelphia,PA 19103 KVM .{{yyam 1 Line Article Number Name of Addressee,Street,and Post Wice.Address -;'Poste e> \ {g` (( e� 1 **** • •UNKNOWN HETRS,.SUC ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS '$0.46 .4�, tl Ili a CLAIMING RIGHT,TITLE OR EREST FROM OR UNDER VIRGINIA A.EIDENSCRINK, " - . DECEASED "°° , S CAMPBELL PLACE ''Oa 1 CAMP HILL,PA,1.70I1-2530 -` r 'RE:UNKNOWNHEIRS,SU.CCESS'.1RS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS $0.46 i CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A,EIDENSCIIINK, •.DECEASED(CUMBERLAND) PH#.757375ti200: Page 1 nil ; Tad Nuaba of Teal NuebaMPieces • Pannmuiv:Iris(Name of The rue declaration of value is required m all domeR+c and iniemionital nigi0.a eQ.mail The ma: Mats Listed by Souks Receivsd at Peas Offer Raeiv,ot Ernteyeri fa due recrosouction ofmmeg iiahk doeumem Oder Smarm Mail d tsecanurvt on vi . A piecc:;ubjet b Annie of MOM per cMera ciAlie maximum iniennity payable an Eepicas - ... •• 331 eloennem indemnity ie ab o is 525.000 fee misfiled mail,wm with optimal mamma.See R900 Sot I and 5421 for hmitr8nns of coverage - Farm 3877 Facsimile 4 1 75'737. Phelan Hallinan, LLP Jonathan M. Etkowicz, Esq., Id. No.208786 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonathan.etkowicz@phelanhallinan.com 215-563-7000 JP MORGAN CHASE BANK, NATIONAL • Court of Common Pleas • ASSOCIATION S/B/M CHASE HOME FINANCE, LLC S/B/M TO CHASE • Civil Division MANHATTAN MORTGAGE CORPORATION : Plaintiff : CUMBERLAND County • v. • No.: 12-3583-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendant CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Reassess Damages, and Brief in Support thereof, were sent to the following individual on the date indicated below. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 Phelan Hallinan,LLP DATE: • 3 By: Abbe Jo ran M. Etkowicz, Esquire A ORNEY FOR PLAINTIFF 757375 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JP MORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION S/B/M CHASE HOME • FINANCE, LLC S/B/M TO CHASE • Civil Division MANHATTAN MORTGAGE CORPORATION • Plaintiff • CUMBERLAND County v. • No.: 12-3583-CIVIL • UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendant RULE AND NOW, this gv day of ,ilb6-4/ 2013, a Rule is entered upon the Defendant to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant shall have twenty (20) days from the date of this Order to file a response to Plaintiffs Motion to Reassess Damages. If no response is filed with the Court, Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. BY THE COURT /04-- J. rri c CD r'i c-> r T i 757375 onathan M. Etkowicz,Esq., Id.No.208786 Phelan Hallinan,LLP 1617 JFK Boulevard, Suite 1400 Philadelphia,PA 19103 TEL: (215)563-7000 FAX: (215)563-3459 1KNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 1 ES r 757375 U S/k3 757375 Phelan Hallman, FIT l ,l- �i I �ONCi Allison F. Zuckerman, Esq., Id. No.309519 �I'�htNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 ZC13 OCT I I Q� One Penn Center Plaza CUMBERLAND COUNTY Philadelphia. PA 19103 PENNSYLVANIA allison.zuckerman(a)phelanhattinan.com 215-563-7000 JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION S/B/M CHASE HOME FINANCE, I.LC S/B/M TO CHASE. Civil Division MANI IAT7-AN MORTGAGE CORPORATION Plaintiff CUMBERLAND County vs. No.: 12-3583-CIVIL UNKNOWN HEIRS, SUCCESSORS.. ASSIGNS, AND ALL. PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCIIINK, DECEASED Defendant CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's October 2, 2013 Rule directing the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not he granted was served upon the following individual on the date indicated below. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS. AND ALL PERSONS, FIRMS OR ASSOCIATIONS CLAIMING RIGHT'_TITLE, OR INTERFS"f FROM OR UNDER VIRGINIA A. EIDENSCIIINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 ;Phe 4Hal 5cke7m,DATE: By. . Esq, ld. No.309519 757375 13 TA PC: C5 .p 4,: EF:LAN!D COUNTY PENNSYLVANIA Phelan Hallinan, LLP Jonathan M. Etkowicz, Esq., Id. No.208786 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonathan.etkowicz@phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK, NATIONAL Court of Common Pleas ASSOCIATION S/B/M CHASE HOME • FINANCE, LLC S/B/M TO CHASE • Civil Division MANHATTAN MORTGAGE CORPORATION . Plaintiff : CUMBERLAND County vs. • No.: 12-3583-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendant MOTION TO MAKE RULE ABSOLUTE JPMORGAN CHASE BANK,NATIONAL ASSOCIATION S/B/M CHASE HOME FINANCE, LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION, by and through its attorney, hereby petitions this Honorable Court to make Rule to Show Cause absolute in the above-captioned action, and in support thereof avers as follows: 1. A Motion to Reassess Damages was filed with the Court on September 27, 2013. 757375 2. In accordance with Cumberland County Local Rule 208.3(9), Plaintiff sent a copy of its proposed Motion to Reassess Damages and Order to the Defendant on September 17, 2013 and requested the Defendant's Concurrence. Plaintiff did not receive any response from the Defendant. True and correct copies of Plaintiffs letter pursuant to Local Rule 208.3(9) and certificate of mailing are attached hereto, made part hereof, and marked as Exhibit A. 3. A Rule was issued on October 8, 2013 directing the Defendant to show cause by October 28, 2013 why the Motion to Reassess Damages should not be granted. A true and correct copy of the Rule is attached hereto, made part hereof, and marked Exhibit B. 4. The Rule to Show Cause was timely served upon all parties on in accordance with the applicable rules of civil procedure. A true and correct copy of the Certificate of Service is attached hereto, made part hereof, and marked Exhibit C. 5. Defendant failed to respond or otherwise plead by the Rule Returnable date of October 28, 2013. WHEREFORE, Plaintiff requests that this Honorable Court make the Rule to Show Cause absolute and grant Plaintiffs Motion to Reassess Damages. PheL .11' -. , L I DATE: 1,1 1145 By: Aiss Ala GINIL Jo ath. M. tkowicz,Esq., Id.No.208786 Att■ r. -y for Plaintiff 757375 Exhibit "A" 757375 . o n Name and Phelan Hal lino,LLP Address 1617)Ft:Boulevard,Suite 1400 i III :.. Of Sender One Penn Center Plaza ill p a ��. ^,' Phi delphia PA 1 9103 K V M �� '�� b i1: Line Article Number Name of Addressees Street,and Post()Met Address Posi' �- " 1 ,•*,, UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALLPERSONS,FIRMS,OR ASSOCIATIONS 50.46 A, i o CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER'VIRGINIA A.EIDENSCHINK„ � mth ». DECEASED A\\ . '. , rn ,. 9.,,,`,6 S CAMPBELL PLACE D Np0 CAMP HILL,PA 17011-2-530 RE:UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS 50A6 �t�1 ^ .. 7:,' CLAIMING RIGHT,TITLE OR IN"'EREST FROM OR UNDER VIRGINIA A.EIDENSCH INK, ' ' DECEASED(CUMBERLAND) PH#75737511200 Page I of I 4;,., d %ti k ,: ', Tml N Cr of Tow N.mta of Noon P.e..art,Po(Nine of Thc RO14ec4taafen er raWe as Fega red oo an demeease lost kprermom*rnristaad man.'Thera .Y•,'. Plats Lund by Scrdu Recerwd a[Pot Ms Remrvimm Emplo,al for tilt noombruOlw of rot ejeda6{e documents mu*Esrrest NW Amami ttCaaY»ttwr m pao babied ao a Smtot15O0,0DYperoavcrmce.TMeeaimfm ioderenitgpayabie on Erprrn ;:: The muiuwn m�i.r.ty P•*At ks1:3,090 Fro roa6+ecd md,sow.ii6 oRtgeN loos rrsecc Soc iR R900391}cod Sfl I forhrematkr,of.„veye., Form 3877 Facsimile "s" i,,t': `r" "'' 75737. ' PHELAN HALLINAN, LLP 1617 John F. Kennedy Boulevard Suite 1400 Philadelphia, PA 19103 (215) 563-7000 FAX#: (215) 563-3459 Phelan Hallinan,LLP Representing Lenders in Pennsylvania September 17,2013 UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL,PA 17011-2530 RE: JP MORGAN CHASE BANK,NATIONAL ASSOCIATION SB/M CHASE HOME FINANCE,LLC S/B/M TO CHASE MANHATTAN MORTGAGE CORPORATION v. UNKNOWN HEIRS, SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED Premises Address: 8 CAMPBELL PLACE CAMP HILL,PA 17011 CUMBERLAND County CCP,No. 12-3583-CIVIL Dear Defendant, Enclosed please find a true and correct copy of my proposed Motion to Reassess Damages and Order. In accordance with Cumberland County Local Rule 208.3(9), I am seeking your concurrence with the requested relief that is,increasing the amount of the judgment. Please respond to me within 5 days,by 9/23/2013. Should you have further questions or concerns,please do not hesitate to contact me. Otherwise,please be guided accordingly. V-- trul yours, Jo .than.M. Etkowicz,Esq.,Id.No.208786 Attorney for Plaintiff Enclosure 757375 Exhibit "B" 757375 lk IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA JP MORGAN CHASE BANK,NATIONAL • Court of Common Pleas ASSOCIATION S/B/M CHASE HOME .• FINANCE, LLC S/B/M TO CHASE Civil Division MANHATTAN MORTGAGE CORPORATION • Plaintiff • CUMBERLAND County v. • No.: 12-3583-CIVIL UNKNOWN HEIRS, SUCCESSORS,ASSIGNS, AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendant RULE AND NOW,this l V day of G 4b6.4f 2013, a Rule is entered upon the Defendant • to show cause why an Order should not be entered granting Plaintiff's Motion to Reassess Damages. Defendant shall have twenty (20) days from the date of this Order to file a response to Plaintiff's Motion to Reassess Damages. If no response is filed with the Court,Plaintiff may file a Motion to Make Rule Absolute and no hearing will be scheduled on this matter. 0/4.. BY THE COURT / J. -v r'1 C-, rrl_._ ;'7 --1 -,_L., DC +. Y ,r' Cpl ' - -t a 757375 • onathan M.Etkowicz,Esq.,Id.No.208786 Phelan Hallinan,LLP 1617 JFK Boulevard, Suite 1400 Philadelphia,PA 19103 TEL: (215)563-7000 FAX: (215)563-3459 OWN HEIRS, SUCCESSORS, ASSIGNS,AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL,PA 17011-2530 COTO 757375 kio 757375 • Exhibit "C" riLEO-CE iUL. Phelan Hallinan, LLP OF THE RROTHONOTA Allison F. Zuckerman, Esq., Id. No.309519 2013 iCTIll' :Y'fR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza CUMBERLAND COUNT` Philadelphia, PA 19103 PENNSYLVANIA allison.zuckerman@phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION S/B/M CHASE HOME FINANCE, LLC S/B/M TO CHASE Civil Division MANHATTAN MORTGAGE CORPORATION Plaintiff CUMBERLAND County vs. No.: 12-3583-CIVIL UNKNOWN HEIRS, SUCCESSORS,ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED �,�turi1 Defendant CERTIFICATION OF SERVICE I hereby certify that a true and correct copy of the Court's Octi r ? : "e. ° le directing the Defendant to show cause as to why Plaintiffs Motion to Reassess Damages should not be granted was served upon the following individual on the date indicated below. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS,FIRMS, OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK,DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 Phelan I"1a11i+an/1 1"' DATE: ll �s Bey: 4 Allisim I uekcr , Esq., Id.No.309519 torn 9 16r Plaintiff 757375 Phelan Hallinan, LLP Jonathan M. Etkowicz, Esq., Id. No.208786 ATTORNEY FOR PLAINTIFF 1617 JFK Boulevard, Suite 1400 One Penn Center Plaza Philadelphia, PA 19103 jonathan.etkowicz@phelanhallinan.com 215-563-7000 JPMORGAN CHASE BANK,NATIONAL • Court of Common Pleas ASSOCIATION SB/M CHASE HOME • FINANCE, LLC S/B/M TO CHASE • Civil Division MANHATTAN MORTGAGE CORPORATION • Plaintiff • CUMBERLAND County vs. • • No.: 12-3583-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendant CERTIFICATION OF SERVICE I hereby certify that true and correct copies of Plaintiffs Motion to Make Rule Absolute was served upon the following individual on the date indicated below. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED 8 CAMPBELL PLACE CAMP HILL, PA 17011-2530 1 Ph; an Halli �' DATE: i\ I Ii 1/ 13 By: _ � . Jo athan . Et swicz,Esq., Id.No.208786 A I orne or Plaintiff 757375 r!L.ED-Ur-F1i•C. '0 r THE PROT�0''0 ?r; 2913 NOY 15 FM 2: 27 CUMBERLAND COUN'i`I; PENNSYLVANIA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL Court of Common Pleas ASSOCIATION S/B/M CHASE HOME FINANCE, LLC S/B/M TO CHASE Civil Division MANHATTAN MORTGAGE CORPORATION Plaintiff CUMBERLAND County VS. No.: 12-3583-CIVIL UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED Defendant ORDER AND NOW, this Ir' day of /lhrvr-- , 2013, upon consideration of Plaintiff's Motion to Make Rule Absolute, it is hereby ORDERED and DECREED,that the Rule entered upon Defendant shall be and is hereby made absolute and Plaintiff's Motion to Reassess Damages in the above captained matter is hereby GRANTED. The Prothonotary is ORDERED to amend the judgment and the Sheriff is ORDERED to amend the writ nunc pro tunc as follows: Principal Balance $101,132.76 Interest Through December 4, 2013 $22,098.72 Late Charges $219.00 Legal fees $1,550.00 Cost of Suit and Title $2,106.31 757375 r Property Inspections $490.00 Appraisal/Brokers Price Opinion $340.00 Mortgage Insurance Premium/Private Mortgage Insurance $4,430.40 Mortgage Insurance Premium to be paid prior to December $553.80 4, 2013 Escrow Deficit $5,581.88 TOTAL $138,502.87 Plus interest at six percent per annum. Note: The above figure is not a payoff quote. Sheriffs commission is not included in the above figure. BY T TTU COURT: J. co « Pat A F-4kaca,&?, be-- . //3 1 757375 ED-OFFICE r 01 C HHO O I AC'c,. • • PHELAN HALLINAN,LLP `"i 'ti Atttorney for Plaintiff . • Adam H.Davis,Esq.,Id.No.203034 CUMBERLAND COUNTY 1617 JFKBoulevard, Suite.1400 PENNSYLVANIA ' One Penn Center Plaza • • •• Philadelphia,PA 19103 • • • • Adam.Davis @PhelanHallinan.com • 215-563-7000 • IN THE COURT OF COMMON PLEAS • OF CUMBERLAND COUNTY,PENNSYLVANIA • . JPMORGAN CHASE BANK,NATIONAL CUMBERLAND COUNTY ASSOCIATION SB/M CHASE HOME FINANCE, . LLC SB/M TO CHASE MANHATTAN COURT OF COMMON PLEAS MORTGAGE CORPORATION Plaintiff, CIVIL DIVISION v. No.: 12-3583-CIVIL UNKNOWN HEIRS,SUCCESSORS,ASSIGNS, AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK, DECEASED Defendant(s) AFFIDAVIT OF SERVICE PURSUANT TO RULE 3129.2 COMMONWEALTH OF PENNSYLVANIA ) PHILADELPHIA COUNTY ) SS: As required by Pa. R.C.P. 3129.2(a)Notice of Sale has been given to Lienholders and any known interested party in the manner required by Pa. R.C.P. 3129.2(c)on each of the persons or parties named,at that address,set forth on the Affidavit and as amended if applicable.A copy of the Certificate of Mailing(Form 3817)and/or Certified Mail Return Receipt stamped by the U.S.Postal Service is attached hereto Exhibit"A". -rAX/L__ Adam H.Davis,Esq.,Id.No.203034 Date: l V �///'` r y Attorney for Plaintiff IMPORTANT NOTICE: This property is sold at the direction of the plaintiff. It may not be sold in the absence of a representative of the plaintiff at the Sheriff's Sale. The sale must be postponed or stayed in the event that a representative of the plaintiff is not present at the sale. PH#757375 JPMORGAN CHASE BANK,NATIONAL • COURT OF COMMON PLEAS ASSOCIATION SB/M CHASE HOME FINANCE,LLC SB/M TO CHASE MANHATTAN MORTGAGE CIVIL DIVISION • CORPORATION Plaintiff. • • NO:: 12-3583-CIVIL • • • V. • •• CUMBERLAND COUNTY • • UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,AND ALL PERSONS,FIRMS,OR ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR • • • UNDER VIRGINIA A. EIDENSCHINK,DECEASED Defendarit(s) • • • AMENDED AFFIDAVIT PURSUANT TO RULE 3129.1 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION S/B/M CHASE HOME FINANCE,LLC SB/M TO CHASE MANHATTAN MORTGAGE CORPORATION,Plaintiff in the above action,by the undersigned attorney,sets forth as of the date the Praecipe for the Writ of Execution was filed,the following information concerning the real property located at 8 CAMPBELL PLACE, CAMP HILL,PA 17011-2530. 1. Name and address of Owner(s)or reputed Owner(s): Name Address(if address cannot be reasonably ascertained, please so indicate) UNKNOWN HEIRS,SUCCESSORS,ASSIGNS, 8 CAMPBELL PLACE AND ALL PERSONS,FIRMS,OR CAMP HILL,PA 17011-2530 ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED 2. Name and address of Defendant(s)in the judgment: Name Address(if address cannot be reasonably ascertained,please so indicate) UNKNOWN HEIRS,SUCCESSORS,ASSIGNS, 8 CAMPBELL PLACE AND ALL PERSONS,FIRMS,OR CAMP HILL,PA 17011-2530 ASSOCIATIONS CLAIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK,DECEASED 3. Name and last known address of every judgment creditor whose judgment is a record lien on the real property to be sold: Name Address(if address cannot be reasonably ascertained,please indicate) CUMBERLAND COUNTY ADULT 1 COURTHOUSE SQUARE PROBATION CARLISLE,PA 17013-3387 4. Name and address of last recorded holder of every mortgage of record: Name Address(if address cannot be reasonably ascertained,please indicate) None. 5. Name and address of every other person who has any record lien on the property: PH#757375 • Name Address(if address cannot be reasonably ascertained,please indicate) • None. . • • 6. Name and address of every other person who has any record interest in the property and whgse interest may be affected by the • sale. . . . Name Address(if address cannot be . . reasonably ascertained,please indicate) . LONG MEADOWS TOWNEHOUSES 2104 MARKET STREET ASSOCIATION CAMP HILL,PA 17011 C/O EDMUND J.BERGER,ESQUIRE • • 'LONG MEADOWS TOWNEHOUSES 204 TALL OAK DRIVE • ASSOCIATION NEW CUMBERLAND,PA 17070-2347 C/O EDMUND J.BERGER,ESQUIRE LONG MEADOWS TOWNEHOUSES 2 RICHLAND LANE ASSOCIATION WORMLEYSBURG,PA 17043 C/O JAMES STRUPE,PRESIDENT LONG MEADOWS TOWNEHOUSES 16 CAMPBELL PLACE ASSOCIATION CAMP HILL,PA 17011 7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which may be affected by the sale: Name Address(if address cannot be reasonably ascertained,please indicate) TENANT/OCCUPANT 8 CAMPBELL PLACE CAMP HILL,PA 17011-2530 COMMONWEALTH OF PENNSYLVANIA 6TH FLOOR,STRAWBERRY SQ. BUREAU OF INDIVIDUAL TAXES DEPT 280601 INHERITANCE TAX DIVISION HARRISBURG,PA 17128 DEPARTMENT OF PUBLIC WELFARE,TPL P.O.BOX 8486 CASUALTY UNIT,ESTATE RECOVERY WILLOW OAK BUILDING PROGRAM HARRISBURG,PA 17105 DOMESTIC RELATIONS OF 13 NORTH HANOVER STREET CUMBERLAND COUNTY CARLISLE,PA 17013 COMMONWEALTH OF PENNSYLVANIA P.O.BOX 2675 DEPARTMENT OF WELFARE HARRISBURG,PA 17105 INTERNAL REVENUE SERVICE ADVISORY 1000 LIBERTY AVENUE ROOM 704 PITTSBURGH,PA 15222 U.S.DEPARTMENT OF JUSTICE 228 WALNUT STREET,SUITE 220 U.S.ATTORNEY FOR THE MIDDLE PO BOX 11754 DISTRICT OF PA HARRISBURG,PA 17108-1754 FEDERAL BUILDING JOSHUA EIDENSCHINK,IN HIS CAPACITY 8 CAMPBELL PLACE AS HEIR OF VIRGINIA A.EIDENSCHINK, CAMP HILL,PA 17011-2530 DECEASED NICHOLAS EIDENSCHINK,IN HIS 6330 ANTILLES COURT CAPACITY AS HEIR OF VIRGINIA A. MECHANICSBURG,PA 17050-5249 EIDENSCHINK,DECEASED PH#757375 • TAYLOR SHELLENBERGER,IN HER 6330 ANTILLES COURT CAPACITY AS HEIR OF VIRGINIA A. MECHANICSBURG,PA 17050-5249 • EIDENSCHINK,DECEASED • • • • CASSANDRA ECKRICH GUARDIAN FOR ' 6330 ANTILLES COURT •. • • TAYLOR SHELLENBERGER,IN HER MECHANICSBURG,PA 17050-5249 • . CAPACITY AS HEIR OF VIRGINIA A. • EIDENSCHINK,DECEASED • I verify that the statements made in this affidavit are true and correct to the best of my personal knowledge or information and belief. I understand that false'statements herein are made subject to the penalties • of 18 Pa. C.S.A. § 4904 relating to unsworn falsification to authorities.. . Date: � _ sy: Phelan Hallinan,LL Adam H.Davis,Esq.,Id.No.203034 Attorney for Plaintiff PHELAN HALLINAN,LLP 1617 JFK Boulevard,Suite 1400 One Penn Center Plaza,Philadelphia,PA 19103 215-563-7000 • PH#757375 1111111011■111 _ 4E-- a K N sa . E.x- LA • taa rt fa. 40 ••••1 .-4 ..4 V 'A u% "21 " * * * CD Itt) * * I C* * g . er CD ■-• (0 PI I I:71 ri ,/ A I-' re) .- nottor) 2 , * .0 z n it i t;s1 °jt": ri. 0: 0 6:-: 11 1 i ii;,' '/' 0 .0.1; iver % g04. ;:1P^ E. .... goor, tv ›.. 51. (=3 2v2,..r Ritiq ga Ti 4 4,. t,.., ..c,;, ..,, ,. F.. 0 > 0 a P - S 71 d 0 8 :.; id ?ii C a. t4 x ko o I a' 4, A I . eil q tml 0 et, vil .3 Cl) 0 > V > CA gu toi (0) el t21 .3 ct, . •■••1 04 A.S 1.0 2 1.1 I z, o< 2 it 4 sA a. o 0 $ 2 , m . co r © g a 1 • 9...61 - 5g " 71' a' •iT i l q .".48 '°. 'e P — 1:1 T = 2-6. m 0 m xi (-) S R a . CI 4 5- Cl) 0 Cl) tIl 5'r2s a 3 . . ...z.l.i H. : . . in in `,"^"Tokit,',,,:: ,in ■-xl . . . . . • c. I NO' 0 • • . ' . • 1 g I Li CA :D.' '•,t1---*'''''N\sl* et th ,... ,..,:vo • 4144. , .. • - • . . . V , ;..:ii rwri 3... • S . • ' •.. 4,,,,... I . • . • • -. •. • . • • . • • qi•. • • X • b. • . Tn.t.4".:.,;,7„....r&C 1.4 L74'. '.1.- >)PITNYBOWEs •.:.14.411: 7.3 4 k....." -.-94,.-,________.. . . . Irmez,..41==7 • -• I rOiri-}0`. 41P "1163'$ 002 580 • • • • • . tv57-4,--GC5, 8001381181140V 04 1 . . , . . • .. . . . . . - . - • .. . . • . • • • :and Phelan Hallolan,LLP ass 111110 1617 JFK Boulevard,Suite 1400 leder One Penn Center Plana • Philadelphia,PA 19103 AZICJSCS-12/04/2013 SALE . Article Number Name of Addtessee,Street,and Post Office Address. . Postage _ 1 Fee **** TENANT/OCCUPANT $0.45 8 CAMPBELL PLACE c r..) • • CAMP HILL,PA 17011-2530 • to 0 • *** *'COMMONWEALTH OF PENNSYLVANIA BUREAU OF INDIVIDUAL TAXES INHERITANCE TAX DIVISION • $0.45 N N 6TH FLOOR,STRAWBERRY SQ.,DEPT 210601 SI o HARRISBURG,PA 17128 vv�II**** DEPARTMENT OF PUBLIC WELFARE,TPL CASUALTY UNIT,ESTATE RECOVERY PROGRAM $0.45 ,1 t ' P.O.BOX 8486,WILLOW OAK BUILDING ,a• • HARRISBURG,PA 17105 "' **** LONG MEADOWS TOWNEHOUSES ASSOCIATION CIO EDMUND J.BERGER,ESQUIRE • $0.45 {�{ m t 2104 MARKET STREET �C CAMP HILL,PA17011 to ti cto - ****• t.ONG MEADOWS TOWNEHOUSES ASSOCIATION CIO EDMUND J.BERGER ESQUIRE $0.45 ,.aoo • 204 TALL OAK DRIVE ' NEW CUMBERLAND,PA 17070.2347 Sl vtc' •1.� - � ' **** LONG'MEADOWS TOWNEHOUSES•ASSOCIATION CIO JAMES STRUPE,PRESIDENT I' • $0.45 �x).'t /".14e3 2 RICHLAND LANE .. 7r # WORM LEYSBURG,PA 17043 - **** JOSHUA EIDENSCHINK,IN HIS CAPACITY AS HEIR OF VIRGINIA A.EIDENSCHINK,DECEASED( $0.45 • 8 CAMPBELL PLACE ,/�?•„� CAMP HILL,PA 17011-2530 / 1 **** NICHOLAS EIDENSCHINK,IN HIS CAPACITY AS HEIR OF VIRGINIA A.EIDENSCHINK,DECEASED ( .45 6330 ANTILLES COURT MECHANICSBURG,PA 17050-5249 .a **** TAYLOR SHELLENBERGER,IN HER CAPACITY AS HEIR OF VIRGINIA A.EIDENSCHINK,DECEASED }f 45� f 6330 ANTILLES COURT l' !1'. t«a'�"� MECHANICSBURG,PA 17050-5249 f)V• **** DOMESTIC RELATIONS OF,CUMBERLAND COUNTY $0.45 13 NORTH HANOVER STREET s CARLISLE,PA 17013 ***'* COMMONWEALTH OF PENNSYLVANIA,DEPARTMENT OF WELFARE $0.45 P.O.BOX 2675 HARRISBURG.PA 17105 RE:UNKNOWN HEIRS,SUCCESSORS,ASSIGNS;AND ALL PERSONS,FIRMS,OR ASSOCIATIONS (AIMING RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDENSCHINK., ' --. ./ DECEASED(CUMBERLAND) PBS#263542/1021 Page 1 of 2 Writ Team Somber of Total Number of Pima Postmaster.Pet(Name of -The full declaration of value is required on all donemk and irsemationel registered nail.The maximum indemnity payabk Listed by Sender Received at Post Office Receiving rmptoyee) for the*construction ofnoraegolioble documents under Express Mail document*construction lmvran-e is S50.002 per ploeo subject to a limn of 5500.000 per ocetirteure,The maximum indemnity pe obk on E xis reaO Mat merchandise is 5500. The maximum indemnity payabk is 521,000 for registered mail.arm with optional insurance.See Domestic Mail Manual - R900 5913 and S921 for limitations otrovsnge. . in 3877 Facsimile t r e and Phelan Hallinan,LLP 1 fens 111110, 1617 JFK Boulevard,Suite 1400 ender One Penn Center Plaza Philadelphia,PA 19103 AZKJSCS-12/04/2013 SALE • Article Number Name of Addresse Street and Post Office Address Posta_e I Pee. 1 w*** '. INTERNAL REVENUE SERVICE ADVISORY • . 50.45 • • • 1000 LIBERTY AVENUE ROOM 704 �' ° PITTSBURGH.PA 15222 p1 F. **" U.S.DEPARTMENT OF JUSTICE $0,45 ` c•• • U.S.ATTORNEY FOR THE MIDDLE DISTRICT OF PA p FEDERAL BUILDING C 228 WALNUT STREET,SUITE 220,PO BOX 11754 •• • . 'HARRISBURG,PA 17105-1954 . . \4 o• wwww ur -,,,,,fro, o m ° gl o 0 w:a* • *www ;7�t, �r�.' a��4�! wwww ,'..• '4r R1rR* y RE..i UNKNOWN HEIRS,SUCCESSORS,ASSIGNS,ANTALL PERSONS,FIRMS,OR ASSOCIATIONS-- -- SD �, C C AIMI$ RIGHT,TITLE OR INTEREST FROM OR UNDER VIRGINIA A.EIDEN5CI JX, ca a' DECEASED(CUMBERLAND) PHS#263542/1021 Page 2 of 2 Writ Team [ , 1`; lumber of Total Number of Pieces Pmnmsur,Per(Nam*of The futi deetuet,nnof vituc is required on all domotic and intemuionat reps it mx7t�tepaiesvkmn ty payabk Listed by Sender Received at Pau Office Receiving Employee) for the reeomtncchaa of noancgotisbk documents under Express Mail loco nnoi rem, ,ten meWa(n $S50.000 Pe+ piece subject m a limit ofSSOO,000 per oceurrerce,'TM oganmum indemnity payabk on Espies;Mail merchandise is SS00. The maximum Indemnity payable is S2S.000 for registered mail,sent with optional intumnce.Sec Domestic Mail Manual 0900 5913 and 5921 for limitations of coverage. in 3877 Facsimile Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFFICE OF TkE SkERIFF F/LrD'CiT/CI7 Tl / T1 ',IT: 0 MONO .,.`/ / MAR 27 pN 2/5 JP Morgan Chase Bank National Association va. Virgina A Eidenschink Deceased Unknown Heirs q Case Number 2012-3583 SHERIFF'S RETURN OF SERVICE 09/27/2013 05:34 PM - Deputy Stephen Bender, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 8 Campbell Place, Wormleysburg Borough, Camp Hill, PA 17011, Cumberland County. 10/04/2013 08:13 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, by making known its contents and at the same time personaily handing a true copy to a person representing themselves to be Josh Eidonshink, son, Heir, who accepted as "Adult Person in Charge" for Virgina A Eidenschink Deceased Unknown Heirs at 8 Campbell Place, Wormleysburg Borough, Camp Hill, PA 17011, Cumberland County. 12/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that after due and legal notice had been given according to law, he exposed the within described premises at public venue or outcry at the Cumberland County Courthouse, Carlisle, Cumberland County, Penns \ i on December 04, 2013 at 10:00 AM. He sold the same for the sum of $1.00 to Attorney Joseph Schalk, on behalf of the Bank of Federal National Mortgage Association, being the buyer in this execution, paid to the Sheriff the sum of $ SHERIFF COST: $917.85 SO ANSWERS, February 18, 2014 RON R ANDERSON, SHERIFF (c) County itemheriff, Teleos*/nc. On August 1, 2013 the Sheriff levied upon the defendant's interest in the real property situated in Wormleysburg Borough, Cumberland County, PA, Known and numbered as; 8 Campbell Place, Camp Hill as Exhibit "A" filed with this writ and by this Reference incorporated herein. Date: August 1, 2013 = By: Cubcci_i &j.)ka_ Real Estate Coordinator bil d hi Nfir HOZ LXII 41 CUMBERLAND LAW JOURNAL 10/11/13 Writ No. 2012 -3583 Civil Term JP MORGAN CHASE BANK NATIONAL ASSOCIATION vs. VIRGINA A. EIDENSCHINK DECEASED, UNKNOWN HEIRS, Successors, Assigns and All Persons Firms or Associations Claiming Right Title or Interest From or Under, VIRGINA A. EIDENSCHINK DECEASED Atty.: Joseph Schalk By virtue of a Writ of Execution No. 12- 3583 - CIVIL, JP MORGAN CHASE BANK, NATIONAL ASSO- CIATION s /b /m TO CHASE HOME FINANCE, LLC s /b /m TO CHASE MANHATTAN MORTGAGE COR- PORATION v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, AND ALL PERSONS, FIRMS, OR ASSOCIA- TIONS CLAIMING RIGHT, TITLE OR INTEREST FROM OR UNDER VIR- GINIA A. EIDENSCHINK, DECEASED owner(s) of property situate in the BOROUGH OF WORMLEYSBURG, CUMBERLAND County, Pennsyl- vania, being 8 CAMPBELL PLACE, CAMP HILL, PA 17011 -2530. Parcel No. 47 -19- 1590 - 064 -U8. Improvements thereon: CONDO- MINIUM. Judgment Amount: $115,447.32. 53 PROOF OF PUBLICATION OF NOTICE IN CUMBERLAND LAW JOURNAL (Under Act No. 587, approved May 16, 1929), P. L.1784 COMMONWEALTH OF PENNSYLVANIA : ss. COUNTY OF CUMBERLAND : Lisa Marie Coyne, Esquire, Editor of the Cumberland Law Journal, of the County and State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid, was established January 2, 1952, and designated by the local courts as the official legal periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly issued weekly in the said County, and that the printed notice or publication attached hereto is exactly the same as was printed in the regular editions and issues of the said Cumberland Law Journal on the following dates, viz: October 11, October 18 and October 25, 2013 Affiant further deposes that he is authorized to verify this statement by the Cumberland Law Journal, a legal periodical of general circulation, and that he is not interested in the subject matter of the aforesaid notice or advertisement, and that all allegations in the foregoing statements as to time, place and character of publication are true. s. Marie Coyne, Edit SWORN TO AND SUBSCRIBED before me this 25 day of October, 2013 NOTARIAL SEAL DEBORAH A COLLINS Notary Public CARLISLE BOROUGH, CUMBERLAND COUNTY My Commission Expires Apr 28, 2014 The Co, 2020 Technology Pkwy Suite 300 Mechanicsburg, PA 17050 Inquiries - 717-255-8213 CUMBERLAND GO. SHERIFFS OFFICE CUMBERLAND COUNTY COURT HOUSE CARLISLE PA 17013 ogews Now you know THE PATRIOT NEWS THE SUNDAY PATRIOT NEWS Proof of Publication Under Act No. 587, Approved May 16, 1929 Commonwealth of Pennsylvania, County of Dauphin} ss Marianne Milier, being duly sworn accordng to Iaw, deposes and says: That she is the Assistant Controller of The Patriot News Co., a corporation organized and existing under the laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949, respectively, and aU have been continuously published ever since; That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular daily and/or Sunday/ Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as to the time, place and character of publication are true; and That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on behalf of The Patriot-News Go. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severaily by the stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "M", Volume 14, Page 317. PUBLICATION ~ wPY c� 4 This ad ran on the date(s) shown below: 10/13/13 10/20/13 10/27/13 Swo o a d subscribed before h" 1 day of November, 2013 A.D. ary Public OF PENNSYLVANIA Notarial Seal Holly Lynn Warfel, Notary Public Washington Twp., Dauphin County My -- 2016 uVAN ASSOCIATION 2012 -3583 ChM Term JP MORGAN CHASE BANK NATIONAL ASSOCIATION vs. VIRGINA A EIDENSCHINK. DECEASED UNKNOWN HEIRS, Successors, Assigns and All Persons Firms or Associations Claiming Right Tltie or Interest From or Under, VIRGINA A EIDENSCHINK DECEASED Atty: Joseph Schalk By virtue of a Writ of Execution No. 12- 3583 -CIVIL JP MORGAN CHASE BANK, NATIONAL j ASSOCIATION SB/M TO CHASE HOME FINANCE, LLC S/B/M TO ■ CHASE MANHATTAN MORTGAGE CORPORATION v. UNKNOWN HEIRS, SUCCESSORS, ASSIGNS, ANI5 ALL PERSONS, FIRMS, OR ASSOCIATIONS CLAIMING RIGHT, --.. TALE: OR; .iN EREST" FROM OR UNDER VIRGINIA A. EIDENSCHINK, DECEASED owner(s) of property situate in the BOROUGH OF WORMLEYSBURG, CUMBERLAND County, Pennsylvania, being 8 CAMPBELL PLACE, CAMP HILL, PA 17011 -2530 Parcel No. 47- 19- 1590-064438 (Acreage or steal widress) ' Improvements thereon...CONDOMINIUM Judgment Amount: $115,447.32 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS: I, Tammy Shearer, Recorder of Deeds in and for said County and State do hereby certify that the Sheriffs Deed in which Federal National Mortgage Association is the grantee the same having been sold to said grantee on the 4th day of December A.D., 2013, under and by virtue of a writ Execution issued on the 13th day of June, A.D., 2013, out of the Court of Common Pleas of said County as of Civil Term, 2012 Number 3583, at the suit of JPMorgan Chase Bank, N.A. against Unknow Heirs, Successors, Assigns, and All Persons, Firms or Associations Claiming Right, Title or Interest From or Under Virginia A. Eidenschink (Deceased) is duly recorded as Instrument Number 201406180. IN TESTIMONY WHEREOF, I have hereunto set my hand and seal of said office this day of , A.D. Recorder of Deeds Recorder of Deeds, Cumberland County, Carlisle, PA My Commission Expires the First Monday of Jan. 2018