HomeMy WebLinkAbout12-5259
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KML LAW GROUP, P.C.
SUITE 5000-BNY MELLON INDEPENDENCE ?~,r7C. ~t'*'f{^- !~r`
701 MARKET STREET ~ J- ~ i ~ ~t i t,i Q J~~~ ~
PHILADELPHIA, PA 19106 a ,y ~ ~
(866) 413-2311 C i_1~ ~ a,~ C`; ~ ~ II
JPMORGAN CHASE BANK, NATIONA -;`rl.;;~~j,~'4Pd~ C ~r~r~-Y, IN THE COURT OF COMMON PLEA
AssocIATION ~~;~~S'~' L~r~ ~d
c/o 3415 Vision Drive OF Cumberland COUNTY
Columbus, OH 43219
Plaintff C[VII, ACTION -LAW
vs.
SHAWN W. BENNER ACTION OF MORTGAGE FORECLOS
DORIS E. LOWERY
Mortgagor(s) and Record Owner(s)
1 Meadows Road Cjv~ Q~~" ,~a S , Vr f
Newville, PA l 7241 $
Defendant(s) ~Igv~
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following ages,
you must take action within twenty (20) days after the Complaint and notice are served, by entering a wr tten
appearance personally or by attorney and filing in writing with the court your defenses or objections to t e
claims set forth against you. You are warned that if you fail to do so the case may proceed without you nd a
judgment may be entered against you by the Court without further notice for any money claim in the Co plaint
of for any other claim or relief requested by the Plaintiff. You may lose money or property or other righ s
important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA E A
LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BEL W.
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 PRO IDE
YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELI IBLE
PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
AVISO
Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas a las
paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificaci n.
Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en form
escrita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted n se
defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notific cion.
Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provis ones
de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted.
LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOG O O
SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LL ME
POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARR
AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. a~.~ a I U3 • ~P~ ~ii
718 7S2 ~
~ ~.~?9 733
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SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEEIRE
INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS
ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
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CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT
A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FR01M YOU
WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT.
RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against yo ,you
still may be able to SAVE YOUR HOME FROM FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: 0 717-
243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Ho es.
4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist home wners
in default. Please See the PHFA website httn://www.phfa.org,/consumers/homeowners/real.as~x.
5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home
Retention options.
6). Foreclosure Resource Center: http://www.philadelphiafed.or~Jforeclosure/
7). Call or contact our office to request the amount to bring the account current, or payoff them rtgage
or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or vi email
at homeretention(c~kmllawgroup.com. Call Seth at 215-825-6329 or fax 215-825-6429. The figure and/ r
package you requested will be mailed to the address that you request or faxed if you leave a message wit that
information. The attorney in charge of our firm's Homeowner Retention Department is David Fein who an be
reached at 215-825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of 113617F .
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.
This Action of Mortgage Foreclosure will continue unless you take action to stop it.
COMPLAINT IN MORTGAGE FORECLOSURE
1. Plaintiff is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, c/o 3415 Vision Drive,
Columbus, OH 43219.
2. The name(s) and address(es) of the Defendant(s) is/are SHAWN W. BENNER, 1 Meadows Road
Newville, PA 17241 and DORIS E. LOWERY, 1 Meadows Road, Newville, PA 17241, who is/ e the
mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described.
3. On April 13, 2006 mortgagor(s) made, executed and delivered a mortgage upon the Property her 'nafter
described to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE OR
PHILADELPHIA FINANCIAL MORTGAGE A DIVISION OF LEESPORT BANK, which mo gage
is recorded in the Office of the Recorder of Deeds of Cumberland County on April 13, 2006 as B ok
1946, Page 4009 Instrument # 200612116. The mortgage has been assigned to: JPMORGAN C ASE
BANK, NATIONAL ASSOCIATION by assignment of Mortgage recorded on June 04, 2012 as
Instrument # 201216537. Plaintiff is the real party in interest pursuant to an Assignment of Mort age to
Plaintiff attached as Exhibit C. The Mortgage is a matter of public record and is incorporated by his
reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves he
Plaintiff from its obligation to attach documents to pleadings if those documents are matters of p blic
record. A loan modification agreement dated 12/1/2008 is hereby attached as Exhibit D.
4. The Property subject to the Mortgage is more fully described in the legal description. set forth as xhibit
«A» (<`Property").
5. The mortgage is in default because the monthly payments of principal and interest are due and un aid
for May O 1, 2011 and each month thereafter and by the terms of the Mortgage, upon default in su h
payments for a period of one month or more, the entire principal balance and all interest due and ther
charges are due and collectible.
6. The following amounts are due to Plaintiff on the Mortgage as of July 31, 2012:
Principal Balance ..........................................................................................$89,386.80
Interest from 04/01/2011 through 07/31/2012 .............................................$7,746.88
Accrued Late Charges ........................................................................................$269.01
Escrow Advance .............................................................................................$2,230.23
Property Inspection ..............................................................................................$98.00
Reasonable Attorney's Fee .............................................................................$1.450.00
$101,180.92
7. If the Mortgage is reinstated prior to a Sheriffls Sale, the Attorney's Fees set forth above may be ess
than the amount demanded based on work actually performed. Plaintiff reserves the right to requ st
additional attorney's fees if the complexity of the action results in fees in excess of the amount
demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, b t not
limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any o her
costs of the action in accordance with the mortgage documents and applicable law.
8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against th
Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such
right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy
proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the pers nal
liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Prope
pursuant to Pennsylvania law.
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9. Notice of Intention to Foreclose and a Notice of Homeowners' Emergency Mortgage Assistance has
been sent to Defendants by certified and regular mail, as required by Act 160 of 1998 of the
Commonwealth of Pennsylvania, on the date(s) set forth in the true and correct copy of such noti e(s)
attached hereto as Exhibit "B". The Defendants have not had the required face-to-face meeting ithin
the required time and Plaintiff has no knowledge of any such meeting being requested by the De ndants
through the Plaintiff, the Pennsylvania Housing Finance Agency, or any appropriate Consumer C edit
Counseling Agency.
WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $101,180. ,
together with interest, costs, fees and charges collectible under the Note and Mortgage including but not invited
to attorney's fees and costs, and for the foreclosure and sale of the mortgage property.
By: _
L GROUP, P. .
~ichael McKeever Pa. ID 56129
?Jay E. Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa. ID 61858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua I. Goldman Pa. ID 205047
Jill P. Jenkins Pa. ID 306588
Andrew F. Gornall Pa. ID 92382
Attorneys for Plaintiff
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Pennsylvania Verification
Jennifer Jordan ,hereby states that he/she is Vice President of
JPMor~an Chase Bank, N.A. the 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
falsificatio to authorities.
Jenn fer J rdan
Vice Pres dent
Date: 08/06/12
JPMor~an Chase Bank, N.A
Borrower: Benner
Property Address: 1 Meadows Rd
County: Cumberland
Last Four of Loan Number: 7489
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T GlamberLuid Coup
ALL those eertaia two (2) certeum fracas of lead situate m Lower MtBim ownsb~p, tY
Pennsylvania, accoxdimgtoasubdivisiompLmpt+cpacedby7olmR.KissiQgerSurvcy~g,cntitlcdS - . .
for Edward L. Stutti, dated Sep~+mber 25, 20(10 amd recorded in Ctanberland County Plea Boole 82, Peg
50, bounded and deecn'bcd as follows, to wit:
TRACT NO 1:
BECxiNNWG at a set railroad spike located m 7'18, known as Meadows Road, at the conger cf Lot I0
the Plain desen'bod hdrein; thence along Lot 10 North 46 degrees 29 urinates 01 seconds east 297.17 fret
a act item pin locabod at the career of Lot 1 OA end 11 A; theorx slang Lot i 1 A soutbt 44 deg~mees 25 mien
10 seconds east 320.00 feet to a setraa'lmad spOco kacated in the eenterlwae ofPeansylv8aia Route 997, a
kziowa as the Roxbury Road; thence through ~e rxnterline of Pennsylvania Rouse 997, also known
Roxbury Rosd south 43 degrees 16 minutes 1A socoads west 95.07 feet ao a point located inn, t]v; ceatal'
of rho said roadway, thence coatvluiag tht+oagh the centcfdine of said roadway south 45 degtue 57 min
24 seconds worst 240.18 feel to an existing railroad spike located at the intarscction of Pounsyl~?ania Rou
997, also known as Ra~bury Road sod T-418, also known as Mmdurove Road; thenco tlrrnttgb the said -
418, also lrnown as Meadows road, north 37 degrcoa 46 tninntes 59 aeoonda west 329,14 f i;et b a s
railroad spike, the place of BEGINNING. CONTAINII~TQ a total of 2.3ti05 acres,
BE1NQ known se Lot 11 of the Subdivision referenced above.
TRACT N0.2:
BEGINNING at a act railroad spike located is the centerline of Pennsyhraaia Routo 997, also k oowrl as
Roxbury Road, at the corns of Let 11; thence along Lot 11 aoxth 44 degrees 25 minutes 10 seconds wo
320.00 feet to a set iron pin. located at tho corner of Lot 11 sad Lot 10; thence along Lot 1tIA north 7
- degrces 19 minutes 20 seconds east 164,10 pct to a point locaiod at lands now or formerly of Richard
Piekcn; ~enco along lands ofPiclaen South 46 degrees 2S minutes 38 seconds East 277,33 feat to a t
railroad sp>7ce located in ffie centexiine of Pennaytvaaia Route 997, also known as the Roxbury Road; them
through the said omaterline south 43 degrocs 16 uvnutee 24 seconds west 10b.50 feet to a set railroad ap
the placx of BEGINNIIVG. CONTAINING 0.6942 acres total.
BEING known as Lot 11A of the aforementioned Subdivision.
Both tracts arc sabjtct to conditions and restrictions es act forth in the aforementioned Subdivision.
BfiINQ the same prcmiaea which Richard L. Whirler and Janet S. Whister, husband and wife, by th '
Aced dated February 26, 2002, and recorded in Cutuberlead County, Permsylvania, Ueod B«~~k 250, P
3507, greeted sad conveyed unto Bruce E. Cater and tEethy R t:,aler, husband artd wife.
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*Exhibit has been redacted to remove all personally identiftable information or non public information
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REPRESENTATION OF PRINTED DOCUMENT
Chase (FL5-7734) ~H
PO BOX 44090 ~IK
Jacksonville, FL 32231-4090
July 6, 2011
SHAWN W BENNER
1 MEADOWS RD
NEWVILLE PA 17241-9615
Acceleration Warning (Notice of Intent to Foreclose)
Account:~7489 (the "Loan")
Property Address: 1 MEADOWS RD
NEWVILLE, PA 17241 (the "Property")
Dear SHAWN W BENNER:
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
Thi i n ffi i 1 ti th t n r h i i f It n th 1 r
in ends t forecl se. ifi infor a ' n hen tur of th faul is rovid din
the attached pages.
h M E ER E Y RT TAN E PR RA
HE m 1 h rh xl' rm
w i E P 1 A N I
THI TI E. Tak thi ti 'th w n m 'th th lin A n
Th n r an h n n r f r r 't n A n i 'n
r r lit he n f f v u o m 11
th v - p .t
impaired hearing can call (717] 780-1869.E
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help ex lain
it. You may also want to contact an attorney in your area. The local bar association may
be able to help you find a lawyer.
INTERNET REPRINT
REPRESENTATION OF PRINTED DOCUMENT
Chase (FLS-7734) G~ r~~r
PO BOX 44090 j'~ C
Jacksonville, FL 32231-4090
July 6, 2011
DORIS E LOWERY
1 MEADOWS RD
NEWVILLE PA 17241-9615
Acceleration Warning (Notice of Intent to Foreclose)
Account:~7489 (the "Loan")
Property A ess: 1 MEADOWS RD
NEWVILLE, PA 17241 (the "Property")
Dear DORIS E LOWERY:
ACT 91 NOTICE
TAKE ACTION TO SAVE YOUR
HOME FROM FORECLOSURE
Thi i an ffi i 1 ti th h n r h i i 1 n t r
intends to forecl se. cific inform tin u h nature of the defa I i rovid din
the attached.pages.
Th M WNE ' EME ENCY M T A E I TAN E R
E P ma I h 1 t r Th' In
w r o i E n h l t T RE IT
- Y
THI TI E. Tak thi ti 'th h n t ith th li A n
Th n m an h n n r f n r it i 'n
r ar lit a h' f o h 11
t 'a a - p
impaired hearing can call (717] 780-18691
This Notice contains important legal information. If you have any questions,
representatives at the Consumer Credit Counseling Agency may be able to help ex lain
it. You may also want to contact an attorney in your area. The local bar association may
be able to help you find a lawyer.
INTERNET REPRINT
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REPRESENTATION OF PRINTED DOCUMENT
LA NOTIFICACION EN ADJUNTO ES DE SUMA IMPORTANCIA, PLIES AFE TA
SU DERECHO A CONTINUAR VIVIENDO EN SU CASA. SI NO COMPRENDE EL
CONTENH)O DE ESTA NOTIFICACION OBTENGA UNA TRADUCCION
INMEDIATAMENTE LLAMANDO A ESTA AGENCIA (PENNSYLVANIA
HOUSING FINANCE AGENCY) SIN CARGOS AL NUMERO MENCIONADO
ARRIBA. PUEDE SER ELEGIBLE PARR UN PRESTAMO POR EL PROGRAM
LLAMADO "HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANCE
PROGRAM" EL CUAL PUEDE SALVAR SU CASA DE LA PERDIDA DEL
DERECHO A REDIMIR SU HIPOTECA.
HOMEOWNER'S NAME(S): SHAWN W BENNER
DORIS E LOWERY
PROPERTY ADDRESS: 1 MEADOWS RD
NEWVILLE, PA 17241
LOAN ACCT_ NUMBER: _7489
ORIGINAL LENDER: PHILADELPHIA. FINANCIAL MORTGAGE A DIVISION OF
LEESPORT BANK, A PENNSYLVANIA BANKING
CURRENT LENDER/SERVICER: JPMorgan Chase Bank, N.A. ("Chase")
HOMEOWNERS' EMERGENCY MORTGAGE ASSISTANC
PROGRAM
YOU MAY BE ELIGIBLE FOR FINANCIAL ASSISTANCE
WHICH CAN SAVE YOUR HOME FROM FORECLOSURE AND
HELP YOU MAKE FUTURE MORTGAGE PAYMENTS.
IF YOU COMPLY WITH THE PROVISIONS OF THE HOMEOWNERS' EMERGENC
MORTGAGE ASSISTANCE ACT OF 1983 (THE "ACT"), YOU MAY BE ELIGIBLE F R
EMERGENCY MORTGAGE ASSISTANCE:
• IF YOUR DEFAULT HAS BEEN CAUSED BY CIRCUMSTANCES BEYOND Y UR
CONTROL,
• IF YOU HAVE A REASONABLE PROSPECT OF BEING ABLE TO PAY YO
MORTGAGE PAYMENTS, AND
• IF YOU MEET OTHER ELIGIBILITY REQUIREMENTS ESTABLISHED BY T E
PENNSYLVANIA HOUSING FINANCE AGENCY.
TEMPORARY STAY OF FORECL,OSLiRF -Under the Act, you are entitled to a temporary stay
of foreclosure on your mortgage for thirty (30) days from the date of this Notice (plus three [3] days for
mailing). During that time, you must arrange and attend a "face-to-face" meeting with one of the Consum r
Credit Counseling Agencies listed at the end of this Notice.
THIRTY-THREE DAYS OF THE DATE OF THI4 NOTICE IF YOU DO NOT APPI Y FOR
T A I
PART F THI N TI E ALLED "H T RE Y R M RT A E DEFA LT" E LAIN H T
BRING YOUR MORTGAGE UP TO DATE.
CONSUMER CREDIT COUNSELING AGENCIE - If you meet with one of the Consumer Credit
Counseling Agencies listed at the end of this Notice, the lender may NOT take action against you for thi (30)
days after the date of this meeting. The na e e and tel h n tuber of a n
't r in t'
It is only necessary to schedule one face-to-face meeting. Advise your lender immediately of your intenti ns.
INTERNET REPRINT
REPRESENTATION OF PRINTED DOCUMENT
APPLICATION FOR MORTGAGE ASSISTANCE -Your mortgage is in default for the reasons set',
forth later in this Notice (see following pages for specific information about the nature of your default).
You have the right to apply for financial assistance from the Homeowners' Emergency Mortgage
Assistance Program ("HEMAP"). To do so, you must fill out, sign, and file a completed HEMAP
Application with one of the designated Consumer Credit Counseling Agencies listed at the end of this
Notice. Only Consumer Credit Counseling Agencies have applications for the program and they will
assist you in submitting a complete application to the Pennsylvania Housing Finance Agency. To
temporarily stop the lender from filing a foreclosure action, your application MUST be forwarded to
the Pennsylvania Housing Finance Agency ("PHFA") and received within thirty (30) days of your face-to face
meeting with the counseling agency.
YOU SHOULD FILE A HEMAP APPLICATION AS SOON AS POSSIBLE. IF YOU HAVE A
MEETING WITH A COUNSELING AGENCY WITHIN THIRTY-THREE (33) DAYS OF THE
POSTMARK DATE OF THIS NOTICEAND FILE AN APPLICATION WITH THE PHFA WITHIN
THIRTY (30) DAYS OF THAT MEETING, THEN THE LENDER WILL BE TEMPORARILY
PREVENTED FROM STARTING A FORECLOSURE ACTION AGAINST YOUR PROPERTY, AS
EXPLAINED ABOVE, IN THE SECTION CALLED "TEMPORARY STAY OF FORECLOSURE."
YOU HAVE THE RIGHT TO FILE A HEMAP APPLICATION EVEN BEYOND THE E TIME
PERIODS. A LATE APPLICATION WILL NOT PREVENT THE LENDER FROM STARTING A
FORECLOSURE ACTION, BUT IF YOUR APPLICATION IS EVENTUALLY APPROVED AT ANY
TIME BEFORE A SHERIFF'S SALE, THE FORECLOSURE WILL BE STOPPED.
A_ GENCY ACTION -Available funds for emergency mortgage assistance are very limited. They will b
disbursed by the Agency under the eligibility criteria established by the Act. The Pennsylvania Housing
Finance Agency has sixty (60) days to make a decision after it receives your application. During that
time, no foreclosure proceedings will be pursued against you if you have met the time requirements set
forth above. You will be notified directly by the Pennsylvania Housing Finance Agency of its decision on
your application.
NOTE: IF YOU ARE CURRENTLY PROTECTED BY THE FILING OF A PETITION I
BANKRUPTCY, THE FOLLOWING PART OF THIS NOTICE IS FOR INFORMATIO
PURPOSES ONLY AND SHOULD NOT BE CONSIDERED AS AN ATTEMPT TO COLL CT
THE DEBT.
(If you have filed bankruptcy, you can still apply for Emergency Mortgage Assistance.)
HOW TO CURE YOUR MORTGAGE DEFAULT brin it u to
date .
NATURE OF THE DEFAULT -The mortgage debt held by the above lender on your Property located
at: 1 MEADOWS RD, NEWVILLE, PA 17241 IS SERIOUSLY IN DEFAULT because:
YOU HAVE NOT MADE MONTHLY MORTGAGE PAYMENTS starting OS/O1/11 through 07/06/201 ,and the
following amounts are now past due.
If you have any questions about the amounts below, please contact us as soon as possible at (800) 848-93 0.
Total Monthly Payments Past Due: $2,364.09
Late Charges: $0.00
Insufficient Funds (NSF) Fees: $0.00
Other Fees and Advances*: $80.00
Amount Held in Suspense: $67.97
TOTAL AMOUNT DUE TO CURE DEFAULT: $2,376.12
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REPRESENTATION OF PRINTED DOCUMENT
*Other Fees and Advances include those amounts allowed by your Note and Security
Instrument. If
you need additional information regarding any of these amounts, please
contact us at the number provided below.
HOW TO CURE THE DEFAULT -You may cure the default within THIRTY (30) DAYS of the dat
of this Notice BY PAYING THE TOTAL AMOUNT PAST DUE TO THE LENDER, WHICH IS
$2,376.12, PLUS ANY MORTGAGE PAYMENTS AND LATE CHARGES WHICH BECOME
DUE DURING THE THIRTY (30)-DAY PERIOD. P nt m t m i t f h i r' k
money order or certified check and sent to:
Regular Mail: Chase
PO BOX 78420
Phoenix, AZ 85062-8420
Overnight Mail: Chase
Attention PO Box 78420
1820 East Sky Harbor Circle South
Phoenix, AZ 85034-9700
IF YOU DO NOT CURE THE DEFAULT - If you do not cure the default within THIRTY (30) DAY
of the date of this Notice, the lender intends to exercise its rights to accelerate the mortg;~ge debt.
This means that the entire outstanding balance of this debt will be considered due immediately and you
may lose the chance to pay the mortgage in monthly installments. If full payment of the total amount past
due is not made within THIRTY (30) DAYS, the lender also intends to instruct its attorneys to start legal
action to foreclose upon your mortgaged Pro~ert~
IF THE MORTGAGE IS FORECLOSED UPON -The mortgaged Property will be sold by the Sheri f
to pay off the mortgage debt. If the lender refers your case to its attorneys, but you cure the delinquency
before the lender begins legal proceedings against you, you will still be required to pay the reasonable
attorney fees that were actually incurred, up to $50.00. However, if legal proceedings are started against
you, you will have to pay all reasonable attorney fees actually incurred by the lender even if they exceed
$50.00. Any attorney's fees will be added to the amount you owe the lender, which may also include othe
reasonable costs. If you cure the default within the THIRTY (30~ DAY period, you will not be
re~.liired to ~av attorney fees.
OTHER LENDER REMEDIES -The lender may also sue you personally for the unpaid principal
balance and all other sums due under the mortgage.
RIGHT TO CURE THE DEFAULT PRIOR TO SHERIFF'S SALE - If you have not cured the
default within the THIRTY (30)-DAY period and foreclosure proceedings have begun, you still have the
right to cure the default and prevent the sale at any time un to one hour before the Sheriffs Sale. You may
do so by paying the total amount then past due, plus any late or other charges then due, reasonable
attorney fees and costs connected with the foreclosure sale, and any other costs connected with the
Sheriffs Sale as specified in writing_by the lender, and by
performing any other requirements under the
mort~a~e. Curing your default in the manner set forth in this Notice will restore your mortgage to
the same position as if you had never defaulted.
EARLIEST POSSIBLE SHERIFF'S SALE DATE - It is estimated that the earliest date that such a
sheriff s sale of the mortgaged Property could be held would be approximately five to six (5-6) months rom
the date of this Notice. A notice of the actual date of the Sheriffs Sale will be sent to you before the sale Of
course, the amount needed to cure the default will increase the longer you wait. You may find out at any 'me
exactly what the required payment or action will be by contacting the lender.
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REPRESENTATION OF PRINTED DOCUMENT
HOW TO CONTACT THE LENDER•
Name of Lender: Chase
Address: Mail Code OH4-7356 'i
3415 Vision Drive
Columbus, OH 43219-6009 ~I
Phone Number: (800) 848-9380
Fax Number: (614) 422-7912
Contact Person: Justin Powell-Wilburn
E-Mail Address: Justin.L.Powell-Wilburn@chase.com
EFFECT OF SHERIFF'S SALE -You should realize that a Sheriffs Sale will end your ownership of
the mortgaged Property and your right to occupy it. If you continue to live in the Property after the
sheriff s sale, a lawsuit to remove you and your furnishings and other belongings could be started by the
lender at any time.
ASSUMPTION OF MORTGAGE -You may be eligible to sell or transfer your home to a buyer or
transferee who will assume the mortgage debt, provided that all the outstanding payments, charges, and
attorney's fees and costs are paid prior to or at the sale and that the other requirements of the mortgage ar
satisfied. To determine eligibility, you must contact our office to verify the assumability of your Prope
YOU MAY ALSO HAVE THE RIGHT:
• TO SELL THE PROPERTY TO OBTAIN MONEY TO PAY OFF THE MORTGAGE DEBT OR
TO BORROW MONEY FROM ANOTHER LENDING INSTITUTION TO PAY OFF THIS DEB .
• TO HAVE THIS DEFAULT CURED BY ANY THIRD PARTY ACTING ON YOUR BEHALF.
• TO HAVE THE MORTGAGE RESTORED TO THE SAME POSITION AS IF NO DEFAULT H D
OCCURRED, IF YOU CURE THE DEFAULT. (HOWEVER, YOU DO NOT HAVE THIS RIGH
TO CURE YOUR DEFAULT MORE THAN THREE TIMES IN ANY CALENDAR YEAR.)
• TO ASSERT THE NONEXISTENCE OF A DEFAULT IN ANY FORECLOSURE PROCEEDIN
OR ANY OTHER LAWSUIT INSTITUTED UNDER THE MORTGAGE DOCUMENTS.
• TO ASSERT ANY OTHER DEFENSE YOU BELIEVE YOU MAY HAVE TO SUCH ACTION Y
THE LENDER..
• TO SEEK PROTECTION UNDER THE FEDERAL BANKRUPTCY LAW.
Sincerely,
Chase
(800)848-9380
(800) 582-0542 TDD /Text Telephone
www.chase.com
Enclosures
- Federal Trade Commission Pamphlet
- HEMAP Consumer Credit Counseling Agencies
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REPRESENTATION OF PRINTED DOCUMENT
CERTIFIED MAIL: Return Receipt Requested and First Class Mail
An important reminder for all our customers: As stated in the "Questions and Answers for Borrow~rs
about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration,
"Borrowers should beware of any organization that attempts to charge a fee for housing counseling r
modification of a delinquent loan, especially if they require a fee in advance." Loan modification sc ms
should be reported to PreventLoanScams.org, or by calling (888) 995- HOPE. Chase offers loan
modification assistance free of charge (i.e., no modification fee required). Please call us immediately at
(800) 848-9380 to discuss your options. The longer you delay the fewer options you may have.
We are a debt collector.
BR860
INTERNET REPRINT
_ _
REPRESENTATION OF PRINTED DOCUMENT
HUD COUNSELING AGENCIES -PENNSYLVANIA
AGENCIES PHONE ADDRESS CITY ZIP C DE
CCCS of Western PA 888-511-2227 524 Franklin Avenue Ali ui a 1500
Housin O ortunities of Beaver Coun 724-728-7511 320 Cone a Avenue Unit 1 Beaver 1500
Housin O ortunities of Beaver County, Inc. 724-728-7511 282 East End Avenue Beaver 1501
Mon Valle Initiative 412~64~000 303-305 E 8th Avenue _ Homestead _ 1512
CCCS of Western PA 888-511-2227 2403 Sidney Street River Pittsburgh 1520
Park Commons
Action-Housin Inc. 412-281-2102 425 6th Avenue -Suite 950 Pittsbur h____ 1521
Neighborworks Western PA, formerly Neighborhood 412-281-9773 710 5th Avenue -Suite 1000 Pittsburgh 1521
Housing Services, Inc.
PA Housin Finance A enc 412-429-2842 2275 Swallow Hill Road Bld 200 Pittsburgh _ 1522
Three Rivers Center for Inde endent Livin 412-371-7700 900 Rebecca Avenue Pittsburgh 1522
Fair Housin Partnershi of Greater Pittsbu h Inc. 412-391-2535 2840 Libe Avenue -Suite 205 Pittsbur h 1522
Urban Lea ue of Greater Pittsbu h _ 412-227-4163 610 Wood Street _ Pittsbur h 1522
Garfield Jubilee Associates 41265-5200 5138 Penn Avenue _ Pittsburgh _ 1522
Nazareth Housin Services 412-931-6996 301 Bellevue Road Pittsbur h_ 1522 _
CCCS of Western PA _ _ 888-511-2227 41 E Chestnut Street Washington 1530
Commun" Action Southwest _ 724-255-9550 150 W Beau StreetSuite 304 Washington _ 1530
Southwestern PA Le of Services Inc 800-846-0871 10 W Che Avenue Central Office Washin ton 1530
Southwestern PA Le al Services Inc. 800-846-0871 63 S Washin ton Street Wa nesbur~c , 1537
Fa efts Coun Communi Action A enc 724~137~050 140 N Beeson Avenue _ Uniontown_ 1540
Southwestern PA Legal Services, Inc 800-846-0871 132 E Catherine Street Somerset _ 1550
CCCS of Western PA _ 888-511-2227 1 North ate Square Greensbur _ 1560
Westmoreland Community Action 724-834-1260 226 S Ma le Avenue Greensburg 1560
Indiana Coun Communi Action Pro ram Inc. 724-465-2657 827 Water Street P.O. Box 187 Indiana 1570
The NORCAM Grou _ 814-948-4444 4200 Crawford Avenue Suite 200 Northern Cambria 1571
Northern Tier Communi Action Co oration 814-486-1161 135 W 4th Street Em oriu_m_ _ 1583
CCCS of Western PA 888-511-2227 112 Hol ood Drive -Suite 101 Butler 1600
Housin Autho ' of Butler Coun 724-287-6797 114 Wood Drive Butler 1600
Lawrence Coun Social Services, Inc. 724-658-7258 241 W Grant Street P.O. Box 189 New Castle _ _ 1610
Shenan o Valle Urban_ League 724-981-5310 601 Indiana Avenue _ Farcell__ _ 1612
CCCS of the Midwest 800-355-2227 734 Stambau h Avenue Sharon 1614
Commun' Action Partnershi of Mercer Coun 724-342-6222 75 S Dodc Street Sharon 1614
Armstron Coun Communi Action Agency 724-548-3405 124 Arcnsdale Road -Suite 211 Kittanning_ 1620
CCCS of Western PA 888-511-2227 312 Chestnut Street -Suite 227 _ Meadville 1633
Center for Fami Services Inc. 814-337-8450 213 W Center Street Meadville__ 1633
Warren Forest Counties EOC 814-726-2400 1209 Pennsylvania Avenue W Warren 1636
P.O. Bax 547
Greater Erie Communi Action A enc 81459-4581 18 W 9th Street Erie_ _ 1650
Booker T. Washin ton _ 814-453-5744 1720 Holland Street Erie _ 1650
Saint rvlartin Center Inc. _ 814-452-6113 1701 Parade Street _Erie _ 1650
Voices for Inde ndence _ 814-874-0064 1107 Pa ne Avenue _ Erie 1650
Ba nt Nato Inc. _ _ _ 81459-2761 312 Chestnut Street _Erie _ 1650
CCCS of Western PA _ 888-511-2227 4402 Peach Street Erie 1650
Blair County Community Action Agency 814-946-3651 2100 6th Avenue -Suite 102 Altoona 1660
P.O. Box 1833
CCCS of Western PA 888-511-2227 917 A Logan Boulevard Altoona 1660
Royal/Remax Plaza
CCCS of Northeastern PA 814-238-3668 202 W Hamilton Avenue _ State Colle a 1680
The Trehab Center of Northeastern PA 570-724-5252 144 E East Avenue Wellsboro 1690
Penns Ivania Housin Finance A enc 717-780-3907 211 N Front Street Hanisburg__ 17101
CCCS of Western PA 888-511-2227 2000 Lin lestown Road Harrisbu _ 1711
Fair Housin Council of the Ca ital Re ion Inc. 717-238-9540 2100 N 6th Street Harrisbur 1711
Loveshi Inc._ _ 717-232-2207 2320 N 5th Street _ Harrisbur _ 1711
PHFA _ _ 717-780-3940 211 N Front Street Harrisbu _ 1711
Maranatha _ 717-762-3285 43 Philadel hia Avenue Wa nesboro _ 1726
CCCS of Western PA 888-511-2227 55 Clover Hill Road _ Dallastown 1731
Adams County Interfaith Housing Authority 717-334-1518 40 E High Street Gettysburg 1732
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REPRESENTATION OF PRINTED DOCUMENT
American Red Cross -Hanover Chapter 717-637-3768 529 Carlisle Street Hanover _ 1731
Housin Alliance of York _ _ 717-854-1541 35 S Duke Street York 174 1
O ortun' ,Inc 717-424-3645 301 E Market Street _ York__ 174 3
SACA Development Corp. _ _ _ 717-399-4292 453 S Lime Street Suite B Lancaster _ 176 2
Base, Inc. _ 717-392-5467 447 S Prince Street Lancaster 176 3
Tabor Communi Services, Inc. 717-397-5182 308 E King Street _ Lancaster _ 176
CCCS of Northeastern PA____ _ 570-323-6627 201 Basin Street -Suite 600 Williamsport _ 177 1
Lycoming-Clinton Counties Commission for 570-326-0587 2138 Lincoln Street P.O. Box 3568 Williamsport 177
Community Action
CCCS of Northeastern PA _ _ _ 800-922-9537 217 S Center Street Sunbury 178 1
CCCS of Northeastem PA _ 800-922-9537 702 Sawmill Road _ Bloomsbur _ 1781
Schu Ikill Commun' Action _ 570-622-1995 225 N Centre Street _ Pottsville 1790
Communi Action Committee of Lehi h Valle ,Inc. 610-691-5620 1337E 5th Street Bethlehem _ 1801
EI Shaddai Bethlehem Ministries _ 610-625-3500 529 E Broad Street Bethlehe_m___ 1801
CCCS of Lehi h Valle , A Division of MM_I 800-220-2733 306 Spring Garden Street _ _ Easton 1804
CCCS of Lehigh Valley, A Division of MMI 800-220-2733 3671 Crescent Court E_ Whitehall _ _ 1805
Alliance for Buildin Communities 610-439-7007 830 Hamilton Mall Allentown_ _ 1810
Nei hbofiood Housing Services of the Lehi h Valle 610-437-4571 239 N 10th Street Allentown _ 1810
Catholic Charities Diocese of Allentown 610-435-1541 530 Union Boulevard Allentown _ _ 1810
CCCS of Northeastern_PA______ 800-922-9537 81 S Church Street Hazleton _ 1820
Op ortunity, Inc. 570-236-7642 West End Plaza Unit No. 10 _ _ Brodheadsville_ 1832
CCCS of Northeastem PA _ 570-420-8980 411 Main Street -Suite 102 _ Stroudsburg _ 1836
CCCS of Northeastern PA 800-922-9537 232 Sunrise Avenue Route 191 Honesdale 1843
The Trehab Center of Northeastem PA 570-253-8941 1225 Main Street Honesdale 1843
Catholic Social Services
Catholic Social Services, Diocese of Scranton 570-207-2283 516 Fig Street _ Scranton _ 1850
United Nei hbofiood Centers of Northeastem PA 570-346-0759 425 Alder Street _ _ _ _ Scranton ' 1850
Neighbofiood Housing Services of Lackawanna 570-558-2490 709 E Market Street Scranton 1850
County
- -
Opportunity, Inc. 570-236-7642 Aharts Plaza/Key Real Estate Blakeslee 1861
Route 15 8 940 _ _
The Trehab Center of Northeastern PA 570-928-9667 German Street P.O. Box 389 Dushore 1861
American Credit Counseling Institute 888-468-8847 212 Berwick-Hazefton Highway Nescopeck 1863
CCCS of Northeastem PA 570-602-2227 401 Laurel Street Pittston 1864
The Trehab Center of Northeastern PA 570-836-6840 115 SR 92S Tunkhannock 1865
CCCS of Northeastem PA 570-821-0837 77 E Market Street, 7th Floor Wilkes Barre 1870
Commission on Economic Opportunity of Luzeme 570-826-0510 165 Amber Lane P.O. Box 1127 Wilkes Barre 1870
County
The Trehab Center of Northeastern PA 570-278-5227 10 Public Avenue Montrose 1880
The Trehab Center of Northeastem PA 570-888-0412 703 S Elmer Avenue Suite M.6 Sayre 1884
Bucks County Housing Group 215-598-3566 2324 2nd Street Pike -Suite 17 Wrightstawn 1894
CCCS of Lehigh Valley, A Division of MMI 800-220-2733 127 S 5th Street Quakertown 1895
Credit Counseling Center 215-396-1880 832 2nd Street Pike 1895
American Credit Counseling Institute 215-444-9429 530 W Street Road -Suite 201 Warminster 1897
Opportunity, Inc. 610-660-6687 Two Bala Plaza Suite 300 Philadelphia 1900
CCCS of the Delaware Valley 215-563-5665 1230 New Rogers Road -Suite F1 Bristol 1900
American Red Cross of Chester 610-874-1484 1729 Edgemont Avenue Chester 1901
CCCS of the Delaware Valley 215-566-5335 130E 7th Street Chester 1901
American Financial Counseling Services 267-228-7903 871 N Easton Road Glenside 1903
CCCS of the Delaware Valley _ 800-989-2227 261 Oki York Road Pavilion Suite 401 Jenkintown 1904
CCCS of the Delaware Valley 215-563-5665 280 N Providence Road Media 1906
Media Fellowship House _ 610-565-0434 302 S Jackson Media 1906
CCCS of the Delaware Valley 215-566-5335 240 N Bishop Street Springfield 1906
American Credit Alliance 215-295-7195 2 S Delmorr Avenue Morrisville 1906
Advocates for Financial Independence 215-389-2810 202 E Hinkley Avenue Ridley Park 1907
American Credit Counseling Institute 610-971-2210 175 Strafford Avenue -Suite 1 Wayne 1908
Housing Association of Delaware Valley 215-545-6010 1500 Walnut Street Suite 601 Philadelphia 1910
Unemployment Information Center 215-557-0822 112 N Broad Street 11th Floor Philadelphia 1910
CCCS of the Delaware Valley 215-563-5665 1608 Walnut Street 10th Floor Philadelphia 1910
PA Council For Community Advancement 215-567-7803 100 N 17th Street Suite 600 Philadelphia 1910
Philadelphia Council for Community Advancement 215-567-7803 1617 JFK Boulevard -Suite 1550 Philadelphia 1910
Urban League of PA 215-985-3220 1818 Market Street 20th Floor Philadelphia 1910
Intercultural Family Services, Inc. 215-386-1298 4225 Chestnut Street Philadelphia 1910
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The Partnership CDC___ _ _ 215-662-1612 4027 Market Street _ _ Philadelphia 19104
Libe Resources _ 215-634-2000 714 Market Street Suite 100 Philadel hia _ 1910
CCCS of the Delaware Valley _ 215-563-5665 901 A Wood Street Philadelphia 1910
Philadelphia NHS 215-988-9879 121 N Broad Street #502 Philadelphia 1910
Urban Lea ue of PA _ 215-985-3220 121 S Broad Street 9th FI_o_o_ r_ _ Philadelphia _ 1910
American Financial Counseling Services 267-228-7903 1917 Welsh Road _ Philadelphia _ 1911
Mt Airy, USA _ 215-844-6021 6703 Germantown Avenue -Suite 20_0 Philadelphia _ 1911
Korean Community Development Services Center 215-276-8830 6053-55 N 5th Street _ _ Philadel hia _ 1912
APM _ 215-235-6788 2147 N 6th Street Philadelphia _ 1912
Association De Puertorriquenos En Marcha 215-235-6070 600 W Diamond Street Philadelphia _ _ 1912
Housing Association of Delaware Valley _ 215-978-0224 1528 Walnut Street Philadel hia _ 1912
NACA Philadelphia, PA _ 215-531-5221 1341 N Delaware Avenue -Suite 312 Philadelphia _ 1912
New Kensin ton Communi Develo ment Corp. 215-d27-0350 2515 Frankford Avenue _ Philadelphia 1912
Carroll Park Commun" Council, Inc. 215-877-1157 5218 Master Street Philadelphia 1913
Hispanic Alliance for Communi Advancement _ 21567-8932 2740 N Front Street Philadelphia 1913
CCCS of the Delaware Valle 800-989-2227 7340 Jackson Street _ _ _ Philadelphia _ 1913
West Oak Lane Community Development _ 215-224-0880 7300-02 O ontz Avenue _ Philadelphia _ 1913
CCCS of the Delaware Valle 215-566-5335 4400 N Reese Street _ Philadelphia _ 1914
His nic Association of Contractors and Enterprises 215-426-8025 167 W Alle he~Avenue, Suite 200 Philadelphia 1914
- -
Nueva Es ranza 215-324-0746 4261 N 5th Street Philadelphia 1914
- -
FOB CDC _ 215-549-8755 1201 W Olne Avenue Philadelphia _ 1914
Northwest Counselin Service _ 215-324-7500 5001 N Broad Street Philadelphia 1914
West Oak Lane 215-224-0880 6259 Limekiln Pike _ Philadelphia 1914
Southwest Community Development Corp. 215-729-0800 6328 Paschall Avenue Philadelphia _ 1914
Germantown Settlement _ _ 215-849-3104 5538 Wa ne Avenue Building C_ Philadelphia _ 1914
Advocates for Financial Independence 215-389-2810 1806 S Broad Street -Suite 1 B Philadelphia _ 1914
Esperanza _ 215-336-3511 1920 S 20th Street _ Philadelphia _ 1914
South PA H.O.M.E.S. 215-334-4430 1444 Point Breeze_ Avenue Philadelphia 1914
Universal Companies 215-732-6518 800 S 15th Street _ _ Philadelphia 1914
Philadel hia Senior Center _ _ 215-546-5879 509 S Broad Street Philadel hia _ 1914
United Communities Southeast PA _ 215-467-8700 2029 S 8th Street _ Philadel hia 1914
American Credit_Counseling Institute _ 888-212-6741 _ 229 E Chestnut Street 1st Floor _ Coatesville _ 1932
CCCS of the Delaware Valle 215-563-5665 1001 E Lincoln Highway Suite Coatesville _ 1932
Housin Partnershi of Chester County 610-518-1522 41 W Lancaster Avenue _ Downin town 1933
Alliance for Better Housin ,Inc. 610-925-1880 648 Buena Vista Drive _ Kennett Square _ 1934
American Credit Counselin Instkute 888-212-6741 21 S Church Street _ West Chester _ 1938
CCCS of the Delaware Valley 800-989-2227 790 E Market Street -Suite 1_70 West Chester _ 1938
American Credit Counseling Institute _ 601-971-2210 526-528 Dekalb Street Norristown 1940
CCCS of the Delaware Valley 215-563-5665 113 E Main Street - 2nd Floor Norristown__ 1940
Consumer Credit Counseling Service of Delaware 610-272-0578 190 Germantown Pike, Suite 140 Norristown__ 1940
Genesis Housin Corp. 610-275-4357 208 Deltalb Street P.O. Box 1170 Norristown _ 1940
American Financial Counseling Services 267-228-7903 405 W Gemtantown Pike _ Norristown_ 1940
CCCS of the Delaware Valle 800.989-2227 1777 Sentry Padcway West _ Blue Bell _ _ 1942
American Financial Counselin Services 267-228-7903 2880 Berge Road -Suite 4 _ Hatfield 1944
American Credit Counselin Instkute 888-212-6741 937 N Hanover Street Pottstown 1946
CCCS of Lehi h Valle , A Division of MMI 800-220-2733 1954 E High Street_ _ Pottstown_ 194
PA Interfaith Commun' Pro rams, In_c. 610-562-2288 22 Willow Road _ Hambur~_ 1952
Bud et Counselin Center 610-375-7866 247 N 5th Street Reading _ 1960
Nei hborhood Housin Services of Readin ,Inc. 610-372-8433 213 N 5th Street -Suite 1030 Reading 19601
American Financial Counseling Services 267-228-7903 906 Penn Avenue Wyomissing 1961
Rev. 10/09
FM646
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*Exhibit has been redacted to remove all personally identifiable information or non public information
~ _
r
ROBERT P. ZIEGLER
RECORDER OF DEEDS ~
CUMBERLAND COUNTY ~
1 COURTHOUSE SQUARE ' ' ~ aK
_Q
CARLISLE, PA 17013
717-240-6370 ' '
Instrument Number - 201216537
Recorded On 6/4/x012 At 11:44:45 AM * Total Fages - 3
* Instrument Type -ASSIGNMENT OF MORTGAGE
Invoice Number -109748 User ID - MSW
* Mortgagor - BENNER, SHAWN W
* Mortgagee - JPMORGAN CHASE BANK N A
* Customer -NATIONWIDE TITLE CLEARING
* FEES
sTATE WRIT TAx $o .5o Certification Page
STATE JCS/ACCESS TO $23.50
JusTICE DO NOT DETACH
RECORDING FEES - $12.00
RECORDER OF DEEDS
PARCEL CERTIFICATION $10.00 This page is now part
FEES of this legal document.
COUNTY ARCHIVES FEE $2.00
ROD ARCHIVES FEE $3.00
TOTAL PAID $51.00
I Certify this to be recorded
in Cumberland County PA
f cet
o d .
° RECORDER O
* -Information denoted by an asterisk may change during
the verifcation process and may not be reflected on this page.
IIIIINNIIII~III~
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3
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Prepared By /Return To:
E.Lance/1VTC, 2100 A1t.19 North,
Palm Harbor, FL 34683
(800),346-9152
.`:Loan 489
i
NSC
Tax CodelPIN: 15-05-0411-030
I ICI ~ III ~N 111 ~NI 1111 I II I
ASSIGNMENT OF MORTGAGE
Contact JPMORGAN CHASE BANK, N.A. for this instrument 780 Kansas Lane, Snite A, Monroe, LA
71203, telephone # (866) 756.8747, which is responsible for receiving payments.
FOR GOOD AND VALUABLE CONSIDERATION, the sufficiency of which is hereb ackngwledged, the
undersigned, MORTGAGE ELECTRONIC REGbSTRATION SYSTEMS, INC. ASS NO FOR
PHILADELPHIA FINANCIAL MORTGAGE, A DIVISION OF LEESPORT BANK ITS S~CESSORS
AND ASSIGNS (MERS Address: 1901 E Voorhees Street, Saite C, Danville, II. 61>~34) by these presents
does convey, grant, sell, assign, transfer and set over the described Mortgage therein to ether with all interest
secured thereby, all liens, and any rights due or to become due thereon to JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 KANSAS LANE, MC 8000, MONROE, LA
71203 (866)756-8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE).
Said Mortgage is dated 04/1312006, in the amount of $83,128.00, made by SHAWN W. BENNER AND DORIS
E. LOWERY to MORTGAGE ELECTRONIC REGISTRATION SYSTEMS,IIVC., recorded on 10/0312008,
in the Office of the Recorder of Deeds of CUMBERLAND County, Pennsylvania, in Book 1946, Page 4009,
and/or Document # 200833415. Modification: DT 08/012007 REC DT 11/13/2007 INSTR 200742631.
Property is cow?mmonly known as: 1 MEADOWS ROAD TWP. OF LOWER MIFFLIN, NEWVII.LE, PA 17241.
Dated on y~ /012 (NIlVi/DD/YYYY)
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR PHILADELPHIA
FINANCIAL MORTGAGE, A DIVISION OF LEESPORT BANK, ITS SUCCESSORS AND ASSIGNS
By:
VICE PRESIDENT
7PCAS 16449025 -CHASE CJ3779033 N4 M1N 100129200123060881 HERS PHONE 1-888-679-HERS
FRMPA 1
16449025
_ _ _ _
T _ ~
r
Y
Loan #:489
STATE OF LOUISIANA PART~H_ O'F O CHITA
Befor n~~_ /~12 (MM/DD/YYYY), personally appeared
f r °~ll as VICE PRESIDENT of MORTGAGE ELECTRONIC
REGISTRATIONS STEMS, INC. AS NOMINEE FOR PHILADELPHIA FINANCIAL MORTGAGE, A
DIVISION OF LEESPORT BANK, ITS SUCCESSORS AND ASSIGNS, who being authorized to do so,
executed the foregoing instrument for the purposes therein contained by his/her/their free act and deed.
He/shelthey is (are) personally known to me.
y / Q_ ~ HELFSI P. TUBLiS, NOTARY PUBLIC
Le~~ MOREHOUSE, LOUISIANA
:e.e1 / 4 LIFETIME COMMtSSiON
Notary Public -State of LOUISIANA NOTARY lD # 40392
Commission expires: Upon My Death
Assignment of Mortgage from:
MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC. AS NOMINEE FOR PHILADELPHIA
FINANCIAL MORTGAGE, A DNISION OF LEESPORT BANK ITS SUCCESSORS AND ASSIGNS
{HERS Address: 1901 E Voorhees Street, Snite C, Danville, II.6183)
to: _ _
MC 5000, ONROEEL 71203 (867
6-8747,, I'I'SCSUCICESSORSOOR ASSIGN (ASSIGNEE)SAS LANE,
Mortgagor. SHAWN W. BENNER AND DORLS E. LOWERY
When Recorded Return To:
JPMorgan Chase Bank, NA
C/O NTC 2100 Alt. 19 North
Palm Harbor, FI.34683
All that certain lot or piece of ground situated in
Mortgage Premise: 1 MEADOWS ROAD TWP. OF LOWER h~IIFFLIN
NEVWII.LE, PA 17241
CUMBERLAND
(Borough or Townshi i/f stated), Commonwealth of Pennsylvania.
Bein more particularly described iun said mortgage.
~ ~ 1/f5~v~, r//Ul~ . , do certify that ttte precise address of the within named assignee
is:
7PMORGAN CHASE BANK, NATIONAL ASSOCIATION, WHOSE ADDRESS IS 700 KANSAS LANE, MC
8000, MONROE, LA 71203 (866)756-8747, ITS SUCCESSORS OR ASSIGNS, (ASSIGNEE)
c
By:
VICE PRESIDEi IT
*164490?,5* JPCAS 16449025 -CHASE CJ3779033 N4 MIN 100129200123060881 MFRS PHONE
I-888-679-HERS FRMPAI
I * ~~I~~
16449025
r
i
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*Exhibit has been redacted to remove all personally identifiable information or non public information
I
After Recording Return To:
Chase Home Finance, LLC
3415 Vision Drive
Columbus, Ohio 43219
(Space above for Recording Data)
Parcel Number.
Loan Number. 17489
MODIFICATION AGREEMENT
This Modification Agreement ("Agreement"), is entered into by Shawn W. Benner and Doris E.
Lowery ("Borrower", whether one or more) in favor of Chase Home Finance LLC, successor by
merger to Chase Manhattan Mortgage Corporation (which, together with arty other subsequent holder
or owner of the Loan is hereinafter referred to as "Lender") and modifies the promissory note or credit
agreement ("Note") dated April 13, 2006, executed by $orrower in favor of Lender. The Note evidences
the indebtedness (the "Loan") owed by Borrower to Lender, in the anginal principal amount of $$3,128.00,
including any subsequent written extensions, renewals, or modifications thereto. The Note is secured by a
MortgageJDeed of Trust or similar security instrument (the "Mortgage") dated and filed for record under
Book VoI. Liber Page Document No. ,Date
Recorded, , in the Office of the County Clerk/Real Property Records/Recorder of Deeds of
Cumberland County, Pennsylvania.
The Mortgage creates a lien or security interest in certain real property described therein and which address
is 1 Meadows Rd, i~lewville, PA 17241 (the "Property"). The Note, Mortgage, and arty other documents
evidencing or securing the Loan are hereinafter refen~ed to as the "Loan Documerrts." Borrower and Lender
have agreed to certain amendments to the Loan Documents, to be effective on December 1, 2008 (the
"Effective Date") notwithstanding the date of execution of this Agreement by the Borrower.
For goad and valuable consideration, including the mutual promises and agreements contained in this
Agreement, Borrower and Lender agree that as of the Effective Date the Loan and Loan Docurrterrts are
modified as follows:
The unpaid principal balance of the Loan is $92,560.97, which includes the amount of 57,783.26 in
deferred fees, interest and other charges, which has been capitalized and added to the principal balance
evidenced by the Note and secured by the Mortgage, and which Borrower hereby renews and extends and
promises to jointly and severally pay to the order of the Lender, together with interest and all other amounts
due and payable under the Loan Documents.
Page 1 of 4
i
' ~'he maturity date of the Note and other Loan Documents is May 1, 2036.
'The interest rate on the Note will be charged at the rates specified as follows:
The annual rate of 6.500% for the period from November 1, 2008 to the maturity date of the loan.
Bonnwer will make monthly payments of principal and interest on the Note as follows:
Monthly payments of 5602.75 beginning on December 1, 2008, and continuing through and
including the maturity date of the loan.
All payments will be made to the following address, or such other address as Lender may direct in writing:
Chase Home Finance LLC
3415 Vision Drive
Columbus, Ohio 43219
If this Agreement arises out of a separate letter agreement between Lender and Borrower with respect to the
modified terms of the Loan, such letter agreement expressly survives execution, delivery and recording of
this Agreement. Except as expressly modified by the terms and provisions of this Agreement, each and
every term and provision of the Note, Mortgage and arty other documents governing, evidencing, security
or pertaining to the Loan are hereby ratified and confirmed and shall remain in MI force and effect.
Upon request of Lender, Borrower agrees to execute or procure and deliver to Lender such other and
further documents and instruments as shall be reasonably requested by lender to better evidence and perfect
the modification transaction contemplated by this Agreement, including, but not limited to, such actions as
shall be necessary (a) to record this Agreement and arty related instrument, document or agreement; (b) to
cause an insurer satisfactory to Lender to issue a mortgagee policy of title insurance, or endorsement
thereto, with respect to the lien of the Mortgage in form satisfactory to Lender, and (c) to satisfy appraisal,
flood, insurance and other legal requiremerds under the terms of the Note and Mortgage and applicable law
and/or in accordance with Lender's policies and procedures.
Any individual who signs this Agreement a5 Borrower but has not previously executed the Note is
executing this Agreement only to mortgage, punt and convey such person's interest in the Property under
the terms of this Agreement and the Mortgage.
[Signatures continue on following pages]
Page 2 of 4
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BORROWER:
BY SIGNING BELOW, Borrower accepts, acknowledges, and agrees to the terms, conditions. and
covenants contained herein.
S;g
we vale Siputym Datc
• Shawn W. Benner Doris E. Lowery
'/t C~.l/
w;o~cu w;mas
ACKNOWLEDGEMENT(S) OF BORROWERS:
STATE OF
COUNTY OF r1? ~
Before me, a Notary Public, in and for said County, personally appeared the above named who,
being personally known to me acknowledged that he/she did sign the foregoing instrument, and that the
same is his/her fire act and deed.
In T moray Wher~ i; I ~~ve hereurut subscribed m name d affixed my office seal at
~D~PII~~• /f~I1.Y;~$this ~ day of ~ , 20
'~a .
Notary Public
~..r~
My commission expires: ~ ~j~ Lti11 AA
p~tllERT
Notary'nbNe
NEWVILLE 1080.. CWYNI~LAMD
My Commlalan i. ZOIZ
Page 3 of 4
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I
' LENDER:
Chase Home Finance LLC, successor by merger to Chase Manhattan Mortgage Corporatian
By: 1~~~-- .
Maritza Nieto, Assists t Vice President
ACKNOWLEDGEMENT(S~ OF LENDER:
STATE OF ~ ~ ~O
COUNTY OF t'y'a o, l
~ f ~
Before me, a Notary Public, in and for said County, personally appeared the above named Maritza
Nieto, Assistant Vice President of the Lender identified in this Agreement, who, being personally known to
me acknowledged that he/she did sign the foregoing instrument for and on behalf of such Lender, and that
the same is his/her free act and deed.
In Testimony Whereof, T have hereunto subscribed my name and affixed my official seal at
C a~ u,a~ b o 3 O ti e o - ,this Z t sf day of A- a v~ l 20_~.
~'jdAL ~}8flflJ(P fl ~
' ~ ~ tary Public
~~~11.042pf0
My commission expires:
Page 4 of 4
' ,BORROWER: ~
BY SIGNING BELOW, Borrower accepts, acknowledges, and agrees to the terms, conditions, and
covenants contained herein.
s ~ S;~ om
Shawn W. Benner Doris E. Lowery
wimrn w~
ACKNOWLEDGEMENT(S) OF BORROWERS:
STATE OF
COUNTY OF
Before me, a Notary Public, in and for said County, personally appeared the above named who,
being personally known to me acknowledged that he/she did sign the foregoing instrument, and that the
same is hisJher free act and deed.
i Testi y ereof, I have hereu tg subscribed name and affixed my offici seal at
this day of ~ ~2 , 20~~ .
I ~wt/1 ~
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My commission expires: l1tA A 011
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MY Cotn4Mglon lE>~lM 1ybM
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' ' • F..ENDER:
Chase Home )Finance LLC, successor by merger to Chase Manhattan Mortgage Corporation
By:
Maritza Nieto, Assistant Vice President
ACKNOWLEDGEMENT(S) OF LENDER:
STATE OF
COUNTY OF
Before me, a Notary Public, in and for said County, personally appeared the above named Maritza
Nieto, Assistant Vice President of the Lender identified in this Agreement, who, being personally known to
me acknowledged that he/she did sign the foregoing instrument for and on behalf of such Lender, and that
the same is liis?her free act and deed.
In Testimony Whereof, I have hereunto subscribed my name and affixed my official seal at
,this day of ~ 20
Notary Public
My commission expires:
Page 4 of 4
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
c ° ~ ,
JPMORGAN CHASE BANK, NATIONAL ~ a ~ ~
ASSOCIATION ~
Plaintiff Case No. So7S ~ ter-' N c~
o -~r-c
SHAWN W. BENNER zp ~ ~cm,
DORIS E. LOWERY D
Defendant(s) ~
~
NOTICE OF RESIDENTIAL MORTGAGE FORECLOSU
DIVERSION PROGRAM
You have been served with a foreclosure complaint that could cause you to lose your home.
[f you own and live in the residential property which is the subject of this foreclosure action, you ay be able
to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your len er.
If you do not have a lawyer, you must take the following steps to be eligible for a conciliatio
conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services
at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal
representative at no charge to you. Once you have been appointed a legal representative, you must promp ly meet
with that legal representative within twenty (20) days of the appointment date. During that meeting, you ust
provide the legal representative with all requested financial information so that a loan resolution proposal an be
prepared on your behalf. If you and your legal representative complete a financial worksheet in the forma attached
hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which
must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. I you do so
and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of y ur lender
in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit p oceeds
forward.
If you are represented by a lawyer, you and your lawyer must take the following steps to be ligible for
a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointor nt of a
legal representative. However, you must provide your lawyer with all requested fmancial information sot at a loan
resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial workshe t in the
format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the ourt,
which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a
conciliation conference is scheduled, you will have an opportunity to meet with a representative of your le der in an
attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit procee s forward.
IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE TEPS
REQUIRED BY THI5 NOTICE. THIS PROGRAM IS FREE.
Respectfully submitted:
(Signa ' e of unsel for Plainti
vj1~z
Date
_ _ _ i
Cumberland County Residential Mortgage Foreclosure Diversion Pragrram
Financial WorksEleeE
Date j
Cumberland County Court of Common Pleas Docket
BORROWER REQUES'T' FpR HARDSITYP ASSISTANCE
'i`o complete•your request for hardship assistance, your lender must consider your
circumstances to determine possible options while working with your
Please provide the fallowing information to the best of your knawledgec
Borrower name(s):
Property Address:
City: State:_. Zip:......
!s the property far sale? Yes ~ No ? Listing date: Price: $
Realtor Name:. Realtor Phone:
Borrower Occupitd? Yes „_J Na
Mailing Address (if different):
City: State' Zip:
Phone Numbers: Home: Offtce:
Cell: pther~ _
Email:
ofpeople in household: How long?
Mailing Address;
City: State: Zip:
Phone Numbers: Home: office: _
Cell: Other:
Email;
# of people in household: How lung?
First Mortgage Lender:
Type of Loan:
Loan Number: Date You Closed Yaur I1oan:
Second Mortgage Lender:
Type of Loan:
Loan Number.
Total Mortgage Payments Amount: $ Included Taxes & l,asurance:
Date of Last Payment:
t?rimary, Reason for Default:
is the loan in Baiilcruptcy? 'Yes ? Na
if yes, provide names, location of court, case nur~nber & attorney;
- - - I
i
Assets Amount Owed: Value:
I-Iamc: $ $
Other Real Estate: $
Retirement Funds: S S
Investments: $ $
Checking: $ $
Savings: $ $
Other: $ $
Autornabilc #1: Model: Year:
Amount owed: Value:
Automobile #2: Model: Year:
Amount awed• Value;
Other trans}wrtatian (ttutomobiles,,boots. motorcycles~, Model:
Year. Amount owed: Value
Monthly Income
Name of .Employers:
f.
? ~ - - -
Additional Income Description (nest wages}:
1. monthly amount:
2. monthly amauat:
Borrower Pay Days: Co-Harrower Fay Days:
Monthly Expenses: (Please only include expenses you are currently paying}
EXPENSE AMOUNT EXPENSE A.1VlOUNT
Mo Food
2 M Utilities -
Car Pa ens Cando/Nei .Fees
Auto Insurance Med.. not covued
Auto fvcl/re irs 4t}Eer ro , a went
Install. Loan Pe ment Cables TV
Child Su rt/Aiirn. S din More
Da JChild Care/Tuet, ether Ex nscs
Amount Available for Monthly Mortgage Payments Based on Tncotne & Expenses:
Have you been working with a Housing Counseling Agency?
'Y'es No ?
Tf yes, please provide the following information:
Counseling Agency:
Couciselor:
..Phone (Office): Eax:
)<n~ai l
Have you. made application for Homeowners Emergency Mlartgage Assistance Program
(I-bEMAI'} assistance?
Yes No
If yes, please indicate the status of the application:
Have you had any prior negotiations with your tender or bender's loan servicing company
to resolve your delinquency?
Yes ? N'a
If yes, please indicate the status of those negatiadons:
Please provide the following information, if krtaw, regarding your lender or lender's loan
servicing company:
Lender's Contact (Name}: _ Phone:
Servicing Company (Name):
Contact: Phone.:
T/We, ,authorize the above
named to uselrefer this information to my lenderlservicer far the sole
purpose of evaluating my financial situation for possible mortgage options. UWe
understand that Uwe amlare under no obligation to use the services provided by the above
named
Borrower Signature Date
Ca-Borrower Signature Date
Please forward this document along with the following information to lender sad
lend~etr's counsel:
~Y Proof of income
_~V Pant 2 bank statements
Y Proof of arty expected income for the last ~5 days
Copy of a current utility bill
Letter explaining reason for deliuquency and any supporting documentation
(hardship letter}
V Listing agreement (if property is currently on the ~rtarket)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ut ?t?u?- 1(J(t? ? t _
) Ht PRi t HONG - rj
Jody S Smith
Chief Deputy 2912 SEP _b QM 10: 13
Richard W Stewart
Solicitor CUMBERLAND COUNTY
PERNSYMNI.A
JP Morgan Chased Bank, NA
Case Number
vs.
Shawn W. Bennet (et al.) 2012-5259
SHERIFF'S RETURN OF SERVICE
08/27/2012 06:061 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on August
27, 2012 at 1806 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and
Notici0 of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit:
Shawo W. Benner, by making known unto Doris E. Lowery, adult in charge at 1 Meadows Road, Newville,
Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personally the
said true and correct copy of the same.
$HKIV'11111% %111111' SHALL, DEPUTY
08/27/2012 06:061 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on August
27, 2012 at 1806 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and
Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit:
Doris E. Lowery, by making known unto herself personally, at 1 Meadows Road, Newville, Cumberland
Coun y, Pennsylvania 17241 its contents and at the same time handing to her personally the said true
and correct copy of the same.
UTSH , PUN
SHERIFF COST: $56.00
August 28, 2012
SO ANSWERS,
(5Z
WON R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Teleosoft, Inc.
WRIT OF EXECUTION and/o-• ATTACHMENT
COMMONWEALTH OF I'ENNSYL'dANtA)
COUN"fY OF CUMBERLAND)
NO. 12-5259 Civil
CIVIL ACTION - LA'W
TO Tl-lE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION Plaintiff (s)
From SHAWN W. BENNER, DORIS E. LOWERY
(() You are directed to levy upon the property of the defendant (s)and to sell SEE LECaAL
DESCRIPTION .
(") y"au 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 fi•om
paving any debt to or for the account of the defendant (s) and from delivering any property of t:}~ie defendant
(s) or otherwise disposing thereof;
(=) 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 helshe has been added as a
garnishee and is enjoined as above stated.
4mount Due: $102,291.82 L.L.:.50
Interest FROM 10/10/2012 TO DATE', OF SALE PER D[EM AT $15,87
Atry's Cumm: °io Due Prothy: $2.25
Atty Paid: $207.25 Other Costs:
Plaintiff Paid:
Date: 10/12/12 ^~ ~''`
1~~ ~-/ i
David D. Buell, Prothonotary
(Seal} ~~ ~
Deputy
RF,QUEST[NG PAR"]'Y:
Name:.NIi~L P. JENKINS, ESQUIRE
Address: KML LAW CROUP, P.C.
SUITE 5000 - BNY INDEPENDENCE CENTER
?O1 MARKET STREET
PHILADELPHIA, PA 19106
Atti~rney i~or: PLAINTIFF
Telephone: 215-627-1:322
Supreme Court ID No. 306588
'' PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE)
P.R.C.P 3180-3183
___.
,_, -
KML Law Group, P.C. ~~
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Suite 50(10 -1=SNY Independence Center ~--~~ ..:
701 Market S~~treet ~"' _~_
Philadelphia, PA 19106 -- ~ = _ _
215-627-1322 ~ "
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Attorney (or Plaintiff _ ~~ ~ ~ ~ .
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JPMORGAN CHASE BATIK, NATIONAL ~ ~ - -_~=, =
ASSOCIATION
c/o 3415 Vision Drive 1N THE COURT OF COIvCMON PLEAS
Columbus, OH 43219
vs.
Plaintiff
of Cumberland Cuunty
SHAWN W. I3ENNER
DORIS E. LOWERY
Mortgagor(s) and Record Owner(s)
1 l~feadows Road
Newville. PA 17241
CIVIL ACTION -- LA W
ACTION OF MORTGAGE kORECLOSURE
No. 12-5:?59 Civil
Defendant(s)
PRAECIPI; FOR WRIT OF EXECUTION
TO THE PROTHONOTARY':
Issue Writ of Execution in the above. matter:
Amount Due
Interest from
lOl 1Of2012 to Datc of
Sale per diem at
$15.87
(Costs to be added)
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3
By. j ~
$102,291.82
KML O P, P.C.
~ ~ ~y ~ ~~~ a ~ Michael cK ver Pa. ID 56129
-~ ~ _Jay E. Kivitz Pa. ID 26769
~~~ Lisa Lee Pa. ID 78020
_ (~ (( Kristina Murtha Pa. ID 61858
03 , ~ ~ ~~ ~~ David Fein Pa. ID 82f>28
~~ ~~ __Thomas Puleo Pa. ID 27615
~~ ~~ Joshua I. Goldman Pa. 205047
~~~ Jill P. Jenkins Pa. ID 3065H8
~~ ~ Attorneys for Plaintiff
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ALL those certain two (2j certain tracts of land situate in Lower Mifflin Township, Cumbc:~rland County,
Pennsylvania, according to a subdivision plan prepared by John R. Kissinger Surveying, E:~ntitled
Subdivision for Edward L. Stum, dated September 25, 20001 and recorded in Cumberland County Plan
Back 82, Page 50, bounded and described as follows, to wit:
TRACT NO 1:
BEGINNING at a set railroad spike located in T-418, known as Meadows Road, at the corner of Lot 10 of
the Plan described herein; thence along Lot 10 North 46 degrees 29 minutes 01 seconds east 297.17 feet
to a set iron pin located at the corner of Lot 10A and 11A; thence along Lot 11A south 44 degrees 25
minutes 10 seconds east 320.00 feet to a set railroad spike located in the centerline of Pennsylvania
Route 997, also known as the Roxbury Road; thence through the centerline of Pennsylvania Route 997,
also known as Roxbury Road south 43 degrees 16 minutes :?4 seconds west 95.07 feet to a point located
in the centerline of the said roadway; thence continuing through the centerline of said roadway south
45 degrees 57 minutes 24 seconds west 240.18 feet to an existing railroad spike located ,:~t the
intersection of Pennsylvania Route 99;r, also known as Roxbury Road and T-418, also known as
Meadows Road; then~~e through the said T418, also known as Meadows road, north 37 degrees 46
minutes `_i9 seconds west 329.14 feet to a set railroad spike, the place of EEGINNING.
CONTAINING a total of 2.3605 acres.
BEING known as Lot 11 of the Subdivision referenced above.
TRACT NO. 2:
BEGINNING at a set railroad spike located in the centerline of Pennsylvania a Route 997, also is known as
the Roxbury Road, at the corner of Lot 11; thence along Lot 11 north 44 degrees 25 minui:es 10 seconds
west 320.00 feet to a set iron pin located at the corner of Lot 11 and Lot 1~D; thence along Lot 10A north
67 degrees 19 minutes 20 seconds east. 104.10 feet to a point located at lands now or formerly of
Richard L Picken; thence along lands of Picken South 46 degrees 25 minutes 38 seconds 1=ast 277.33
feet to a set railroad spike located in the centerline of Pennsylvania Route 997, also known as the
Roxbury Road; thence through the said centerline south 43 degrees 16 minutes 24 seconds west 106.50
to a set railroad spike, the place of BEGINNING. CONTAINING 0.6942 acres total.
BEING known as Lot 1].A of the aforementioned Subdivision.
Both tracts are subject to conditions and restrictions set forth in the aforerentioned Subdivision
IMPROVEMENTS consi>t of a residential dwelling.
MUNICIPALITY LOWER MIFFLIN TOWNSHIP
BEING PREMISES: 1 Meadows Road, Newville, PA 17241
SOLD as the property of Shawn W. Benner and Doris E. Lowery,
TAX PARCEL #15-OS-04:1 1-030
if~
K ~L Law Group, P.C.
S~ to 5000 - BNY Independence Center
70 l Market Street
Ph ladelphia, PA 191.06
~-6? ~-13_~2
At ornev for Plaintiff
.iP`~10RGAN CHASE BANK, NATIONAL
AS SOCCATI`ON
c/c 3415 Vision Drive
Co>umbus, OH 43219
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IN THE COURT OF COMMON PLEAS
of Cumberland 4 ~"ounty
Plaintiff
vs.
SHAWN W. BENNER
DORIS E. LOWERY
(Mortgagor(s) and Record Owner(s))
1 Meadows >;:oad
Newville. PA 17241
Defendant(s)
CIVR. ACTION - L,aw
ACTION OF MORTGAGI? FORECLOSURE
No. 12-5259 Civil
AFFIDAVIT PURSUANT TO RULE 3129
JPMORGAN CHASE BANK, NATIONAL ASSOCIATION., Plaintiff in the above action, by counsel, KML Law
Group, P. C., sets forth as of the date the praecipe for the writ of execution was tiled the following information concerning the
real property located at:
1 Meadows Road
Newville. PA 17241
l .Name and address of Owne~x(s) or Reputed Owner(s):
SHAWN W. BENNER
1 1Vieadows Road
Newville, PA 17241
DORIS E. LOWERY
1 Pvleadows Road
Newville, PA ] 7241
2. Name and address of Dcfendant(s) in the judgment
SHAWN W. BENNER
1 ndeadows Road
Newville, PA 17241
DORIS E. LOWERY
1 Meadows Road
Newville, PA ]7241
3 Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle, PA 17013
PA DEPARTMENT OF PUBLIC WELFARE -Bureau of Child Support E;ntbrcement
health and Welfare Bldb. -Room 432
F'.O. Box ?675
Harrisburg, PA 17105-2675
4. Vame and address of the last recorded holder of every mortgage of record:
5. Name and address of every other person who has any record interest in or record lien nn the property and whose interest
ma ~ be of fecte~d by the sale:
6. Name and address of every other person of whom the plaintiff has knowledge: who has any record interest in the property
which may he affected by the sale.
7. Name and address of every other person of whom the plaintiff has knowledge who has any interest in the property which
ma~~ be al fected by the sale.
TENANTSlOCCUP ANTS
1 .Meadows Road
Newville. PA 1724]
I verify that the statements made in this affidavit are true and correct to the best of my information and belief. I
understand that false statements herein are made subject to the penalties of l~4 Pa. C.S. Section 4904 relating to unsworn
falsification to autho~itie~ ~ i ~
DATF_D: _ ---- ~ ~f") ~ ~ t'om' ~ i ~ ~ !i
,~, `
KML ~L~ ' ~# P, P.C.
Michael McKeever Pa. ID 56129
Jay E. Kivitz Pa. ID 26769
__Lisa Lee Pa. ID 78020
_Kristina Murtha Pa. ID 61858
_ David Fein Pa. ID 82628
VThomas Pulc;o Pa. ID 27615
_`Joshua I. Goldman Pa. 205047
__~Jil1 P. Jenkins Pa. ID 30658f,
Attorneys for Plaintiff
1:'.-5'?_59 Civil
KML Law Group, P.C
Sure 5(~- BNY Independence Center
701 M~uket Street
Philadelphia, PA 19106
t215)6~7-1322
Attorney for Plaintiff
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JYMORGAN CHASE BANK, NATIONAL
ASSOCIATION
r/o 3415 Vision hive
Columbus, OH 43219
Plaintiff
vs.
SHAWN W. BENNER
DOR:[S E. LOWERY
Mortgagor(s) and Record Owner(s)
1 Meadows Road
Newville, PA 17241
Defendants
CIVIL ACTION -LAW
ACTION OF MORTGAGE
FORECLOSURE
Docket No. 12-5259 Civil
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT' A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BF;
USED FOR THAT PURPOSE.
]NOTICE OF SHERIFF'S SALE OF' REAL PROPERTY
TO: BENNER. SHAWN W.
SHAWN W. BENNER
I Meadows Road
Newville, PA 17241
Your house at 1 Meadows Road, Newville, PA 17241 is scheduled to be sold at Sheriffs Sale on
Wednesday, March 06, 2013, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of $]02,291.82 obtained by JPMORGAN CHASE BANK, ]NATIONAL
ASSOCIATION against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
(~~~ prevent this Sheriffs Sale you must take immediate action:
I . The sale will be cancelled if you pay to JPMORGAN CHASE BANK, INATIONAL
ASSOCIA"PION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how
much you must pay ca71 our office at 215-825-6329 or 1-866-413-231 I.
~" ~~ ~',~ ~~n
IN THE COURT OF COMMON PLEAS
of Cumbe-nand Coutrry
'~ You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if
the judgment was impiroperly entered. You may also ask the Court to postpone tihc sale for ~*ood cause.
l ~" -ti259 Civil
3. 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 morn, chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOLI HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. ]f the Sheriff's Sale is not stopped, your property will be sold to the highest bidder. Ynu may find
uut the price bid price by calling the Sheriff of 717-240-6390.
_'.. You may be able Io petition the Court to set aside the sale if the bid price was grossl~>> inadequate
compared to the value of your property.
The sale will go through only if the buyer pays the Sheriff the full amount due in the sate. To find
out if this has happened, you may call the Sheriff' of 717-240-6390,
4. If the amount due from the Buyer is not paid to the Sheriff, you will }remain the owner i~f she
property as if the sale never happened.
S. You have a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff rives 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 schedule of
distribution oC the money bid for your house will be filed by the Sheriff within thirty (30) days t~rom the,
date of the Sheriffs Sale. This schedule. will state who will be receiving that money. The money will be
paid out in accordance with this schedule unless exceptions (re:asons why the proposed distribution is
wrong) are filed with the Sheriff within ten (10) days after the schedule of distribution is filed.
7 You may also have other rights and defenses, or ways of getting your house back, if you at~t
immediately after the sale.
t( You may contact the Foreclosure Resource Center: http://www.philadelphiafed.or,lforeclosure/
YUU SHOULD TA>tiE THIS PAPER TO YOUR LAWYER A,T ONCE- IF YOU DO NOT HAVE A
LAWYER OR CANNOT AFFORD ONE, CO TO OR TELEPHONE THE OFFICE LISTED BELOW TO
FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle, PA 17013
717-243-9400
'-~~"~59 Civil
Resources a~•ailable for Homeowners in Foreclosure
ACT NOW!
Even though your lender (and our client) has filed an Action of Mortgage
h'oreclosure against you, you still may be able to SAVE YOUR l`-TOME FROMI
FORECLOSURE.
] ). Call an attorney. For referrals to a qualified attorney call either of t ~~e
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-8C-0-989-2227 fc~r ft-ee
counseling.
3). Visit HUD'S website www.hud.~ for Help for Homeowners Facin~* the
Loss of Their Hames.
4). Pennsylvania Housing Finance Agency ~~lso offers other loan programs that
play assist homeowners in default. Please See the P1HFA website
http:/lwww.phfa.or~/consumers/homeownersireal.as~.
5). Call the Plaintiff (your lender) at and ask to speak to someone about I.~osS
Mitigation or Home Retention options.
6}. Call or contact our office to request the amount to bring the account. current,
or pa~roff the mortgage or request a Loan Workout I Home Ketention Package. (:'all our
toll free number at I-866-413-2311 or via email at
homeretentionC kmllawgrou~.com.com. Call Seth at 215-825-6329 or fax 215-82>~-
6429. The figure andlor package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in cl~~arge of
our firm's Homeowner Retention Department is David Fein who can be reached at 2 ] 5-
825-6.318 or Fax: 215-825-6418. Please reference our Attorney File Number of
113617FC.
Para inforrnacion en espanol puede communicarse con Loretta al 21.5-825-6344.
KML Law Grout, P.C.
Suite 5000 - BNY Independence Center _ _
701 Market Street ~ ~ -~ _ .
Philadelphia, PA 19106 ~ ~ ~ v '' `~'
., 4,_ ,
21 _>"-627-1322 1 ` ~ _ i ~ ~. r , { ~ 6 VJ ,
Attorney for Plaintiff -. i, 9~
~ „'~°,'1
JPMORGAN CIIASE BANK, NATIONAL ASSOCIA~TT~~ '
c/o 341.5 Vision Drive
Columbus, OH 432.19
U a ~ 4`f
+rg}<
Plaintiff
vs.
SHAWN W. BENNER
DORIS E. LOWERY
Mortgagor(s) and Record Owner(s)
1 Meadows Road
Newville, PA 17241
Defendant(s)
CERTIFICATION AS TO THE SALE OF REAL, PROPERTY
IN THE. COURT OF
COMM(:)N PLEAS
of Cumberland County
CIVIL ACT10N -LAW
ACTION OF
MORTGAGE FORECLOSURE
NO. 12-5259 Civil
Plaintiff, by counsel, hereby ceRifies that it has complied with the provisions of Act 91 of 1983 and/or the real
property in question is not subject to the Act.
~! i
J
By:
KML P, P.C. ----
Michael cKeever Pa. TD 56129
Jay E. I~ivitz Pa. CD 26769
Lisa Lee Pa ID 78020
Krishna Murtha F'a. ID 6l 858
David Fein Pa. ID 82628
Thomas Puleo Pa. ID 27615
Joshua L Goidmam Pa. 205047
___;~Jill P. Jenkins Pa. ID 306588
Attorneys for Plaintiff
r
K1VIL LAW GROUP,P.C. 113617FC
Suite 5000 CF: 08/23/2012
BNY Mellon Independence Center 1 t i.•E D-0 F F I CE: SD: 06/05/2013
701 Market Street OF I HE PROTH0140 rAt Y $102,291.82
Philadelphia,PA 19106-1532 7013 MAY 10 P11 3: 12
215-627-1322
Attorney for Plaintiff rl IMAPP
JPMORGAN CHASE BANK,NATIONAL" N N$LVA I A HE COURT OF COMMON PLEAS
ASSOCIATION
c/o 3415 Vision Drive of Cumberland County
Columbus,OH 43219
Plaintiff CIVIL ACTION—LAW
vs.
ACTION OF MORTGAGE FORECLOSURE
SHAWN W.BENNER
DORIS E.LOWERY Term
Mortgagor(s)and No. 12-5259 Civil.
Record Owner(s)
1 Meadows Road
Newville, PA 17241
Defendant(s)
CERTIFICATE OF SERVICE
PURSUANT TO Pa.R.C.P.3129.2 (c)(2)
Robert Murray, an employee of KML Law Group,P.C., counsel of Plaintiff,hereby certifies that service
on the Defendants of the Notice of Sheriff Sale was made by:
(X) Personal Service by the Sheriffs Office/competent adult(copy of return attached).
( ) Certified mail by KML Law Group,P.C. (original green Postal return receipt attached).
( ) Certified mail by Sheriffs Office.
( ) Ordinary mail by KML Law Group,P.C. to Attorney for Defendant(s)of record(proof of mailing
attached).
( ) Acknowledgment of Sheriffs Sale by Attorney for Defendant(s)(proof of acknowledgment attached).
( ) Ordinary mail by Sheriffs Office to Attorney for Defendant(s)of record.
IF SERVICE WAS ACCOMPLISHED BY COURT ORDER.
( ) Premises was posted by Sheriffs Office/competent adult(copy of return attached).
( ) Certified Mail&ordinary mail by Sheriffs Office(copy of return attached).
( ) Certified Mail&ordinary mail by KML Law Group,P.C. (original receipt(s)for Certified Mail
attached).
( ) Published in accordance with court order(copy of publication attached).
Pursuant to the Affidavit under Rule 3129(copy attached), service on all lienholders(if any)has been made by
ordinary mail KML Law Group,P.C. (copies of proofs of mailing attached).
The undersigned understands that the statements herein are subject to the penalties provided by 18 Pa. C.S.A.
Section 4904.
Respectfully submitted,
BV: Rob M y
Legal Assista
r �
Name antl Address of Sender Check type of mall or service:
Aft Stamp Here re GOLDBEC (if issued
SUITE 5000 q Ce tied ❑Recorded oar very(International) cartiecate of mailing,
701 MARKET STREET q COD q Registered or for additional copies ---—_-- ------- -- --- -
PHILADELPHIA,PA q Delivery Confirmation q Return Receipt for Merchandise Of this bill) --'--
q Express Mall q Signature Confirmation Pos""and 1
191 Q6-1532 q insured
- 0afa of Recobt
Amide Number" Addessee(Name,StmK City,same,&bp Code) Postage Fee Handling
W �w Rr` iR 4
1. DOMESTIC RELATIONS OF CUMBERLAND 01.320
COUNTY 0 2 1M
PO Box 320 TENAN S/OCCUP 4NTS 000428SS57 xTie 2012
CODE 19106 h
Carlisle,PA 17013 1 Mead ws Road MAILED FROM r
2. Newvoll -PA-T7241--
_. .. ..
DEPARTMENT OF PUBLIC WELFARE- .. -
Bureau of Child Support Enforcement Iti,
Health and Welfare Bldg.-Room 432 (ia
3• Harrisburg,PA 17105-2675 G
Sb LL
4. m
5. �r
6.
lid
7. r
ri
t;
t
3otat Number f Pieces Total N bar of Pieces Posirrraster,Per(Name receiving ample _
urea by Received office See Privacy Act Statement on Reverse
f"
PS Form 387 , ebruary (Page 1 of 2) Complete by Typew lter,Ink,or Bail Point Pen i
11361*C Cumberland County Sale Date:03/06/201 is?
SHAWN W.BENNER&DORIS E.LOWERY .try
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
,Sheriff
;iutp rtFr�l�
Jody S Smith
Chief Deputy :r
-.-._. R ichard W Stewart
SolicitorrF:e.;r
JP Morgan Chase Bank, NA Case Number
vs.
Shawn W. Benner(et al.) 2012-5259
SHERIFF'S RETURN OF SERVICE
01/02/2013 02:23 PM-Deputy Amanda Cobaugh, being duty 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 1 Meadows Road, Newville,PA 17241,Cumberland
County.
01/02/2013 02:23 PM-Deputy Amanda Cobaugh, 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 personally handing a true copy to a person representing themselves to be DORIS LOWERY,
WIFE,who accepted as"Adult Person in Charge"for Shawn W. Benner at 1 Meadows Road, Lower
Mifflin Township, Newville,PA 17241,Cumberland County.
01/02/2013 02:23 PM-Deputy Amanda Cobaugh, being duty 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 personally handing a true copy to a person representing themselves to be the Defendant,to
wit: Doris E. Lowery at 1 Meadows Road, Lower Mifflin Township, Newville, PA 17241, Cumberland
County.
SHERIFF COST: $1,264.20 SO ANSWERS,+'' �,�
January 22,2013 RONW R ANDERSON, SHERIFF
C)CouryS"W.-h n1,1f,let. acar,,n,.
K 4L- R!kW GROUP,P.C.
Suite 5000—BNY Mellon Independence Center
701 Market Street
Philadelphia,PA 19106
215-825-6320
Attorney for Plaintiff
JPMORGAN CHASE BANK,NATIONAL IN THE COURT OF COMMON PLEAS
ASSOCIATION
c/o 3415 Vision Drive of Cumberland County
Columbus,OH 43219
Plaintiff
CIVIL ACTION-LAW
vs.
SHAWN W.BENNER ACTION OF MORTGAGE FORECLOSURE
DORIS E.LOWERY
Mortgagor(s)and Record Owner(s) Term
No. 12-5259 Civil
1 Meadows Road
Newville,PA 17241
Defendant(s)
AFFIDAVIT PURSUANT TO RULE 3129
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,Plaintiff in the above action, by and
through an authorized employee of its attorneys,KML Law Group,P.C., sets forth as of the date the praecipe for
the writ of execution was filed the following information concerning the real property located at:
1. Meadows Road
Newville, PA 17241
1.Name and address of Owner(s)or Reputed Owner(s):
SHAWN W. BENNER
1 Meadows Road
Newville,PA 17241
DORIS E.LOWERY
1 Meadows Road
Newville,PA 17241
2.Name and address of Defendant(s)in the judgment:
SHAWN W.BENNER
1 Meadows Road
Newville,PA 17241
DORIS E. LOWERY
1 Meadows Road
Newville,PA 17241
3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be
sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle,PA 17013
PA DEPARTMENT OF PUBLIC WELFARE
Bureau of Child Support Enforcement
Health and Welfare Bldg. -Room 432
P.O. Box 2675
Harrisburg,PA 17105-2675
4.Name and address of the last recorded holder of every mortgage of record:
5.Name and address of every other person who has any record interest in or record lien on the property and
whose interest may be affected by the sale:
6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in
the property which may be affected by the sale.
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.
TENANTS/OCCUPANTS
1 Meadows Road
Newville,PA 17241
I verify that the statements made in this affidavit are true and correct to the best of my personal
knowledge or information and belief. I understand that false statements herein are made subject to the penalties of
18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
DATED: May 9, 2013
KW L-a -fou C.
BY: Robert Mu
Legal Assistant
KML LAW GROUP,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106-1532
Attorney for Plaintiff
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION IN THE COURT OF COMMON PLEAS
c/o 3415 Vision Drive
Columbus,OH 43219 of Cumberland County
Plaintiff
vs.
Term C'-) -�
SHAWN W.BENNER No. 12-5259 Civil C_- u, —3
DORIS E.LOWERY k
Mortgagors and Record Owners ;
1 Meadows Road 1 V
Newville,PA 17241
Defendants
MOTION TO POSTPONE SHERIFF'S SALE
Plaintiff,JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,by and through its attorneys,
in support of its Motion to Postpone Sheriffs Sale represents as follows:
1. Plaintiff is the holder of first mortgage upon the premises, 1 Meadows Road Newville,PA 17241,
hereinafter the"mortgaged premises."
2. Defendants are the mortgagors and record owners of the mortgaged premises.
3. A Sheriffs Sale of the mortgaged premises was scheduled. for March 06, 2013, and was
postponed until May 01,2013;and further postponed to June 05,2013 in order for Plaintiff to review the loan
for possible alternatives to foreclosure.
4. Plaintiff requests an additional postponement to July 10,2013 to allow additional time to explore
possible alternatives to foreclosure.
5. This case has not been previously assigned to a Judge.
6. The Defendants are unrepresented by counsel and the Plaintiff has no means to seek concurrence
of the instant motion except by mail.
7. There is no prejudice to any party.
WHEREFORE,Plaintiff requests that the Court enter Plaintiffs proposed order,which will postpone
the sale until Wednesday,July 10,2013.
Respectfully submitted,
By: �
K II,LAW G OUP,P.C.
Michael McKeever Pa.ID 56129
Jay E.Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615
Jill P.Jenkins Pa.ID 306588
Alyk L.Oflazian Pa.ID 312912
Attorneys for Plaintiff
WOLF&WOLF,14, neys at Law
Date: June ,2013 By:
Nat .W4Wquire
0 West Hi t
Carlisle,PA 013
Supreme Court I.D.No. 87380
(717)241-4436
Local Counsel for Plaintiff
>:
KML LAW GROUP,P.C.
Suite 5000-RNY Independence Center
701 Market Street
Philadelphia,PA 19106-1532
Attorney for Plaintiff
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION
c/o 3415 Vision Drive IN THE COURT OF COMMON PLEAS
Columbus,OH 43219 Plaintiff
vs. OF Cumberland COUNTY
SHAWN W.BENNER and DORIS E.LOWERY
Mortgagors and Record Owners Term
1 Meadows Road No. 12-5259 Civil
Newville,PA 17241
Defendants
MEMORANDUM OF LAW
Pennsylvania Rule of Civil Procedure 3129.3(b) allows a judgment creditor to postpone a sheriffs
sale up to two times within a one hundred thirty day period without new notice. The postponement must be
announced to all assembled bidders. As outlined in the attached motion,the Sheriff's Sale has already been
postponed as allowed by Pa.RC.P.3129.3(b). Plaintiff seeks Court approval under,inter alia Pa.RC.P. 126,
to postpone the sale again. This postponement will be announced to all assembled bidders.
CONCLUSION
For all the reasons discussed above and in the attached Motion,the Court should enter the
attached Order postponing the Sheriffs Sale.
Respectfully submitted,
By:
KML LA GROUP,P.C.
Michael McKeever Pa. ID 56129
Jay E.Kivitz Pa.ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
.—Thomas Puleo Pa.ID 27615
Zill P.Jenkins Pa.ID 306588
�Ail,k L.Oflazian Pa.ID 312912
Attorneys for Plai ff
WOLF&WOLF tt ne aw
Date:June j,2013 By:
Nat C.W;IfAsquire
West High Street
Carlisle,PA 17013
Supreme Court I.D.No. 87380
(717)241-4436
Local Counsel for Plaintiff
- -
KML LAW GROUP,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106-1532
Attorney for Plaintiff
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION IN THE COURT OF COMMON PLEAS
c/o 3415 Vision Drive
Columbus,OH 43219 OF Cumberland County
Plaintiff
VS.
Term
SHAWN W.BENNER No. 12-5259 Civil
DORIS E.LOWERY
Mortgagors and Record Owners
1 Meadows Road
Newville,PA 17241
Defendants
VERIFICATION
Esquire, hereby states that he/she is the attorney for Plaintiff
herein, and that all of the facts set forth within the attached Motion to Postpone Sheriffs Sale are true and
correct to.the best of his/her knowledge, information and belief. The undersigned understands that the
foregoing statements are made subject to the penalties of 18 Pa.C.S.A. §4904.
Respectfully submitted,'
By:
KMIL LA GROUP,P.C.
Michael McKeever Pa. ID 56129
Jay E.Kivitz Pa.ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615
Jill P.Jenkins Pa.ID 306588
Alyk L.Oflazian Pa.ID 312912
Attorneys for Plaintiff
KML LAW GROUP,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106-1532
Attorney for Plaintiff
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION
c/o 3415 Vision Drive IN THE COURT OF COMMON PLEAS
Columbus, OH 43219"
Plaintiff OF Cumberland County
vs.
SHAWN W.BENNER and DORIS E.LOWERY Term
Mortgagors and Record Owners No. 12-5259 Civil
1 Meadows Road
Newville,PA 17241
Defendants
CERTIFICATE OF SERVICE
Lisa Davis, an employee of KML LAW GROUP, P.C., counsel for Plaintiff, hereby certifies that a
copy of Plaintiffs Motion to Postpone Sheriffs Sale was mailed by first class mail, postage prepaid, to
Defendants on June 4,2013.
SHAWN W.BENNER
1 Meadows Road Newville,PA 17241
DORIS E.LOWERY
I Meadows Road Newville,PA 17241
Respectfully submitted,
KML LA, GROUP P.C.
r
By:
Lisa Davi ,Lega Assistant 215-825-6377
It X
lJ
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION
c/o 3415 Vision Drive IN THE COURT OF COMMON PLEAS
Columbus,OH 43219
Plaintiff OF Cumberland County
vs.
SHAWN W.BENNER and DORIS E.LOWERY Term
Mortgagors and Record Owners No. 12-5259 Civil
1 Meadows Road
Newville,PA 17241
Defendants
ORDER
AND NOW,this day of ,2013 upon consideration of Plaintiffs
Motion to Postpone Sheriffs Sale and any response t ereto,it is
ORDERED and DECREED:
That the Motion is granted and the Sheriffs Sale in the above-captioned matter is hereby
postponed until Wednesday,July 10,2013,without need for further notice,costs,and advertising.
BY THE COURT: -U=c ,z
r-n cZ
f
Mr� id
Distribution:
LAW GROUP,P.C.
Attorney for Plaintiff
701 Market Street,Philadelphia PA. 19106
Shawn W. Benner,Pro Se and
Doris E. Lowery,Pro Se
1 Meadows Road
Newville,PA 17241 (�
,,/§heriff of Cumberland County — Lue_.L
1 Courthouse Square, Carlisle,PA. 17013
la � 13
1 �
M
KML LAW GROUP P.C. ?. 3
Suite 5000—BNY Independence Center
701 Market Street 2013 JUL 3 0 PM 4: 2 2
Philadelphia,PA 19106-1532
215-627-1322 CUI"IB PENNSYLVANIA
D COUNTY
Attorney for Plaintiff
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION IN THE COURT OF COMMON PLEAS
c/o 3415 Vision Drive
Columbus, OH 43219 of Cumberland County
Plaintiff
vs.
SHAWN W. BENNER
DORIS E. LOWERY No. 12-5259 Civil
(Mortgagor(s)and Record owner(s))
I Meadows Road
Newville,PA 17241
Defendant(s)
PRAECIPE TO VACATE JUDGMENT
TO THE PROTHONOTARY:
Kindly vacate the judgment upon payment of ALAW "C'-Pw�.
By:
KML
Michael McKeever Pa.ID 56129
Jay E.Kivitz Pa. ID 26769
Lisa Lee Pa. ID 78020
Thomas Puleo Pa. ID 27615
David Fein Pa. ID 82628
�ilyk ll P.Jenkins Pa. ID 306588
L.Oflazian Pa.ID 312912
Salvatore Filippello,Attorney ID 313897
Attorneys for Plaintiff
KML LAW GROUP,P.C.
° SUITE 5000-BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA,PA 19106
(215)627-1322
ATTORNEY FOR PLAINTIFF
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION IN THE COURT OF COMMON PLEAS
Plaintiff OF Cumberland COUNTY
VS.
CIVIL ACTION -LAW
SHAWN W. BENNER
DORIS E.LOWERY ACTION OF MORTGAGE
(Mortgagor(s)and Record Owner(s)) FORECLOSURE
Defendant(s) No. 12-5259 Civil
CERTIFICATE OF SERVICE
Angela M. Smith , hereby certifies that he/she did serve true and correct copies of
Praecipe to Vacate Judgment and all supporting papers attached hereto upon Defendant, by first
class mail,postage pre-paid, on
SHAWN W. BENNER
1 Meadows Road
Newville, PA 17241
DORIS E. LOWERY
1 Meadows Road
Newville, PA 17241
By:
KML LA GROUP,P.C.
Angela M . mith ,Legal Assistant
asmith @kmllawgroup.com
215-825-6325 (Direct Phone)
KML LAW GROUP, P.C.
Suite 5000—BNY Mellon Independence Center Y j pf�lcj �,Utz `i, ,
701 Market Street f�{f
Philadelphia,PA 19106-1532 JUL 3 0 Pt., 1,: 23
215-627-1322
P COU
BANK,NATIONAL ��-'�j S��'�'
JPMORGAN CHASE �I��!���
ASSOCIATION IN THE COURT OF COMMON PLEAS
c/o 3415 Vision Drive
Columbus, OH 43219 OF CUMBERLAND COUNTY
Plaintiff
vs.
SHAWN W. BENNER No. 12-5259 Civil
DORIS E. LOWERY
(Mortgagor(s) and Record owner(s))
1 Meadows Road
Newville, PA 17241
Defendant(s)
PRAECIPE TO DISCONTINUE AND END
TO THE PROTHONOTARY:
Kindly mark the above case Discontinued and Ended without prejudice upon payment of
your costs only.
KML LAW WROUP,F/K/A GO FFERTY& Mc KEEVER
By.
Micha 56129
Jay E. 9
Lisa Lee Pa.ID 8020
Thomas Puleo Pa.ID 27615
David Fein Pa.ID 82628
O )ill P.Jenkins Pa.ID 306588
Alyk L. Oflazian Pa.ID 312912
Salvatore Filippello,Attorney ID 313897
Attorneys for Plaintiff
KML LAW GROUP,P.C.
Suite 5000—BNY Mellon Independence Center
701 Market Street
Philadelphia, PA 19106
(215)627-1322
Attorney for Plaintiff
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION IN THE COURT OF COMMON
Plaintiff PLEAS
VS. OF CUMBERLAND COUNTY
SHAWN W. BENNER CIVIL ACTION - LAW
DORIS E. LOWERY
(Mortgagor(s) and Record Owner(s)) ACTION OF MORTGAGE
FORECLOSURE
Defendant(s)
No. 12-5259 Civil
CERTIFICATE OF SERVICE
Angela M. Smith ,hereby certifies that he/she did serve true and correct copies of Praecipe
to Discontinue and End and all supporting papers attached hereto upon Defendant, by first class
mail,postage pre-paid, on ?
SHAWN W. BENNER
I Meadows Road
Newville,PA 17241
DORIS E. LOWERY
I Meadows Road
Newville, PA 17241
KML LAW GROUP,P.C.
F/K/A GOLD ECK McCAFFE Y& McKEEVER
By:_ _ A
Angela M. Smith , Legal Assistant
asmith@kmllawgroup.com
215-825-6325 (Direct Phone)
, ^
SHERIFFS OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson -
/Sheriff ^
^^�
� TlPr°
'�/- �T' w/�w JodySSnith .
Chief Deputy 121w" JUL 30 Y
Richard VVStexva,t - ' - ~ ,
Solicitor mFrTEor THE nKERI= CUMBER Ty
PENNSYLVANIA
JP Morgan Chase Bank, NA
vs. Case Number
Shawn VK Benner(et a|.) | 2012'6259
SHERIFF'S RETURN OF SERVICE 01/02/2013 O2:23pyN - Deputy Amanda Cobaugh. being duly sworn according ho 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 1 Meodows Road, Newville, PA 17241, Cumberland
County.
01/02/3013 02:23 PM-Deputy Amanda Cobaugh, 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 personally handing atruo copy to a person representing themselves to be DORIS LDVVERY.
WIFE , who accepted as"Adult Person in Charge"for Shawn W. Benner at 1 Wleedmwm Road. Lower
Mifflin Township, NewwiUe. PA17241. Cumberland County.
01/02/2013 02:23 PM-Deputy Amanda Cobaugh, being duly sworn according to law, served the requested Real
Estate Writ, Notice and Oeaoription, in the above titled ocfion, by making known its contents and at the
same time personally handing o true copy tou person representing themselves bzbe the Defendant,to
wit: Doris E. Lowery at 1 Meadows Road, Lower Mifflin Township, Newville, PA 17241, Cumberland
County.
02/21/2013 As directed by Jill Jenkins,Attorney for the Plaintiff, Sheriffs Sale Continued to5/1/2O13
04/18X2013 As directed by Jill Jenkins,Attorney for the Plaintiff, Sheriffs Sale Continued to6/5/2O13
06/05/2013 As directed by Jill Jenkino,Attorney for the Plaintiff, Sheriffs Sale Continued to7/1O/2O13
07/09/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned"stayed",
per letter of instruction from Attorney.
SHERIFF COST: $1.529�34 SO ANSWERS,
July 3D. 2U13 Rumw, n*mucnSu/v. oncmrr
� �°= co
~&�" �*�-
- �--
�--
wcoumstfitesivriff,nueosoft,/= .
�
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO. 12-5259 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION Plaintiff(s)
From SHAWN W.BENNER,DORIS E.LOWERY
(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: $102,291.82 L.L.: .50
Interest FROM 10/10/2012 TO DATE OF SALE PER DIEM AT$15.87
Atty's Comm: % Due Prothy:$2.25
Arty Paid: $207.25 Other Costs:
Plaintiff Paid:
Date: 10/12/12 � ��=-���
David D.Bu 11 Prothonotary
(Seal)
Deputy
REQUESTING PARTY:
Name:JILL P.JENKINS,ESQUIRE
Address: KML LAW GROUP,P.C.
SUITE 5000-BNY INDEPENDENCE CENTER
701 MARKET STREET
PHILADELPHIA,PA 19106
Attorney for: PLAINTIFF
Telephone: 215-627-1322
Supreme Court ID No.306588
TRUE C"""" "10M, 'RECORD
1p-Testimonyv'.'�-z sere unto set my hand
and the see l' at Carlisle,Pa.
FhIS !,y 0 C+ 20
Prothonotary
&-
On October 17, 2012 the Sheriff levied upon the
defendant's interest in the real property situated in
Lower Mifflin Township, Cumberland County, PA,
Known and numbered as, 1 Meadows Road,
Newville, more fully described on Exhibit
"A" filed with this writ and by this reference
incorporated herein.
Date: October 17, 2012
By:
Real Estate L�
Coordinator
S 1j 1101
��1831N
CUMBERLAND LAW JOURNAL
Writ No. 2012-5259 Civil CONTAINING a total of 2.3605
acres.
JP Morgan Chase Bank,NA BEING known as Lot 11 of the
VS. Subdivision referenced above.
TRACT NO. 2:
Shawn W. Benner, BEGINNING at a set railroad spike
Doris E. Lowery located in the centerline of Pennsyl-
Atty.:Jill Jenkins vania a Route 997,also is known as
ALL those certain two (2) certain the Roxbury Road, at the corner of
tracts of land situate in Lower Mif- Lot 11; thence along Lot 11 north
flin Township, Cumberland County, 44 degrees 25 minutes 10 seconds
Pennsylvania, according to a sub- west 320.00 feet to a set iron pin
division plan prepared by John R. located at the corner of Lot 11 and
Kissinger Surveying, entitled Sub- Lot 10; thence along Lot 10A north
division for Edward L. Stum, dated 67 degrees 19 minutes 20 seconds
September 2S,2000 and recorded in east 104.10 feet to a point located at
Cumberland County Plan Bock 82, lands now or formerly of Richard L.
Page 50,bounded and described as Picken;thence along lands of Picken
follows,to wit: South 46 degrees 25 minutes 38
TRACT NO 1: seconds East 277.33 feet to a set
BEGINNING at a set railroad spike railroad spike located in the center-
located in T-418,known as Meadows line of Pennsylvania Route 997,also
Road, at the corner of Lot 10 of the known as the Roxbury Road;thence
Plan described herein; thence along through the said centerline south 43
Lot 10 North 46 degrees 29 minutes degrees 16 minutes 24 seconds west
01 seconds east 297.17 feet to a set 106.50 to a set railroad spike, the
iron pin located at the corner of Lot place of BEGINNING. CONTAINING
10A and I IA; thence along Lot 11A 0.6942 acres total.
south 44 degrees 25 minutes 10 sec- BEING known as Lot 11A of the
onds east 320.00 feet to a set railroad aforementioned Subdivision.
spike located in the centerline of Both tracts are subject to condi-
Pennsylvania Route 997,also known tions and restrictions set forth in the
as the Roxbury Road;thence through aforementioned Subdivision.
the centerline of Pennsylvania Route IMPROVEMENTS consist of a
997, also known as Roxbury Road residential dwelling.
south 43 degrees 16 minutes 24 MUNICIPALITY LOWER MIFFLIN
seconds west 95.07 feet to a point TOWNSHIP.
located in the centerline of the said BEING PREMISES: 1 Meadows
roadway;thence continuing through Road,Newville,PA 17241.
the centerline of said roadway south SOLD as the property of Shawn W.
45 degrees 57 minutes 24 seconds Benner and Doris E. Lowery.
west 240.18 feet to an existing rail- TAX PARCEL#15-05-0411-030.
road spike located at the intersec-
tion of Pennsylvania Route 997,also
known as Roxbury Road and T-418,
also known as Meadows Road;thence
through the said T418, also known
as Meadows road, north 37 degrees
46 minutes 59 seconds west 329.14
feet to a set railroad spike,the place
of BEGINNING.
20
PROOF OF PUBLICATION OF NOTICE
IN CUMBERLAND LAW JOURNAL
(Under Act No. 587, approved May 16, 1929), P. L.1784
COMMONWEALTH OF PENNSYLVANIA
ss.
COUNTY OF CUMBERLAND :
Lisa Marie Coyne,Esquire, Editor of the Cumberland Law Journal, of the County and
State aforesaid, being duly sworn, according to law, deposes and says that the Cumberland Law
Journal, a legal periodical published in the Borough of Carlisle in the County and State aforesaid,
was established January 2, 1952, and designated by the local courts as the official legal
periodical for the publication of all legal notices, and has, since January 2, 1952, been regularly
issued weekly in the said County, and that the printed notice or publication attached hereto is
exactly the same as was printed in the regular editions and issues of the said Cumberland Law
Journal on the following dates,
viz:
January 25, February 1, and February 8, 2013
Affiant further deposes that he is authorized to verify this statement by the Cumberland
Law Journal, a legal periodical of general circulation, and that he is not interested in the subject
matter of the aforesaid notice or advertisement, and that all allegations in the foregoing
statements as to time,place and character of publication are true.
L sa Marie Coyne, E itor
SWORN TO AND SUBSCRIBED before me this
da y of Februar 2013
-J/
1
Notary
NOTARIAL SEAL
DEBORAH A COLLINS
Notary Public
CARLISLE BOROUGH,CUMBERLAND COUNTY
My Commission Expires Apr 28,2014
F ,
The Patriot-News Co.
the Patr1*ot*1Xews
2020 Technology Pkwy
Suite 300
Mechanicsburg, PA 17050 NOW you know
Inquiries - 717-255-8213
CUMBERLAND CO. SHERIFFS OFFICE
CUMBERLAND COUNTY COURT HOUSE
CARLISLE PA 17013
THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No. 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin) ss
Marianne Miller, being duly sworn according to law, deposes and says:
That she is a Staff Accountant of The Patriot News Co., a corporation organized and existing under the laws of the
Commonwealth of Pennsylvania, with its principal office and place of business at 2020 Technology Pkwy, Suite 300, in the
Township of Hampden, County of Cumberland, State of Pennsylvania, owner and publisher of The Patriot-News and The Sunday
Patriot-News newspapers of general circulation, printed and published at 1900 Patriot Drive, in the City, County and State
aforesaid; that The Patriot-News and The Sunday Patriot-News were established March 4th, 1854, and September 18th, 1949,
respectively, and all have been continuously published ever since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published in their regular
daily and/or Sunday/Community Weekly editions which appeared on the date(s) indicated below. That neither she nor said
Company is interested in the subject matter of said printed notice or advertising, and that all of the allegations of this statement as
to the time, place and character of publication are true; and
That she has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this statement on
behalf of The Patriot-News Co. aforesaid by virtue and pursuant to a resolution unanimously passed and adopted severally by the
stockholders and board of directors of the said Company and subsequently duly recorded in the office for the Recording of Deeds
in and for said County of Dauphin in Miscellaneous Book"M", Volume 14, Page 317.
L10J il".ATlnPJ COPY This ad ran on the date(s)shown below:
>fe�of _off asolo►ea,(aur oan�a ..,,,,
► ISE 01/22/13
2012-5259 Civil
JP Min Chase Bank,NA C 01129/13
Vs —
n W.Benner 02/05/13
ls E:Lowery
JIII Jenkins I!,
ALL those certain two (2) certain tracts
of land situate in Lower Mifflin'Ibwnship,6, Sworn to and sub cubed before me 1 ay of February, 2013 A.D.
- Cumberland County, e
Pennsylvania, according to a subdivision
plan prepared by John R. Kissinger u
Surveying,entitled Subdivision for Edward
L. Stum, dated September 2S, 2000 and No ublic
recorded in Cumberland County Plan Bock
82, Page 50,bounded and described as MONW LTH OF FENNSY VANIA
follows,to wit:
TRACT N01: Notarial Seal public
BEGINNING at a set railroad spike located Holly Lynn Warfel,Notary
in T-018,known as Meadows Road,at the o Washington Twp.,Dauphin county
corner of Lot 10 of the Plan described My cOMMI5510n Expires Dec,
herein; thence along Lot 10 North 46 E MEMBER,PENNSYLVANIA ASSOCIATION OF NOTARIES
degrees 29 minutes 01 seconds east 297.17
feet to a set iron oin located at the comer
KML Law Group,P.C.
Suite 5000—BNY Independence Center
701 Market Street
Philadelphia,PA 19106
215-627-1322
Attorney for Plaintiff
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION IN THE COURT OF COMMON PLEAS
c/o 3415 Vision Drive
Columbus,OH 43219 of Cumberland County
Plaintiff
vs.
CIVIL ACTION-LAW
SHAWN W. BENNER
DORIS E.LOWERY
(Mortgagor(s) and Record Owner(s)) ACTION OF MORTGAGE FORECLOSURE
1 Meadows Road
Newville,PA 17241
Defendant(s)
No. 12-5259 Civil
AFFIDAVIT PURSUANT TO RULE 3129
JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,Plaintiff in the above action,by counsel,KML Law
Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the
real property located at:
1 Meadows Road
Newville,PA 17241
1.Name and address of Owner(s)or Reputed Owner(s):
SHAWN W.BENNER
1 Meadows Road
Newville,PA 17241
DORIS E.LOWERY
1 Meadows Road
Newville,PA 17241
2.Name and address of Defendant(s)in the judgment:
SHAWN W.BENNER
1 Meadows Road
Newville,PA 17241
DORIS E.LOWERY
1 Meadows Road
Newville,PA 17241
3.Name and last known address of every judgment creditor whose judgment is a record lien on the property to be sold:
DOMESTIC RELATIONS OF CUMBERLAND COUNTY
PO Box 320
Carlisle,PA 17013
PA DEPARTMENT OF PUBLIC WELFARE-Bureau of Child Support Enforcement
Health and Welfare Bldg.-Room 432
P.O.Box 2675
Harrisburg,PA 17105-2675
4.Name and address of the last recorded holder of every mortgage of record:
5.Name and address of every other person who has any record interest in or record lien on the property and whose interest
may be affected by the sale:
6.Name and address of every other person of whom the plaintiff has knowledge who has any record interest in the property
which may be affected by the sale.
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.
TENANTS/OCCUPANTS
1 Meadows Road
Newville,PA 17241
I verify that the statements made in this affidavit are true and correct to the best of my information and belief.I
understand that false statements herein are made subject to the penalties of I Pa.C.S. Section 4904 relating to unsworn
falsification to autho "tie
DATED:
I /
By: 1 /
KML L^ P,P.C.
Michael McKeever Pa.ID 56129
Jay E.Kivitz Pa.ID 26769
Lisa Lee Pa.ID 78020
Kristina Murtha Pa.ID 61858
David Fein Pa.ID 82628
Thomas Puleo Pa.ID 27615
Joshua I. Goldman Pa.205047
_gill P.Jenkins Pa.ID 306588
Attorneys for Plaintiff
¢' 12-5259 Civil
T .
KML Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106
(215)627-1322
Attorney for Plaintiff
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION IN THE COURT OF COMMON PLEAS
c/o 3415 Vision Drive
Columbus, OH 43219 of Cumberland County
Plaintiff
CIVIL ACTION-LAW
vs.
SHAWN W.BENNER ACTION OF MORTGAGE
DORIS E.LOWERY FORECLOSURE
Mortgagor(s) and Record Owner(s)
1 Meadows Road
Newville,PA 17241 Docket No. 12-5259 Civil.
Defendant(s
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: BENNER,SHAWN W.
SHAWN W. BENNER
1 Meadows Road
Newville,PA 17241
Your house at 1 Meadows Road,Newville,PA 17241 is scheduled to be sold at Sheriffs Sale on
Wednesday,March 06,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of$102,291.82 obtained by JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriff s Sale you must take immediate action:
1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION,the back payments,late charges,costs and reasonable attorney's fees due.To find out bow
much you must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if
the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause.
12-5259 Civil
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you
will have of stopping the sale. (See notice below 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 NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find
out the price bid price by calling the Sheriff of 717-240-6390.
2. You may be able to petition the Court to set aside the We 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 the Sheriff of 717-240-6390.
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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer.At that tune,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 schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the
date of the Sheriffs Sale.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 schedule of distribution is filed.
7. You may also have other rights and defenses,or ways of getting your house back,if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: http://www.philadelphiafed.org/foreclosure/
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
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
b
12-5259 Civil
Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender(and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: .or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
hiip://www. hp fa.org/consumers/homeowners/real aspx.
5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention @kmllaw"roup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
113617FC.
Para informacion en espanol puede communicarse con Loretta al 215-825-6344.
12-5259 Civil
KML Law Group,P.C.
Suite 5000-BNY Independence Center
701 Market Street
Philadelphia,PA 19106
(215)627-1322
Attorney for Plaintiff
JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION IN THE COURT OF COMMON PLEAS
c/o 3415 Vision Drive
Columbus, OH 43219 of Cumberland County
Plaintiff
CIVIL ACTION-LAW
vs.
SHAWN W.BENNER ACTION OF MORTGAGE
DORIS E.LOWERY FORECLOSURE
Mortgagor(s) and Record Owner(s)
1 Meadows Road
Newville,PA 17241 Docket No. 12-5259 Civil
Defendants
THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO
COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO
COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE
USED FOR THAT PURPOSE.
NOTICE OF SHERIFF'S SALE OF REAL PROPERTY
TO: LOWERY,DORIS E.
DORIS E. LOWERY
1 Meadows Road
Newville,PA 17241
Your house at 1 Meadows Road,Newville,PA 17241 is scheduled to be sold at Sheriffs Sale on
Wednesday,March 06,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce
the court judgment of$102,291.82 obtained by JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION against you.
NOTICE OF OWNER'S RIGHTS
YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE
To prevent this Sheriffs Sale you must take immediate action:
1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK,NATIONAL
ASSOCIATION,the back payments,late charges,costs and reasonable attorney's fees due.To find out how
much you must pay call our office at 215-825-6329 or 1-866-413-2311.
2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if
the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause.
4 '
12-5259 Civil
3. You may also be able to stop the sale through other legal proceedings.
4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you
will have of stopping the sale. (See notice below on how to obtain an attorney).
YOU MAY STELL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS
EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE.
1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder.You may find
out the price bid price by calling the Sheriff of 717-240-6390.
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 the Sheriff of 717-240-6390.
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 a right to remain in the property until the full amount due is paid to the Sheriff and the
Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you.
6. You may be entitled to a share of the money which was paid for your house.A schedule of
distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the
date of the Sheriffs Sale. 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 schedule of distribution is filed.
7. You may also have other rights and defenses,or ways of getting your house back,if you act
immediately after the sale.
8. You may contact the Foreclosure Resource Center: hLtp://www.philadelphiafed.orp,/foreclos
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
2 Liberty Avenue
Carlisle,PA 17013
LEGAL SERVICES INC
8 Irvine Row
Carlisle,PA 17013
717-243-9400
12-5259 Civil
.Resources available for Homeowners in Foreclosure
ACT NOW!
Even though your lender(and our client) has filed an Action of Mortgage
Foreclosure against you, you still may be able to SAVE YOUR HOME FROM
FORECLOSURE.
1). Call an attorney. For referrals to a qualified attorney call either of the
following numbers: or 717-243-9400.
2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free
counseling.
3). Visit HUD's website www.hud.gov for Help for Homeowners Facing the
Loss of Their Homes.
4). Pennsylvania Housing Finance Agency also offers other loan programs that
may assist homeowners in default. Please See the PHFA website
hqp://www.phfa.org/consumers/bomeowners/real.aspx.
5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss
Mitigation or Home Retention options.
6). Call or contact our office to request the amount to bring the account current,
or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our
toll free number at 1-866-413-2311 or via email at
homeretention@kmllawaoup.com.com. Call Seth at 215-825-6329 or fax 215-825-
6429. The figure and/or package you requested will be mailed to the address that you
request or faxed if you leave a message with that information. The attorney in charge of
our firm's Homeowner Retention Department is David Fein who can be reached at 215-
825-6318 or Fax: 215-825-6418. Please reference our Attorney File Number of
113617FC.
Para informacion en espanol puede communicarse con Loretta a1215-825-6344.