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Home My WebLink About12-5965KML LAW GROUP, P.C. r. ,, ,-,~, ,. r r. r ^+.- SUITE 5000 - BNY MELLON INDEPENDENCE CENTER ,~ , ~__'. ' } ~' ~' ' ~~. 701 MARKET S"1'REET ~. , -r :E.. + ~ ~ . ~ ~ itrE:°~ PHILADELPHIA, PA 19106 n -, n ." (866) 413-2311 y ~ , ~ ~ ~ ~, ~ ; ; (~ : ~~ `~ JPMORGAN CHASE BANK, NATIONAL ''' ' ' ~ ^' r-:. ASSOCIATION, SUCCESSOR IN INTEREST BY ,~ r;`' C ; "; PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 Plaint vs. BETH A.FETTERHOFF JOHN G. FETTERHOFF Mortgagor(s) and Record Owners} 56 Broad Street Newville, PA 17241 Defendant(s) Na. - S~~S ~v( ~ ~a CIVIL ACTION: IVIORTOAGE FORECLOSURE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOIJ DU NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 'THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LA WYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de; la demanda y la notificacion. Hace falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decider a favor del demandante y requiere que usted cumpla con todas las provision de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. s ~M~ X103. ~Spd a~ C~Id~ ~ ~o~y ~~ a$1~3 ~= Cl i~ O ~ r ~'HE COURT OF COMMON PLEA S OF' Cumberland COUNTY CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO T1ENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA I_FGAL. SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA C)FICINA PUEDF, PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243 -9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following members: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-$00-989-2227 for free counseling. 3). Visit HUD'S website www.hud. ov 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 http://www.phfa.or~/consumers/homeowners/real aspY. 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.philadelRhiafed.org/foreclosure/ 7}. Ca11 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 1-866-41 3-2311 or via email at homeretention~kmllawgroup.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 111713FC. Para information en espanol puede communicarse con Loretta al 215-825-6344. 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, SUCCESSOR 1N INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A., 3415 Vision Drive, Columbus, OH 43219. 2. The name(s) and address(es) of the Defendant(s) is/are BETH A. FETTERHOFF, 56 Broad Street, Newville, PA 17241 and JOHN G. FETTERHOFF, 56 Broad Street, Newville, PA 17241, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. On October 12, 2001 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to WASHINGTON MUTUAL BANK FA, which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on October 16, 2001 as Book 1735 Page 4122.. The Mortgage is a matter of public record and is incorporated by this reference in accordance with Pennsylvania Rule of Civil Procedure 1019(g); which Rule relieves the Plaintiff from its obligation to attach documents to pleadings if those documents are matters of public record. Plaintiff and Defendant entered into a loan modification agreement on April 22, 2004 a true and correct copy is attached as Exhibit C. 4. The Property subject to the Mortgage is more fully described in the legal description set firth as Exhibit '`A" ("Property"). 5. "The mortgage is in default because the monthly payments of principal. and interest are due and unpaid for August O 1, 2011 and each month thereafter and by the terms of the Mortgage, upon default in such payments for a period of one month or more, the entire principal. balance and all interest due and other charges are due and collectible. 6. The following amounts are due to Plaintiff on the Mortgage as of July 31, 2012: Principal Balance ............................................................. Interest from 07/01 /2011 through 07/31 /2012 .............. Accrued Late Charges ...................................................... Escrow .............................................................................. B PO/Appraisals ................................................................ Property Preservation ....................................................... Property Inspections ......................................................... Suspense .................................. Reasonable Attorney's Fee .... ....................$109,623.67 ........................ $6, 977.10 ...........................$439.14 ........................$3,058.07 ........................... $225.00 .................$4,545.83 ....................$208.25 .................. ($905.81) ........,.........$1,450.00 $125,621.25 If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable ]aw. 8. Plaintiff is not seeking a judgment of personal liability (or an "in personam" judgment) against the Defendants in this Action but reserves its right to bring a separate Action to establish that right, if such right exists. If Defendants have received a discharge of their personal liability in a Bankruptcy proceeding, this Action of Mortgage Foreclosure is, in no way, an attempt to re-establish the personal liability that was discharged in Bankruptcy, but only to foreclose the Mortgage and sell the Property pursuant to Pennsylvania law. 9. Notice of [ntention to Foreclose has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit "B". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $125,621.25, together with interest, costs, fees and charges collectible under the Note and Mortgage including but not limited to attorney's fees and costs, and for the foreclos re a d s e of the mortgage property. By: ~~ ,. KML LA 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 J shwa I. Goldman Pa. ID 205047 ill P. Jenkins Pa. ID 306588 ndrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff VERIFICATION ~A~'NOw~- ~ ~ ~tiiJ ,hereby states that/she is ~ j ~ ~ {~ ftb ~~ of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. Plaintiff in this matter and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my knowledge, information and belief. The undersigned understands that this statement is made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unsworn falsification to authorities. Date: ql Z / /~, ~~ Name: owl k, ~aS Title: V,~~ IPft~ltt tw~" #111713FC BETH A. FETTERHOFF and JOHN G. FETTERHOFF ~E.~hi6itA ALL THAT CERTAIN and erected lot of land and t New~,ille- C thereon, situate at he improvements bounded and Berland Count 56 Broad Street situated described Y- Pennsylvania Borough of as follows: ~ more particularly ON South property now o by said Broad by an a11e r formerly of Clair S lIe et- °n the West Glenn Mohn Y, and on the East by pro e nberger; on the Norty P rtY now or formerly of HA~7ING a fronts e and extending in deg °n said Broad Street o (180) feet to said a21e at an even width One S1XtY (60) feet a two ana one- Y on the North. Hundred Eighty improvements. half story brick dwelli BEING improved 9 house with and other BEFNG the same premises which and wife, by their deed dated OctobeHarold D. Snyder and Tenna K. Recorder of Deeds in and far C' I2, 200 Snyder, husband Page , and recorded in the Office of the granted and Berland County, Pennsylvania, husband and wife conveyed to John G. Fetterhoff a in Deed $ook _ mortgagors herein, nd Beth A. Fetterhoff, ~Ex(tidit B *Exhibit has been redacted to remove all personally identifiable information car non puhlic inforrr~ation Chase (FLS-7734) PO BOX 44090 Jacksonville. FL 32237-4090 12/22/2011 0000968 O7 MB 0.367 ""AUTO 7g 0 6057 17247-152356 _ -C07-I #BWNCLNN# #0900509168996297# JOHN G FETTERHOFF 56 BROAD ST NEWVILLE PA 17241-1523 "~11'~'~In~~~'Illnl~lll~lll~l~l~~ll'n~I~I~l~l~ll~ll~l~l~lll~ Acceleration Warning (Notice of Intent to Foreclose) Account: - 8962 (the "Loan ') Property Address: 56 BROAD ST NEWVILLE; PA 17241 (the "Property') Dear JOHN G FETTERHOFF: CHASE ~ Under the terms of the Mortgage or Deed of Trust ("Security Instrument") securing your Loan. JPMorgan Chase Bank, N.A.("Chase-') hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due 08/01/2011.. 2. As of 12/22/2011, total monthly payments (including principal, interest, and escrow if applicable), late fees, insufficient funds (NSF) fees, and other fees and advances due under the terms of your loan documents in the total amount of $5867.26 are past due. This past~iue amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If youu have any questions about the amounts detailed below, please contact us as soon as possible at (800) 848-9380. Total Monthly Payments $5268.90 Late Fees $400.60 NSF Fees $0.00 Other Fees* $0.00 Advances* $197.76 Amount Held in Suspense $0.00 *F~ther Fees and Advances include those amounts allowed by your Note and ,Security Instrument. If you need additional information ,regarding any of these amounts. please contact us at the number provided below. You are also responsible for paying any amounts that become due from the date of this letter through the expiration date of 01/24/2012 set forth in Paragraph 4 below. These an~ounts may include, but are not limited to, taxes, insurance, inspection fees and other fees. as permitted by applicable law. If you have am reason to dispute the past-due amount listed above. or if you believe your Loan is current, please contact us at the number provided belo«~. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately. If full payment of the amount of default is not made within 33 days. ~~~e also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. You have the right to cure the default, or anyone acting on your behalf. and pay your account current amrtime at least one hour prior to the commencement of bidding at a sheriff s sale or other judicial sale, not more than three times in any calendar year. To do so. you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that «~ould have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation ~~-hich you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default. as specified in writing by the mortgagee d) Pay any reasonable late penalty, if outlined in the mortgage Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees. NSF fees. and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 6. If you fail to cure the default on or before 01/24/2012. Chase will accelerate t:he maturity of the Loan, terminate your credit line if the Loan provides for revolving advances, declare all sums secured by the Security Instrument immediately due and payable and commence foreclosure proceedings, all «-ithout further notice to you. If this happens; Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure/attorney fees and other expenses permitted by your loan documents or applicable law. 7. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees related to any foreclosure action we initiate. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase ~~~II not accept a Direct Check FastPay or SpeedPay payment. 0000968/BW840 Regular Mail: CHASE PO BOX 78420 PHOENIX, AZ 8062-8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034-970(1 Except as required b_y law, we are under no obligation to accept less than the full amount owed. if you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan ~zthout waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance v<~ith Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeov<•ners' assistance programs that might help you resolve your default and keep youur home: however; we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at (800) 848-9380. 10. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property. including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly; your plans for curing the default and paving this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt. You ma_y have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who ~~ill assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeo~~nership counseling and approved by the Secretary of Housing and Urban Development (HLTD). A listing of such organizations ma_y be obtained by calling HUD toll-free at (800) 569-4287 or at ~i~vw.hud.gov. Sincerely, Chase (800) 848-9380 (800) 582-0542 TDD /Text Telephone ~~vw.chase.com F,nclosure - Federal Trade Commission Pamphlet IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS If you are a servicemember who is, or recently was, on "active duty" or "active service" or a dependent of such a servicemember_ you may be entitled to certain legal rights and protections, including protection from foreclosure or eviction, pursuant to the Servicemembers Civil Relief Act (50 USC App. §§ 501-596), as amended (the "SCRA") and possibly certain similar state statutes. Eligible service may include: • Active duty (as defined in section ]O1(d)(1) of title 10, United States Code) with the Army, Navy. Air Force, Marine Corps or Coast Guard • Active service with the National Guard • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration • Active service as a commissioned officer of the Public Health Service • Service with the forces of a nation v~~ith which the United States is allied in the prosecution of a war or military action • Service with the National Guard or a state militia under a state call to duri Eligible service also includes any period during which a servicemember is absent from duty on account of sickness. wounds, leave or other lawful cause. if you are such a servicemember, or a dependent of such a servicemember, you should contact Chase Military Services toll-free at (866) 840-5826 to discuss your status. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org or by calling (888) 995-HOPE. Chase offers loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at (800) 848-9380 #o discuss your options. The longer you delay, the fewer options you may have. Chase is a debt collector. If you are represented by an attorney, please refer this letter to your attorney and provide us vc~ith the attorney s name, address and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BW840 oooos6H/swaao Facing foreclosure? Scammers are targeting people having trouble paying Their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while othf;rs promise loan modifications - for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing sihiation go from bad to W OI'SC. Don't Get Hit by a Pitch. "We can stop your foreclosure!" "97% success rate!" "Guaranteed to save your home!" These kinds of claims are the tell-tale signs of a foreclosure rip-off. Steer clear of anyone who offers an easy out. Don't Pay for a Promise. Don't pay any business, organization, or person who promises to prevent foreclosure or get you a new mortgage. These so-called "foreclosure rescue companies" claim they can help save your home, but they're out to make a quick buck. Some may request hefty fees in advance -and then stop returning your calls. Others may string you along before disclosing their charges. Cut off all dealings if someone insists on a fee. Send Payments Directly. Some Scammers offer to handle financial arrangements for you, but then just pocket your payment. Send your mortgage payments ONLY to your mortgage servicer. Don't Pay for a Second Opinion. Have you applied for a loan modification and been turned down? Never pay fora "second opinion." Imitations =Frustrations. Some con artists use names, phone numbers, and websites to make it look like they're part of the government. If you want to contact a government agency, type the web address duectly into your browser and look up any address you aren't sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Pages in your phone directory. Don't click on links or open any attachments in unexpected emails. Talk to aHUD-Certified Counseling Agency -For Free. If you're having trouble paying your mortgage or you've already gotten a delinquency notice, free help is a phone call away. Call 1-888-995 -HOPE for free personalized advice from housing counseling agencies certified by the U.S. Department of Housing and Urban Development (HUD). This national hotline - open 24/7 - is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD-certified counseling agencies. For free guidance online, visit www.hopenow.com. For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov. ,,, Federal Trade Commission ftc.gnv; MoneyMatte!s Call 1-888-995-HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and. Urban Development. The Homeowner's HOPETM Hotline -open 24/7 - is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD-certified counseling agencies. Or visit www.hopenow.com For free information on the President's plan to help homeowners.. visit www.makinghomeaffordable.gov "~n HOPENOW Support & Widance For Homeowners MAKING HOME AFFORDABLE.cov Chase (FL5-7?34) PO BOX 44090 Jacksonville, FL 32231-4090 12/22/2011 0000969 01 MB 0.387 *"AUTO T9 0 8057 17241-752356 -C07-I #BWNCLNN# #0900509168996297# BETH A FETTERHOFF 56 BROAD ST NEWVILLE PA 17241-1523 Acceleration Warning (Notice of Intent to Foreclose} Account: _ 8962 (the "Loan") Property Address: 56 BROAD ST NEWVILLE, PA 17241 (the "Property") Dear BETH A FETTERHOFF: CHASE ! i Under the terms of the Mortgage or Deed of Trust ("Security Instrument') securing youur Loan. JPMorgan Chase Bank- N.A.("Chase ') hereby notifies you of the following: 1. You are in default because you have failed to pay the required monthly installments commencing with the payment due 08!01/2011. 2. As of 12/22/2011, total monthly payments (including principal, interest, and escrow if applicable), late fees. insufficient funds (NSF) fees. and other fees and advances due under the terms of your loan documents in the total amount of $5867.26 are past due. This past-due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If you have any questions about the amounts detailed below, please contiict us as soon as possible at (800)848-9380. Total Monthly Payments $526890 Late Fees $400.60 NSF Fees $0.00 Other Fees* $0.00 Advances* $197.76 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts allowed by your Note and ~S'ecurity Instrument. If you need additional information regarding any c f these amounts. please contact us at the number provided below. You are also responsible for pa_y~ng any amounts that become due from the date of this letter through the expiration date of 01/24/2012 set forth in Paragraph 4 below. These amounts ma_y include; but are not limited to, taxes, insurance; inspection fees and other fees. as permitted by applicable law. If you have any reason to dispute the past-due amount listed above. or if you believe youur Loan is current, please contact us at the number provided below. 4. If you are unable to pay your account current within 33 days; we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately. If full payment of the amount of default is not made «~ithin 33 day s, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property ~~11 be sold by the sheriff to pay off the mortgage debt. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. You have the right to cure the default, or anyone acting on your behalf.., and pa_y your account current am•time at least one hour prior to the commencement of bidding at a sheriff's sale or other judicial sale, not more than three times in any calendar year. To do so; you must: a) Pa_y or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; h) Perform any other obligation which you would have been bound to perforn~ in the absence of default or the exercise of acceleration: c) Pay or tender any reasonable attorne_y's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default. as specified in writing by the mortgagee d) Pa_y any reasonable late penalty, if outlined in the mortgage Action required to cure the default: You must pa_y the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees. NSF fees. and other fees and advances are still valid and ~~ill need to be repaid under the terms of your loan documents. If you fail to cure the default on or before 01/24/2012, Chase will accelerate the maturity of the Loan, terminate your credit line if the Loan provides for revolving advances, declare all sums secured by the Security Instrument immediately due and payable and commence foreclosure proceedings, all ~~ithout further notice to you. If this happens, Chase ~~ill be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include; but not be limited to, allowable foreclosure/attorney fees and other expenses permitted by youur loan documents or applicable la~~ . 7. If permitted by your loan documents or applicable law, you have the right to reinstate after acceleration of the Loan and the right to bring a court action to assert the nonexistence of a default or any other defense to acceleration, foreclosure, and sale. However, the amount required to reinstate may be higher than what is owed under Paragraph 2 above due to additional fees and charges that we are entitled to collect under the Loan, including attorney fees related to any foreclosure action we initiate. Kindly remit the total amount due, shov<~n in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPa_v payment. oooos6s/ewsao Regular Mail: CHASE PO BOX 78420 PHOENIX_ AZ 81062-8420 Overnight Mail CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX_ AZ 85034-9700 Except as required by law, we are under no obligation to accept less than the full amount owed. 1f you send us less than the full amount owed, we ma_y in our sole discretion apply such partial pay~rnent to your Loan ~~-ithout waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance vtith Paragraph 4 above. 9. If you are unable to pay the amount past due.. Chase has a variety of homeowners' assistance programs that might help you resolve youur default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at (800) 848-9380. 10. While the Loan remains in default, we will perforn~ certain tasks to protect our interest in the Property, including visits to youur Property at regular intervals during the default. This ~~-ill be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly, your plans for curing the default and paying this Loan on time. You should anticipate that any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who ~~nll assume the mortgage debt. provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right ma_y exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeo~mership counseling services to borrowers in some areas. Counseling is also available through a varieh of nonprofit organizations experienced in homeovt~nership counseling and approved by the Secretary of Housing and Urban llevelopment (HUD).. A listing of such organizations may be obtained by calling HUD toll-free at (800) X69-4287 or at v<~v.hud.gov. Sincereh. Chase (800)848-9380 (800) 582-0542 TDD /Text Telephone www. chase. com Enclosure - Federal Trade Commission Pamphlet IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR. DEPENDENTS if you are a servicemember ~~~ho is, or recently was, on "active duty' or "active service" or a dependent of such. a servicemember, you ma_y be entitled to certain legal rights and protections, including protection from foreclosure or eviction, pursuant to the Sen~cemembers Civil Relief Act (50 USC App. §~ 501-596), as amended (the "SCRA") and possibly certain similar state statutes. Eligible service may include: • Active duty (as defined in section I O 1(d)(1) of title 10, United States Code) ~~~ith the Army, Navy. Air Force, Marine Corps or Coast Guard • Active service with the National Guard • Active service as a commissioned officer of the National Oceanic and Atmospheric Administration • Active service as a commissioned officer of the Public Health Service • Service with the forces of a nation with which the United States is allied in the prosecution of a war or military action • Service with the National Guard or a state militia under a state call to duty Eligible service also includes any period during which a servicemember is absent from duty on account of sickness, ~~•ounds. leave or other la~~~ful cause. If you are such a servicemember, or a dependent of such a servicemember, you should contact Chase Militan_- Services toll-free at (866) 840-5826 to discuss your status. An important reminder for all our customers: As stated in the "Questions and Answers for Borrowers about the Homeowner Affordability and Stability Plan" distributed by the Obama Administration, "Borrowers should beware of any organization that attempts to charge a fee for housing counseling or modification of a delinquent loan, especially if they require a fee in advance." Loan modification scams should be reported to PreventLoanScams.org or by calling (888) 995-HOPE. Chase offers loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at (800) 848-93801:0 discuss your options. The longer you delay, the fewer options you may have. Chase is a debt collector. If you are represented by an attorney, please refer this letter to youur attorney and provide us with the attorney's name, address and telephone number. 'Co the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. t3w840 0000969/BW840 Facing foreclosure? Stammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications - for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. "We can stop your foreclosure!" "97% success rate!" "Guaranteed to save your home!" These kinds of claims are the tell-tale signs of a foreclosure rip-off. Steer clear of anyone who offers an easy out. Don't Pay for a Promise. Don't pay any business, organization, or person who promises to prevent foreclosure or get you a new mortgage. These so-called "foreclosure rescue companies" claim they can help save your home, but they're out to make a quick buck. Some may request hefty fees in advance -and then stop returning your calls. Others may string you along before disclosing their charges. Cut off all dealings if someone insists on a fee. Send Payments Directly. Some stammers offer to handle financial arrangements for you, but then just pocket your payment. Send your mortgage payments ONLY to your mortgage servicer. Don't Pay for a Second Opinion. Have you applied for a loan modification and been turned down? Never pay fora "second opinion." Imitations =Frustrations. Some con artists use names, phone numbers, and websites to make it look like they're part of the government. If you want to contact a government agency, type the web address directly into your browser and look up any address you aren't sure about. Use phone numbers listed on agency websites or in other reliable sources, like the Blue Pages in your phone directory. Don't click on links or open any attachments in unexpected emails. Talk to aHUD-Certified Counseling Agency -For Free. If you're having trouble paying your mortgage or you've already gotten a delinquency notice, free help is a phone call away. Call 1-888-995 -HOPE for free personalized advice from housing counseling agencies certified by the U.S. Department of Housing and Urban Development (HUD). This national hotline - open 2417 - is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD-certified counseling agencies. For free guidance online, visit www.hopenow.com. For free information on the President's plan to help homeowners, visit www.makinghomeaffordable.gov. ~!~'!!~ Federal Made Commission ftc.gov/MoneyMatters Call 1-888-995-HOPE for free personalized guidance from housing counseling agencies certified by the U.S. Department of Housing and Urban Development. The Homeowner's HOPETM Hotline -open 24/7 - is operated by the Homeownership Preservation Foundation, a nonprofit member of the HOPE NOW Alliance of mortgage industry members and HUD-certified counseling agencies. Or visit www.hopenow.com For free. information on the President's plan to help homeowners, visit www. makinghomeaffordable.gov w~- 'HOPENOW Support & Gufdante For Momeowneis ~~~ SM MAKING HOME AFFORDABLE.GOv E~hi6it C *Exhibit has been redacted to rerraove all personally identifiable information ~r non public information --. , , • a Return Recorded Document To: Washington Mutual Bank, FA Michelle Stinson Default Specialist lI 7301 Baymeadows Way Jacksonville, FL 32256 Mail Sto : JAXA2000 Loan # ~8962/FETTERHOFF Investor Loan #1678786138 Mail Tax Statement To: Transamerica 6053 S. Fashion Square Drive Suite 200 Murray, UT 84107 {Space Above This Line for Recording Data) LOAN MODIFICATION AGREEMENT PROVIDING FOR FIXED INTEREST RATE This Loan Modification Agreement ("Agreement', made this 22ND day of APRIL, 2004 between JOHN G. FETTERHOFF AND BETH A. FETTERHOFF, HUSBAND AND W]TF, (`Borrower's residing at 56 BROAD STREET, NEWVILLE, PENNSYLVANIA, 17241, and WASHINGTON MUTUAL BANK, FA, ("LENDER'S with an address of c/o 730I Baymeadows Way, Jacksonville, FL 32256, amends and supplements { 1) the Mortgage, Deed of Trust or Deed to Secure Debt (the "Security Instrument"), dated OCTOBER 12, 2001 recorded OCTOBER 16, 2001 as BOOK NO. 1735, PAGE NO. 4122, in the Official Records of the Recorder of CUMBERLAND County, State of PENNSYLVANIA, in the original principal sum of $81,000.00 and (2) the Note bearing the same date as, and secured by, the Security Instrument, which covers the real personal property described in the Security Instrument and defined therein as the `Propert}~', located at 56 BROAD STREET, NEWVIGLE, PENNSYLVANIA, 17241 the real property described being set forth as follows: LEGAL DESCRII'TION ATTACHED HERETO AND MADE A PART HEREOF. PARCEL ID NUMBER: 28-21-0361-040 Jn consideration of the mutual promises and agreements exchanged, the parties hereto agree as follows (notwithstanding anything to the contrary contained in the Note or Security Instrument): The unpaid principal balance of this Mortgage prior to the execution of the Loan Modification Agreement was $79,343.67. As of MAY 1, 2004 the amount payable under _..the__Note and the Security Instrument the {"Unliaid Principal Balance") is U.S. $89,893.93, consisting of the amount{s) loaned to the Borrower by the Lender and any interest capitalized to date. 2. The Borrower promises to pay the Unpaid Principal Balance, plus interest, to the order of the Lender or as Lender directs. Interest will be charged on the unpaid balance at the rate of 5.875%, as defined in the Note, wmmencing MAY 1, 2004 and Borrower agrees to' make monthly payments of principal and interest in the amount of $719.17 commencing on JUNE 1, 2004 and each and every month thereafter on the same day of each succeeding month until the principal and interest are fully paid. If on NOVEMBER 1, 2031 (the "Maturity Date', the borrower still owes amounts under the Note and Security Instrument, as amended by this Agreement, the Borrower wr11 pay these amounts in full on the Maturity date. The Borrower will make such payments at P.O. Box 34150, San Antonio, TX. 78265 or at such other place as the Lender may require. .l , If all or any part of the Property or any interest in it is sold or transferred {or if a Beneficial interest in the Borrower is sold or transferred and the Borrower is not a natural person) without the Lender's prior written consent, the Lender may, at its option, require immediate payment in full of all sums secured by this Security Instrument- If the Lender exercises this option, the lender shall give the Borrower notice of acceleration. The notice shall provide a period of not less than 30 days from the date the notice is delivered or mailed within which the Borrower must pay all sums secured by this Security Instrument. If the Borrower fails to pay these sums prior to the expiration of this period, the Lender may invoice any remedies permitted by this Security Instrument without further notice or demand on the Borrower. 4. The Borrower also will comply with all other covenants, agreements, and requirements of the Security Instrument, including without limitation, the Borrower's covenants and agreements to make all payments of taxes, insurance premiums, assessments, escrow items, impounds, and all other payments that the Borrower is obligated to make under the Security Instrument S. Nothing in this Agreement shall be understood or construed to be a satisfaction or release in whole or in part of the Note and Security Instrument Except as otherwise specifically provided in this Agreement, the Note and Security Instrument will remain unchanged, and the Borrower and Lender will be bound by, and comply with, all of the terms and provisions thereof, as amended by this Agreement. By. / ~ J HN G,. )H'ETTERHOFF - Bornb~n+er BY- t`-~ t .~ . n~Q~.~C~ BETH A. }<i'ETTERHOEF - Bo er By. WENDY KN LC-VI PRESIDENT WASHING MUTCI BANK, PA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM :~•° , ~._, :.~? THE FDIC AS RECEIVER OF WASHINGTON l~~ ~ ~ N ==`~' MUTUAL BANK F/K/A WASHINGTON MUTUAL ~~_ ~ _ Case o. ~. ~ -__, ~,~~ ~ .-;~~ BANK. F.A. ~ _ _ ~ , Plaintiff ~-"'; ~ r~ .~ r,-~ VS. CIi r~~t ~ __ ~ ,,.„ : ~ . ~ ... } . '- l -r; F ETTERHOFF BETH A `" __ . ' , ~ ' JOHN G. FETTERHOFF ~ - ' Defendant(s) ~~_ ~, ; ;,~ NOTICE OF RESIDENTIAL MORTGAGE FORECLOSURE DIVERSION PROGRAM: You have been served with a foreclosure complaint that: could cause you to lose your home. if you own and live in the residential property which is the subject of this foreclosure action, you may be able to participate in acourt-supervised conciliation conference in an effort to resolve this matter with your lender.. If you do not have a lawyer, you must take the following steps to be eligible for a conciliation conference. First, within twenty (20) days of your receipt of this notice, you must contact MidPenn Legal Services at (717) 243-9400 extension 2510 or (800) 822-5288 extension 2510 and request appointment of a legal representative at no charge to you. Once you have been appointed a legal representative, you must promptly meet with that legal representative within twenty (20) days of the appointment date. During that meeting, you must provide the legal representative with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your legal representative complete a financial worksheet in the format attached hereto, the legal representative will prepare and file a Request for Conciliation Conference with the Court, which must be filed with the Court within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you will have an opportunity to meet with a representative of your lender in an attempt. to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. If you are represented by a lawyer, you and your lawyer must take the following steps to be eligible for a conciliation conference. It is not necessary for you to contact MidPenn Legal Service for the appointment of a legal representative. However, you must provide your lawyer with all requested financial information so that a loan resolution proposal can be prepared on your behalf. If you and your lawyer complete a financial worksheet in the format attached hereto, your lawyer will prepare and file a Request for Conciliation Conference with the Court, which must be filed within sixty (60) days of the service upon you of the foreclosure complaint. If you do so and a conciliation conference is scheduled, you. will have an opportunity to meet with a representative of your lender in an attempt to work out reasonable arrangements with your lender before the mortgage foreclosure suit proceeds forward. IF YOU WISH TO SAVE YOUR HOME, YOU MUST ACT QUICKLY AND TAKE THE STEPS REQUIRED BY THIS NOTICE. THIS PROGRAM IS FREE. e of Counsel for Plaintiff) 9,20/2012 Date Respectfully submitted: 1~ -- ignatur Cumberland County Residential Mortgage Foreclosure Diversion Program Financial Worksheet I?ate __ _ Curnberland~County Caurt of Common Fleas Dacke* # BOIutOWER REQUEST' FQIZ I-IARDSHIP ASSISTANCE "Ta eomptete~yaur request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your _____ Please provide the following information to the best of your knowledge: Borrower name(s); Property Address: City: State: dip: ~_ Is the property for sate? Yes Q No Q Listing date: Price: $~,____ Realtor Name: _ Realtor Phone: Harrower O;,cupied? Ye- s-~ 1~0 ~~'] ~..~ Mailing Address (if different):. _ Cify: Stater .Zip ..~.~ Phone Numbers: Email; ~ of people in household: How long? Mailing Address: City: Phone plumbers: Email: # afpeople in household: Firsi Mortgage Lender: _ 'T'ype of Loan: Loan 1VUmber: Second Mortgage Lender: Type of Loan; __._ Loan Nurnbcr: Home: Cell; Home: Cell: Office: Other: Office: Other: How long? State: Zip: Date You Closed Your Loan: Total Mortgage Payments Amount: $ fncluded Taxes & Insurance.; Date of Last Payment: _._.~.._._.. Prinary Reason for Default: Is the loan in Bankruptcy? Yes ® No Q if yes, provide names, location. of court, case nu3nher & attorney: Assets An~o~:nt Owed: Value: Other Rea! Estate: $ $ _ _ ~ _ Retirement Funds; $ $ Jravestments: $ $ Checking: $ $ Savings: $ $ Other: $ $ Automobile #1: Ibiodel: Amount owed: A~mobile #2: Model:, Amount owed: Value: Year: Value: C)ther transportation (automobiles, boats,,,mo€orcyelesl: Model: 'Fear; Amount owed: - -Value Monthly Income :Name of Employers: -~ ~. Additional income Description (not wages,): 1.~ monthly amount: 2. monthly amount: Borrower Pay bays: Co-Borrower Pay Days: Monthly Expenses: (Please only include expenses you are currently paying) EXPENSE AMOUNT EXPENSE _ AMOUNT ~1o a . Food _~_ ~-_ ~2 M c Utilities ~ Car Pa to s Condo/Nei ,1~ees Auto Insurance Med. not covered Auto fuel/ irs t7ther ro . a merit Y Install. Loan Pa meet Cable TV -~--- Child Su NAtim. S ndin Mone ,_ ll~hild Carel'Tuit, Other Ex uses Amount Available far Monthly Mortgage Payments Based on tneome & Expenses: Have you. been working with a Housing Counseling Agency? 'Y'es ~ No ~ Il' yes, please provide the following information: Couc~seling Agoney: Couriselor_ Phone Office}: _ 1~'ax: Year: ~,; ~~ai: rave yc~u r.?ace application for Homeowners Emergency Mortgage Assistance Program (HEMAP) assistance? Yes ^ No U If yes, pieace indicate the status of the application: Have you had any prior negotiations with your leader or lender's loan servicing company to resolve youur delinquency? Yes ^ No Q -* yes, please indicate the status of those negotiations: Please provide the followzng information, if know, regarding your lender ar lender's loan. servicing ec~mpany: Lender's Contact {IVarae): Servicing Company (l~tame): Contact: Phone: Phone: If We, _` ,authorize 'the above named to use/refer this information to my lender/servicer for the sole purpose of evaluating my financial situation for possible mortgage options. UWe understand that Uwe am/ase under na obligation to use the services provided by the above named Borrower Signature Date Ca-Borrower Signature Date Flease forward this document along with the following information to lender and lend_e(r's coua~sel: -~fi Proof of income 1~ Past 2 bank statements Proof of any expected income for the last ~5 days r ~ Copy of a current utility bill 1~ Letter explaiiniing reason far delinquency and any sapgorting documentation (hardship letter) i y l,~sting agreement {if property is currently an the market} SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ¢ rr,r, a.P~, ~- -,;- ~~ f l OCT 31 PM 3~ I ~ ~;l1ML~ERL~;~U CUI~~dT`}' ~F'~NSYI_V,~~dIA. JP Morgan Chase Bank. NA vs. Beth A. Fetterhoff (et al.) Case Number 2012-5965 SHERIFF'S RETURN OF SERVICE 10/18/2012 05:48 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October ", 8, 2012 at 1748 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: Beth A. Fetterhoff, by making known unto herself personally, at 56 Broad Street, 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. ~.`;~ / _. , RONALD HOOVER, DEPUTY 10/18/2012 05:48 PM -Ronald Hoover, Deputy :>heriff, who being duly sworn according to law, states that on October 8, 2012 at 1748 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: John G Fetterhoff, by making known unto Beth A. Fetterhoff, Wife of Defendant at 56 Broad Street, 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. _ ,_ r /' ~ ~ ~ ti ~ ~, ~,/ RONALD HOOVER, DEPUTY SHERIFF COST: $56.00 October 22. 2012 SO ANSWERS, ~'~.~---~j~ RONNY R ANDERSON. SHERIFF In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. No. 2012-05965 3415 Vision Drive :-•; ~._m Columbus, OH 43219 ~ ~ ~;,, _"t ~ Plaintiff c` R ~~ ~ ' ~ ...- `` BETH A. FETTERHOFF ~, r" ~ ° :=: ~ ; JOHN G. FETTERHOFF -< :~ ~` ' ~" '_~ ;' (Mortgagor(s) and Record Owner(s)) ~ ~ ~ -_'+ r 56 Broad Street 7" ~ ~ ,~~ ~ ~' ~~ ~ ~ t Newville, PA 17241 ~' : Defendant(s) ~ r°`. .' ~~ ~~ .- PRAECII'E FOR iUDGMENT THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. Enter the Judgment in favor of Plaintiff and against BETH A. FETTERHOFF and JOHN G. FETTERHOFF by default for want of an Answer. Assess damages as follows: $127,596.93 Debt Interest from 11/21/2012 to Date of Sale per diem at $17.64 Total (Assessment of Damages attached) I CERTIFY THAT FOREGOING ASSESSMENT OF DAMAGES IS FOR SPECIFIED AMOUNTS ALLEGED TO BE DUE IN THE COMPLAINT AND IS CALCULABLE AS A SUM CERTAIN FROM THE COMPLAINT. I certify that written notice of the intention to file this praecipe was mailed or delivered to the party ~nst whom judgment is to be entered and to his attorney of record, if any, after the default occurr d t least ten da p ' to the date of the filing of this praecipe. A copy of the notice is attached. R.C.P. 237.1 sy: xi~ LAw , P.c. Michael McKeever Pa. ID 56129 -Jay E. Kivitz Pa. ID 26769 4~ -Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 ` Ao~T s,~'SG~ _ ID 82628 David Fein Pa r d VV''""'p ~ ~7~ . Thomas Puleo Pa. ID 27615 ~ C r_18 ~~ 2 -Joshua I. Goldman Pa. 205047 ~ ~ ~l Q -Jill P. Jenkins Pa. ID 306588 ~ Attorneys for Plaintiff ~0 AND NOW ~~ . ~ ~ ~ ~~ > Judgment is entered in favor of JPMORGAN CHASE BANK,RNATIONAL ASSOCIATION, SUCCESSOR IN IN'T'EREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTO UTU .and against BETH A. FETTERHOFF and JOHN G. FETTERHOFF by default for want of an Ana and da es din the of $127,596.93 as per the above certification. ~ ~ ~ Prothonotary Rule of Civil Procedure No. 236 -Revised IN THE COURT OF COMMON PLEAS OF Cumberland COUNTY, PENNSYLVANIA CIVIL ACTION -LAW JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 Plaintiff No. 2012-05965 vs. BETH A. FETTERHOFF JOHN G. FETTERHOFF (Mortgagors and Record Owner(s)) 56 Broad Street Newville, PA 17241 Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. NOTICE Notice is given that a judgment in the above-captioned matter has been entered against you. David D. Buell Prothonotary of Cumberland County 1 Courthouse Square Carlisle, PA 17013 Prothonotary By: Y If you have any questions concerning the above, please contact: KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Mazket Street Philadelphia, PA 19106 215-627-1322 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~9~,xip a{ ~~abtrr~?b ~`h t~'F'~. `~~+~r} t ;4f' ..7 . ~.i `4.:~~.. JP Morgan Chase Bank, NA Case Number vs. 2012-5965 Beth A. Fettefioff (et aI.) SHERIFF'S RETURN OF SERVICE 10/18/2012 05:48 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 18, 2012 at 1748 hours, he served a true copy of the within Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Forecosure Diversion Program, upon the within named defendant, to wit: Beth A. Fettefioff, by making known unto herself personally, at 56 Broad Street, Newville, Cumberland County, Pennsylvania 17241 its contents and at the same time handing to her personaly the said true and correct copy of the same. ~~~ 5' ~_J!~L RO LD HOOVER, DEPUTY 10/18/2012 05:48 PM -Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 18, 2012 at 1748 hours, he served a true copy of the w~hrin Complaint in Mortgage Foreclosure and Notice of Residential Mortgage Foreclosure Diversion Program, upon the within named defendant, to wit: John G. Fettefioff, by making known unto Beth A. Fetterhoff, Wife of Defendant at 56 Broad Street, 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. ~ ~ ~~~ RONALD HOOVER, DEPUTY SHERIFF COST: $56.00 October 22, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF (c} Cw~trsuite sne:i+r, Tdioson, i,c. xxz~z3Fc THIS LAW FIRM IS A DEBT COLI.F.(TOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR T'T1E, PURPOSE OF COLLECTING THE DEBT. DATE OF T1BS NOTICE: November 8, 2012 TO: BETH A. FETTERHOFF 56 Broad Smet Newville, PA 17241 IPMORGAN CHAS}s BANK, NATIONAL ASSOCIATION, SUCCESSOR 1N INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASItII+iGTON MUTUAL. RANK F/K/A WASHINGTON MIJi'UAL BANK F.A 3415 Vision 13rive Columbus, 01143219 Plaint~;jJ' vs. BETH A. F>;'I"1'ERHOFF lO1IN ('~. FETTERHOFF (Mortgagor(s) and Record Owner(s)) 56 Broad SVeet Newvillc, PA 17241 Dejendanr(s) TO: BETR A. FE'TTERHOFF 56 Broad Street Newvitle, PA 17241 In the Court of Common Pleas of Cumberland County CTirII. ACTION -LAW Action of Mortgage Foreclosure No. 2012-05965 YOU ARE IN Dkt~'ACILT BECAUSE YOU RAVE FAILED TO ENTl;K A WRTITEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WTIH '!11); COI7RT YOUR DLTTENSES OR OBIECT[ONS TO THE CL.AII~IS SE7' FORTH AGAIIJST YOU. UNL1iSS YOU ACT WITEiIIJ T}iN (10) DAYS FROM THE llATE OF THIS NOTICE, A JUDGINENT MAY BE ENTERED AGATNS7' YOU WITHOUT A TIFARING AND YOU MAY LOSE YO[TR PROPERTY OR OT1iF.R TMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOII DO NOT HAVE A LAWYER, GO TO OR TF.IEPHONE THE OFFICE bZT FORTH B~F.I.OW. '11115 OFFICE CAN PROVIDE. YOU WTfH IIIFORMATION ABOUT EQRING A LAWYtiR TF YOU CANNOT AFFORD TO Ai1tE A LAWYER, THIS OFF1C1 MAY BE ABLE TO PROVIDE; YOU WI'CH INFORMA'I70N ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO E[.IGIBLE PERSONS AT A REI)U('ED FEE OR NO FEE. CUMBF.RI.AND COUNTY BAR ASSOCIATION 2 L'berty Aveauc Carlisle, PA 17013 LEGAL. SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 By: ~-~ R11~L~ LeVW GRO , P.C. Michael McKeever Pa. ID 56129 Lisa Lee Pa. 1D 78!120 ICrieti'a Martha Pa. ID 51858 David Fein Pa. ID 82628 Ttroa~as Paleo Pa. ID 27615 JiH P. Jenluns Pa. tD 3®6588 / Alrtc L. Otlamn Pa..ID 3!2912 215-627-1322 Attorneys for Plaintiff ::.: _ . - 111713FC TffiS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTllVG TO COLLECT A DEBT OWED TO OUR CLIENT. ANY IlVFORMATION OBTAIlVED FROM YOU WILL B1311SED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE: November 8, 2012 TO: JOHN G. FE77ERHOFF 56 Broad Strcct Nevwille,l'A 17241 JPMORGAN CHASI; RANK, NATIONAL ASSOCiATTON, SUCCESSOR IN INT7:REST BY PURCHASl:1~'ROM THE FDIC AS RECEIVER OP WASHllVG'fON MUTUAL BANK F/K/A WASHMtsl'ON MUTUAL BANK FA 3415 Vision Drive Columbus, OH 43219 P[ainn11'' vs. BETH A. FCTI'1;ILHOFF JOHN G.1•'ETTERKOFF (Mortgagor(s) and Record t)wncr(s)} 56 $ruad Street Ncwville, PA 17241 pefendunt(sj TO: JOIiN G. FETTERHOFF 56 Broad Street Newville, PA 17241 Tn the Court of Common Pleas of Cumberland County clvn. nCTTON - LAw Action of Mortgage Foroclosure No. 2012-05965 1MYORTAN'f NOTICE YOU ARE IN DEFA(JLT BECAUSE YOU HAVE FAILED 7'O ENTER A WRITTEN APPEARANCE PERSONALLY OR BY A't'i'ORNEY AND I71.Fi IN WRTTIIVG WTTII 'IT-iE COURT YOUR DEFENSES OR UBIECTIONS TO THE CLAIMS SET POItI'H AGAINST' YOU. UNLESS YOU ACT WfIHIN "1T;'N (10) DAYS FRUM '17E; DATE OF TIi1S NOTICE, A JLiDGdVIi;IdT MAY BE ENTERED AGAINST YOU Wf i rtfiOUT A HEARIIVCi AND YOU MAY LUSR YOUR PROPERTY OR OTTER IMPOR"1'ANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. iF YOU DO NOT HAVE A LAWYER, (.i0 'f0 OR TELEPHONE THE OFFICE SET FOR'ITl BELOW. THIS OM'FICE CAN PRUVIDI; YOU WITH INFORMATION ABOUT HIKING A LAWYER. IF YUU CANN07' AFFORD TO H1RE A LAWYh:R, THIS OFFICE MAYBE ABLE TO PRUVn)E YOU WITH JNFORMATION ABOU'!' AGENC)ES 'THAT MAY OFFER LEGAL SERVICES TO ELIG7tiLE PERSONS AT A RlilliJCED FEE OR NO 1•'EE. ' CUMBERLAND COUNTY BAR ASSOC1AT10N 2 Liberty Avarue Carlislc, PA 17013 LEGAL. SERVICESINC 8 Irvine Row Carlisle, PA 17013 717-243-94W By. KMI. GROUP, P.C. Michael McKeeva~ Ps I.D 56129 Lisa I.ee Pa. >~ 78620 Kristian Murtha Pa. ID b1858 David Fcia Px.1D 82628 Thomas pules Pa. ID 27615 rfl P. Jenidns Pa. ID 306588 ~Alyk L. Otlxziaa Pa. II1312912 21527-1322 - Attorneys far Plaintiff IlV THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. Plaintiff vs. BETH A.FETTERHOFF JOHN G. FETTERHOFF Defendant(s) N0.2012-05965 VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMEMBERS CIVIL RELIEF ACT AS AMENDED 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https•//www.dmdc.osd.miUappj/scra/scraHome.do) for the following individual(s): BETH A. FETTERHOFF, has a last known residence of 56 Broad Street, Newville, PA 17241. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification~thoriti Date ~~ ~•~"~ By: ~4W ~ KML W GROUP, ichael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff Department of Defense Manpower Data Center a~44a7 Pur~uan# #~ ~c~~c~members Curl lief Act Last Name: FETTERHOFF First Name: BETH Middle Name: A. Active Duty Status As Of: Nov-20-2012 Results as of :Nov-20.2012 12:51:38 SCRA 2.3 o~ A~ c>Wy orl A[db(rr ~ stfu. ~. Active Duly st.rf Dale Acute ~ End Dafa' staY/a s.rv+o. ce^rvener" NA NA No NA This response retlecte the fndiv{duals' edFve duty stars based on the Acura Duly Status Dam LeR AdNe Duty WMikr 367 Days of AdNe Duty Statue OM Active Duty Start Da6e Active Duty End D~ Statiw Service fomponsnc NA ~ i'lO ~ This response reflects wAtave dre individual fen active dory steWS rrMrin 387days preoedkp Ure AdNe Duty Status oNe TFn Member or FRaM1fer thrM Was No9Md'd a Futwt CaIFUp b Alive Duty on AdWe Duly 9Ysfus Dale Order NotlBratbn 9hsrt Date Order fJotlAmBon End Date StaWs Satvloe ComponsrN NA NA ib NA This response reflects vuhether Ura indhidtal a hisArer unM has received eery rwtl6oation to report for active duly Upon searching the data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Forte, NOAA, Public Health, and Coast Guard). This status inGudes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. rlay,. ~a ,G..~,-~.- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports tlme enforcement of the Senricemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Sokliers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small error rate. In the event the individual referenced above, or any family member, fiend, or representative asserts in any manner that the individual was on active duty for the active duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verifiption of the person's status by contacting that person's Service via the "defenselink.mil" URL: http://www.defenselink.miUfaq/pis/PC09SLDR.html. If you have evidence the person was on active duty for the alive duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Active Duty status on the Active Duty Status Date (2) Whether the individual left Active Duty status within 367 days preceding the Active Duty Status Date (3) Whether the individual or his/her unit received early notfication to report for active duty on the Active Duty Status Date. More information on "Active Duty Status" Active duty status as reported in this certificate is defined in acx;ordance with 10 USC § 101(d) (1). Prior to 2010 only some of the alive duty periods less than 30 consecutive days in length were available. In the pse of a member of the National Guard, this indudes service under a call to alive service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency dedared by the President and supported by Federal funds. All Alive Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This indudes Navy Training and Administration of the Reserves (TARs), Marine Corps Alive Reserve (ARS) and Coast Guard Reserve Program Administrator (RPAs). Alive Duty status also applies to a Uniformed Service member who is an alive duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and inctudes some categories of persons on alive duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. SCRA protections are for Title 10 and Title 14 active duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certifiption should check to make sure the orders on which SCRA protections are based have not been amended to extend the indusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for alive duty or to be inducted, but who have not actually begun alive duty or actually reported for induction. The Last Date on Alive Duty entry is important because a number of protections of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected WARNING: This certificate was provided based on a last name, SSN/date of birth, and active duty status date provided by the requester. Providing erroneous information will cause an erroneous certificate to be provided. Certificate ID: CSCGGSC07S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. Plaintiff vs. BETH A. FETTERHOFF JOHN G. FETTERHOFF Defendant(s) N0.2012-05965 1. The undersigned attorney with KML Law Group, P.C., as the representative for the Plaintiff in the above entitled matter, does hereby state to the best of his/her information and belief, as follows: 2. That an inquiry has been made with the Defense Manpower Data Center ("DMDC") website operated by the United States Department of Defense (https•//www.dmdc.osd.miUappi/scra/scraHome.do) for the following individual(s): JOHN G. FETTERHOFF, has a last known residence of 56 Broad Street, Newville, PA 17241. The following information was used to search the DMDC (check all that apply): X Last Name X First Name X Social Security Number 3. The DMDC search results, a copy of which is attached, states that based on the information provided, the DMDC does not possess any information indicating that the individual is on active duty or has been on active duty within the last 367 days. The undersigned understands that the statements herein are made subject to penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to au n s. Date ~l d`'' ~~ By: KML LA ROUP, P. . Michael McKeever Pa. ID 56129 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Jay Kivitz Pa. ID 26769 Andrew Gornall Pa. ID 92382 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff Results as of :Nov-2o-2012 12:54:11 Department of Defense Manpower Data Center SCRA 2.3 +,l~kW'~ Pmt to ~'`l~'VfiC+l:1I1C]1Y~1'3~ ~ivr It~lief Act Last Name: FETTERHOFF First Name: JOHN Middle Name: G. Active Duty Status As Of: Nov-20-2012 on adwe Duty o~ Adrvs oay status ~. Aawe arty slap Dab Actlve say End oeie st.we servfw NA NA No NA This response reAae4lfts Yidiiduels' aotfve dory sLhra based on the AdNe Dury Stabs Date Len Adive Duty Wlttdn 387 Days of At~va Duty SiMu Dale Adive Duty Start Dete Attive Duty Erd Date Sfattce 3en4oe Component ~ Nq No NA This response renects where the indNidual IcR active duty stehrs wlFin 387 days pre~q the Active Duly Status Date The #lerrtrei• or tiishler UMI Was WoBfed d r Future CpN-Up b Atllva Dury on Attt» Duly SWus Ds1e Order NoYfotlm Slarl Dab Order NatlncWbn End Date SteWS Service Camponerri NA ~ ~ ~ This response relleuNS whether tlw fndivt0ud « hislher uNt has received eerty notllir~lion to repoR for acute duty Upon searching the data banks of the Department of Defense Manpower Data Carder, based on the information that you provided, the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAH, Public Heakh, and Coast Guard). This status includes information on a Servicemember or his/her unit ret~iving notfication of future orders to report for Active Duty. • ~~ ..n Mary M. Snavey-Dixon, Director Department of Defense -Manpower Data Center 4800 Mark Center Drive, Suite 04E25 Arlington, VA 22350 The,Defense Manpower Data Center (DMDC) is an organization of the Department of Defense (DoD) that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Servicemembers Civil Relief Act (50 USC App. § 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Saibrs' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced only a small eror rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual was on active duty for the adive duty status date, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL: http:/hvww.defer-selink.miUfaq/pis/PC09SLDR.html. If you have evidence the person was on adive duty for the active duty status date and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. § 521(c). This response reflects the following information: (1) The individual's Adive Duty status on the Adive Duty Status Date (2) Whether the individual left Adive Duty status within 367 days preceding the Adive Duty Status Date (3) Whether the individual or his/her unit received early notification to report for adive duty on the Adive Duty Status Date. More information on "Active Duty Status" Adive duty status as reported in this certficate is defined in accordance with 10 USC § 101(d) (1). Prior to 2010 only some of the adive duty periods less than 30 consecutive days in length were available. In the case of a member of the National Guard, this indudes service under a call to adive service authorized by the President or the Secretary of Defense under 32 USC § 502(f) for purposes of responding to a national emergency dedared by the President and supported by Federal funds. All Adive Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This indudes Navy Training and Administration of the Reserves (TARs), Marine Corps Adive Reserve (ARs) and Coast Guard Reserve Program Administrator (RPAs). Adive Duty status also applies to a Uniformed Service member who is an adive duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps). Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Adive Duty under this certificate. SCRA protedions are for Title 10 and Title 14 adive duty records for all the Uniformed Services periods. Title 32 periods of Active Duty are not covered by SCRA, as defined in accordance with 10 USC § 101(d)(1). Many times orders are amended to extend the period of active duty, which would extend SCRA protectors. Persons seeking to rely on this website certifiptlon should check to make sure the orders on which SCRA protedions an: based have not been amended to extend the indusive dates of service. Furthermore, some protedions of the SCRA may extend to persons who have received orders to report for adive duty or to be induded, but who have not adualiy begun adive duty or adually reported for indudion. The Last Date on Active Duty entry is important because a number of protedions of the SCRA extend beyond the last dates of active duty. Those who could rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are proteded WARNING: This certificate was provided based on a last name, SSN/date of birth, and adive duty status date provided by the requester. Providing erroneous information will cause an erroneous cerfifigte to be provided. Certificate ID: MMPBKM8T9V KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Mazket Street Philadelphia, PA 19106 215-627-1322 Attornev for Plaintiff ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. BETH A. FETTERHOFF JOHN G. FETTERHOFF (Mortgagor(s) and Record owner(s)) 56 Broad Street Newville, PA 17241 Defendant(s) ORDER FOR iUDGMENT IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION LAW ACTION OF MORTGAGE FORECLOSURE No. 2012-05965 Please enter Judgment in favor of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A., and against BETH A. FETTE d JOHN G. RHOFF for failure to file an Answer in the above action within (20) days from the date of se a the Complai t, in um of $127,596.93. By: KML L GROUP, P. Michae cKeever Pa. I 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. lD 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff I hereby certify that the above names aze correct and that the precise residence address of the judgment creditor is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 and that the name(s) and last known address a Defen (s) ' az BETH A. FETTERHOFF, 56 Broad Street Newville, PA 17241 and JOHN G. F~j7~OFF, 56 ad t N~wville, PA 17241; By: "~' _ KML L GROUP, Pit . Michae cKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 _~bavid Fein Pa. ID 82628 // Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff , ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $109,623.67 Interest from 07/01/2011 through $8,952.78 11/20/2012 Reasonable Attorney's Fee $1,450.00 Late Charges $439.14 Escrow $3,058.07 BPO/Appraisals $225 •~ Property Preservation $4,545.83 Property Inspections $208.25 Suspense ($905.81) $127,596.93 By: KML LAW G P, P.C. Michael Mc ver Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff AND NOW, this a~ day of IV~/~/ • , 2012 damages are assessed as above. '~'" ~! ; ,. l , thy' 2012-05965/111713FC PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 ~ :~ ~_ G: ~ . KML Law Group, P.C. ._,,. _~--_ ~"~ ~M ,~, -;~~- ~ ."°.: Suite 5000 - BNY Independence Center =-~ `~~- 701 Market Street ~ ~ ~`' Philadelphia, PA 19106 ~~ Y~, ~~ , 215-627-1322 ~ sa ~ -~. ~, `-'`' Attorney for Plaintiff ~ ~ - ~ `,.T, .~ JPMORGAN CHASE BANK, NATIONAL . ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF IN THE COURT OF COMMON PLEAS WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. of Cumberland County 3415 Vision Drive Columbus, OH 43219 CIVIL ACTION -LAW vs. BETH A. FETTERHOFF JOHN G. FETTERHOFF Mortgagor(s) and Record Owner(s) 56 Broad Street Newville, PA 17241 Plaintiff Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 2012-05965 PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 11/21/2012 to Date of Sale per diem at $17.64 (Costs to be added) $127,596.93 Sco.Oo V~oF (I q i~, SO 5 0 It q ~" ~ a ~ ~~~.~5 By: LAW GRO .C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 _lbavid Fein Pa. ID 82628 ~/ Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attormys for Plaintiff ~ ~. aS "eve Co. ~, sor.~ ~~ 7~rVra / e1F e783v(o2 ~,~.~r? ~ ~c ~SSur.G~ W a O ~~ "' O 0 N ~ op oa z~ 0 x E r~ O~~ ~~~ ~Q~Q ~a z~ ~ Q ex~ ~ ~~-~'O zO~jE"~ a z~ H X30 c~~o~ x Q ~c UQV~ ~UQw SUM ~~~ .ti ~ ~~ ~ ti U ~ ~Op ~N ~~ W U ~ Vc_o ~ ~ ~, ~Q ~ C7 o CS~ e sN ,~ ~~ - pG ~ 3 a . ~ >, 3 ~., ~ :.~ ~ ~ ~ ~~ ~ a ~ ~ ~N o ~ ~,-~ W ~' ALL THAT CERTAIN lot of land and the improvements situated and erected thereon, situate at 56 Broad Street, Borough of Newville, Cumberland County, Pennsylvania, more particularly bounded and described as follows: ON THE South by said Broad street; on the West by property now or formerly of Clair Sollenberger; on the North by an alley; and on the East by property now or formerly of Glenn Mohn. HAVING a frontage on said Broad Street of Sixty (60) feet and extending in depth at an even width One Hundred Eighty (180) feet to said alley on the North. BEING improved with a two and one-half story brick dwelling house and other improvements. BEING the same premises which Harold D. Snyder and Tenna K. Snyder, husband and wife, by their deed dated 10/12/01, and recorded 10/16/01 in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 248 Page 3920, granted and conveyed to John G. Fetterhoff and Beth A. Fetterhoff, husband and wife TAX PARCEL #28-21-0361-040 BEING PREMISES: 56 Broad Street, Newville, PA 17241 IMPROVEMENTS improved with a two and one-half story brick dwelling house and other improvements. MUNICIPALITY Borough of Newville SOLD as the property of John G. Fetterhoff and Beth A. Fetterhoff, husband and wife KML Law Group, P.C. Suite 5000 - BNY Independence Center .- 701 Mazket Street "' ~ ' " ` ` t,'t. ~'~a~ r;iEij~ ~r=', I Philadelphia, PA 19106 215-627-1322 ~ ~ ~ ~,~ ~ ~ ~~~ ~ ~ : ~ Attorney for Plaintiff '.i~9l1?! t~ktn rn~~-~-rv JPMORGAN CHASE BANK, NATIONS ~~ S Y LVA ~ I ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 Plaintiff IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW vs. BETH A. FETTERHOFF JOHN G. FETTERHOFF (Mortgagor(s) and Record Owner(s)) 56 Broad Street Newville, PA 17241 Defendant(s) ACTION OF MORTGAGE FORECLOSURE No. 2012-05965 AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A., Plaintiff 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: 56 Broad Street Newville, PA 17241 1.Name and address of Owner(s) or Reputed Owner(s): BETH A. FETTERHOFF 56 Broad Street Newville, PA 17241 JOHN G. FETTERHOFF 56 Broad Street Newville, PA 17241 2. Name and address of Defendant(s) in the judgment: BETH A. FETTERHOFF 56 Broad Street Newville, PA 17241 JOHN G. FETTERHOFF 56 Broad Street 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 DISCOVER BANK Edward Stock, c/o Stock & Grimes, LLP 804 West Avenue Jenkintown, PA 19046 DISCOVER BANK 502 E. Mazket Street Greenwood, DE 19950 CITIBANK SOUTH DAKOTA, N.A Michael F. Ratchford, c/o Edwin A. Abrahamsen & Assocociates 120 N. Keyser Avenue Scranton, PA 18504 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 56 Broad Street 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 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: aj By: L LAW G UP, 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 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff 2012-05965 I~VII. 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, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 vs. BETH A. FETTERHOFF JOHN G. FETTERHOFF Mortgagor(s) and Record Owner(s) 56 Broad Street Newville, PA 17241 Plaintiff Defendants; ~~~~ ~ ,-;; F1~'7~~~f1~r',; E IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 2012-05965 THLS 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: r-E•t-rExxor-F, B~rx a. BETH A. FETTERHOFF 56 Broad Street Newville, PA 17241 Your house at 56 Broad Street, 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 $127,596.93 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THLS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 2012-05965 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A., the back payments, late chazges, 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. 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 S RIFFS 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 compazed 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: http:/lwww philadelphiafed orglforeclosure/ 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 Cazlisle, PA 17013 717-243-9400 2012-05965 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.~ov 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 htt~//www phfa org/consumers/homeowners/real.asyx. 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@kmllawgroup.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 chazge 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 111713FC. Para informacion en espanol puede communicazse con Loretta al 215-825-6344. 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, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. BETH A. FETTERHOFF JOHN G. FETTERHOFF Mortgagor(s) and Record Owner(s) 56 Broad Street Newville, PA 17241. Defendant(s) ~~ f .~ F '*' ~~ 1 ~~~ d ~' r LY,~~11q IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION -LAW ACTION OF MORTGAGE FORECLOSURE N0.2012-05965 CERTIFICATION AS TO THE SALE OF REAL PROPERTY Plaintiff, by counsel, hereby certifies 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. By: LAW GROUP .C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 avid Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. 205047 Jill P. Jenkins Pa. ID 306588 Attorneys for Plaintiff WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-5965 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, SUCCESSOR IN INTEREST BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A WASHINGTON MUTUAL BANK F.A. Plaintiff (s) From BETH A. FETTERHOFF, JOHN G. FETTERHOFF (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: $127,596.93 L.L.: $.50 Interest FROM 11/21/2012 TO DATE OF SALE PER DIEM AT $17.64 Atty's Comm: Due Prothy: $2.25 Atty Paid: $207.25 Other Costs: Plaintiff Paid: Date: 11 /26/12 David Buell, Protl y . (Seal) BY~ Deputy REQUESTING PARTY: Name: THOIVIAS PULED, ESQUIRE Address: KMIJ 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. 27615 KML LAW GROUP,P.C. Suite 5000—BNY Independence Center OF ]'Jy, �Ffy 701 Market Street Rl*1 Wol*' Philadelphia, PA 19106-153213gpR rAR r 215-627-1322 Attorney for Plaintiff �"+7Q 10-. 40 JPMORGAN CHASE BANK,NATIONAL �MIq ASSOCIATION, SUCCESSOR IN INTEREST BY IN THE COURT OF COMMON PLEAS PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL BANK F/K/A of Cumberland County WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 Plaintiff vs. No. 2012-05965 BETH A. FETTERHOFF JOHN G. FETTERHOFF (Mortgagor(s)and Record owner(s)) 56 Broad Street Newville, PA 17241 Defendant(s) PRAECIPE TO VACATE JUDGMENT TO THE PROTHONOTARY: Kindly vacate the judgment upon payment of your costs only. r By: _Z4 KML LAW GROUP,P. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa. ID 82628 Jill P.Jenkins Pa. ID 306588 Alyk L.Oflazian Pa.ID 312912 Salvatore Filippello,Attorney ID 313897 ttomeys for Plaintiff 0,n�� .s d at It LbT 71 7J9,9 cP " 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, SUCCESSOR IN INTEREST BY IN PURCHASE FROM THE FDIC AS RECEIVER OF THE COURT OF COMMON PLEAS WASHINGTON MUTUAL BANK F/K/A OF Cumberland COUNTY WASHINGTON MUTUAL BANK F.A. CIVIL ACTION -LAW Plaintiff VS. ACTION OF MORTGAGE BETH A. FETTERHOFF FORECLOSURE JOHN G. FETTERHOFF (Mortgagor(s)and Record Owner(s)) No. 2012-05965 Defendant(s) CERTIFICATE OF SERVICE Angela M. Smith , hereby certifies that he/she did serve true and correct copies of Praecipe to Vacate Judgment and alls supporting papers attached hereto upon Defendant, by first class mail, postage pre-paid, on ,f--I y 47 BETH A. FETTERHOFF 56 Broad Street Newville, PA 17241 JOHN G. FETTERHOFF 56 Broad Street Newville, PA 17241 By: KM4AR UP, P.C. Angela M. Smith, Legal Assistant asmith@kmilawgroup.com 215-825-6325 (Direct Phone) � s KML LAW GROUP, P.C. Suite 5000—BNY Mellon Independence Center FILES-OFFICE 701 Market Street OF THE PROTHONOTARY Philadelphia, PA 19106-1532 1013 APR _5 AN 10: 48 215-627-1322 JPMORGAN CHASE BANK,NATIONAL PE YLVi4I�IA ASSOCIATION, SUCCESSOR IN INTEREST IN THE COURT OF COMMON PLEAS BY PURCHASE FROM THE FDIC AS RECEIVER OF WASHINGTON MUTUAL OF CUMBERLAND COUNTY BANK F/K/A WASHINGTON MUTUAL BANK F.A. 3415 Vision Drive Columbus, OH 43219 No. 2012-05965 Plaintiff vs. BETH A. FETTERHOFF JOHN G. FETTERHOFF (Mortgagor(s) and Record owner(s)) 56 Broad Street 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 GROUP,P.C. F/K/A GOLDBECK McCAFFERTY& McKEEVER By: Michael McKeever Pa 56129 Jay E. Kivitz Pa. ID 2 769 Lisa Lee Pa. ID 78020 Thomas Puleo Pa. ID 27615 David Fein Pa.ID 82628 Jill P.Jenkins Pa. ID 306588 Alyk L. Oflazian Pa. ID 312912 Salvatore Filippello,Attorney ID 313897 Attorneys for Plaintiff t 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, SUCCESSOR IN INTEREST IN THE COURT OF COMMON BY PURCHASE FROM THE FDIC AS PLEAS RECEIVER OF WASHINGTON MUTUAL OF CUMBERLAND COUNTY BANK F/K/A WASHINGTON MUTUAL BANK F.A. CIVIL ACTION - LAW Plaintiff VS. ACTION OF MORTGAGE FORECLOSURE BETH A. FETTERHOFF JOHN G. FETTERHOFF No. 2012-05965 (Mortgagor(s)and Record Owner(s)) Defendant(s) 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 BETH A. FETTERHOFF 56 Broad Street Newville, PA 17241 JOHN G. FETTERHOFF 56 Broad Street Newville, PA 17241 KML LAW GROUP,P.C. F/K/A GOLDBECK McCAFFER7&McKEEVER By: 4MAna .oSmithl, Legal Assistant asmith@kmllawgroup.com 215-825-6325 (Direct Phone)