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KMI. LAW GROUP, P.C. SUITE 5000 - BNY MELLON INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106 (866)413-2311 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION c/o 3415 Vision Drive Columbus, OH 43219 Plaint vs. SONYA NEFF Mortgagor(s) and Record Owner(s) 331 North West Street Carlisle, PA 17013 Defendant(s) IN THE ~~' ` ~ ~ ~~ 1~~. ,, ,~ -~ PLEAS OF Cumberland CC~~NTY CIVIL ACTION -LAW ~ ~a,~7155 v' I ACTION OF MORTGAGE FORECLOSURE CIVIL ACTION: MORTGAGE: ~~I~6~$ NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after the Complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the Court without further notice for any money claim in the Complaint of for any other claim or relief requested by the Plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 AVISO Le han demandado a usted en la torte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dial de plazo al partir de la fecha de la demanda y la notificacion. Hate falta ascentar una comparencia escrita o en persona o con un abogado y entregar a la torte 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 torte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la torte puede decider a favor del demandante y requiere que usted cumpla con todas las provisioner de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICO. VAYA EN PERSONA O LLAME~ POR TELEFONO A LA OFICINA CUYA DIItECCION SE ENCUENTRA ESCRITA ABAJO PARR I ~~ AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. ate} ~ )~'3, ~ SCI '~~`~ a s s vsa SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE INFORMACION ACERCA AGENCIAS QUE PUEDAN OFRECER SERVICIOS LEGAL A PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle, PA 17013 717-243-9400 THIS FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CLIENT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. RESOURCES AVAILABLE FOR HOMEOWNERS IN FORECLOSURE ACT NOW! Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717- 243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.g_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 httn:/1www.nhfa.or~/consumers/homeowners/real aspx. 5). Call the Plaintiff (your lender) and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Foreclosure Resource Center: httn://www.nhiladelphiafed.org/foreclosure/ 7). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout /Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention(cr~,kmllawgrouy.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 116536FC. Para informacion en espanol puede communicarse con Loretta a1215-825-6344. This Action of Mortgage Foreclosure will continue unless you take action to stop it. COMPLAINT IN MORTGAGE FORECLOSURE 1. Plaintiff is JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, c/o 3415 Vision Drive, Columbus, OH 4321.9. 2. The name(s) and address(es) of the Defendant(s) is/are SONYA NEFF, 331 North West Street, Carlisle, PA 17013, who is/are the mortgagor(s) and record owner(s) of the mortgaged premises hereinafter described. 3. On July 25, 2008 mortgagor(s) made, executed and delivered a mortgage upon the Property hereinafter described to JPMORGAN CHASE BANK, N.A., which mortgage is recorded in the Office of the Recorder of Deeds of Cumberland County on August 07, 2008 as Instrument # 200826946. 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. 4. The Property subject to the Mortgage is more fully described in the legal description set forth as Exhibit "A" ("Property"). 5. The mortgage is in default because the monthly payments of principal and interest are due and unpaid for May O1, 2012 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 October 31, 2012: Principal Balance ........................................................................................$100,929.90 Interest from 04/01/2012 through 10/31/2012 .............................................$3,532.55 Accrued Late Charges ............................................................................................$0.00 Escrow Advance .............................................................................................$1,099.59 Property Inspection ..............................................................................................$56.00 Reasonable Attorney's Fee .............................................................................$1,650.00 $107,268.04 If the Mortgage is reinstated prior to a Sheriff's Sale, the Attorney's Fees set forth above may be less than the amount demanded based on work actually performed. Plaintiff reserves the right to request additional attorney's fees if the complexity of the action results in fees in excess of the amount demanded. Further, Plaintiff will request recovery of all costs incurred in this action including, but not limited to, costs of suit, process serving and skip tracing, title searches, recording costs and any other costs of the action in accordance with the mortgage documents and applicable law. 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 Intention to Foreclose has been sent to Defendants by certified mail, on the date set forth in the true and correct copy of the Notice attached and incorporated as Exhibit "B". WHEREFORE, Plaintiff demands a de terris judgment in mortgage foreclosure in the sum of $107,268.04, 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 foreclosure and sale of the mortgage property. By' ~~~~~` KML LA~ G~OUP, P.C. Michael McKeever Pa. ID 56129 Jay E. Kivitz Pa. ID 26769 Lisa Lee Pa. ID 78020 Kristina Murtha Pa. ID 61858 David Fein Pa. ID 82628 Thomas Puleo Pa. ID 27615 Joshua I. Goldman Pa. ID 205047 -dill P. Jenkins Pa. ID 306588 Andrew F. Gornall Pa. ID 92382 Alyk L. Oflazian Pa. ID 312912 Attorneys for Plaintiff VERIFICATION ~T ~' ~dI'I /"~ ~~Q~~ ,hereby states that e/ he is ~'G~ 6SicIFn of JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff in this matter and is authorized to make this Verification. The statements of fact contained in the foregoing Civil Action in Mortgage Foreclosure are true and correct to the best of my 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: /~-~ -~~ ~~ Name: ~E f a~ ~~ca,~ Title: /r'cr /D.CESi:~Ea~ #116536FC SONYA NEFF ~FciditA THE LAND REFERRED TO HEREIN IS SITUATED IN THE STATE OF PENNSYLVANIA, COUNTY OF CUMBERLAND, CITY OF CARLISLE, AND DESCRIBED AS FOLLOWS: ALL THAT CERTAIN PIECE OR PARCEL OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE ON THE EAST SIDE OF NORTH WEST STREET, BETWEEN PENN AND LINCOLN STREETS, TO WIT: NO. 331 NORTH WEST STREET, IN THE FOURTH WARD OF THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY, PENNSYLVANIA, MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: ON THE NORTH BY PROPERTY NOW OR FORMERLY OF DAVID C. SHEIBLEY; ON THE EAST BY OTHER PROPERTY NOW OR FORMERLY OF ORLEAN S. ELLIOTT; ON THE SOUTH BY THE PROPERTY NOW OR FORMERLY OF MARY E. CAMPBELL; ON THE WEST BY NORTH WEST STREET. SAID LOT FRONTS TWENTY-SIX (26) FEET, MORE OR LESS, ON NORTH WEST STREET AND IS ONE HUNDRED (100) FEET, MORE OR LESS, IN DEPTH. ~hi6it ~ *Exhibit has been redacted to remove all personally identifiable information or non public information Chase (FL5-7734) PO Box 44090 Jacksonville, FL 32231-4090 I~~~III~~~III~~~~~,11.,I1~~~~lll~l~~~ll~~~~~ll~~fl~~~~lll~~~ll 00033548 HDLG ZB 18012 -BR840 SONYA NEFF 331 NWST CARLISLE, PA 17013 Acceleration Warning (Notice of Intent to Foreclose) Account:~6499 (the "Loan") Property ess: 331N W ST CARLISLE, PA 17013 (the "Property") Dear SONYA NEFF: CHASE ! i June 28, 2012 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 May 1, 2012. As of June 28, 2012, 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 $1,822.02 are past due. This past-due amount is itemized below. If applicable, your account may have additional escrow amounts that have been paid out and are due on the Loan. 3. If you have any questions about the amounts detailed below, please contact us as soon as possible at (800) 848-9380. Total Monthly Payments $1,822.02 Late Fees $0.00 NSF Fees $0.00 Other Fees* $0.00 Advances* $0.00 Amount Held in Suspense $0.00 *Other Fees and Advances include those amounts assessed in accordance with your loan documents, and/or permitted by applicable law, or that were authorized for services rendered. 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 July 31, 2012 set forth in Paragraph 4 below. These amounts may include, but are not limited to, taxes, insurance, inspection fees and other fees, as permitted by applicable law. If you have any reason to dispute the past-due amount listed above, or if you believe your Loan is current, please contact us at the number provided below. 4. If you are unable to pay your account current within 33 days, we intend to exercise our right to accelerate the mortgage payments. This means that whatever is owed on the original amount borrowed will be considered due immediately. If full payment of the amount of default is not made within 33 days, we also intend to instruct our attorneys to start a lawsuit to foreclose your mortgaged property. If the mortgage is foreclosed, your mortgaged property will be sold by the sheriff to pay off the mortgage debt. We may also sue you personally for the unpaid principal balance and all other sums due under the mortgage. 5. You have the right to cure the default, or anyone acting on your behalf, and pay your account current anytime at least one hour prior to the commencement of bidding at a sheriff s sale or other judicial sale, not more than three times in any calendar year. To do so, you must: a) Pay or tender in the form of cash, cashier's check or certified check all sums that would have been due at the time of payment or tender in the absence of default and the exercise of acceleration; b) Perform any other obligation which you would have been bound to perform in the absence of default or the exercise of acceleration; c) Pay or tender any reasonable attorney's fees the reasonable costs of proceeding to foreclosure that were actually incurred up to and including the date the debtor cures the default, as specified in writing by the mortgagee d) Pay any reasonable late penalty, if outlined in the mortgage Action required to cure the default: You must pay the Total Monthly Payments listed in Paragraph 2 within 33 days from the date of this notice in order to cure this default. All late fees, NSF fees, and other fees and advances are still valid and will need to be repaid under the terms of your loan documents. 6. If you fail to cure the default on or before July 31, 2012, Chase will accelerate the maturity of the Loan, terminate your credit line if the Loan provides for revolving advances, declare all sums secured by the Security Instrument immediately due and payable and commence foreclosure proceedings, all without further notice to you. If this happens, Chase will be entitled to collect its expenses incurred in pursuing the remedies provided in the Security Instrument, which may include, but not be limited to, allowable foreclosure/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. 8. Kindly remit the total amount due, shown in Paragraph 2 above, to the remittance address listed below. Please note that Chase policy requires certified funds if two insufficient funds (NSF) payments have been received in the last six months. In this event, Chase will not accept a Direct Check, FastPay or SpeedPay payment. Payments cannot be made at Chase retail bank branches. Please refer to the addresses below for payment information or contact us if you have any questions. Regular Mail: CHASE PO BOX 78420 PHOENIX AZ 85062-8420 Overnight Mail: CHASE PO BOX 78420 1820 EAST SKY HARBOR CIRCLE SOUTH PHOENIX, AZ 85034-9700 Except as required by law, we are under no obligation to accept less than the full amount owed. If you send us less than the full amount owed, we may in our sole discretion apply such partial payment to your Loan without waiving any default or waiving our right to accelerate the Loan and continue with foreclosure proceedings in accordance with Paragraph 4 above. 9. If you are unable to pay the amount past due, Chase has a variety of homeowners' assistance programs that might help you resolve your default and keep your home; however, we need to talk with you to discuss these options and determine which of them might be appropriate for your circumstances. Please call us as soon as possible at (800) 848-9380. 10. While the Loan remains in default, we will perform certain tasks to protect our interest in the Property, including visits to your Property at regular intervals during the default. This will be done to determine, as of the date of the inspection the property condition, occupancy status, and, possibly, your plans for curing the default and paying this Loan on time. You should anticipatethat any costs incurred by Chase will be added to the amount you now owe if permitted by your loan documents or applicable law. 11. You have additional rights to help protect your interest in the property. You have the right to sell the property to obtain money to pay off the mortgage debt or to borrow money from another lending institution to pay off this debt. You may have the right to sell or transfer the property subject to the mortgage to a buyer or transferee who will assume the mortgage debt, provided that all the outstanding payments, charges and attorney fees and costs are paid prior to or at the sale (and that the other requirements under the mortgage are satisfied). Contact us to determine under what circumstances this right may exist. You have the right to have this default cured by any third party acting on your behalf. Chase offers homeownership counseling services to borrowers in some areas. Counseling is also available through a variety of nonprofit organizations experienced in homeownership counseling and approved by the Secretary of Housing and Urban Development (HUD). A listing of such organizations may be obtained by calling HUD toll-free at (800) 569-4287 or at www.hud.gov. Sincerely, Chase (800)848-9380 (800) 582-0542 TDD /Text Telephone www.chase.com Enclosure - Federal Trade Commission Pamphlet IMPORTANT NOTICE TO SERVICEMEMBERS AND THEIR DEPENDENTS If you are or recently were on active duty or active service, you may be eligible for benefits and protections under the federal Servicemembers Civil Relief Act (SCRA). This includes protection from foreclosure or eviction. You may also be eligible for benefits and protections under state law. SCRA and state military benefits and protections also may be available if you are the dependent of an eligible servicemember. Eligible service may include: Active duty with the Army, Navy, Air Force, Marine Corps, or Coast Guard, or Active service as a commissioned officer of the National Oceanic and Atmospheric Administration, or Active service as a commissioned officer of the Public Health Service, or Service with the forces of a nation with which the United States is allied in a war or military action, or Service with the National Guard of a state militia under a state call of duty, or Any period when you are absent from duty because of siclrness, wounds, leave, or other lawful cause. For more information, please call Chase Military Services at 866-840-5826. 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; 888-995-4673. We offer loan modification assistance free of charge (i.e., no modification fee required). Please call us immediately at 866-550-5705 to discuss your options. The longer you delay, the fewer options you may have. We are attempting to collect a debt, and any information obtained will be used for that purpose. If you are represented by an attorney, please refer this letter to your attorney and provide us with the attorney's name, address and telephone number. To the extent your original obligation was discharged, or is subject to an automatic stay of bankruptcy under Title 11 of the United States Code, this notice is for compliance and/or informational purposes only and does not constitute an attempt to collect a debt or to impose personal liability for such obligation. However, a secured party retains rights under its security instrument, including the right to foreclose its lien. BR840 An important message from the Federal Trade Commission Facing foreclosure? Scammers are targeting people having trouble paying their mortgages. Some claim to be able to "rescue" homeowners from foreclosures, while others promise loan modifications - for a fee. The Federal Trade Commission, the nation's consumer protection agency, wants you to know how to avoid scams that could make your housing situation go from bad to worse. Don't Get Hit by a Pitch. "We can stop your foreclosure!" "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 offall 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 directly into your browser and lookup 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.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 ~HOPENOw Support & Guidance For Homeowners ~~ ~ ~ MAILING HOME AFFORDABLE.GOv JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Plaintiff vs. SONYA NEFF Defendant(s) IN THE COURT OF COMMON PLEAS Ql~. ~,->>. CUMBERLAND COUNTY, PENNSYLVA~sTIA:~~ry "- ...., . ... _ ... F. ,. - ., . ." _ . .., ~~ .. .. t! 7 ~..,, `~ , Case No. 1 ~~ ~ - ~-, C lYl1 ~,~"° z ~.._ ~, , ~' ._~:a 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 REQUIItED BY THIS NOTICE. THIS PROGRAM IS FREE. Res~e 11 sub fitted: (Si a el for Plaintii~ 11/19/2012 Date Cumberland County Residential Mortgage P'nreclosure Diversion Fragrant l+`inancial Worksheet Date Cumberland County Court of Common Pleas Docket # BaRROWER REQUEST FOR HARDSHIP ASSISTANCE To complete•your request for hardship assistance, your lender must consider your circumstances to determine possible options while working with your Please provide the fallowing information to the best of your knowledge: Borrower name(s): Property Address; City: State:--- -- -Zip:. Ts the property for sale? Yes ~'J No ^ Listing date: Price: Realtor Name: Realtor Phone: Borrower Occupied? Yes No Mailing Address (if different): _ Cify: Fhone Numbers: Email: of people in household: Mailing Address; City: Phone Nurxtbers: Email; # ofpeople in household: First Mortgage Lender: Type of Loan: Home: Cell: State: Zip: Office: Other: Haw long? State: Zip: Home: Office: Ceil; Other: How long? Loan Number: Date You Closed Your Loan: Second Mortgage Lender: Type of Loan: Loan Number; Total Mortgage Payments Amount: $ Date of Last Payment: Primary Reason for Default: Included Taxes ~ lrxsurartce: Is the loan in Bankruptcy? Yes ^ Na [j If yes, provide names, location of court, case number $~ attorney: Assets Amount Owed: Value: I-lome; $ $ Other Rea! Estate: $ $ Retirement Funds: $ $ Investments: $ ~ $ Checking: $ $ Savings: $ ~ $ Other: $ Automobile #I: Model: yew; Amount owed: Value• Automobile #2: Model: ~'~~•- Amount awed• Value: Other transportation (automobiles, boats, motgrcvcles)• Model: Year: Amount owed: Value Monthly Income Name of Employers: 1. Z. 3. Additional Income Description (not wages): I . monthly amount• 2. _ monthly amount: Borrower Pay Days: Co-Borrower Pay bays: Monthly Expenses: (Please only include expenses you are currently payinp~ EXPETTSI AMOUNT 1~XPENSE AMOUNT Mo Food 2 M Utilities Car Pa s Condo/Nei .Fees Auto lfnsurrtice Mad. not covered Auto fueUre irs Other ro . a mcnt Install Loan Pa mart Cable T'Y Child Su rt/Alim. S ndin Mo»e Da /Child CarelTuit. Other Ex s Amount Available far Monthly Mortgage Payments Rased on Iacorne & Expenses: Have you been working with a Housing Counseling Agency? Yes (~ No ^ if yes, please provide the following information: Counseling Agency: Counselor: Phone (Office): Fax: Email: Have you mace application for Homeowners Emergency lvXortgage Assistance i'rogram {HEMAI'} assistance? Yes [] No If yes, please indicate the status of the application: Have you had any prior negotiations with your lender or lender's loan servicing company to resolve your delinquency? Yes^ NoQ If yes, please indicate the status of those negotiations: Please provide the following information, if know, regarding your lender or lender's loan servicing company: Lender's Contact (Name): Servicing Company (Name): Contact: Phone: Shone: I/We, , authari~e the above named to use/refer this information to my lenderlservicer far the sole purpose of evaluating my financial situation for possible mortgage options. UWe understand that Uwe am/are under no obligation to use the services provided by the above named Borrower Signature Co-Borrower Signature Date Date Please forward this document along with tl2e fallowing information to lender and lend_err's counsel: lIf Proof of income _l+r fast 2 bank statements ' `Y' Fraaf of any expected income for the last Q5 days ~f Copy of a current utility bill Letter explaining reason far deliugaency and any supporting documentation {hardship leiter) Listing agreement (if property is currently an the market) T , ' In the Court of Common Pleas of Cumberland County JPMORGAN CHASE BANK,NATIONAL ASSOCIATION c/o 3415 Vision Drive c Columbus,OH 43219 Plaintiff No. 12-715 11 cwa vs. txtw :* SONYA NEFF (Morigagor(s)and Record Owner(s)) � off' 331 North West Street I,.. __4 Carlisle,PA 17013 �'C� t)-n Defendant(s) C) M PRAECIPE FOR JUDGMENT 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 SONYA NEFF by default for want of an Answer. Assess damages as follows: $107,268.04 Debt Interest from 11/1/2012 to Date of Sale per diem at$16.59 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 mail o delivered to the party against whom judgment is to be entered and to his attorney of record,if any,after the defa oc and at least ten days prior to the date of the filing of this praecipe.A copy of the notice is attached.R.C.P. 23 . By: KML L .C. _Michael cKee Pa.ID56129 _Jay E.Kivitz Pa. 26769 _Lisa Lee Pa.ID 78020 _Kristin Murtha Pa.ID 61858 _David Fein Pa.ID 82628 _Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 P.Jenkins Pa.ID 306588 _Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff AND NOW nd _ do ,Judgment is entered in favor of JPMORGAN CHASE BANK,NATIO AL ASSOCIATION and against SONYA bAdIt of an Answer and damages assessed in the sum of$107,268.04 as per the above certification. Protho 4% . I(,.50 Pb A17Y d88118 ASSESSMENT OF DAMAGES TO THE PROTHONOTARY: Kindly assess the damages in this case to be as follows: Principal Balance $100,929.90 Interest from 04/01/2012 through $3,532.55 10/31/2012 Reasonable Attorney's Fee $1,650.00 Escrow Advance $1,099.59 Property Inspection $56.00 j 04 By. KML LC, Michael r 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 1. Goldman Pa.205047 ,Till P.Jenkins Pa.ID 306588 Andrew F.Gomall Pa.ID 92382 Attorneys for Plaintiff AND NOW,this day of 2013 damages are assessed as above. Pro Prothy 12-7155 civiU116536FC KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS c/o 3415 Vision Drive Columbus,OH 43219 of Cumberland County Plaintiff vs. SONYA NEFF CIVIL ACTION LAW (Mortgagor(s)and Record owner(s)) 331 North West Street ACTION OF MORTGAGE FORECLOSURE Carlisle,PA 17013 Defendant(s) No. 12-7155 civil ORDER FOR JUDGMENT Please enter Judgment in favor of JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,and against SONYA NEFF for failure to file an Answer in the above action witXds the date of service of the Com plaint,in the sum of$107,268.04. By. KML L . Michae . 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristin Murtha Pa.ID 61858 David Fein Pa.ID 82628 Thomas Puleo Pa.ID 27615 Joshua I.Goldman Pa.205047 gill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff I hereby certify that the above names are correct and that the precise residence address of the judgment creditor is JPMORGAN CHASE BANK,NATIONAL ASSOCIATION c/o 34 WcKeer olumbus,OH 43219 and that the name(s)and last known address(es)of the Defendant(s)is/are S rth West Street Carlisle,P A 17013; By: KML L , Michael 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 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff 116536FC TWS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT OWED TO OUR CL1JFNT.ANY INF0RMATI0N OBTAINED FROM YOU WILL BE USED FOR THE PURPOSE OF COLLECTING THE DEBT. DATE OF THIS NOTICE. Fcbraary 28,2013 TO: SONYA NEFF 331 North West Street C.adisle,PA 17013 In the Court of JPMORGAN CHASE,BANK,NATIONAL ASSOCIATION Common Pleas do 3413 Vision Drive of Cumberland Canty Columbus,OH 43219PhAntiij V& CIVIL.ACTION-LAW SONYANEFF (Mortgagot(s)and Record Owner(s)) Action of 331 North West Street Mortgage Frmxkisore Carlisle,PA 17013 No.12-7155 civil Defendant(s) TO: SONYA NEFF 331 North West.Street Carlisle,PA 17013 DWORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAIW)TO ENTER A VMI TI N APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WMI THE COURT YOUR DEh'ENSF.S OR OBJECTIONS TO THE CLAIMS SET F0RTH AGAINST YOU. UNLESS YOU ACT WMI1N TEN (10)DAYS FROM THE DATE OF THIS NOTICE,A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PR0PF1t1'Y OR OTHER RvIPORTANT RWAM. YOU SHOULD"IAKF TT-iG5 PAPER TO YOUR LAWYER.AT ONCE. 1F YOU DO NOT HAVE A I.AWYFR, GO TO OR TEIZPIIONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INF0RMA110N ABOUT MING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER,7111S OFFICE MAY BE ABLE TO PROVIDE YOU WIIIi 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 Cmiisk,PA 17013 LEGAL SERVICES D4C 8 Irvine Row Carlisle,PA 17013 717-243-9400 7 KM7,LAW GROUP .C. Michad McKeever Pa.LID 56124 Lisa Lae Pa.ID 78020 ICrbdna Martha Pa.1D 61858 David Fein Pa.W SM28 Thongs Peke Pa.ID 27615 Ji11 P_Jcalmrs Pa.ID 306568 –&-Alyk L.Ofkziaa Pa.ID 312912 215627-1322 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA JPMORGAN CHASE BANK,NATIONAL ASSOCIATION Plaintiff vs. SONYA NEFF NO.12-7155 civil Defendant(s) VERIFICATION OF NON-MILITARY SERVICE UNDER THE SERVICEMENMERS 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(bttps://www.dmdc.osd.mil/aDi)i/scra/scraHome.do) for the following individual(s): SONYA NEFF, has a last known residence of 331 North West Street, Carlisle,PA 17013. 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.4)04 r Aating to unsworn falsification to on *es. d- Date By: KNILLAW UZI V P.C. —.Michael 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. 11)205047 Salvatore Filippello Pa. ID 313897 -4K_-Jill P.Jenkins Pa. ID 306588 Attorneys for Plaintiff • Department of Defense Manpower Data Center Results as of:Mar-20-2013 06:36:46 SCRA 3.0 Saw Rtleft Pummt to ervicemembas Civil l ichef Act Last Name: NEFF First Name: SONYA Middle Name: Active Duty Status As Of: Mar-20-2013 On AO" sou zs* service OW#M" Active DtAytrrtDa� AtxAatlutyEne Drfttt' ..., NA NA No NA This response reflects 1ho*Whriduaft active duty stab n based on the At"OW Status Date t eft Ve( Wlt,* 7DeyaofAOWD*Sialltebsik AOgve Duty sw now AtdNe C4lyt nil DeNa ' T ae 5arvlas OWMOtt ant t NA No NA This response reflects where fire individual left active duty staple wM in.367 days precadkg the Active Duty Status Date e ttleotttM or FNw4lsrtJrik-N�a"tl;0md"of 9lruditre ItP to Adive or," i Dtdy 8 to 0010 Drder s>IxL Dafg tkder .:. End Ds* 1s Service NA NA No NA TNs response rellects whew the Wmiduntort0s4w unit has renewed sarlyno tIOon to report for active duty Upon searching the data banks of the Department of Defense Manpower Data Gersten,based on the information that you provided,the above is the status of the individual on the active duty status date as to all branches of the Uniformed Services(Army,Navy,Marine Corps,Air Force,NOAA,Public Health,and Coast Guard). This status includes information on a Servicemember or his/her unit receiving notification of future orders to report for Active Duty. HOWEVER,WITHOUT A SOCIAL SECURITY NUMBER,THE DEPARTMENT OF DEFENSE MANPOWER DATA CENTER CANNOT AUTHORITATIVELY ASSERT THAT THIS IS THE SAME INDIVIDUAL THAT YOUR QUERY REFERS TO.NAME AND DATE OF BIRTH ALONE DO NOT UNIQUELY IDENTIFY AN INDIVIDUAL. • A Matt'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 the enforcement of the Servicemembers Civil Relief Act(50 USC App.§501 at seq,as amended)(SCRA)(formerly known as the Soldiers'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,friend,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 verification of the person's status by contacting that person's Service via the "defenselink.mii"URL:http://www.defenselink.mil/faq/pisIPC09SLDR.htmi. If you have evidence the person was on active 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 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 notification 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 accordance with 10 USC§101(d)(1). Prior to 2010 only some of the active duty periods less than 30 consecutive days in length were available. in the case of a member of the National Guard,this includes service under a call to active service authorized by the President or the Secretary of Defense under 32 USC§502(0 for purposes of responding to a national emergency declared by the President and supported by Federal funds. AiI Active Guard Reserve(AGR)members must be assigned against an authorized mobilization position in the unit they support. This includes Navy Training and Administration of the Reserves(TARs),Marine Corps Active Reserve(ARs)and Coast Guard Reserve Program Administrator(RPAs). Active Duty status also applies to a Uniformed Service member who is an active 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 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 certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore,some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted,but who have not actually begun active duty or actually reported for induction. The Last Date on Active 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: H2Q836F3WO8CKOO . , Eƒ @ A @ N o 0) � | �! I_c■� z n k7�r�CA m 4 n`o 0 : WrXc�> � . 4 � . IU2 -Um©QrL Q I o��� Oa c e _ - �© c: $ 3 �m & >M » z m ; � ƒ C3 \( k� J � p¢ M a Jz . co ( \� cp / )� . / @ CD C o . 9 =r # ooOO � J Ito 2 E2 K � 0 I . � w $ 0000 0 I £9t ■ - ; lig M T E� . C, a %« ■ � � (. � § \ D ; , ƒo ±73$ \ �\f%i?I{ �k �■-I i- / � 1: � � � g n $ $ l J 2\ ! ' \ n om� \ \tom % \ 6� �o - �« ' Print Your Documents Page 2 of 3 uSPS manifest mailing!,�ygten - ------------------- --------- --- '----------------- ! Mailer's Name i Address 1 Permit Number I MAC Ver. Number [01 Law Group 1 123 i ConnectShip Progistirs 6.5 T01 Market Street I------------------------------ f SuiteSD00 ---------------------------------------------------------- I Sequence Number f Class of mail Philadelphia, PA-19106 1 632-4 1. I Mixed ------------------- Article 9/ Addressee Name ES Insurance Due Piece IJ Deli '''"""res ?otal 7/ - Type Postage ?ee Amount Sender Charge ES ---- ------------ -------- `. -- . NEFtr', SONYA' �` D.860 5.21 --- 91719949917032661889 331 North Nest Street (� ERA 1.25 Carlisle, PA-1 7 13 C 3.10 ` S , INGA 1.520 5 87 9171999991703266188479 1600 Angeiw-ng Drive [/ ERR 1 25 Silver Spring, ND-20904 C 3.10 DOLOBAI, HERRIETTA W. 1.52.0 5.87 9171999991703266188981 1600 An ling Drive ERR 1.25 Silver Spring, MD-209C4 C 3.10 St* nAVILLE, INCA 1.520 5.87 9171999991703266186498 210 Golf Road ERR 1.25 Darby, PA-19023 C 3.10 DOLOBAI, HENRIETTA y,. _ 1.520 x.87 9_71999991703266188504 210 Golf Road (/J/ ERR 1.25 Darby, PA-19023 C 3.10 SHERMAN, BRANT D. 1.520 91719999917032664520_0 16 Hilgert Avenue EAR 1.25 5.87 SCillington, PA-19607 C 3.10 SHERMAN, BRINIT D. V 1.520 9171999991703266452025 53 Lexingtoi Boulevard 5.87 ERR 1.25 - Madison, OR-44057 V C 3.10 SHERMAN, BRAN: D. 1.520 9171999991703266452032 1.663-1665 North 10th Strpst ERR 1.25 5.87 Reading, PA-19604 V C 3.10 SHERMAN, BRANT D. 1.520 9171999991703266452049 P.D. Box 12399 !RR 1.25 5.67 Reading, PA-19612-0006 3.10 SHERMRN, BRANT D. 1.520 91'1199999:703266452056 P.O. Box 14591 1,/ ERR 1.25 5.67 Reading, PA-19612 C 3.10 -------------------------------------------- age Totals 10 19.59 93.50 Cumulative TCCais 10 19.59 43.50 58.04 4 _ 1 _ http://pbpc/sendsuite%201ive/projects/image.aspx 2/7/2013 --- --. ... -. JC IL Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION IN THE COURT OF COMMON c%3415 Vision Drive PLEAS Columbus,OR 43219 OF Cumberland COUNTY vs. CPnL ACT10N-LAW SONYA NEFF ACTION OF MORTGAGE Mortgagors) FORECLOSURE 331 North West Street Carlisle,PA 17013 Terns Defendant(s) No. 12-7155 civil Y CERTIFICATE OF SERVICE r. The undersigned,on behalf of Plaintiff,hereby certifies that on t he did serve upon Defendant SONYA NEFF a true and correct copy of the above-captioned Complaint by certified and regular mail in accordance with the Court Order dated January 22'2013. The undersigned understands that the statements herein and subject to the penalties provided by 18 P-S.Section 4904. Respectfully submitted, By KNE Law Group,P.C. Nick Barone,Legal Assistant NBarone(@IcmUawgLQup.com awronp.com 215-825-6365(Direct Phone) I - SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff i r Sol?of>an hpt..4 Jody S Smith Chief Deputy q, •r5�Z��� �a� Richard W Stewart - ? ' Solicitor OFFICE GF'x 8e45.�F JP Morgan Chase Bank, NA VS. Case Number . Sonya Neff 2012-7155 SHERIFF'S RETURN 01F SERVICE 02/07/2013 12:48 PM-Deputy William Cline,being duly sworn according to law,served the requested Notice Qf Residential Mortgage Foreclosure Diversion Program&Complaint in Mortgage Foreclosure upon the within named Defendant,to wit:Sonya Neff,pursuant to Order of Court by"Posting"the.premises`located at 331 North West Street,Carlisle Borough, Cailiple, PA 17013 with a true and Corr Ct copy according to law. WILLIAM CLI E,-DEPUTY SHERIFF COST. $40.00 SO ANSWERS, February 11,2013 RONlW R ANDERSON, SHERIFF . ;�1 Cui rlyS+te StW,7ftc=11,i 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 c/o 3415 Vision Drive Columbus,OH 43219 Plaintiff No. 12-7155 civil VS. SONYA NEFF (Mortgagors and Record Owner(s)) 331 North West Street Carlisle,PA 17013 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 Courthousaut74 Carlisle,PA Prothonotary By: If you have any questions concerning the above,please contact: KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia, PA 19106 215-627-1322 PRAECIPE FOR WRIT OF EXECUTION- (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 C-) KML Law Group,P.C. Suite 5000-BNY Independence Center �CO : T � � (,n-- 701 Market Street Z Philadelphia,PA 19106 r+ N 215-627-1322 NCS' to ©C� Attorney for Plaintiff 3=n c CD JPMORGAN CHASE BANK,NATIONAL ASSOCIATION c%3415 Vision Drive IN THE COURT OF COMMON PLEAS Columbus,OH 43219 Plaintiff of Cumberland County VS. SONYA NEFF CIVIL ACTION—LAW Mortgagor(s)and Record Owner(s) ACTION OF MORTGAGE FORECLOSURE 331 North West Street Carlisle,PA 17013 Defendant(s) No. 12-7155 civil PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: QAmount Due ,FTO jO p'ny Interest from $107,268.04 ""Do 11/1/2012 to Date of 41-6-60 �i Sale per diem at 106,11 $16.59 IG.5a " 1,7 Z _ PD AMY (Costs to be added) I1. Ott t�3 By: KML UP,P.C. Michae McK er Pa.ID 56129 Jay E. Kivitz Pa.ID 26769 Lisa Lee Pa.ID 78020 Kristina Murtha Pa.ID 61858 401,01-S '� oo David Fein Pa.ID 82628 . Thomas Puleo Pa.ID 27615 LL —Thomas I.Goldman Pa.205047 ----..Joshua P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 0�f 73a�o Attorneys for Plaintiff : 12� t 8 1 " 1f+ 1 z 0 H u z w o o � U o 72 raw 2 ¢ z � o O Z ca �z 0 O w ,°onU w ° a o aaio � C-4 bo 0 Z w a C a ti THE LAND REFERRED TO HEREIN IS SITUATED IN THE STATE OF PENNSYLVANIA,COUNTY OF CUMBERLAND,CITY OF CARLISLE,AND DESCRIBED AS FOLLOWS: ALL THAT CERTAIN PIECE OR PARCEL OF LAND WITH THE IMPROVEMENTS THEREON ERECTED, SITUATE ON THE EAST SIDE OF NORTH WEST STREET BETWEEN PENN AND LINCOLN STREETS,TO WIT:NO.331 NORTH WEST STREET IN THE FOURTH WARD OF THE BOROUGH OF CARLISLE, CUMBERLAND COUNTY,PENNSYLVANIA,MORE PARTICULARLY BOUNDED AND DESCRIBED AS FOLLOWS: ON THE NORTH BY PROPERTY NOW OR FORMERLY OF DAVID C.SHEIBLEY;ON THE EAST BY OTHER PROPERTY NOW OR FORMERLY OF ORLEAN S.ELLIOTT;ON THE SOUTH BY THE PROPERTY NOW OR FORMERLY OF MARY E.CAMPBELL;ON THE WEST BY NORTH WEST STREET. SAID LOT FRONTS TWENTY-SIX(26)FEET MORE OR LESS,ON NORTH WEST STREET AND IS ONE HUNDRED(100)FEET,MORE OR LESS,IN DEPTH. IMPROVEMENTS consist of a residential dwelling. MUNICIPALITY FOURTH WARD OF THE BOROUGH OF CARLISLE BEING PREMISES:331 North West Street,Carlisle,PA, 17013 SOLD as the property of Sonya Neff, single person TAX PARCEL#05-20-1798-056 i KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS c/o 3415 Vision Drive Columbus, OH 43219 of Cumberland County Plaintiff vs. CIVIL ACTION-LAW SONYA NEFF (Mortgagor(s)and Record Owner(s)) 331 North West Street ACTION OF MORTGAGE FORECLOSURE Carlisle,PA 17013 Defendant(s) No. 12-7155 civil AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,Plaintiff in the above action,by counsel,KML Law Group,P.C.,sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 331 North West Street Carlisle,PA 17013 Ti " 3 w 1.Name and address of Owner(s)or Reputed Owner(s): --4 rn SONYA NEFF � 331 North West Street -<> N Carlisle,PA 17013 'C) 3 � 2.Name and address of Defendant(s)in the judgment: MCI' y c rn SONYA NEFF ; 331 North West Street Carlisle,PA 17013 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 P 4.Name and address of the last recorded holder of every mortgage of record: ORRSTOWN SANK 77 E. King Street Shippensburg,PA 17257 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 331 North West Street Carlisle,PA 17013 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 s teme is herein are made subject to the penalties of 18 Pa.C.S.Section 4904 relating to unsworn falsification to autho ' es. DATED: _ By: KML GR P,P.C. Michael cKeever 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 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff KML Law Group,P.C. Suite 5000—BNY Independence Center 701 Market Street Philadelphia,PA 19106 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION c/o 3415 Vision Drive Columbus,OH 43219 IN THE COURT OF Plaintiff COMMON PLEAS vs. SONYA NEFF of Cumberland County Mortgagor(s)and Record Owner(s) CIVIL ACTION-LAW 331 North West Street Carlisle,PA 17013 CTION OF ts) MORTGAGE FORECLOSURE NO. 12-7155 civil 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. c7 � By. C ' KML W OUP,P.C. Aw =z Michae McKeever Pa.ID 56129 = Jay E. Kivitz Pa.ID 26769 W r_ p Lisa Lee Pa.ID 78020 <> CD Kristina Murtha Pa.ID 61858 David Fein Pa.ID 82628 3 Thomas Puleo Pa.ID 27615 y a r`v7 Joshua I.Goldman Pa. 205047 ' Jill P.Jenkins Pa.ID 306588 Andrew F.Gornall Pa.ID 92382 Attorneys for Plaintiff r 12-7155 civil KML Law Group,P.C. Suite 5000-BNY Independence Center 701 Market Street Philadelphia,PA 19106 (215)627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK,NATIONAL ASSOCIATION IN THE COURT OF COMMON PLEAS c/o 3415 Vision Drive Columbus,OH 43219 of Cumberland County Plaintiff CIVIL ACTION-LAW vs. SONYA NEFF ACTION OF MORTGAGE Mortgagor(s)and Record Owner(s) FORECLOSURE 331 North West Street Carlisle,PA 17013 Docket No. 12-7155 civil Defendant(s) THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT.THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO c r COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL USED FOR THAT PURPOSE. a 2 sa• rn r= M CD NOTICE OF SHERIFF'S SALE OF REAL PROPERTY r�-z ry --qr-D TO: NEFF,SONYA fir? SONYA NEFF ' 331 North West Street p Carlisle,PA 17013 Your house at 331 North West Street,Carlisle,PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday,September 04,2013,at 10:00 AM,in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of$107,268.04 obtained by JPMORGAN CHASE BANK,NATIONAL ASSOCIATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK,NATIONAL ASSOCIATION,the back payments,late charges,costs and reasonable attorney's fees due.To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment,if the judgment was improperly entered.You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. 12-7155 civil 4. You may need an attorney to assert your rights.The sooner you contact one,the more chance you will have of stopping the sale. (See notice below on how to obtain an attorney). YOU MAY STILL BE ABLE TO SAVE YOUR PROPERTY AND YOU HAVE OTHER RIGHTS EVEN IF THE SHERIFF'S SALE DOES NOT TAKE PLACE. 1. If the Sheriffs Sale is not stopped,your property will be sold to the highest bidder. You may find out the price bid price by calling the Sheriff of 717-240-6390. 2. You may be able to petition the Court to set aside the sale if the bid price was grossly inadequate compared to the value of your property. 3. The sale will go through only if the buyer pays the Sheriff the full amount due in the sale.To find out if this has happened,you may call the Sheriff of 717-240-6390. 4. If the amount due from the Buyer is not paid to the Sheriff,you will remain the owner of the property as if the sale never happened. 5. You have a right to remain in the property until the full amount due is paid to the Sheriff and the Sheriff gives a deed to the buyer.At that time,the buyer may bring legal proceedings to evict you. 6. You may be entitled to a share of the money which was paid for your house. A schedule of distribution of the money bid for your house will be filed by the Sheriff within thirty(30)days from the date of the Sheriffs Sale.This schedule will state who will be receiving that money.The money will be paid out in accordance with this schedule unless exceptions(reasons why the proposed distribution is wrong)are filed with the Sheriff within ten(10)days after the schedule of distribution is filed. 7. You may also have other rights and defenses,or ways of getting your house back,if you act immediately after the sale. 8. You may contact the Foreclosure Resource Center: htip://www.philadelphiafed.orWforeclosure/ YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE LISTED BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013 LEGAL SERVICES INC 8 Irvine Row Carlisle,PA 17013 717-243-9400 'r • 12-7155 civil Resources available for Homeowners in Foreclosure ACT NOW! Even though your lender(and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.orp-/consumers/homeowners/real.aspx. 5). Call the Plaintiff(your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout/Home Retention Package. Call our toll free number at 1-866413-2311 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 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 116536FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO. 12-7155 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due JPMORGAN CHASE BANK,NATIONAL ASSOCIATION, Plaintiff(s) From SONYA NEFF (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 gamishee(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: $107,268.04 L.L.:$.50 Interest from 11/1/12 to Date of Sale per diem @$16.59 Atty's Comm: Due Prothy:$2.25 Atty Paid: $.,Z 3 t.SO Other Costs: Plaintiff Paid: Date: 3/22/13 hOurid �. tx� David D Buell,Pro ono ry (Seal) By: 'yn Deputy REQUESTING PARTY: Name: JILL P.JENKINS,ESQUIRE Address: KML LAW GROUP,P.C. SUITE 5000-BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA,PA 19106 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No.306588 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R And on Sheriff of tir1b 1¢ or THEE p&-T}F0 i'o TAii .. Jody S Smith �`�! Chief Deputy 2013 NOV -6 AN 10: 53 Richard W Stewart Solicitor of tCEOFTHESHERIF CUM RLAND COUNT Y PENNSYLVANIA JP Morgan Chase Bank, NA vs. Case Number Sonya Neff 2012-7155 SHERIFF'S RETURN OF SERVICE 06/24/2013 04:11 PM -Deputy Noah Cline, being duly sworn according to law, states service was performed by posting a true copy of the requested Real Estate Writ, Notice and Description, and Sale Handbill in the above titled action, upon the property located at 331 North West Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County. 06/24/2013 04:11 PM - Deputy Noah Cline, being duly sworn according to law, served the requested Real Estate Writ, Notice and Description, in the above titled action, upon the within named Defendant, to wit: Sonya Neff, pursuant to Order of Court by"Posting"the premises located at 331 North West Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County with a true and correct copy according to law. 08/28/2013 As directed by Jill Jenkins,Attorney for the Plaintiff, Sheriffs Sale Continued to 11/6/2013 11/04/2013 Ronny R Anderson, Sheriff, being duly sworn according to law, states that this writ is returned "stayed", per letter of instruction from Attorney. SHERIFF COST: $815.19 SO ANSWERS, November 05, 2013 RONIV ANDERSON, SHERIFF s7- t L pd- e4 A 3>sy fi ,2 97 ://, ic'Coun'ySuite Sheriff,Teleosoft Inc. PRAECIPE FOR WRIT OF EXECUTION - (MORTGAGE FORECLOSURE) P.R.C.P 3180-3183 KML Law Group, P.C. Suite 5000 - BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION c/o 3415 Vision Drive Columbus, OH 43219 vs. SONYA NEFF Mortgagor(s) and Record Owner(s) 331 North West Street Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION — LAW ACTION OF MORTGAGE FORECLOSURE No. 12-7155 civil PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Issue Writ of Execution in the above matter: Amount Due Interest from 11/1/2012 to Date of Sale per diem at $16.59 (Costs to be added) *ag -50 PD 39 . ao 013F 40. co 81S. let " Ib3 . 175 fJ . '15 " Ilp. 50 " 7(S . SO " /08z. iq - Pb arry $a.a5 Due Co e 784935 e,* 3t510/ By: INJ $107,268.04 AW GROUP, P.C. ael 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 _ t .34 v i et t- o. V�1. CYk et1 ea 11:• 3 t -n 44 IN THE UNITED STATES BANKRUPTCY COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA IN RE: Sonya Kaye King f/k/a Sonya Kaye Neff Debtor JPMorgan Chase Bank, National Association Movant vs. Sonya Kaye King f/k/a Sonya Kaye Neff Debtor Charles J. DeHart, III Esq. Trustee ORDER CHAPTER 13 NO. 1:13-bk-02602 MDF 11 U.S.C. Section 362 and 1301 Upon consideration of Movant's Motion for Relief from the Automatic Stay, it is ORDERED AND DECREED that: The Automatic Stay of all proceedings, as provided under 11 U.S.C. Sections 362 of the Bankruptcy Reform Act of 1978 (The Code) 11 U.S.C. Sections 362 (if applicable), are modified to allow JPMorgan Chase Bank, National Association and its successor in title to proceed with the execution process through, among other remedies but not limited to Sheriffs Sale regarding the premises 331 North West Street Carlisle, PA 17013 and a possessory action if necessary. Under the terms of the subject Mortgage and pursue its State Court remedies including, but not limited to, taking the Property to Sheriff's sale, in addition to potentially pursuing other loss mitigation alternatives including, but not limited to, a loan modification, short sale or deed -in -lieu of foreclosure. Additionally, any purchaser of the Property at Sheriff's Sale (or purchaser's assignee) may take any legal action for enforcement of its right to possession of the Property. The stay provided by Bankruptcy Rule 4001(a)(3) has been waived. By the Court Dated: December 9, 2014 Chief Bankruptcy Judge (.IG) Case 1:13-bk-02602-MDF Doc 38 Filed 12/09/14 Entered 12/09/14 12:19:11 Desc Main Document Page 1 of 1 KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION c/o 3415 Vision Drive Columbus, OH 43219 vs. SONYA NEFF (Mortgagor(s) and Record Owner(s)) 331 North West Street Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE No. 12-7155 civil AFFIDAVIT PURSUANT TO RULE 3129 JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, Plaintiff in the above action, by counsel, KML Law Group, P.C., sets forth as of the date the praecipe for the writ of execution was filed the following information concerning the real property located at: 331 North West Street Carlisle, PA 17013 1.Name and address of Owner(s) or Reputed Owner(s): SONYA NEFF 331 North West Street Carlisle, PA 17013 2. Name and address of Defendant(s) in the judgment: SONYA NEFF 331 North West Street Carlisle, PA 17013 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 12-7155 civil KML Law Group, P.C. Suite 5000- BNY Independence Center 701 Market Street Philadelphia, PA 19106 (215)627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION c/o 3415 Vision Drive Columbus, OH 43219 vs. SONYA NEFF Mortgagor(s) and Record Owner(s) 331 North West Street Carlisle, PA 17013 Plaintiff Defendant(s IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE Docket No. 12-7155 civil THIS LAW FIRM IS A DEBT COLLECTOR AND WE ARE ATTEMPTING TO COLLECT A DEBT. THIS NOTICE IS SENT TO YOU IN AN ATTEMPT TO COLLECT A DEBT. ANY INFORMATION OBTAINED FROM YOU WILL BE USED FOR THAT PURPOSE. NOTICE OF SHERIFF'S SALE OF REAL PROPERTY TO: NEFF, SONYA ) SONYA NEFF 331 North West Street Carlisle, PA 17013 Your house at 331 North West Street, Carlisle, PA 17013 is scheduled to be sold at Sheriffs Sale on Wednesday, June 03, 2015, at 10:00 AM, in Commissioners Hearing Rm 2nd FL Courthouse to enforce the court judgment of $107,268.04 obtained by JPMORGAN CHASE BANK, NATIONAL ASSOCIATION against you. NOTICE OF OWNER'S RIGHTS YOU MAY BE ABLE TO PREVENT THIS SHERIFF'S SALE To prevent this Sheriffs Sale you must take immediate action: 1. The sale will be cancelled if you pay to JPMORGAN CHASE BANK, NATIONAL ASSOCIATION, the back payments, late charges, costs and reasonable attorney's fees due. To find out how much you must pay call our office at 215-825-6329 or 1-866-413-2311. 2. You may be able to stop the sale by filing a petition asking the Court to strike or open judgment, if the judgment was improperly entered. You may also ask the Court to postpone the sale for good cause. 3. You may also be able to stop the sale through other legal proceedings. KML Law Group, P.C. Suite 5000 — BNY Independence Center 701 Market Street Philadelphia, PA 19106-1532 215-627-1322 Attorney for Plaintiff JPMORGAN CHASE BANK, NATIONAL ASSOCIATION c/o 3415 Vision Drive Columbus, OH 43219 vs. SONYA NEFF Mortgagor(s) and Record Owner(s) 331 North West Street Carlisle, PA 17013 Plaintiff Defendant(s) IN THE COURT OF COMMON PLEAS of Cumberland County CIVIL ACTION - LAW ACTION OF MORTGAGE FORECLOSURE NO. 12-7155 civil 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. Bv: LAW GROUP, P.C. ael McKeever Pa. ID 56129 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 1. c5m:a W • CJnec 1 'a'0. CD 5)—T-7 4 ( Ay T Resources available for Homeowners in Foreclosure ACT NOW! 12-7155 civil Even though your lender (and our client) has filed an Action of Mortgage Foreclosure against you, you still may be able to SAVE YOUR HOME FROM FORECLOSURE. 1). Call an attorney. For referrals to a qualified attorney call either of the following numbers: or 717-243-9400. . 2). Call the Consumer Credit Counseling Agency at 1-800-989-2227 for free counseling. 3). Visit HUD'S website www.hud.gov for Help for Homeowners Facing the Loss of Their Homes. 4). Pennsylvania Housing Finance Agency also offers other loan programs that may assist homeowners in default. Please See the PHFA website http://www.phfa.org/consumers/homeowners/real.aspx. 5). Call the Plaintiff (your lender) at and ask to speak to someone about Loss Mitigation or Home Retention options. 6). Call or contact our office to request the amount to bring the account current, or payoff the mortgage or request a Loan Workout / Home Retention Package. Call our toll free number at 1-866-413-2311 or via email at homeretention@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 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 116536FC. Para informacion en espanol puede communicarse con Loretta al 215-825-6344. 4. Name and address of the last recorded holder of every mortgage of record: ORRSTOWN BANK 77 E. King Street Shippensburg, PA 17257 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 331 North West Street Carlisle, PA 17013 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 pena' CSSection 4904 relating to unsworn falsification to authorities. oilties DATED: 12 261 I i By: icha Jay E AW GROUP, P.C. McKeever Pa. ID 56129 .vitz Pa. ID 26769 sa 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 Vic '0. V) • ch 0.-1) THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PA DAVID D. BUELL, PROTHONOTARY One Courthouse Square • Suite100 • Carlisle, PA • 17013 (717) 240-6195 www.ccpa.net JPMORGAN CHASE BANK, NATIONAL ASSOCIATION Vs. NO 12-7155 Civil Term CIVIL ACTION — LAW SONYA NEFF WRIT OF EXECUTION TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the judgment, interest and costs in the above matter you are directed to levy upon and sell the following described property: (1) See legal description. (2) (Specifically describe personal property when judgment results from a mortgage covering both personal and real property pursuant to Section 9604(a)of the Uniform Commercial Code) NOTE: Description of property must be attached to the writ. Amount Due: $107, 268.04 L.L.: Interest from 11/1/12 to Date of Sale per diem @ $16.59 Due Prothy: $2.25 Other Costs: Atty's Comm: Atty Paid: $1,083.19 Plaintiff Paid: Date: 1/2/15 (Seal) David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name: VICTORIA W. CHEN, ESQUIRE Address: KML LAW GROUP PC SUITE 5000 - BNY INDEPENDENCE CENTER 701 MARKET STREET PHILADELPHIA, PA 19106-1532 Attorney for: PLAINTIFF Telephone: 215-627-1322 Supreme Court ID No. 317741